Sulfur Dioxide Use in Wineries

Sulfur Dioxide Use in Wineries

Bruce Olson WSDA Pesticide Compliance Specialist Wenatchee, WA

Topics Background/History of SO2 Sulfur Dioxide In Wineries Current Regulatory Status

SO2 Background 1947 - Federal Insecticide, Fungicide & Rodenticide Act enacted 1998 FIFRA (Federal Insecticide, Fungicide & Rodenticide Act) Amendments

SO2 Background Required EPA to Conduct a Comprehensive Pesticide Reregistration Review Purpose: to ensure previously registered pesticide measure up to current scientific and regulatory standards

SO2 Background Complete review of human health and environmental effects 1150 different Active Ingredients grouped into 613 cases Review results summarized in a Reregistration Eligibility Decision (RED)

RED examines: SO2 Background Use Information Physical/Chemical Properties Hazard Assessment Occupational Risk Bystander Inhalation Risk Dietary Exposure Drinking Water

RED examines: SO2 Background Aggregate Assessment Cumulative Exposure Human Health Risk Characterization Ecological Risk Tolerance Reassessment

SO2 Background RED for Inorganic Sulfites issued May 2007 Includes: Sulfur Dioxide and Sodium Metabisulfite http://www.epa.gov/pesticides/reregistration /REDs/inorganicsulfites.pdf

SO2 Background RED Inorganic Sulfates Determination: Sulfur Dioxide or Sodium Metabisulfite are eligible for reregistration provide the necessary label changes are made

SO2 Background REQUIRED LABEL STATEMENTS FOR SULFUR DIOXIDE END USE PRODUCTS: Before moving or using this product, handlers must be trained how to appropriately use respirators which conform to OSHA requirements (described in 29 CFR Part 1910.124) and how to appropriately handle and use sulfur dioxide.

SO2 Background When making gas applications or checking connections wear a NIOSH/MSHA approved full face respirator with an organic-vapor removing cartridge, in addition to sulfur dioxideimpervious gloves, boots and coveralls over long-sleeved shirt and long pants.

SO2 Background When treating grapes in a truck, trailer or other transport vehicle, do not release treated air into the atmosphere containing concentrations of sulfur dioxide in excess of 2 ppm (as determined by a Sensidyne or Kitagawa syringe sampler, or a Draeger handpump).

SO2 Background If a sulfur dioxide concentration of 2 ppm is exceeded at any time, all persons working in the fumigation area must wear a NIOSH/MSHA approved full face respirator with an organic vapor removing cartridge. If sulfur dioxide concentrations of 10 ppm are exceeded, or when concentrations are unknown, an approved selfcontained breathing mask (SCBA) or combination air supplied SCBA respirator must be used by all persons working in the fumigation area.

SO2 Background August 2008 Snowden Enterprises obtains Reregistration for The Fruit Doctor Restricted Use Pesticide Only registered in California currently Label very specific and calls for some very restrictive use requirements

SO2 Background Fall 2008 California Department of Pesticide Regulation issues Sulfur Dioxide Use in Wineries document, with updates in 2009 Feb 2010 WSDA issues Important Notice to Washington State Wineries and Sulfur Dioxide Use in Wineries Fact Sheet

Sulfur Dioxide Use in Wineries SO2 Pesticidal Uses: Sanitizing barrels, corks & equipment SO2 Non-Pesticidal Uses: Preventing oxidation in the winemaking process Inhibiting the growth of wild yeast in the fermenting process

Sulfur Dioxide Use in Wineries What makes it a Pesticidal Use? A pesticide is defined by EPA & WSDA as: any substance intended to prevent, destroy, control, repel or mitigate any pest. Any pest includes microbial pests such as: viruses, bacteria, algae and protozoa.

Sulfur Dioxide Use in Wineries The intent, whether primary or not, when gassing barrels with SO2 is to sanitize. Therefore it is an antimicrobial pesticide. (If you say you use SO2 in barrels to extract more oaky flavors, it is still a pesticide because the barrel is being sanitized.)

Sulfur Dioxide Use in Wineries SO2 used in the winemaking process is considered a Food Additive by the FDA Per FDA in winemaking process it is GRAS (Generally Recognized As Safe) Not regulated by EPA/WSDA

Sulfur Dioxide Use in Wineries SO2 Use in Wineries Fact Sheet: Licensing Recordkeeping Worker Safety

Sulfur Dioxide Use in Wineries WSDA Pesticide Applicator Licensing Totally 100% Estate Wines Private Applicator License 1 Exam: Private Applicator Supervision would entail the licensed applicator to be available if & when needed to meet direct management responsibility

Sulfur Dioxide Use in Wineries WSDA Pesticide Applicator Licensing Grapes used from other sources and/or in addition to your own grown grapes Private Commercial License 2 Exams: Laws & Safety; Fumigation Endorsement Supervision would entail the licensed applicator being within eye-and-ear-shot

Sulfur Dioxide Use in Wineries WSDA Pesticide Applicator Licensing With either situation, one person could hold the license and oversee the application.

Sulfur Dioxide Use in Wineries WSDA Pesticide Applicator Licensing Testing offered weekly in Olympia & Yakima monthly in Spokane & Wenatchee 70% Score to pass $33.00 fee for each license annually Pesticide Licensing Fact Sheet: http://agr.wa.gov/pestfert/docs/form4375.pdf

Sulfur Dioxide Use in Wineries WSDA Pesticide Applicator Licensing Study Materials: WSU Pesticide Study Material Form http://cru.cahe.wsu.edu/cepublications/c0886/ c0886.pdf

Current Regulatory February 2010 Important Notice to Washington State Wineries The Fruit Doctor, EPA Reg. #11191-1 Restricted Use Product Not registered in Washington at that time Only pesticide registered with EPA that lists the fumigation of wine barrels and corks.

February 2011 Current Regulatory Fruit Doctor still not registered for use in Washington No Sulfur Dioxide product registered for use in Washington

Current Regulatory February 2011 WSDA is still in an Informative Stage We will continue to phase in any new requirements over time We will not be conducting any enforcement activities this growing season We will continue to keep you informed of all new developments

Bruce Olson WSDA Pesticide Compliance Specialist Wenatchee, WA 509-665-3395 bolson@agr.wa.gov