Structural Fumigation Use Monitoring Inspection Training Module Aeration

Structural Fumigation Use Monitoring Inspection Training Module Aeration Phase • Module 2. 1: California Aeration Plan (CAP) 1 California Department of Pesticide Regulation 1001 I Street, Sacramento CA 95814 October 2015

Structural Fumigation: Aeration via CAP WHO SHOULD TAKE THIS TRAINING? This series of training modules is intended for County Agricultural Commissioner (CAC) staff who perform structural fumigation inspections. The procedures described in this presentation are intended solely for the guidance of employees of DPR and CACs. They do not constitute rulemaking by DPR and CACs may deviate from the procedures and guidance contained in the modules provided deviations do not conflict with law, regulation or policy. This guidance was developed in May 2015 after consultation with the Structural Pest Control Board. If you have any questions, please contact the Department of Pesticide Regulation, Enforcement Branch Liaison serving your county. 2

Structural Fumigation: Aeration via CAP GUIDANCE AND REFERNCES Before starting this module, have these three manuals available to consult: • Inspection Procedures Manual (Vol. 4 of DPR’s “PUE Program Standards Compendium”) http: //www. cdpr. ca. gov/docs/enforce/compend/vol_4/inspect_procedures. htm • Laws and Regulations (Vol. 2 of DPR’s “PUE Program Standards Compendium”) http: //www. cdpr. ca. gov/docs/enforce/compend/vol_2/lawsregs. htm • Laws and Regulations Relating to the Practice of Structural Pest Control (including Business and Professions Code; a convenient booklet format published by Structural Pest Control Board) http: //www. pestboard. ca. gov/pestlaw/act. shtml 3

Structural Fumigation: Aeration via CAP GUIDANCE AND REFERNCES You will also need: Inspection form PR-ENF-107 (revised 1/2010) 4 http: //www. cdpr. ca. gov/docs/enforce/prenffrm/prenf 107. pdf

Structural Fumigation: Observing the Application PHASES OF A STRUCTURAL FUMIGATION The three phases of a structural fumigation include: • Application Phase • Aeration Phase • Certification Phase 5

Structural Fumigation: Aeration via CAP Structural Fumigation: Aeration Phase The Aeration Phase has two modules: • Aeration via CAP (California Aeration Plan) SCBA not required (unless structure is entered before CAP aeration period ends, such as for emergencies) • Aeration via sulfuryl fluoride Product labeling procedures SCBA is required for entry 6

Structural Fumigation: Aeration via CAP Aeration Phase via CAP This Aeration Phase via CAP training module covers 18* requirements on the Structural Fumigation Use Monitoring Inspection Report form: # REQUIERMENT # REQUIREMENT 1 Registered in county 23 Structure vacated / secured against reentry 2 County notified 24 hours prior 25 2 SCBA / CPR chart/ Mfg. instructions 12 Handler(s) trained 28 Direct supervision 13 Emergency medical care, posting 29 Warning signs on all sides of structure 15 SCBA worn/ cont. monitoring / CAP 30 Required information on warning signs 17 2 trained employees 37 Methyl bromide requirements 18 Fume of enclosed spaces / proper entry 38 MB- tarps accept. /condition/ ret. method 19 Proper management of treated area 39 MB- warning agents/ fans/ aeration 20 Connecting structures 40 MB- measuring concentration * In total, there are 40 inspection requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) 7

Structural Fumigation: Aeration via CAP Requirement #1: Registered in county What and how to inspect: • Check SPCB website; Review files at CAC office • Has SPCB issued a company registration? • Was structural pest control company registered with FAC 15204. 5 (a) lists structural pest control applicators as having to register under Branch 1 requirements. CAC prior to performing structural pest control for hire BPC 8505. 2 only allows structural pest control operators and field representatives to perform structural fumigations. within the county? BPC 8507. 1(a) defines the scope of a structural pest control applicator license • Are Field Reps, & Operators licensed by SPCB? FAC 15204. 5 (c ) requires “in person” registration. • Were licensees registered with CAC prior to working? ENF 07 -31 (pg 3), and ENF 07 -31 Addendum address “in person” registration For more information: • FAC § 15204. 5 • Enforcement letter ENF 07 -31 & Addendum (click to close) Click for more info 8

Structural Fumigation: Aeration via CAP Requirement #1: Registered in county Is this registration in compliance (yes or no)? • CAC Registration: Company • CAC Registration: Licensees Kilzall Brothers Pest Control SPCB Reg # PR-7777 879 Bug St. , Ento City, CA 92234 (999) 222 -0000 Jim Kilzall OPR-9998 Jerry Kilzall FR-2345 Jonnie Kilzall FR-1357 Qualifying Manager: Joe Kilzall, Address above SPCB License # OPR-9999 Issued: 7/1/2012 Kilzall Brothers Pest Control 879 Bug St. , Ento City, CA 92234 (999) 222 -0000 Answer: Yes, this registration is in compliance For required info on registration form – FAC § 15204. 5(b) 9

Structural Fumigation: Aeration via CAP Requirement #2: County notified 24 hours prior What and how to inspect: • Review Notices of Intent (NOIs) at CAC office. • Did the structural pest control company submit its NOI at least 24 hours prior to commencing fumigation? For more information: • FAC § 15204. 5(d) • Check with your supervisor - - your CAC might have chosen to waive this requirement (“or as approved on a case-by-case basis by the commissioner”) 10

Structural Fumigation: Aeration via CAP Requirement #2: County notified 24 hours prior What and how to inspect: • Review Notices of Intent (NOIs) at CAC office. • Did the structural pest control company submit its NOI at least 24 hours prior to commencing fumigation? For more information: • FAC § 15204. 5(d) • Check with your supervisor - - your CAC might have chosen to waive this requirement (“or as approved on a case-by-case basis by the commissioner”) 11

Structural Fumigation: Aeration via CAP Requirement #2: County notified 24 hours prior Is this in compliance (yes or no) ? Notice of Structural Fumigation To: Bestest County Ag. From: Kilzall Brothers P. C. Phone: 999 -222 -0000 Date: June 13, 2013 Fumigant: Vikane Site: 847 Pope St. , Bestest City Fume date: June 15, 2013 NOI faxed to CAC: Date: June 13, 13 Time: 4: 30 pm Answer: No This NOI is missing the address of the structural pest control Only a single NOI is required (24 hours prior to the start of operations). There is no requirement for an operator or company. additional NOI for the aeration phase or the clearance phase. (click to close) The address is required by FAC § 15204. 5(d) Follow up with your supervisor: • Based on the criteria in 3 CCR § 6128 & § 6130 (ACP) , or 16 CCR § 1922 (SCP) what action (if any) should you take in response to this violation? Click for more info 12

Structural Fumigation: Aeration via CAP Requirement #12: Handler(s) Trained What and how to inspect: • Ask to see each handler’s license • A person holding a Structural pest control operator or field representative license is considered trained • Evaluate each handler’s knowledge of CAP Inlet device & ducting requirements; cubic area of structure; required *Workers handling tarps after the introduction of a fumigant are considered handlers. Not all “handlers” are aeration duration licensed. • Structuraltarpcontrol applicators are not licensed totraining 1 fumigations. Ask pest crew about pesticide perform Branch • Does the handler’s responses/actions cause concern? to close) (click For more information: • 3 CCR § 6724(d) & § 6000* (certified applicator, handle) • Check Inspection Procedures Manual / CAP Click for more info 13

Structural Fumigation: Aeration via CAP Requirement #12: Handler(s) Trained Are handlers in compliance (yes or no) ? Two employees of Kilzall Brothers Pest Control are working as handlers during the aeration: • Jim Kilzall, SPCB license: OPR-9998 • Jerry Kilzall, SPCB license: FR-2345 Answer: Yes Jim and Jerry Kilzall both meet the definition of “certified commercial applicator” and therefore are considered trained 14

Structural Fumigation: Aeration via CAP Requirement #13: Emergency Medical Care What and how to inspect: • Is information about emergency medical facility posted in a prominent place (work site / truck)? • Must include name, address, and phone number • “Call 911” or wallet card are not sufficient For more information: • 3 CCR § 6726 – particularly re: working in multi-city, or multi-county areas • Check Inspection Procedures Manual 15

Structural Fumigation: Aeration via CAP Requirement #13: Emergency Medical Care Is this posting in compliance (yes or no) ? Sticker posted on sun visor inside truck cab The employer must have CONTACTED the medical facility and assured that it is capable of handling illnesses and injuries caused by pesticide exposure - - see 3 CCR § 6726(a). Employees that work in a wide geographic area, the employer must post procedures for obtaining emergency medical care when the listed facility is too far away to be reasonably available. To check this, ask the crew, how many minutes would it take you to drive from the work site to the medical facility that is listed on the posting? (click to close) Answer: Yes (if visor is down). Information is complete, and posted in a prominent place. If information was stored inside glove box rather than posted, that would not be in compliance. “Emergency Medical Care Posting” was one of the most common violation categories in structural inspections (2009 -11). Click for more info 16

Structural Fumigation: Aeration via CAP Requirement #15: SCBA/Cont. Monitoring/CAP What and how to inspect: • Verify CAP procedures are followed correctly Do inlet & aeration devices comply with number, size, & location requirements? CAP is optional, as long as inlet is covered in a manner that allows opening from outside during Inlet • device shape steps 1 -6 performed in sequence? Step 1 of CAP. • Licensee present? • Inlet Device Placement - - “Must be located where the opening is not blocked”, and “Must have the entire inlet opening be at least 4 feet above exterior grade”. • Precautions taken to prevent exposure? Is a certified SF continuous monitoring device on site? Used for CAP - Step 6? “Whenever possible”, inlet devices should be placed opposite from where discharge (aeration ducting) is located. The phrase “Whenever possible” makes this advisory, not mandatory (not enforceable). (click to close) • • For more information: • CAP / 3 CCR § 6780(b) • Check Inspection Procedures Manual Click for more info 17

Structural Fumigation: Aeration via CAP Requirement #15: SCBA/Cont. Monitoring/CAP Are CAP elements in compliance (yes or no) ? 1 2 6’ Hedge 1. No, brick wall behind inlet obstructs air flow to vent 2. No, aeration duct <10 feet; bended duct restricts air flow Follow up with your supervisor: • Based on 3 CCR § 6128 & § 6130 (ACP), or 16 CCR § 1922 (SCP), what action (if any) should you take in response to this violation? 18

Structural Fumigation: Aeration via CAP Requirement #17: 2 Trained Employees What and how to inspect: 1. Ask employees to demonstrate use of SCBA • How many SCBAs should be available? • How full should each SCBA be? • What does ringing mean? 2. Employees trained in artificial resuscitation? • Proof of CPR training available? or Generally, 2 trained persons are not required to be present during the initiation of aeration when utilizing the CAP since no one enters the structure, or the certification phase because the licensee does not require PPE • Instruction chart of artificial resuscitation when appropriately using a continuous monitoring device (click to close) available? For more information: • 3 CCR § 6782(a) • Check Inspection Procedures Manual • re: when 2 trained employees do not have to be present Click for more info 19

Structural Fumigation: Aeration via CAP Requirement #17: 2 Trained Employees Are these employees in compliance (yes or no) ? 1 CAC Inspector 2 Tarps dropped; unknown PEL Employee entering; Signs up 1. Yes, employees providing info re: SCBA & CPR training 2. No, employee entering post fume, prior to clearance without using SCBA or continuous monitoring device Follow up with your supervisor: • Based on 3 CCR § 6128 & § 6130 (ACP), or 16 CCR § 1922 (SCP), what action (if any) should you take for this violation? 20

Structural Fumigation: Aeration via CAP Requirement #18: Enclosed Space / Entry What and how to inspect: • Unprotected employees are prohibited from entering a fumigated enclosed space unless SF is <1 ppm • Is approved SF detection device on site? • Does licensee know how to use it? Non-compliance examples: Cracked hose, improper placement of snakes or clips, not using enough • Is device in the tarp, etc. chloropicrin, large holescalibration current? What are some of the questions that you can ask the fumigator concerning protection of workers and persons • Is device listed on SF labeling? not involved in the fumigation? • Is respiratory equipment listed on SF labeling? Record violation(s) as #41 on Form 107 & describe details of the violation(s) in the “Remarks” section. • What is purpose for entering enclosed space? For more information: • 3 CCR § 6782(d) / SF Labeling re: aeration & reentry • Check Inspection Procedures Manual (click to close) Click for more info 21

Structural Fumigation: Aeration via CAP Requirement #18: Enclosed Space / Entry Are these employees in compliance (yes or no) ? 1 2 Employees 1. Yes, licensee checking concentration using Interscan 2. No, employees are in enclosed space without SCBA or continuous monitoring device Follow up with your supervisor: • Based on 3 CCR § 6128 & § 6130 (ACP), or 16 CCR § 1922 (SCP), what action (if any) should you take in response to this violation? 22

Structural Fumigation: Aeration via CAP Requirement #19: Proper Management of Treated Area What and how to inspect: • After completion of the fumigation: • How does the licensee prevent employees from entering the structure prior to it being certified safe to reenter? • What precautions are taken to protect employees from being exposed to a concentration in excess of the Permissible Exposure Limit (PEL)? For more information: • 3 CCR § 6782(f) • Check Inspection Procedures Manual; SF Labeling 23

Structural Fumigation: Aeration via CAP Requirement #19: Proper Management of Treated Area Are these employees in compliance (yes or no) ? 1 2 Tarps dropped; unknown PEL Employee entering; Signs up 1. Yes, employee wearing SCBA to repair blowout 2. No, employee entering post fume, prior to clearance Follow up with your supervisor: • Based on 3 CCR § 6128 & § 6130 (ACP), or 16 CCR § 1922 (SCP) • What action (if any) should you take for this violation? 24

Structural Fumigation: Aeration via CAP Requirement #20: Connecting Structures What and how to inspect: Is the fumigated structure connected to any nearby structure via construction elements, drains, conduits, or vacuum systems that could allow the fumigant to enter? • Licensee should have checked prior to Conduits The fumigated structure should be inspected for pipes, conduits, youor others features which would result in fumigation, but for safety, ducts, should double fumigant loss outside of the fumigated space. -check at aeration. If possible, these features should be sealed to stop excessive gas loss. Click for more info • If so, is the nearby structure being aerated? (click to close) For more information: • 16 CCR § 1970. 6 / FAC § 12973 • Check Inspection Procedures Manual 25

Structural Fumigation: Aeration via CAP Requirement #20: Connecting Structures Is this in compliance (yes or no) ? 1 2 How do you know what might be connected? How can you tell which drain system belongs to the fumigated structure? How do you determine that the fumigator asked the right questions? Answers: Depends (click 1. Any conduits identified between house and garage? to close) 2. Is drain at the gutter connected to the fumigated home? Follow up with your supervisor: • Based on 3 CCR § 6128 & § 6130 (ACP), or 16 CCR § 1922 (SCP), • What action (if any) should you take for this violation? Click for more info 26

Structural Fumigation: Aeration via CAP Requirement #20: Connecting Structures Is this in compliance (yes or no) ? Detached Garage Licensee has no plan to aerate or monitor this detached garage House This house was fumed, & will be aerated via CAP Answer: No Conduit carries electrical wires from house to detached garage Garage should be considered a connecting structure. Should have been tarped (too late). It should be aerated. Follow up with your supervisor: • Based on 3 CCR § 6128 & § 6130 (ACP), or 16 CCR § 1922 (SCP), what action (if any) should you take for this violation? 27

Structural Fumigation: Aeration via CAP Requirement #23: Structure Vacated/Secured What and how to inspect: Prior to commencement of a fumigation, structure must be: • Vacated by all occupants. Ask how this was verified particularly with multi-unit structures. • Secured (all entrances) against entry, including door ways used for air exchange, until structure is cleared for re-occupancy. Ask licensee about secondary locks. For more information: • 16 CCR § 8505. 7 / CAP • Check Inspection Procedures Manual 28

Structural Fumigation: Aeration via CAP Requirement #23: Structure Vacated/Secured Are structures in compliance (yes or no) ? 1 2 3 Answers: 1. No, pet door not secured 2. No, opening 3” minimum, but not secured 3. No, secondary lock allows gap; door not used as airway Question for supervisor: • Based on 3 CCR § 6128 & § 6130 (ACP), or 16 CCR § 1922 (SCP), what action (if any) should you take for this violation? 29

Structural Fumigation: Aeration via CAP Requirement #25: 2 SCBA / CPR Chart What and how to inspect: • Fume crews must have a safety kit on-site • Verify presence & completeness of safety kit. • Ask crew about purpose, use & care of safety kit. • Ask crew if/when it had first aid & CPR training. + • Two SCBA units must be readily available • Check pressure gauge on air tanks. Enough air to complete job? Extra tanks available? • Ask crew what bell ringing on SCBA means. If ringing when in structure? For more information: • 16 CCR § 1971(a) / CAP / 3 CCR § 6739 • Check Inspection Procedures Manual re: CAP exemption 30

Structural Fumigation: Aeration via CAP Requirement #25: 2 SCBA / CPR Chart Are these in compliance (yes or no) ? 1 2 Answers: Yes 1. 3 SCBA in vehicle; sufficient air in tanks 2. Instructions for artificial resuscitation available 31

Structural Fumigation: Aeration via CAP Requirement #28: Direct Supervision What and how to inspect: • Structural fumes require direct supervision: • During fumigant release • During CAP – Aeration/Reentry Steps 1 -6 • For reentry clearance • Identify supervising licensee; ask to see SPCB license • Check that supervising licensee is present for CAP steps For more information: • B&P Code § 8505. 2 / B&P Code § 8505. 3 • CAP / Check Inspection Procedures Manual 32

Structural Fumigation: Aeration via CAP Requirement #28: Direct Supervision Is Direct Supervision in compliance (yes or no) ? Answer: Yes Image meant to convey presence of licensee during key elements of CAP process 33

Structural Fumigation: Aeration via CAP Requirement #29: Warning Signs – all sides What and how to inspect: • Prior to commencing fume, post warning signs: • On structure • On tarps • At all joint seams • Warning signs posted: signs posted at required locations? Are warning On structure: under tarps, • Are warning structure; until structureentrances safe for re-occupancy. Torn? signs at or near all is posted to read? too weathered On each side of On tarps: • Posted jointvisible from all accessible sides of structure; from any direction sitemissing? for requiredstduration? Visible? Any is approached At all seams of tarp at 1 floor level (click to close) For more information: • 16 CCR § 1974 • Check Inspection Procedures Manual for posting specifics Click for more info 34

Structural Fumigation: Aeration via CAP Requirement #29: Warning Signs – all sides Are these signs in compliance (yes or no) ? 1 2 Answer: Depends 1. Warning sign not readable. What about others? 2. Window is not an entrance; placement of other signs? Question for supervisor: • Based on 3 CCR § 6128 & § 6130 (ACP), or 16 CCR § 1922 (SCP), what action (if any) should you take for the violation? 35

Structural Fumigation: Aeration via CAP Requirement #30: Information on warning signs What and how to inspect: • Warning Signs: specific dimensions, colors, statements, and images • In addition to English, is Spanish required? • Do letters / images meet required height? Note: • 16 CCR 1974(c) is not in the 2010 Structural Act. It can be found on SPCB’s website: Is it the correct color? • Warning Signs shall include specific information Neither BPC 8505. 10 nor 16 CCR 1974 mention any requirement for Spanish text on the Warning Sign; however, • Include fumigant trade name & active ingredient? the sign image with Spanish text included in the regulation. The image contains the text required to be in Spanish. Companies can include other text in Spanish. • Fumigator info complete? “Time shot” included? (click to close) • Difference between signs on structure vs on tarp? For more information: • B&P Code § 8505. 10 / *16 CCR § 1974(c) • Check Inspection Procedures Manual Click for more info 36

Structural Fumigation: Aeration via CAP Requirement #30: Information on warning signs Is this 13 required* items. Sign in compliance (yes or no) ? Meets 12 of Warning (BPC 8505. 10): -Warning sign (letters/images) printed in red on white background Answer: Time Not Given -Contains “Danger-Fumigation” statement Yes, since sign is structure on ______. -Danger-Fumigation statement is >2” tall -Skull & Crossbones present -Skull & Crossbones >1” tall -Fumigant name present -Date present -Item 6 & 7 letters >. 5” -Registered company name -Registered company address -Registered company phone numbers (day & night) -Items 9, 10, 11 letters >. 5” If sign was on tarp _____ , no. Date listed *13) Time fumigant introduced (shot) – Not Required since sign is obviously posted on the structure (underneath the tarp). Time is required on Warning Signs posted on the fumigation tarp. (click to close) Click for more info 37

Requirements #37 -40: Methyl Bromide # REQUIREMENT 37 Methyl bromide requirements 38 MB- tarps accept. /condition/ ret. method 39 MB- warning agents/ fans/ aeration 40 MB- measuring concentration • The use of Methyl Bromide (MB) is a rare occurrence. • Not applicable would be checked on the inspection form if MB is not used. • If MB is used, consult with your supervisor. • For more information: • 3 CCR 6454 • Inspection Procedures Manual 38

Structural Fumigation: Aeration via CAP CONGRATULATIONS! You have completed the Aeration Phase via CAP training module, which covered the following 18* requirements: # REQUIERMENT # REQUIREMENT 1 Registered in county 23 Structure vacated / secured against reentry 2 County notified 24 hours prior 25 2 SCBA / CPR chart/ Mfg. instructions 12 Handler(s) trained 28 Direct supervision 13 Emergency medical care, posting 29 Warning signs on all sides of structure 15 SCBA worn/ cont. monitoring / CAP 30 Required information on warning signs 17 2 trained employees 37 Methyl bromide requirements 18 Fume of enclosed spaces / proper entry 38 MB- tarps accept. /condition/ ret. method 19 Proper management of treated area 39 MB- warning agents/ fans/ aeration 20 Connecting structures 40 MB- measuring concentration *In total, there are 40 inspection requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) 39

Please complete the remaining modules before conducting an actual inspection of the aeration phase of a structural fumigation: • Aeration via CAP • Aeration via Sulfuryl Fluoride Reason: Aeration that began via CAP may require aeration completion via SF product labeling procedures Examples: Blowouts, malfunction of CAP equipment, intentional cutting of tarps (burglary) Inspectors need to be prepared for both aeration methods. 40

FOR MORE INFORMATION, CONTACT: 41 California Department of Pesticide Regulation 1001 I Street, Sacramento CA 95814 October 2015