Dublin, CA September 25, 2013 Peggy Byerly DPR Enforcement Branch

Overview of ENF 2013-07:Overview of ENF 2013-07:California Aeration PlanCalifornia Aeration Plan

for Structural Fumigationsfor Structural Fumigations(a.k.a. “CAP 2013”)(a.k.a. “CAP 2013”)

Dublin, CADublin, CASeptember 25, 2013September 25, 2013

Peggy ByerlyPeggy ByerlyDPR Enforcement BranchDPR Enforcement Branch

CAP Presentation OverviewCAP Presentation Overview

Key Points covered include:Key Points covered include:

3CCR 6780 & B1 fumigation safety plan3CCR 6780 & B1 fumigation safety plan

Overview of ENF 2013-07 CAP:Overview of ENF 2013-07 CAP:

Requirements vs. Advisory LanguageRequirements vs. Advisory Language

Tables 1 & 2Tables 1 & 2

CAP CAP 66 Steps Steps

New CAP Section: “Blow Opens”New CAP Section: “Blow Opens”2

3CCR 6780 & B1 Fume Options3CCR 6780 & B1 Fume Options

6780(c): 6780(c):

Upon written application by an employer, Upon written application by an employer,

the director will review and may accept a the director will review and may accept a Fumigation Safety ProgramFumigation Safety Program that describes that describes

methodsmethods, , work practiceswork practices, , devicesdevices, or , or processesprocesses

which the Director determines will ensure that which the Director determines will ensure that employees will not be exposed to concentrations of employees will not be exposed to concentrations of fumigants in excess of the Permissible Exposure fumigants in excess of the Permissible Exposure

LevelLevel

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CAP Fume Prep: Internal OpeningsCAP Fume Prep: Internal Openings

CAP 2013 Revision:

The section stating “Open all operable & accessible doors & windows including attics, storage chests, cabinets etc. has been removed from CAP.

This violation must now be written only as “no” for FAC 12973 only, not as a CAP (3CCR 6780) violation.

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CAP Fume Prep: Internal OpeningsCAP Fume Prep: Internal Openings

Each operable attic Each operable attic access must be open access must be open ……[but] if there are multiple [but] if there are multiple

access areas access areas [to the [to the same attic]…same attic]…

a circulation fan a circulation fan is NOT required is NOT required

at at eacheach access point. access point.

““Direct a circulation fan Direct a circulation fan into each attic”into each attic”

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CAP Fume Prep: External OpeningsCAP Fume Prep: External Openings

New CAP 2013: Attached Storage Sheds For “storage sheds” under staircase or attached on outside of structure…

Extra circulation fan not needed in the shedShed w/operable window: open > 3 inchesShed w/o window: open door > 3 inches

& secure against unauthorized entry

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CAP Fume Prep: Aeration DevicesCAP Fume Prep: Aeration Devices

New CAP 2013: Minimum thickness/durability

Aeration ducting, duct covers, inlets, and inlet covers…

must be constructed of material w/same retention & durability capabilities (at least 4 mil thickness)

as required by SF labeling & 16 CCR 1970.1(b)

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CAP Fume Prep: Aeration DevicesCAP Fume Prep: Aeration Devices

For tarpaulin fumigations,For tarpaulin fumigations,aeration equipment is installed aeration equipment is installed

PRIOR to PRIOR to [introduction of] [introduction of] fumigation,fumigation,so aeration can be initiated so aeration can be initiated

from from outsideoutside the fumigated space the fumigated space

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CAP Fume Prep: Aeration DuctingCAP Fume Prep: Aeration Ducting

New CAP 2013: Ducting Reinforcement

Aeration ducting shall be constructed in a manner that maintains its minimum 18-inch diameter without being inflated by the airflow of the fan…

Intention is for ducting to have the same internal size…whether the fan is operating or not…

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CAP 2013 Revisions: Ducting Installation

Connect [18 inch fan to ducting…] so the ducting does not easily collapse or restrict air flow when installed through the tarpaulin or when it is extended…

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CAP 2013 Revisions: Ducting Placement

Position the ducting so the release point…is outside the tarp and fumigant is discharged vertically..

Place aeration ducting in an open area away from sensitive sites such as occupied structures.

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CAP 2013 Revisions: Ducting Placement Advisory

Whenever practical, spacing aeration ducting across the side of the structure…helps to facilitate aeration…

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CAP 2013 Revisions: Duct Cover

The duct cover shall not restrict or block the aeration duct opening after the duct cover is removed… [in CAP Step 1]

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““GARLIC TOP”GARLIC TOP”Industry slang for a duct or its cover

that partially or completely collapses on itselfWhen fan is operating,

causing obstruction of air flow:

during during AerationAeration Phase Phase ““Garlic Top” Garlic Top”

(Full or Partial Blockage) (Full or Partial Blockage) would be a CAP Violationwould be a CAP Violation

CAP Fume Prep: Inlet DevicesCAP Fume Prep: Inlet Devices

CAP 2013 Revisions: Inlet Devices Advisory

Objective of inlets…draw in fresh air & promote cross-ventilation

Inlet size & spacing across side of structure…influence/help facilitate aeration of the structure

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CAP 2013: 6 Inlet Requirements“Inlet Devices MUST…”

1.Maintain the integrity of required opening

2.Have an opening of at least 240 square inches minimum up to a maximum opening of 381 square inches

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3.3. Have the opening covered w/material allowing ventilation, such as mesh, net, or wire…

4. 4. Be located where the opening is notblocked & will draw in fresh air tocreate negative pressure & promotecross-ventilation of the structure…

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5.5. Have the entire inlet opening be at least 4 feet above exterior grade

6. 6. Be sealed in a way that allows external* opening during aeration

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*INLETS ARE *INLETS ARE NOTNOT REQUIRED TO BE OPENED “REMOTELY” REQUIRED TO BE OPENED “REMOTELY”LIKE DUCTING BECAUSE FANS ARE ALREADY TURNED ONLIKE DUCTING BECAUSE FANS ARE ALREADY TURNED ON

CAP Inlet Device RequirementsCAP Inlet Device Requirements

Inlet Device PlacementInlet Device PlacementADVISORYADVISORY

Whenever possible, Whenever possible, place inlets on place inlets on the side the side oppositeopposite from from

where the aeration where the aeration ducting is located…ducting is located…

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CAP Table 1: InletsCAP Table 1: Inlets

CAP 2013 Additional: Inlet Size RangeCAP 2013 Additional: Inlet Size Range

In addition to changing the minimum size of In addition to changing the minimum size of each inlet, Table 1 now has a each inlet, Table 1 now has a maximummaximum inlet inlet sizesize

Total number of inlets required per size of Total number of inlets required per size of structure in cubic feet with “options”structure in cubic feet with “options”

New examples of how to calculate # inlets & New examples of how to calculate # inlets & DAFs needed for that size structureDAFs needed for that size structure

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CAP Table 1: # DAFs vs # InletsCAP Table 1: # DAFs vs # Inlets

When the structure’s When the structure’s size in cubic feetsize in cubic feet has has been determined by the PCB, been determined by the PCB,

review CAP Table 1 review CAP Table 1 for the for the minimumminimum

number of ducted air fans & inlet devices req’dnumber of ducted air fans & inlet devices req’d

[Table 1 # DAFs per cubic feet didn’t change][Table 1 # DAFs per cubic feet didn’t change]

CAP 2013 Change In Table 1CAP 2013 Change In Table 1: : Determining the Determining the total # Inlets total # Inlets per size of per size of

structure is based on a structure is based on a “range” “range” calculationcalculation 21

CAP 2013 Revision: Inlet Size RangeCAP 2013 Revision: Inlet Size Range

Minimum Inlet Size Minimum Inlet Size decreaseddecreased from from

254 square inches (approx. 16” X 16”)254 square inches (approx. 16” X 16”) to the new minimum inlet size: to the new minimum inlet size:

240240 square inches (~15.5” X 15.5”)square inches (~15.5” X 15.5”)

ANDAND

Now there’s also a Now there’s also a maximummaximum inlet inlet sizesize

381381 square inches (~19.5” X 19.5”) square inches (~19.5” X 19.5”)22

CAP 2013 Revision: Inlet Size RangeCAP 2013 Revision: Inlet Size Range

Minimum Inlet Size = 240 square inchesMinimum Inlet Size = 240 square inches

2 inlets this size = 480 sq. inches2 inlets this size = 480 sq. inches

3 inlets this size = 720 sq. inches3 inlets this size = 720 sq. inches4 inlets this size = 960 sq. inches4 inlets this size = 960 sq. inches

Maximum inlet size = 381 square inchesMaximum inlet size = 381 square inches

2 inlets this size = 762 sq. inches2 inlets this size = 762 sq. inches

3 inlets this size = 1,143 sq. inches3 inlets this size = 1,143 sq. inches4 inlets this size = 1,524 sq. inches4 inlets this size = 1,524 sq. inches

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CAP Table 2: Aeration HoursCAP Table 2: Aeration Hours

Once the structure’s cubic feet is measured Once the structure’s cubic feet is measured and the sulfuryl fluoride label calculations and the sulfuryl fluoride label calculations for concentration of fumigant are known, for concentration of fumigant are known,

consult CAP Table 2 to determine consult CAP Table 2 to determine minimum number of hours aeration timeminimum number of hours aeration time..

Example: For Example: For << 16 ounces 16 ounces SF per 1K cu ftSF per 1K cu ft

Minimum Aeration TimeMinimum Aeration Time = = 12 hours12 hours

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CAP 2013: Intro To The StepsCAP 2013: Intro To The Steps“Aeration & Reentry”“Aeration & Reentry”

All of the following CAP steps (1-6) must be completed in sequence…

[But when multiple] tasks in each step, they may be accomplished in any order

Licensee (B1 Operator or Field Representative) must be present for & assure completion of Steps 1-6

CAP 2013: Step 1 - Initiating AerationCAP 2013: Step 1 - Initiating Aeration (“Aeration Fans On”) (“Aeration Fans On”)

Step 1Step 1 Remove seal(s) from each Remove seal(s) from each

previously installed exterior duct(s)previously installed exterior duct(s)andand

Activate aeration fans from outside Activate aeration fans from outside (by “remote activation”)(by “remote activation”)

Sdkl;j

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CAP Step 2CAP Step 2 (Initiating Aeration: “Inlets Opened”)(Initiating Aeration: “Inlets Opened”)

Step 2Step 2[“After [“After ALLALL (ducted) (ducted)

aeration fansaeration fans are activated…”]are activated…”]

Remove inlet cover (seals) from Remove inlet cover (seals) from eacheach of the of the previously installed previously installed inlet devicesinlet devices

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CAP Step 3CAP Step 3(“Fans Off”)(“Fans Off”)

Step 3Step 3

Anytime after the required # hours Anytime after the required # hours

of aeration specified in Table 2of aeration specified in Table 2are completed… are completed…

Turn off Turn off

the aeration fansthe aeration fans

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CAP Step 4 CAP Step 4 (“Tarps Off”)(“Tarps Off”)Step 4Step 4

(After fans turned off) (After fans turned off)

Remove all tarpaulins Remove all tarpaulins and/or seals and/or seals

from the structure…from the structure…

Do Not Enter Do Not Enter structure w/o SCBA structure w/o SCBA

oror Continuous Continuous Monitoring until Monitoring until

Step 6Step 6 completedcompleted29

CAP Step 5CAP Step 5

Licensee assuresLicensee assures::

IFIF central air/heating systems, turn on the central air/heating systems, turn on the fan/blower fan/blower ONLYONLY for for eacheach operational unit… operational unit…

OROR a a circulation fan may be placed circulation fan may be placed in front of furnace inlet to blow air into the in front of furnace inlet to blow air into the heating/cooling ductsheating/cooling ducts

Remove all chloropicrin pans from the Remove all chloropicrin pans from the fumigated spacefumigated space

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CAP Step 6 CAP Step 6 (Ready To Clear For Re-entry)(Ready To Clear For Re-entry)

Next measure the concentration of fumigant Next measure the concentration of fumigant

in breathing zones in breathing zones

using approved fumigant detection device using approved fumigant detection device per the registered label.per the registered label.

If structure tests If structure tests << 1.0 ppm, it’s ready for 1.0 ppm, it’s ready for

Certification…Certification…

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CAP Step 6 CAP Step 6 (Clear For Re-entry)(Clear For Re-entry)

OR…OR…If concentration measures If concentration measures >> 1.0 ppm 1.0 ppm, ,

or warning agent detectedor warning agent detected, ,

open operable doors & windows for open operable doors & windows for additional ventilation (usually a few minutes) additional ventilation (usually a few minutes)

until detection device confirms until detection device confirms << 1.0 ppm & 1.0 ppm & structure may be re-occupiedstructure may be re-occupied

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CAP 2013 New Section:CAP 2013 New Section:“Blow Opens”“Blow Opens”

33Photo contribution for training purposes from Santa Barbara CAC

CAP 2013 Additional:CAP 2013 Additional:“Blow Opens”“Blow Opens”

CAP 2013 new section states the options depending upon what time in the fume process the tarps open…

First paragraph clarifies PCB must still comply with 3CCR 6780 for “blow opens”…

Determine SF level in the exterior workspace before resealing or removing tarps. If SF level > 1.0 ppm in the exterior use SCBA when reseal/remove tarps…

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If fume is “finished” (estimated # hours exposure long enough

to control the pest treated):

Can be resealed & aerated using CAPOR

If cannot be resealed, tarps can be removed BUT aeration must be completed using SF labeling “Aeration Procedure 1 or 2”

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If fume is NOT “finished” (insufficient # hours exposure

to control the pest treated):

Can be resealed, more fumigant added if necessary, & aerated using CAP

If cannot be resealed (fume job to be rescheduled), tarps can be removed BUT aeration must be completed using SF labeling “Aeration Procedure 1 or 2”

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ANY OTHERANY OTHER CAPCAP

QUESTIONS???QUESTIONS???See PBSee PB

During the During the breakbreak

Documents

Dublin, CA September 25, 2013 Peggy Byerly DPR Enforcement Branch