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Regulatory Alert (RA 00-20)

Member Pipeline - Regulatory - Alert (RA 00-20)

To: Members & Affiliates
From: National Office
Date: October 4, 2000
Subject: USE OF CHLORINE GAS SUBJECT TO ADDITIONAL TRAINING REQUIREMENTS
Reference: RA 00-20

Action Please By:
November 1, 2000

On September 18, 2000, EPA provided notice of its intent to reclassify the use of chlorine gas for water and sewage treatment as a "restricted use" under federal pesticide labeling and application regulations. This reclassification would allow only certified and trained applicators to use chlorine gas. POTW plant operators using chlorine gas would be required to receive additional training as "certified applicators."

Restricted use pesticides may be applied only by or under the direct supervision of specially trained and certified applicators. Certification and training programs are conducted by states, territories, and tribes in accordance with national standards set by EPA. The September 18 notice stresses the need to integrate certified applicator training into existing wastewater operator training programs, such as those required under Occupational Safety and Health Administration’s (OSHA) Process Safety Management Program and EPA’s Risk Management Program. EPA also indicates that not every worker will need to receive certified applicator training; although one certified applicator would need to be present for all operations.

EPA issued its original Reregistration Eligibility Decision (RED) decision on chlorine gas in February 1999. EPA’s original position was that the majority of uses for chlorine gas should be classified as "restricted use," with the exception of water and sewage treatment, and residential pool treatment. EPA stated that "chlorine products registered for drinking water, sewage and wastewater treatment uses, and residential pool uses will not be considered ‘restricted use’ because few related accidents or incidents of poisoning have been reported, suggesting that existing requirements are satisfactory." Attached is a fact sheet on EPA’s original RED decision for chlorine gas. With the September 18, 2000 notice, EPA has indicated a reversal of its original February 1999 decision concerning use of chlorine gas in water and sewage treatment.

EPA has reopened the comment period for 60 days until November 15, 2000 to allow interested stakeholders to provide comment on EPA’s proposed expansion of the restricted use for chlorine gas. A copy of the Federal Register notice is attached. If you are interested in contributing to AMSA’s comments, please submit your comments to Mark Hoeke at the AMSA National Office by November 1, 2000, at mhoeke@amsa-cleanwater.org or call with questions at 202/833-9106.

 

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