MSU Extension MI Ag Ideas to Grow With

 - Curtis, I see that you've joined us here. Curtis Lilleodden is from Fumigation Supply Services, and Curtis is going to talk to us about some re-registration concerns and some CDL concerns with handling fumigants. So, Curtis thanks for joining us and we'll turn it over to you. - Yeah, thanks Mike. My name is Curt Lilleodden and like Mike I said, I work for a Fumigation Service and Supply. I've been a licensed fumigator for about 32 years and I have worked with Pete Mueller who Klein referred to earlier for about the last 12 years. So, Forgive me. Here I've got the wrong version up here. There we go. I'm not sure what happened here. Give me just a second, I apologize. Let's see how this one does. Okay, here we go. Thank you. I Apologize for that. Like I said, I've worked with Fumigation Service and Supply for about 12 years with Pete, and today I wanna talk to you about three main things. One, I wanna cover where we're at with the EPA registration review on both phosphine and sulfuryl fluoride. I would also like to get you some updates on the clearance monitors for sulfuryl fluoride and some of that. And then finally I want to cover some things on the new entry-level driver's training rule for CDL holders. So with that, I wanna thank you for letting me join you today. And I also usually like to start out with a section on any kind of serious incidents that might have resulted from this applications in the past year, but I could not find any I recorded in the state of Michigan. So I guess, first of all, I'd like to congratulate you all for working safe. So an update on the US EPA registration review for aluminum phosphide, magnesium phosphide, and other phosphine fumigants. I wanna cover the Proposed and Interim Decisions. As you know, the EPA registers all pesticides that we use and those pesticides will also go through our registration review periodically. Not a whole lot has changed in the past year. So I don't know how often you guys do your training in the state of Michigan. I know in the states where I hold my license, a lot of those are every other year. Some are even every every three years. So there are a few things that happened that I would like to address, so. Just a brief review of the timeline on phosphine. This has been going on for quite some years now. In 2013 was first opened up. But what I wanna mainly cover is what has happened since 2020 into 21. They did open up a comment period in 2020. So for any of you who are able to send in your comments to the EPA, I thank you. In situations like this, it's always good when more people comment and give their input on how some of these decisions that they are proposing could affect us especially in a negative way, so. That closed a little over a year ago, so. There was three main points to this interim decision that they made. I will address this. This information was courtesy of Degesch. So it comes right from our industry leader and especially when it comes to phosphine. But the three main things were the updated description of PPE fit, the pesticides resistant management on the labeling Klein head referred to it a little bit. I apologize, I missed the first presentation but as you know we are starting to see more and more resistance with phosphine products and by stored product pests, so. And the other thing, and probably what I'm gonna spend the most time on, is this establishment of buffer zones that they're looking at, so. Updated PPE fit. EPA is proposing that labels specify that occupational handlers wear loose fitting clothing and PPE and that labels prohibit the handler from wearing jewelry. So for those of you who have ever used methyl bromide products it would be a similar wording to that. They want to prevent phosphine becoming trapped against the skin underneath that. The Phosphine Producers Association doesn't really take issue with this. However, it's recognized that this is probably mainly refers to cylinderized phosphine not so much solid phosphine. As you know now with solid phosphine we should be wearing cloth gloves when we're handling those metal phosphide products. And for those of you who've ever worked with gloves you know you can't really wear loose fitting gloves and be very productive, so. That's really the only thing on that issue. As far as resistance management goes, the EPA is proposing some labeling for these metal phosphide products and phosphine products. They wanna provide pest side users with easy access to important information about the effectiveness and usefulness of these pesticides. In particular, they want to include a mode of action box and some wording about fumigant rotation, or other pesticide rotation, consideration of non-chemical practices, especially things like sanitation and sampling for pests before and after. Maybe it might be applicable to phosphine and phosphine products. This is kind of what it would look like on the label. The phosphine producers and most of us in industry agree that due to the unique nature of how these fumigants work, the generic language that EPA is proposing could be confusing, or in some cases even in inaccurate for end users. So what instead we'd rather just see some best practices language inserted into the label to address phosphine resistance concerns. The thing is, is what they're looking at is, for instance, here you see that phosphine is a group 24A mitochondrial complex for electron transport and hinder. To most of us that really doesn't mean a lot. But what it does tell you is what group of pesticides it is in and the mode of action that it takes, but there are still a lot of unknowns about exactly how phosphine works once it gets inside the system. So to just say that this is the mode of action that phosphine does is where we get into that confusion. But if you were worried about resistance, then you would look at moving away from this group and going to a sulfurly fluoride or something like that. It affects the insect in a different way, so. That's why I say we're looking at more, probably just more, some general best practices would be better instead, so. The EPA is also the third thing that is probably going to affect our industry. The most is this proposing that we establish treatment and aeration buffer zones around all phosphine, aluminum phosphide, and magnesium phosphide commodity application sites, so. To develop these buffers is based on single application PERFUM outputs. For those of you that are not familiar with the acronym, PERFUM stands for Probabilistic Exposure and Risks Model for fumigants. It was first developed as an issue of bystander exposures, especially to soil fumigant applications to field workers. But basically what was happening is following applications of the fumigant in the field that some of this materials gonna volatile, become up in the air and be carried downwind. So there's that potential of causing exposure to people in the vicinity of that application. Of course, the closer you are to the application site the higher the exposures are gonna be, and as it moves to outfield and downwind, it's gonna disperse and lower concentration. So as that plume moves, the farther away you are the safer you're gonna be, so. And these were established quite a while ago especially in California where they do a lot of soil fumigation and both US EPA and the California Department of Pesticide Regulation is working on establishing these same types of buffer zones around structural sites. Like what we are probably doing more of. And so you take this perfume data that you would gather. It includes local meteorological records, treatment facility size, your emission release sites. When you go to vent, where is that gas going now? Is it coming out on the ground, or is it going. If it's in a bin, are you pushing out the top of the bin? So it's could be a 100 feet in the air, better. The frequency of treatments that are going on, concentration of the treatment, leakage rates on the bin, ventilation rates, or if you're using any kind of recapture technology. So based on all of these inputs, the PERUM outputs describe an a fumigant air concentration, or what we could predict could happen and from a certain distance of the emission source, so. They're taking this stuff and comparing it to pre-established exposure limits and what they wanna do is establish these buffer zones. So it's a mouthful. But sites that have multiple sequential applications would require buffer zones to be sized based on that total volume fumigated and your application rate and your type of variation equipment. But what they wanna propose is a minimum buffer zone of 10 feet on all fumigations. So, based on these current PERFUM calculations that they've been doing in data on phosphine and metal phosphide usage these buffer zones could range from that minimum 10 feet all the way out to 500 feet. So, quite a range. And some of the things that we recommend when people are asking, you know about these things and what your thoughts are. I mean, the more informed you are, of course, and why we're here today, the better you can talk to people about this. But we are concerned about losing some of these products and we need to let people know that these are essential tools, metal phosphide are essential. They're used to treat a wide variety of commodities safely and economically to protect our world's food supply. And as mentioned earlier, there are certain parts of the world, a lot of them, that they have requirements that we fumigate and they're only approved fumigant right now is metal phosphide. They help preserve the flow of commerce. And like I said, sometimes phosphine is the only acceptable option. So the EPA has indicated that treatment and aeration buffer zones will be proposed on all metal phosphide and phosphine fumes. But other than that 10 foot minimum that they're talking about, there really are no specifics yet. They haven't given us any, and we're just concerned that generic buffer zones for a set of operating parameters really goes against current labelings. Right now the current label requires us to do careful evaluation of each individual site. And what they're trying to do is take a type of site and say that if you're doing this, then these are going to be your buffer zones. when we're doing a fumigation we need to go on each individual site and specifically look at that. What the place looks like. If it's been fumigated before, what's the history and what's the current conditions going on? I mean, things change from year to year. Of course, weather conditions change from day to day, and we need to look at all of that. And that's currently done during the development of our FMP. These look up tables that they are proposing, they'll be in place are gonna put unnecessary restrictions on sites where fumes are already being performed, even though bystander concerns on these locations had already being addressed by that Fumigation Management Plan. And Fumigation Management Plans as you know are already being prepared by certified applicators like ourselves, and we have a good understanding of the fumigants that we're using, the site that we're at, the commodity that we're fumigated. And buffer zones that we establish when we are fumigating are all based on that individual site, the construction, the location, the history, the current conditions. Any monitoring data that we're collecting while the fumigation is going on. For those of you who have ever fumigated you know that things can change quickly. Whether wind direction switch, or temperature fluctuations can cause gas to move from one area to another. And other things can happen that are completely out of our control. Acts of God that something happens to the building, fires, whatever. I mean, there are all things that we have to worry about, and we look at what's going on in the neighborhood around us if we're in. One weekend there might be a ball field that's close by and there's nobody there and the next weekend when we fumigate there might be hundreds of people and some kind of tournament going on. And we need to consider all of that stuff when we're doing that. And we make these adjustments as we go, and we just don't think that these generic buffer zones are gonna account for those kind of things. Applicator, training, education, and experience, coupled with onsite monitoring are always gonna be much more effective than some arbitrary distance that's based on generic model. So we really don't agree with this at all. Generic buffer zones will probably imperil metal Phosphine fumigation at sites that have had a long history of safe applications, especially if their generic buffer zone model says, well, now you have to be this far away. And it's like we've done this fumigation 20 times over the last five years, and we've never had an instant. We monitor, we don't have this. Now this says that we have to stay this far away and you can't do it. Fumigations take place in fixed structures that have fixed infrastructure and they can't easily or economically be relocated. So if these buffer zones prove unworkable, many facilities won't be able to do this when we've already been unable to prove that it's safe, so. We're also worried that once you put these kind of things in place it just takes away that level of thinking that fumigators need to have now instead of really considering what's going on. We could risk sending out more inexperienced fumigators and just going by these look up tables and saying, well, we did what they said, and that's as far as we went, and I just don't think that that is going to be a good route to take. So, I think the FMP that most of us are hopefully all of us are currently using and as it's implemented is shown to protect potential bystander exposure, and we really don't see how it, there's no justification for the 10 foot mandatory buffer zone. That again is gonna be very site-specific. I've fumigated a lot of buildings and bins where you can walk right around in the building after you shoot the gas into there, or put it in, and we don't have any readings. So there's really no justification to say that it absolutely has to be 10 feet. If you've got two bins that are within 10 feet of each other, or two structures and one building cannot be vacated, this would eliminate that fumigation where we can currently do monitoring both inside the building and out and guarantee and ensure people's safety from the fumigate, and this would eliminate that, so. Really if there's no risk to buy standard exposure from concentrations over the pesticide exposure limit at a shorter distance. There's really no reason to have that conflict zone. So what are the next steps? The EPA is gonna continue to review, and evaluate, and respond to public comments. They're doing the interim registration review right now. The final decision on phosphine it'll come after. Well, the Endocrine Disruptor Screening Program that is done by the Food, Drug, and Cosmetic Act it's because of that. They need to make that determination yet. There's an Endangered Species Act, that determination that we need and consultation. So once that is done, hopefully this will get wrapped up. I have been on the EPA website recently, and I haven't found any updates on this yet other than this one article that came from the Office of Inspector General that says that, the EPAs Endocrine Disruptor Screening Program has made limited progress. So they're really struggling with getting through this and determining the long-term health effects of different pesticides. So it's slowed way down so. It could cause this whole process to take a little bit longer. Next, I wanna to review a little bit about what's happened with sulfuryl fluoride as well. In particula the EPAs Office of Inspector General, you hear that come up again and you just did too with phosphine, but they wanted to address the human health incidents. And this report came out back in 2016, so quite a while ago. But basically it was a titled, "Additional Measures Can Be Taken to Prevent Deaths and Serious Injuries From Residential Fumigations. So of those of you who have been in the business for a few years I'm sure you've heard about some of the very unfortunate incidents that have happened around fumigation and a couple of them particularly with sulfuryl fluoride where there was serious injuries to people, either getting let back into their home after a fumigation when it wasn't clear, or from using the wrong fumigant or people just not following procedures and putting people's lives in risks. So the Office of Inspector General did a long study on this and the EPA believes that the mitigation measures outlined in their interim re-entry mitigation measures is necessary to identify human health risk concerns. So I do want to let you all know that the scope of this interim mitigation is focused on sulfuryl fluoride uses, more of a structural fumigant, and residential use sites. It doesn't focus really on the commodity fumigation that some of you may probably do a lot of in Michigan with PROFUM. So, but once they are done reviewing the residential fumigants, they will in turn look at and go through the commodity fumigants as well. I believe that once happens it'll go quickly because most of their concerns addressed with the residential don't always particularly are concerned with what we are doing. But going back to not quite a year ago, the EPA had a response to that report. They opened up 120-day public comment, and on its proposed labeling changes for sulfurly fluoride and registration of fumigants for residents, so including Vikane. The labeling changes were described in the Sulfuryl Fluoride Draft Interim Re-Entry Mitigation Procedures. These procedures are proposed in response to recommendations from the Office of Inspector General, and we've already went through the title of that report. So, the EPA's response. There were five major things covered in that. The first one was to remove the SF-ExplorIR and the Interscan as approved SF clearance devices. And this was based on a laboratory evaluation that was done by the EPA. The second thing was that they want a more description of warning sign features and placement as to where they're gonna go. The requirement of a Fumigation Management Plan that describes specific information to be documented for each fumigation. They also wanna requires specific stewardship plans by registrants to be posted on EPA website. And they are looking at replacing aeration procedures one and two on label with the California Aeration Plan, or CAP. Just for time constraints I'm not gonna cover the California Aeration Plan right now. It does apply to people fumigating in California. The EPA wants to institute it across the country. There is a possibility that this could happen down the road, but if you do want more information on that CAP, you can Google it and find all kinds of stuff, or you could call your Douglas representative if you're using them, and they will explain that a little more, so. But the other ones we will cover. So the first one that I'm gonna cover is a recommendation for FMP's warning signs and just tighter barriers. So right now what their main addressing is these tent fumigation for dry wood termites. What was happening is people were breaking into them and getting sick or dying. And so they proposed some label changes for all three brands of sulfuryl fluoride that's used for residential fumigation. And one of the things they wanna do is create a barrier to access, or use detection mechanisms to prevent access into these tents. This could include temporary fencing. Maybe even hiring security personnel to guard the place for 24 hours, cameras, different things like that. But definitely making it harder for somebody to just show up at that tent, cut a hole in it with a razor blade and gain easy access to the fumigation So another thing that they're proposing is larger warning signs. So most of you know about how big a warning placard is right now, they are proposing much larger signs with some additional information on it. They're also looking at placement on them. More placements as opposed to just at least one on each side, they wanna have additional placements on there as well. And also then preparing site-specific fumigation plans for applications for residential sites. So I am mostly a commodity fumigator myself. I spent 20 years fumigating Minnesota, and now the last 12 years in Iowa, we just don't do dry wood termite fumigation. I have done a couple of methyl bromide fumigation over the years for wood destroying insects. But for the most part it's been a long time. And I didn't realize that they do not have to put together a Fumigation Management Plan to fumigate a house like we do when we're doing a commodity fumigation. I'm not sure if some of you knew that or not. It's always amazing. To me, I think I've been doing this long, and I didn't even know that. I just assumed that everybody was preparing FMP for every fumigation, but that has not been the case. I believe that is a good idea. I think every fumigation that's done should have one all the way down to a fumigating a semi trailer, so. They're also doing a recommendation on specific stewardship plan. So for any of you who have ever went through Dows or now Douglas's stewardship program in particular PROFUM fumigant. You know how thorough that training is, and I believe that that is probably gonna become a model for all fumigants, but especially what they're addressing here is the other, what some people might call off brand of the same product, sulfuryl fluoride, so. The label language is gonna clearly define the criteria of meeting applicants to upgrade or stewardship training, including the frequency, how often that's gonna be done. For most of you, and for me, we go through that annually. And as you know, when you go through that training there's always an evaluation done, or what we normally call a test. So, it shows the understanding of the training. So if you're going through that already, good job, and thank you for being good stewards, so. The other thing that was really confusing, I'm not sure how much. If you heard about this last year but there was a lot of talk about losing some of these monitors that are widely used in the industry. Their recommendation was to remove both the ExplorIR, bispectrals, and the Interscan. And they conducted an assessment of these clearance devices to evaluate their effectiveness and detecting required clearance levels which with sulfuryl fluoride you know is one less than part per million, and it's still ongoing. But these are the ones that are currently approved for Viken fumigant and also for PROFUM if you're using it. The CLIRcheck,xx the SF-ExplorIR, the Interscan, and the FumiSpec-Lo. So, the SF-ExplorIR. In may last year they proposed to remove the SF-ExplorIl as an approved clearance device. The SF right, I tell now, that the SF-ExplorIl remains an approved clearance device on labeling for Vikane as well as PROFUM. EPA basis proposal on a flawed evaluation that they conducted themselves on the SF-ExplorIl. Here's the thing. They did some bench testing on it but they didn't follow the procedures that Spectros provides when using that piece of equipment. If any of you have ever used it you know that it can be a little temperamental and you need to watch how you use it, and a new study using these procedures was submitted in EPA by Douglas Products in November of last year. So like I said, they didn't follow the procedures of what Spectros recommends in handling the equipment. They all also didn't review an extensive study that Douglas had already done on it. So they used their own and disregarded that. After that they did another study again. And both of the studies showed that the EPA demonstrates that the SF meets appropriate performance criteria. The biggest thing is if you've ever used it, you know that there's an infrared sensor in there. The monitor pulls in fresh air samples. So you take that machine to no one fresh air, fill the bag, and then when you go in to do monitoring, it's constantly taking, or every two seconds is taking a reading from the building, or the structure you're fumigating and comparing it to that clear reading. We really have to be careful is if there's a major difference in temperature and humidity from where you filled it and where you are sampling. So you have to be aware of some of that as you're using it. And they just didn't take that and there was some other things too they didn't take into in consideration. But as for now, with me there, it still remains an approved device. The Interscan, another monitor that has been around for a long time, it's used to monitor low concentrations for clearing any re-entry, but you have to be careful with this monitor. If you expose it to levels over 50 parts per million, you can shorten life at that sensor in there and cause it to fail. Those of you have ever used, you already know this. But this monitor must be calibrated within 30 days of use. So, it requires constant calibration where some of the other monitors is just an annual verification that is working properly. So, the Interscan GF1900. The Interscan remains an approved clearance device right now. It's still on the label because the label has changed. I think some of the flaws that were identified in EPS's evaluation were unique to the SF-ExplorIl and what we were talking about, but some of them probably affected the analysis of the Interscan as well. What we do know is Interscan corporation and Douglas Products have chosen not to conduct any additional research on this monitor. We also know this, that the Interscan corporations decided that it's no longer gonna manufacture. They're no longer gonna repair it, or they're not gonna provide any support for this Interscan monitor and that's effective immediately. So, what does that mean? If any of you have ever used a Pac III for monitoring phosphine. Several years ago Drager said, well, and at least in their case they were recalibrating, but they weren't offering any more support on them or replacement parts. So if the thing went bad on you, it was now junk. And basically the same thing has happened here. There's no longer parts. If something breaks, there's repair. Basically the applicators are a 100% responsible for ensuring that that Interscan is working. That it's calibrated, that it's maintained, that it's operating properly. And as long as you're using it it is a 100% your responsibility. At this time it's unclear when this is gonna come off of the label. It's gonna be up for the EPA to propose the timeframe for the registrants to submit their label amendment. So Douglas products, the makers of Viken, and and PROFUM have stressed to the EPA that label amendments should be made on a schedule that coincides with the completion of the registration review. So we're currently anticipating that that'll happen next year, sometime in 2023, and amending the labels as a it's a multiple step process. It starts with the submission of the new label from the registrant, the manufacturer basically, and then the EPA must review it and approve it, and then following the EPAs approval, then it needs to go to the state. So the state level for each individual state has to prove it for use in theirs state before we can use it. So regardless of when this label amendment process occurs, the manufacturers and the registrants are gonna work with the EPA to establish reasonable timeframe for implementing these label changes to minimize any kind of business disruptions, so. The FumiSpec-Lo. I'm really not gonna spend too much time on this machine because currently there are none of them being used in the United States that I'm aware of. So I doubt any of you have used it. You may have heard of it, but it's a different type of monitor, a little bit of different way of checking the gas. It's a little bit slower as far as reaction goes. I mean, it is accurate and approved use, but I haven't used it personally or had a chance to even test it. So I really I'm gonna leave it. I just wanted to know that it is available. And then if you wanted more information on it, Bill Harris, his contact information is below here. So he works for Uniphos and it is their monitor. I think we will over time probably see more of them out there and you, so. So, what are the responses that were posted to this public doc that happened last year? So they closed this last fall, September 23rd closed. There was a 38 page assessment by the sulfuryl fluoride advisory panel. I mean, this included the companies that make the gas, some pretty large fumigation companies in states like California, Florida, Hawaii, which is where most of these termite treatments are done and along with other states. Pest Control Associations, regulatory advisors, all kinds of people. I mean, they submitted a lot of information to them. 200 pages and more than 125 letters. So it's a lot of stuff to go through. It's unknown how long it's gonna take for them to decide on this. But the public docket was extended for two months, which was good. It allowed for more input. And a lot of comments were submitted and they're required to review every single one, so. That amount of input from the industry in itself is good but it did manage to slow down the process a little bit, so. In addition to any labeling changes required by the EPA, they must be reviewed and improved by all states. Like I said, and sometimes that can take months, so. The last thing, like I said, if you have any questions on this, as far as updates, go to your provider. As far as your manufacturer who you get here. If you're using PROFUM go to your Douglas representative and they will give you anything, updates as things change. So hopefully, like I said, this will be done next year. The final thing I wanted to cover just briefly, but it does affect our industry and the Federal Motor Carrier Safety Administration put into effect as of February 7th, 22, just last month that any entry-level drivers, anybody new to getting a CDL, class A or class B, must complete this entry-level driver's training course before being able to go take your, like your written test or your skills test, you're on the road test. What actually is this? Actually this goes back a long ways to December, 2016, the final rule was set in place. And then it was not rolled out right away. It was pushed back couple of years. So it finally came into enactment this year. So it sets a federal standard for Mandatory Training for Entry-Level Commercial Drivers. It establishes minimum requirements for the training. So if you go to an approved provider it'll cover at least these particular things. Depending on your state, they might have requirements that exceeded. I don't know of any in the Midwest but there is a possibility. Also what it did is it established it the need for training provider registry. So if you were going to get that you knew where you could go. So what does it require CDL applicants? So any entry-level drivers must complete this training from a provider listed on that training provider registry prior to taking these tests. An individuals who obtain them. If you have your commercial learners permit already, you had it before February 7th, then you wouldn't be required to meet these as long as you get it done before that learner's permit expires. But if you haven't done that as of yet you know that that window is already closed. So, who is required? Individuals that are applying for a Class A, or a Class B CDL for the first time. So if you're gonna drive semi or school bus, anybody that has a Class B already and wants to upgrade to a Class A, that applies to you. But here's where it affects our industry 'cause a lot of us probably don't have a Class A, is obtaining a school bus, a passenger, or this one, the hazardous material endorsement for the first time. So, right now, for instance myself, I have a Class C commercial CDL, a commercial driver's license. And it allows me to drive a normal truck, van, car, whatever. Anything under, I believe it's 18,000 pounds, not positive on that. But a smaller vehicle, I can drive-on. It doesn't have air brakes. But I need that license in order to get at my hazardous material endorsement. And we need to have this hazmat endorsement if we're gonna haul gas. So there's always been some confusion about Degesch, a permit to haul small amounts. But really all that permit says is that you don't have to put a placard on you vehicle if you're hauling that small amount. It only applies to their products. It still requires you to have a commercial driver's license with the hazardous material endorsement. You do have to fill out shipping papers for the product that you're hauling. You just don't have to put placards on it if it's that small of an amount and you're using it to take it to a job and not delivering it to another customer. That is the case. So in no one way, shape, or form should you be hauling any fumigant over a public road if you don't have this and in the words of great Wally Karbo, there will be fines in suspension. So know there's been a lot of confusion about that over the years. I just want you to know it's like every other law that gets broken, it's fine until you get caught. But if you did get pulled over by an officer that knew what you were hauling and you didn't have the proper license and endorsements, then you couldn't get in a lot of trouble, so. So, who's exempt? The ELD reg regulations are not retroactive. So individuals who were issued a CDL with these endorsements prior to February 7th they're not required to complete any of this training. And this is the good thing. Even if you had a CDL and let it lapsed, you are technically grandfathered in unless you're upgrading your CDL. So if you had all of that you would not have to go through that training again if you wanna go back and get your license. So for instance, here, Peter Klassen retired, logged 8.7 million miles of driving and retired at 90, but say at 95, he decided to come out of retirement. He would not have to go through the training. But if he didn't have a hazardous material endorsement, or if he didn't have that school bus endorsement and decided he wanted to drive school bus for some kids, he would have to go through the training, so. The training that you receive, so there's two parts to the training. The training provider registry ensures that entry level drivers receive and demonstrate proficiency in both theory training or basically classroom training and behind-the-wheel training. It's basically book learning for part of it and behind-the-wheel for the other part. So there's no minimum hours, it's just whatever assessment they give you, you have to score at least 80%. And it's gonna go through your basic operation, operating procedures, advanced operating procedures, vehicle systems, non-driving activities like your hours of service, all of those kinds of things. So if you're getting your hazards material endorsement, you're gonna cover that training as well. And then the behind-the-wheel training of course is getting in a rig or getting in a school bus and doing that actual behind-the-wheel training. Where do you get it? You can go to this website and they'll tell you. The training provider registry. It can be a little misleading because there's a lot of internal training that's offered for new hires within a company. Like for example, you'll see a lot of UPS, or FedEx, or even school districts. You know that they are doing their own internal training. They got somebody certified by the government. They have a training program that's certified by the government. So if you decide to go work for your local school district and become a school bus driver, they will more than likely, unless it's a really small one, they'll probably provide that training for you. But when you call them and ask them about it, they'll tell you, no, that it's just internally. Most of your opportunities to get this is through community colleges or truck driving schools, or online, especially for the classroom part. So, and of course, depending on what you're gonna get these courses can vary in length and price considerably. And some of these talking to some different truck driving schools and in community colleges that offered in my area, they're saying a lot of them have waiting periods and it's not uncommon to spend four grand on one of those training. And you're probably gonna have to wait for a while and the courses are pretty long. Now there's some good news about this for us. If you are only getting a Class C commercial driver's license, you don't have to go through entry-level driver training. But if you're adding the hazardous material endorsement, you do, but you only have to go through the theory training for the hazardous material part. And we have seen online classes pop up already and they're not too expensive. So if you're only getting a Class C with a hazardous material endorsement, there are definitely online options for you to take. I don't endorse any of them or not endorse any of them, but there are some are a 100 bucks, some are a couple of 100 dollars. I think as time goes on and the industry catches up with all of this, you're gonna see more options, so. And you might even see some locally, you might be able to talk again some community colleges and they basically said that if they can fill seats in a classroom, they'll come up with a curriculum and provide for training. The problem is they're probably gonna be spotty. They might just offer their own online programs that you can sign up for. But I do believe the training industry will develop more and more courses to cover businesses like ours in the future. It's just gonna take a little time. But like I said, there are some out there already. I knew that they would respond. I didn't think they'd respond this fast, but it is good. And like I said, I think if they can fill classes, you're gonna see more options out there, so. I've spoke with a lot of members of the DOT, law enforcement agencies, and other people. I mean, I think they felt that industries like ours weren't given a tremendous amount of consideration when they brought this in. But like I said, I think that the training industry is responding pretty well, so. That covers that. Again I'd like to thank Degesch and Douglas Products, both for providing a lot of information, especially on the fumigant updates for this. And I thank you all for your attention and for attending. And from there I'll open it up to any questions that you might have. - Good. There aren't any questions in the question and answer, the Q&A box. - Okay. - One question I would have is, do you do any training? Does your organization do any training for fumigation application safety procedures, site-specific plans? Just any kind of training? - Yeah, so prior to COVID, we used to offer a couple different locations, some re-certification training, and we did focus on fumigation safety and some application techniques, things like that. But we've had to suspend them. We are hoping to start some of them up again. We have been working on some videos that we are hoping to post online. We just don't have them done yet. Excuse me. I will tell you that if you are concerned, and I've done the same thing in the past. In the past when I've needed to you definitely heavily rely on the manufacturer, in the registrant. If you were buying Degesch products and using them, and you call them, and ask them to help you with some safety training or Douglas products, or even Uniphos, they are all very helpful. I can always tell you the very first thing in any on this is read the label. I mean, if you read and follow the label closely, you are going to stay safe while you're doing applications. But if you want additional, things like that, those people are definitely a good one to lean on. So if you're buying those products from this particular company, go to them, and they're more than helpful. Sometimes even just your supplier can help you out with some of that stuff too. The other thing is, like organizations like Jeeps, we talked a little bit in earlier talks about bin entry. Some of those things are the most dangerous part of doing the fumigation is getting inside that bin. And so a lot of places don't even allow it anymore. So you might be doing elevated work off of a lift, or repelling it from the top with ropes and making sure you're getting lift certified, if you're gonna run a lift. Those providers are good with helping with that safety training. But yeah, leaning on organizations like industry organizations like Jeeps are great. I know I've attended a couple of different bin entry and rescue training programs through them, and they've been very informative and helpful, so. - Good, Thank you Curtis. - I'm hoping that we can start those classes again. - [Mike] Right. - in the next year. So once this old virus thing seems to subside a little more. - Sounds great. I really appreciate it. - [Curtis] Yeah. - We did get another question in, and I'll read this to you. I think it's a little bit long, but is there an official press release so we can reference about the justification rationale for the Interscan GF1900 discontinuation? - Not yet. Other than if you contact. If you contact Jeremy Jackson from Douglas Products, he will give you all of the latest information on both of those. I do think it really looks to me. I mean, since Interscan, the company itself has decided not to provide any support anymore, that one's gonna be a dead duck after a while. And right now it's an approved unit as long as the current label is in place. And at some point the EPA that this whole label, the whole registration process will come to an end and there will be a new label. And it is my belief that that unit will probably fall off the at label. So at that point even if yours still works you won't be able to use it anymore. So I just don't think there's anywhere to go anymore with the Interscan. The Spectros monitor on the other hand I think has a very good chance of staying on that label. There really is not a whole lot of options other than the one I showed you, so. And there may be more coming out. I'm sure there's other manufacturers working on them, but I think the Spectros stands a very good chance of staying on. I think it's tough when an agency does their testing and comes up one conclusion and then they're kind of pointed out that their testing was flawed. But I do believe in the end they're gonna look at some of the other testing that was done and there might be some additional language to really emphasize basically the manufacturer's directions on how to use it. But if there is anything more current than what I've given you today, definitely your Douglas representative would have that information because this is a critical issue for their company. So they wanna make sure that we're able to continue doing business as usual, so. - Good. Thank you very much. Kind of a question at the tail end of it is, do you or your business conduct any forensic work, or any investigations regarding fumigation? - You mean like insect resistance and things like that? Or do you mean if like testing for residue on fumigation afterwards, or products? - I think it's the latter. - Not so much. We can take things, samples in and analyze them but we can't do as far as testing them with monitors, but we don't have the ability to do too much past that. if it's insect resistance that you're concerned about, or things like that, or if you want support with like bioassays. Like if you're gonna fumigate a structure and you wanna put a sample of some insects in there to verify the effectiveness of your fumigation, then we lean heavily on Insects Limited. They are very close company to ours. Dave Mueller, the founder of Fumigation Service and Supply, or FSS, was also the founder of Insect Limited, so. Our corporate headquarters are in the same area and we work very well with them. So if you ever have any kind of resistance concerns or wanna do some testing there, or if you want bioassays, or things like that, and support on that side, then that's kind of where we've gone with that. - Good. The person that asked the question did qualify and say it was regarding past applications and it was to measure residues. So I think you've answered those. The last question the person asked is about the bioassay and they asked, have you used the segene, or segene bioassay, S-E-G-E-N-E, bioassay test. - I personally have not. I'm not sure about that one. So that would be a good question for them though, for Insects Limited. They would be able to answer that if they haven't, but I have not. - Good, good. We do have one last question but I'm not exactly sure who it pertains to, whether it's you client. I think it was asked during actually Kleine's presentation, but it was regarding the EPA take action steps to address risk from chlorpyrifos and protecting children's health. And I guess the question is, is this similar to the study about the frogs out of Berkeley with atrazine? - Yeah, I can't speak to that one too much. I am aware of in the same way that they're reviewing sulfuryl fluoride and phosphine products. They are reviewing any additional chlorpyrifos products as well. So a lot of that stuff is ongoing but I couldn't answer specifically to that question. - All right. Well, Curtis, you did an excellent job. Thank you very much, stayed on time, answered a lot of questions and really appreciate your participation today. Thank you.