9.3 Pesticide Security, Fire Hazards & Emergency Response Planning

9.3 Pesticide Security, Fire Hazards & Emergency Response Planning

When 40 CFR 171.103 was written, EPA added professionalism as a competency area, and the first item under it is "maintaining chemical security for restricted use pesticides." Utah adopted that language verbatim at R68-7-8(3)(i)(i). Security is now a tested competency, not a business preference.

1. Why Pesticide Security Matters

Stored pesticides are attractive to theft for resale, they are hazardous if children or untrained people reach them, and a stolen restricted-use product creates liability and a reporting obligation for the person it was stolen from. A secure site also protects the applicator's own business: a break-in that spills product produces a cleanup bill, a possible reportable release, and a UDAF inspection.

Conducting a Security Risk Assessment

Work through the site the way someone with bad intent would:

1. What is stored here, and how much? Inventory by product, EPA registration number, container size, and quantity, and reconcile it regularly. An inventory you do not reconcile cannot tell you whether something is missing.
2. Who can reach it? Employees, family members, delivery drivers, customers, contractors, and anyone who can walk onto the property.
3. How would someone get in? Doors, windows, roll-up doors, adjoining rooms, and the perimeter.
4. What would tell you it happened? Locks that show damage, seals, cameras, lighting, and the inventory reconciliation.
5. What would happen next? Who is notified, how quickly, and what is done about the product now in unknown hands.

Practical Security Measures

• Lock storage buildings, cabinets, and the fill caps or valves on nurse tanks and bulk containers.
• Lock or immobilize application equipment when unattended, especially rigs left overnight in the field.
• Restrict keys and access to the smallest workable number of people, and recover keys immediately at separation.
• Light the exterior of the storage area and keep sight lines clear.
• Post the area and keep the perimeter fenced where practical.
• Track deliveries; verify what arrived against what was ordered.
• Train employees to recognize and report unusual purchases, questions, or people around the site. Employee awareness is the single most effective security control on most operations.
• Report a theft of pesticides or of fumigation equipment to law enforcement, and — for fumigants — as the Fumigation Management Plan directs.

2. Utah's Storage Security Rules

R68-7-19(10) governs unattended pesticides and their containers:

Pesticides at the loading area are not considered unattended if the operator maintains visual control or returns at closely spaced intervals to monitor them safely. Once decontaminated, empty containers fall outside these requirements.

R68-7-19(11) adds posting for DANGER/POISON storage areas. Warning signs must show the skull and crossbones symbol and the words "Danger/Poison (Pesticide or Chemical) Storage Area/Keep Out" in letters at least two inches tall. Signs go at each entrance and exit from the storage area and on each exterior wall so a sign is visible from any direction; if the storage area sits inside a larger multipurpose structure, signs must be clearly visible at each entrance to the storage area.

3. Fire Hazards

A pesticide fire is a different problem from an ordinary structure fire:

• Burning pesticides produce toxic smoke and decomposition products, some more hazardous than the original product.
• Water used to fight the fire becomes contaminated runoff that can reach surface water or groundwater.
• Pressurized containers and aerosols can rupture.

Reducing the hazard:

1. Store products in their original containers with labels intact, so responders can identify what is burning.
2. Keep the storage area free of combustible debris and separate from fuel, oil, and ignition sources.
3. Provide the correct type and size of fire extinguisher and keep it serviced.
4. Give the local fire department an inventory in advance, along with a site map showing where products are stored and where water supplies and drains run. Update it when the inventory changes materially. Responders who know what is inside can decide whether to let a fire burn rather than create contaminated runoff.
5. Keep the storage area's ventilation, lighting, and non-porous flooring in good condition, and control temperature so products stay within their labeled range.

4. The Written Emergency Response Plan

An emergency plan is written before the emergency because nobody researches procedures during one. A workable plan answers:

Practice the Plan

A plan that lives in a binder nobody has opened is not a plan. Walk the crew through it at the start of the season, verify that the phone numbers still work, confirm the spill kit is complete and unexpired, and check that the fire department's inventory copy is current. Utah's rule requires business records of employee training — including topics and products covered and the signatures of trainees and trainer — to be kept and retained for two years after an employee leaves (R68-7-16(1)(b)), so the training session that covers the emergency plan should be documented like any other.