Dear FWWS Member,
Most of you have recently received a notice from the Washington State Department of Agriculture (WSDA) regarding the designation of sulfur dioxide gas used for barrel storage as a federally "Restricted Use Pesticide." Use of SO2 gas for barrel fumigation will require a license, special handling requirements, and record keeping.
As stated in the notice, the addition of SO2 to wine (whether via liquid, KMS, or gas) is not considered a restricted use under these new requirements. We have contacted Mr. Bruce Olson, the Pesticide Compliance Specialist at WSDA and compiled the following additional information.
1) This regulation will be phased-in over time.
Mr. Olson has indicated that no enforcement will be conducted over "the next harvest season" as labeling is still being developed (see below).
2) Use of the "old skool" sulfur discs or wicks which make SO2 gas by burning inside the barrel, will not be restricted by the new regulation.
Small wineries may want to weigh the efficacy and inconvenience of these methods against the new regulatory compliance requirements for use of compressed SO2 gas.
3) In the future, use of compressed SO2 gas will require a license.
The appropriate license is the Private Commercial Pesticide Applicator license and is administered by WSDA. Passing two tests is required. The first is the Laws and Safety test which is 100 questions long. The second is the Fumigation test which is 50 questions long. A score of 70% correct answers is required to pass each test. There is no cost for sitting for the test. Testing is conducted the last Tuesday of the month in Wenatchee. Testing is also available in Olympia, Yakima, Moses Lake and Spokane. A study guide is available from WSU extension.
4) Actual requirements for use and documentation will be label specific.
Presently there is only one product federally registered as compressed sulfur dioxide for pesticide use. It is not yet registered with the WSDA, and you probably don't use this brand anyway since this gas generally is supplied to wineries in Washington by gas suppliers. The WSDA is in contact with Oxarc Co. about having their compressed SO2 product registered. They are reportedly interested in pursuing this, but it is a lengthy process and will take some time to achieve. If you have a different gas supplier for compressed SO2 gas please email us at board[at]familywineriesofwashington.org and we will follow up with them. The extensive regulations cited in the circular sent by WSDA are based on the existing federally registered product label and are indicative of what is likely to be on the label guidance of whatever product is eventually registered. The ultimate label requirements of an registered product will control the conditions of use and required documentation.
Bottom line, if you use compressed SO2 in your barrel maintenance program, don't panic but do pay attention. FWWS will provide updates on this issue as they are available. Please email us if you have any questions.