Volume 23, No. 3, JULY 2005
Project Safe Send Collection Sites, Dates Announced for 2005
Learning From Mishaps -Protect Your Eyes From Pesticides
Updated Information Regarding Insect Repellents
WPS for Agricultural-use Pesticides: Information provided by commercial applicators/handlers to growers
Phosphine Fumigant Labeling Questions and Answers
The disagreeable weather we have had to contend with during May/June means than many folks will be turning to aerial applicators this summer to get the job done. And the applicators will, for the most part, get it done in a professional and workmanlike manner. However, turbulence is possible along the way, so here are some things to consider:
• The demand for pesticide aerial application will be huge for the next several weeks at least, so remember, everyone is calling and the pressure on the applicators will be enormous. Be patient and be reasonable.
• Prioritize your requests. Aerial applicators will be short-handed and short on good flying weather, so examine spray job(s) carefully. Perhaps a bit of pesticide application triage is in order. (Some crops may be too far gone to save, others may benefit from reasonably quick action, and still others can wait for treatment.)
• Be clear about your job description. If you have not used an aerial applicator in recent years, do not assume that the applicator knows the lay of the land. Be absolutely precise about what you want the applicator to do.
• Be very clear about your job description. Many pilots are being brought in from surrounding states, as well as from Oklahoma, Texas and Louisiana. Many will be working under the supervision of homegrown operators, but the out-of-state workers still don't know North Dakota, so be really precise about what you want them to do.
• Be wary of fly-by-night aerial applicators. Do business with the locals. They know the neighborhood and will be there when the dust settles. If problems arise, as they surely will, you will be in a much better position to reconcile with them than with someone outside the region.
• Be neighborly. Try to settle misapplication issues without bringing in the North Dakota Department of Agriculture (NDDA). Department staff will have their hands full and will take a dim view of someone who is wasting their time with a complaint because the complainant will not even try to talk things out.
• Aerial applicators have had a reputation of being rogues. But that is no longer is the case. The majority are professionals. If you want to see how far the aerial application industry has come, consider this: In 1999, aerial applicators were the subject of 51 percent of the pesticide complaints the NDDA handled. In 2004, they were responsible for 26 percent of pesticide complaints. No other group of commercial applicators in North Dakota can point to this record of achievement. They can be trusted to get the job done, and they will!
Best regards,
Andrew A. Thostenson
"The Legislature saw the continued need for Project Safe Send by restoring and increasing funding for the program," said Agriculture Commissioner Roger Johnson. "With 16 collection sites, no one should have to drive far to get rid of their waste pesticides safely and at no charge."
All collections will be accepted from 9 a.m. to 3 p.m. (local time) at North Dakota Department of Transportation (DOT) facilities in the following communities:
• Wednesday, July 6 - Cooperstown - one-half mile north of Cooperstown on the west side of North Dakota Highway 45.
• Thursday, July 7 - Grafton - take U.S. Highway 81 north through Grafton, cross the Park River to Division Street (Walsh County Highway 10); take Division Street to N.P. Avenue and then north to Commerce Street. DOT is on the south side of Commerce Street.
• Friday, July 8 - Grand Forks - 1951 N. Washington St.: from I-29, take Gateway exit, go east to Highway 81 (Washington Street), then north one mile.
• Saturday, July 9 - Casselton - Take I-94 Exit 331, go north on North Dakota Highway 18, take frontage road west about three-quarters of a mile.
• Monday, July 11 - Wahpeton - one-half mile west of Wahpeton on North Dakota Highway 13.
• Tuesday, July 12 - Ashley - one-half mile south of Ashley on North Dakota Highway 3.
• Tuesday, July 12 - Cando - two blocks north of North Dakota Highway 17 on east edge of Cando about one mile east of U.S. Highway 281.
• Wednesday, July 13 _ Medina _ East side of road just north of the Medina exit on I-94.
• Wednesday, July 13 - Harvey - Heading east on U.S. Highway 52, go around the business loop to the junction of U.S. Highway 52 and North Dakota Highway 3, go north about 1.3 miles and take a right, go across the railroad tracks and continue on for about two blocks.
• Thursday, July 14 - Litchville - 808 1st Ave.: one-quarter mile south of the railroad tracks on the east side of the road.
• Thursday, July 14 - Garrison - east edge of town on the north side of North Dakota Highway 37.
• Friday, July 15 - Minot - from the intersection of U.S. Highways 83 and 2, go east about three miles, DOT is on the east side of Highway 2, just north of Gooseneck Implement (John Deere dealership).
• Monday, July 18 - Williston - 605 W. Dakota Parkway - on Bypass U.S. Highway 2 and U.S. Highway 85 across from the Kum & Go gas station.
• Tuesday, July 19 - Dickinson - on east side of North Dakota Highway 22, one-half mile north of the Junction of I-94 and Highway 22.
• Wednesday, July 20 - Mott -one-half mile north of Mott, west side of North Dakota Highway 8.
• Thursday, July 21 - Bismarck - 218 S. Airport Road: from I-94, take Exit 161, go south on Bismarck Expressway to Main Avenue, west on Main Avenue to 19th Street, go south on 19th Street across railroad tracks and turn right into district yard.
People with more than 1,000 pounds of pesticides should call (701) 328-4997 to preregister. No other preregistration is required.
Pesticide rinse water also will be accepted at any of the 16 collection sites. The first 100 pounds of rinse water will be taken free of charge, then a fee of $1 will be charged for each additional pound.
Onyx Environmental Services, Blaine, Minn., will collect the pesticides and transport them to federally approved incinerators and disposal sites in other states.
Since 1992, more than 4,500 participants have used Project Safe Send to safely get rid of more than 1.6 million pounds of unusable pesticides, including DDT, arsenic and mercury compounds.
In the last two years, 786 people brought in more than 285,152 pounds of unusable pesticides to Project Safe Send collection sites. Last year's collection was made possible with supplemental funds from the U.S. Environmental Protection Agency.
Barbara Morrissey, pesticide program, Washington State Department of Health
Eye safety glasses or goggles always should be worn when opening bottles or containers, mixing and applying, and during cleanup.
Among pesticide applicators, eye irritation and injury are among the leading symptoms reported. No one expects to be splashed in the eye with a pesticide. It happens fast and can surprise you with how much it hurts. Even pesticides with a "Caution" label can harm your eyes if a splash occurs. It could be the active ingredient, or surfactants and solvents in the product, that cause injury. Dusts and granules also can physically scratch the cornea. Pesticides can be absorbed into the blood stream through the eye. Splashes of highly toxic pesticides into eyes can lead to systemic symptoms. Eye safety glasses or goggles always should be worn when opening bottles or containers, mixing and applying, and during cleanup. The following mishaps are actual cases form 2004.
It was a warm day in July and a licensed applicator was spraying a city right-of way with a tank-mix of Crossbow, Round-up, R-1 1 and blue dye. He heard a hissing sound coming from the back of the truck and went to investigate. As he came around the back of the truck, he saw spray coming from the pressurized hose. The hose burst and herbicides sprayed his clothing and his face. He shut off the sprayer and began cleaning up. He used a washcloth and water from his 400-gallon tank to wash off his face and tongue and he changed out of his wet clothing. Shortly after that he showered. If he had been wearing safety goggles, he could have avoided his only symptom and a trip to the doctor for eye irritation.
LESSONS LEARNED - Accidents like this can happen without warning. You can be prepared by wearing good eye and skin protection, carrying a change of clothing in your truck and keeping an eyewash bottle handy.
A licensed technician was spraying the eaves around a home for spiders. He was using Talstar, a pyrethroid insecticide. His goggles were fogging up so, he removed them to see better. The wind came up and blew insecticide into his face a couple of times while he finished the job. Soon both of his eyes were burning. He rinsed with Visine and water several times during the day. That evening at home, his eyes still were painful. The next morning, his eyelids were swollen and crusted shut, the whites of his eyes looked red and the pain was decreasing. His employer instructed him to go to the doctor. He was diagnosed with chemical burns to both eyes and instructed to rest with cool compresses for two days. Several days later, his eyes had recovered.
LESSON LEARNED - If your goggles fog up, don't take them off. There are safer ways to solve the problem. At the job site, you can try wearing a face shield or using an anti-fog wipe on the goggle lenses. If the problem is persistent, try switching to a different type of goggle with an anti-fog design.
A licensed agricultural applicator was mixing Golden-Dew, a sulfur-based fungicide. He was wearing a rubber suit, rubber gloves and a respirator, but no eye protection. It had not been provided by his foreman. While he was weighing the concentrate, the fine power drifted up into his face and his eyes began to water and hurt. His foreman gave him Visine to use, but that evening his eyes swelled shut. Fours days later, he was seen by a doctor for continuing pain and redness in his right eye. He was given a full eye examination and diagnosed with chemical conjunctivitis. He recovered in the next few days with treatment. The label for this product has the signal word "Caution" and states that the product causes moderate eye irritation. The label requires eye protection for handlers. In this case, the label was not followed and the employer was contacted and the problem corrected.
LESSON LEARNED - IT IS VERY IMPORTANT TO FOLLOW THE LABEL! The pesticide label contains important instructions for protecting against harmful effects of pesticides. If you are handling pesticides and you are not being provided the necessary protective gear, bring this to your employer's attention. Employers must provide safety glasses or goggles if eye protection is required on the label.
Safety goggles protect your eyes. As we go into the peak of pesticide application season, remember to wear your eye protection!
Centers for Disease Control, April 2005
Repellents are an important tool to assist people in protecting themselves from mosquito-borne diseases.
A wide variety of insect repellent products are available. The CDC recommends the use of products containing active ingredients that have been registered with the U.S. Environmental Protection Agency (EPA) for use as repellents applied to skin and clothing. EPA registration of repellent active ingredients indicates the materials have been reviewed and approved for efficacy and human safety when applied according to the instructions on the label.
Of the active ingredients registered with the EPA, two have demonstrated a higher degree of efficacy in the peer-reviewed, scientific literature. Products containing these active ingredients typically provide longer-lasting protection than others:
• DEET (N,N-diethyl-m-toluamide)
• Picaridin (KBR 3023)
Oil of lemon eucalyptus [p-menthane 3,8-diol (PMD)], a plant-based repellent, also is registered with the EPA. In two recent scientific publications, when oil of lemon eucalyptus was tested against mosquitoes found in the U.S., it provided protection similar to repellents with low concentrations of DEET.
Oil of lemon eucalyptus has not been tested against mosquitoes that spread malaria and some other diseases that occur internationally. See the CDC Travelers' Health Web site ( www.cdc.gov/travel/bugs.htm ) for specific recommendations concerning protection from insects when traveling outside the U.S.
In addition, certain products that contain permethrin are recommended for use on clothing, shoes, bed nets and camping gear, and are registered with the EPA for this use. Permethrin is highly effective as an insecticide and repellent. Permethrin-treated clothing repels and kills ticks, mosquitoes and other arthropods, and retains this effect after repeated laundering. The permethrin insecticide should be reapplied following the label instructions. Some commercial products pretreated with permethrin are available.
The length of protection from mosquito bites varies with the amount of active ingredient, ambient temperature, amount of physical activity/perspiration, any water exposure, abrasive removal and other factors. For long-duration protection, use a long-lasting (micro-encapsulated) formula and reapply as necessary, according to label instructions.
The EPA recommends the following precautions when using insect repellents:
• Apply repellents only to exposed skin and/or clothing (as directed on the product label.)
• Do not use repellents under clothing.
• Never use repellents over cuts, wounds or irritated skin.
• Do not apply to eyes or mouth, and apply sparingly around ears. When using sprays, do not spray directly on face - spray on hands first and then apply to face.
• Do not allow children to handle the product. When using on children, apply to your own hands first and then put it on the child. You may not want to apply it to children's hands.
• Use just enough repellent to cover exposed skin and/or clothing. Heavy application and saturation generally are unnecessary for effectiveness. If biting insects do not respond to a thin film of repellent, then apply a bit more.
• After returning indoors, wash treated skin with soap and water or bathe. This is particularly important when repellents are used repeatedly in a day or on consecutive days. Also, wash treated clothing before wearing it again. (This precaution may vary with different repellents - check the product label.)
If you or your child gets a rash or other bad reaction from an insect repellent, stop using the repellent, wash the repellent off with mild soap and water, and call a local poison control center for further guidance. If you go to a doctor because of the repellent, take the product with you to show the doctor.
Note that the label for products containing oil of lemon eucalyptus specifies that they should not to be used on children under the age of 3. Other than those listed above, EPA does not recommend any additional precautions for using registered repellents on pregnant or lactating women, or on children. For additional information regarding the use of repellent on children, please see the CDC's Frequently Asked Questions About Repellent Use, www.cdc.gov/ncidod/dvbid/westnile/qa/insect_repellent.htm .
DEET-based repellents applied according to label instructions may be used along with a separate sunscreen. No data are available at this time regarding the use of other active repellent ingredients in combination with a sunscreen.
See www.epa.gov/pesticides/factsheets/insectrp.htm for additional information on using EPA-registered repellents.
Commercial pesticide handlers (custom applicators) must make sure that their customer - the operator of the farm, forest, nursery or greenhouse - knows certain information about the pesticide before it is applied on the establishment. If the applicators cannot apply the pesticide as scheduled, the customer must be informed of the corrected time and date of the application. Make the correction before the application takes place or as soon as practicable thereafter. Commercial pesticide handlers must inform their customers about:
• The specific location and description of the area(s) on the agricultural establishment that are to be treated with a pesticide
• Time and date the pesticide is scheduled to be applied
• Product name, EPA registration number and active ingredient(s)
• Restricted-entry interval for the pesticide
• Whether the pesticide labeling requires both treated-area posting and oral notification
• Any other specific requirements on the pesticide labeling concerning protection of workers and other people during or after application.
Your customers - the operators of agricultural establishments - must have this information to protect their employees as the WPS requires.
If the applicator can't make the initial notification of an application because of difficulty in reaching the grower (agricultural employer), can notification be made after application?
No. Provisions do not allow notification after application because of earlier difficulty in contacting the grower (agricultural employer).
How soon before an application must a commercial handler (handler employer) provide the information to the grower (agricultural employer)?
The WPS requires that the commercial handler provide the information to the grower anytime before the application takes place. [40 CFR section 170.224]
The WPS requires that, before the application of any pesticide on an agricultural establishment, a commercial handler must provide certain information about the pesticide and the application, or must assure that the customer - the operator of the farm, forest, nursery or greenhouse - is aware of the information. [40 CFR 170.224]. What constitutes compliance with this requirement?
The EPA recommends that the operator of the agricultural establishment (agricultural employer) and the commercial pesticide handler (handler employer) agree on a notification process that will ensure that workers will not be in an area while it is being treated or under a restricted-entry interval (REI). For example, they could agree that without prior mutual agreement, an application never will occur before the scheduled time, and the grower (agricultural employer) will not permit workers into the area to be treated until receiving notification from the commercial handler that:
• The application will not take place until a specified future time at the earliest, or
• The application has taken place and specific information that the WPS requires is provided to the grower.
1. An oral exchange of the required information between the commercial handler and the grower before an application would comply with WPS notification requirements.
2. Leaving a complete message on a telephone answering machine before the application would constitute compliance if the grower received the message before the application.
Leaving a complete message on the answering machine before the application would constitute compliance if the commercial handler and grower had agreed that by leaving a complete message on the answering machine, notification could be accomplished. In this example, the commercial handler would have satisfied the notification obligation under the WPS, even if the grower did not check the message before the application. The grower, however, would remain responsible if workers were sent into treated areas in violation of any portion of the WPS.
Editor's note: Meredith Laws, chief of the EPA's insecticide-rodenticide branch, released the following questions and answers on phosphine. For additional clarification, you may contact her at (703) 308-7038 or laws.meredith@epa.gov
1. What is fumigation?
Fumigation is the act of introducing a pesticide into an enclosed space in such a manner that it disperses quickly and acts in a gaseous state on the target organism. Pesticides formulated as fumigants have physical characteristics that cause them to occupy all air spaces within an enclosed area and to penetrate commodities within these areas. Aluminum and magnesium phosphide fumigants generally are used in space and commodity fumigation, when they are applied to properly sealed structures, containers or rodent burrows.
2. What is a fumigation management plan?
A fumigation management plan (FMP), referred to in Section 21 of the applicator's manual, is a written description of the steps designed to plan for a safe, legal and effective fumigation. It is important to note that some plans will be more comprehensive than others. The certified applicator and owner of the property to be fumigated must address characterization of the structure and/or area and include all safety requirements in the plan prior to application. A new FMP is not needed for every fumigation of an individual facility if conditions, other than general updates such as temperature and humidity recordings, will not vary. The FMP and related documentation, including monitoring records, must be maintained for a minimum of two years.
3. Is an FMP required, and if so, how does a state enforcement official determine if an FMP is in compliance?
Yes, an FMP always is required for phosphine fumigations, including for rodent burrow fumigation. Since these are site-specific, certain requirements of the FMP may not apply. If this is the case, the plan should state why. The degree of enforcement and compliance with individual FMPs rests with the state lead agency.
4. Are fumigations only conducted by certified applicators?
Although the federal labeling allows trained workers to do certain activities associated with fumigations, some states may be more restrictive than others and require that a certified applicator always be physically present on site. Therefore, before proceeding with a fumigation, the client and/or certified applicator should consult with the state lead pesticide regulatory agency to determine regulatory status, requirements and restrictions for use of fumigants in that state. A directory of state pesticide control officials can be found under the AAPCO Web site: www.aapco.ceris.purdue.edu/htm/control.htm .
5. When can a certified applicator turn over supervision of the fumigation to a trained person?
Most fumigation activities are carried out by a certified applicator or by a trained worker under the direct supervision of a certified applicator. As mentioned above, state restrictions and requirements vary. In some states, certain specific activities can be turned over to a trained worker to complete the fumigation independently in the absence of a certified applicator. The certified applicator may remain in voice contact if needed but not be physically present. These specific activities include:
- Monitoring the fumigation site for gas leaks and accumulation of phosphine gas above the permitted limit
- Completing the aeration of a structure after the aeration has progressed and stabilized
- Removal of placards after the aeration is completed
-Receiving, aerating and releasing the content of a vehicle fumigated in transit (Note: Transporting vehicles under fumigation over public roads is prohibited.)
- Transfer of an unaerated commodity from one in-transit container to another storage site to continue with the fumigation
- Disposal of any spent fumigant
- Maintenance of written records of all permitted actions performed
6. Are there circumstances or states in which certain fumigation activities conducted by a trained worker in the absence of a certified applicator cannot be done or are not allowed under state law?
Yes. Some states have additional restrictions on fumigation activities that a trained worker can do independently. The front panel of the applicator's manual states "CONSULT WITH YOUR STATE LEAD PESTICIDE REGULATORY AGENCY TO DETERMINE REGULATORY STATUS, REQUIREMENTS AND RESTRICTIONS FOR FUMIGATION IN THAT STATE."
7. Does a trained technician have to be supervised?
When a fumigation product is being applied, it must be under the supervision of a certified applicator. In many states, "under direct supervision" means the act or process whereby application of a pesticide is made by a competent person acting under the instructions and control of a licensee or certified applicator who is responsible for the action of that person and who is available if and when needed, even though such licensee or certified applicator is not physically present at the time and place the pesticide is applied. However, in some states, certain activities as noted previously may not be performed without the physical presence of the certified applicator.
8. What is voice contact?
Voice contact means that the certified applicator (CA) is supervising the trained worker(s) by maintaining a voice communication, with or without being physically present on site. Voice contact when the certified applicator is present on site may be accomplished by the use of phones or walkie-talkies in a situation where the CA and the trained worker are not working at a visible distance to each other (i.e., when working at a large facility where several sheds or bins will be fumigated at the same time or while trouble-shooting a gas leak after the fumigation has started). When both parties are not physically present on site, voice contact may be accomplished through the use of phones or walkie-talkies.
9. When does fumigation start and end?
Fumigation starts with the introduction of the fumigant into a space or commodity that has been properly placarded and secured. It ends when aeration has rendered the space or commodity at or below established safe limits specified in the product labeling. Safe disposal of the spent fumigant, according to label directions, also must be conducted following completion of the fumigation.
10. Is a separate FMP required for each railcar?
The intent of the label is to develop an FMP that will ensure a safe and effective fumigation. This could mean that one plan would be sufficient to include many cars being fumigated at one time. Or, depending on the application process, how secure the area is, location of the cars, etc., more than one plan may be necessary. An FMP could be developed to cover multiple fumigations during the course of multiple days, provided conditions remain the same for each fumigation.
11. When does the responsibility end for the fumigator of in-transit fumigations?
A certified applicator's responsibility ends when the in-transit fumigated rail car is properly labeled, secured and made ready for shipment and the consignee of the shipment is notified with the appropriate documents. This means that the receiver (consignee) is responsible for having a certified applicator or a trained worker (per state requirements) available on site to receive and process the in-transit fumigated container, since once the in-transit vehicle leaves the state where it was fumigated, it falls under the jurisdiction of another state. Other states may be more or less restrictive. (I would like to add a list of those states that do require a certified applicator be present when fumigated railcars are aerated - need to get this from SFIREG.)
12. Who is responsible for training of workers, and who assures that the workers have completed the appropriate training to open the in-transit fumigated railcars that have been sent to the consignee?
Proper handling of treated railcars at their destination is the responsibility of the consignee. The consignee must be familiar with the properties of phosphide fumigants, worker exposure limits and symptoms, and first aid treatment for phosphide poisoning; know how to make gas concentration measurements; and have a clear understanding of the particular state requirements regarding the receipt of fumigated railcars. Upon receipt of the railcar, railroad boxcars, shipping containers and other vehicles, a trained person must perform the aeration process and must document in writing that monitoring has been conducted and that aeration has been completed. A certified applicator is responsible for training workers, including those employed by the consignee receiving fumigated railcars. This training must follow the procedures outlined in the applicator's manual registered by EPA, or by other training that is accepted by state and local authorities. Additionally, trained workers must receive refresher training annually and the records of the training must be retained for a minimum of three years.
13. What criteria could be used for state approval of training programs?
Most states have regulations in place that would give them criteria for approving training programs for recertification purposes. A similar approval process also could be in place for companies submitting in-house programs used to train individuals who will be receiving fumigated railcars.
14. What methods are allowed for sending the applicator's manuals to the consignee?
here is no restriction in the labeling on how you must send the applicator's manual, only that it must precede or be attached to the shipment. In addition, you are required to provide written notification that a vehicle is under fumigation. This can be done by fax, e-mail, courier service, etc.; however, the label does not specify how you send the manual or provide written notification, only that you must do it. In cases where the shipper and/or applicator recently has sent the applicator's manual (by means of courier, e-mail, etc.) and the receiver still is in possession of the appropriate applicator's manual, the shipper and/or applicator would not have to resend this information. However, it must be documented that the shipper and/or applicator has verified that the information is in the hands of the receiver and is current with up-to-date information.
15. If the applicator manual is not sent ahead of an in-transit shipment, does it need to be attached to each car?
Section 22.5 of the label states that the applicator's manual must precede or accompany all transportation containers and other vehicles (note, section 15.5 of the label prohibits transportation of vehicles under fumigation over public roads) that are fumigated in transit. If there is any possibility or indication that multiple containers/railcars undergoing fumigation may be separated or shunted while in transit, a copy of the manual must be attached to each container or railcar.
16. What is meant by written notification and how often must this be done?
The shipper and/or the fumigator must provide written notification to the receiver of railcars, railroad boxcars, shipping containers and other vehicles that have been fumigated in transit. The purpose of written notification is to ensure that the site receiving the fumigated vehicle is aware of the fumigation and has an adequate program in place to properly receive a fumigated railcar (trained or certified personnel, detection equipment, disposal equipment, etc.). The consignee must receive a copy of the product's application manual in addition to the written notification. It is important to note the shipper typically notifies the receiver of in-transit fumigated vehicles. A contracted certified applicator usually is not involved in the fumigation agreements between shippers and receivers and would not be aware of the end destination of the vehicle. In addition, vehicles may be re-routed in transit and may not end up at the original destination. For fumigations performed on stationary sites, written notification must be provided to local officials, such as the fire and police departments. These officials should be provided with the product's MSDS and the applicator's manual. Section 14 of the manual includes this requirement. The label does not specify how often notification must occur, whether prior to each fumigation or on an annual basis. As an example, local officials may not want to be notified every day that railcars are fumigated as long as they are aware that this will be a seasonal or ongoing activity at a particular facility. If fumigated railcars will be received on a regular basis, annual notification to the receiver may be sufficient. State or local authorities may have more restrictive requirements and must be consulted on this matter.
17. What is the purpose of the "Guidance" section of the FMP?
The intent of Section 21 is to provide more detailed information to the applicator on how to prepare an FMP for as many different types of fumigation sites as possible.
18. What is the purpose of the "Applicator Procedure" section of the applicator manual?
Section 22 contains the same information as this section on previous labeling to provide more detail for different types of common fumigation sites.
19. What is application? Is this different for different types of fumigation?
Application means introducing the solid, liquid or gas fumigant product into an empty space, an area containing a commodity or a rodent burrow. In most cases with space fumigations, the fumigant is applied from outside without actually entering the structure. Application methods differ depending upon (i) the fumigant formulation being used, (ii) site/area being treated and (iii) the target pest. For example, fumigation of infested grain using a solid fumigant product may involve pellets or tablets walked into the surface of the grain, applying pellets down into the grain mass with a probe or the use of an automatic dispenser that uniformly applies the fumigant throughout the grain mass as the bin or silo is filled. When liquid phosphine (liquefied gas or liquefied gas under pressure) is used as a fumigant, it is introduced with approved tubing into the treated site, where it disperses as a gas for quick distribution throughout the fumigated area. Outdoor rodent burrows are fumigated by placing pellets or tablets into the burrow and lightly sealing the entrance/exit.
20. What is a structure?
"Structure" means any building regardless of its design or the type of material used in its construction, whether public or private, vacant or occupied, as well as the foundation thereof, and the adjacent enclosed areas. It also shall include but shall not be limited to warehouses, trucks, boxcars, railcars, ship holds, boxes, tarp covered stacks and other vehicles, or the contents thereof, and fumigation vaults.
21. What is an adjacent enclosed area?
A space that is located next to or near a structure that is being fumigated and has the potential for the phosphine gas to enter into and accumulate or remain in this area. If people or domestic animals may enter into this area during the fumigation or aeration process, you are required to conduct monitoring to be sure no one is exposed above the permitted level of 0.3 ppm on an eight-hour time weighted average.
22. Is notification required for all fumigations, including burrows?
Yes, as required by local regulations. In addition, if you are treating rodent burrows on a property where inhabited structures are located, the applicator must provide the customer (tenant, homeowner or property manager) with the product's MSDS and at a minimum the appropriate parts of the applicator manual prior to application.
23. When and who do you notify prior to a rodent burrow fumigation?
Section 26, "Burrowing Pest Control," states that prior to treating rodent burrows on a property where inhabited structures are located, the person applying the product must provide the customer, i.e., the tenant, homeowner or property manager, with an MSDS or appropriate sections of the applicator's manual.
24. What is the difference between monitoring for safety and monitoring for efficacy?
Monitoring for safety of workers and bystanders is mandatory, according to the label, and is performed to determine (i) when and where respiratory protection is required, (ii) whether phosphine gas is escaping and is accumulating at unsafe levels in any areas and (iii) to take proper actions to prevent accidental exposure. Once fumigation has started and gas containment has been characterized adequately, spot checks must be made, especially if conditions change significantly or if an unexpected garlic odor is detected (cannot be relied on) or a change in phosphine concentration outside the fumigation area is detected. Section 15 of the applicator's manual ("Applicator and Worker Exposure") addresses safety monitoring. Section C.1 in the "Guidance for Preparation of a Fumigation Management Plan" in the applicator's manual also outlines safety monitoring.
Monitoring for efficacy involves the placement of test lines within the structure and determining whether adequate phosphine gas concentration has been reached. Efficacy monitoring also will help determine whether to add more fumigant during fumigation because of poor distribution within the structure or to supplement loss due to leakage. This type of monitoring is not mandatory per labeling and only is recommended. Section C.2 of the "Guidance for Preparation of a Fumigation Management Plan" in the applicator's manual outlines monitoring for efficacy.
25. Who is allowed to conduct and document monitoring?
The certified applicator is responsible for the fumigation and would be the person responsible for ensuring plans are in place for conducting safety monitoring during the fumigation period. Trained workers or the certified applicator may perform monitoring (trained individuals may want to verify gas concentration in a railcar prior to aerating, verify efficacy of grain fumigation underway, etc.). Trained workers must know how to use the detection equipment properly and how to implement site-specific evacuation procedures if necessary.
26. How is monitoring done?
There are a number of devices on the market for the measurement of phosphine gas. The devices range from glass tubes to electronic equipment. Knowledge of the use and limitations of such devices are part of the training program for fumigation workers. Registrants of phosphine products also serve as an additional source for information on these devices.
27. Is monitoring required for all fumigations? If not, when is it required and when is it not required?
Monitoring for safety always is required unless it can be confirmed/concluded by the certified applicator that there is no possibility of workers or bystanders being exposed to phosphine at or above the allowable limits. Monitoring must be done if there even is the slightest possibility of exposure. Exposures to phosphine must not exceed the eight-hour time weighted average of 0.3 ppm or the 15-minute short-term exposure limit (STEL) of 1 ppm.
Contact:
NDSU Pesticide Training and
Certification Program
Box 5051, Fargo, ND 58105-5051
Tel: (701) 231-7180
Fax: (701) 231-5907
E-mail: pesticid@ndsuext.nodak.edu
Internet: www.ndsupesticide.org
Pesticide Quarterly, Volume 23, No. 3, JULY 2005
NDSU Extension Service, North Dakota State
University of Agriculture and Applied Science, and U.S. Department of
Agriculture cooperating. Duane Hauck, Director, Fargo, North Dakota. Distributed
in furtherance of the Acts of Congress of May 8 and June 30, 1914. We offer our
programs and facilities to all persons regardless of race, color, national
origin, religion, sex, disability, age, Vietnam era veterans status, or sexual
orientation; and are an equal opportunity employer.
This publication will be made available in alternative format upon request to
people with disabilities (701) 231-7881