If your firm has used fumigants, chances are you’re no stranger to fumigation management plans (FMP), a written record providing specific logistical, performance, and contact information to help “characterize” the fumigation of a commodity storage site. Designed to promote legal and effective fumigation, FMPs ensure the safety of the applicators, the storage facility employees, the surrounding community and the environment.
“Fumigants must be used responsibly — strict adherence to the label and the manual directions is a must,” says Marty Morgan, fumigation specialist, Dow AgroSciences.
Jim Smiley, manager of information services, Degesch America, notes that FMP compliance is not voluntary; it’s mandatory: “Employees who fail to comply with the required written fumigation management plan provisions of the complete label are subject to criminal and/or civil penalties.”
While FMPs are enforced by the local, state and federal governments, the industry’s fumigant suppliers work diligently to educate their clients.
“Enforcement falls on the state regulatory agency; however, the company needs to prepare the fumigation management plan per the fumigant label/manual and keep it on file, follow it and modify it as needed,” Morgan says.
Companies using fumigants should regularly schedule employee safety meetings and send representatives to attend the training classes offered by industry groups or state regulators.
Things to consider
When thinking about your fumigation management plan, don’t lose sight of regularly following up on these internal checks and balances.
#1 Proper licensing and certified for use of the product
Federal law classifies all fumigants as “Restricted Use Pesticides,” and each state has its own requirements and provisions for licensing and certification, and applicants must pass an examination to demonstrate competence in the use of pesticides. Who provides it? Depending on the state, in accordance with national standards, the state department of agriculture, state chemist or state EPA is in charge of distributing applicator licensing.
The certified applicator is responsible for working with the owners and/or responsible employees of the site to be fumigated to develop and adhere to the FMP. Companies should keep one FMP on file for each type of fumigation done at the facility, e.g., spot fumigation of empty bins; fumigation of grain while loading; railcar fumigations; etc.
Some states require multiple people to be licensed within an organization, but most fumigant labels require one licensed person and one additional person trained in the use of the product, Morgan says. Also, depending on the capacity of the facility, additional certified persons may be recommended. All applicators must have knowledge of “General Standards of Competence” for all certification categories/regulations as required by each state.
Not only does the applicator need to be licensed, they need to read and follow label and manual directions for the fumigant being used, Morgan points out.
“It is critical that all fumigators are aware and compliant to the regulations governing each product,” Jeff Boyer, vice president - agricultural division, Douglas Products, says. “This fumigation will become more governed and restricted in time, not less restrictive. Knowledge and understanding of these rules and regulations is key for effective performance, commodity condition, applicator and public safety, as well as the reputation of our industry.”
All fumigant manufacturers mandate stewardship training, and most offer online training opportunities for users.
#2 Properly train employees in the use of personnel protective equipment
Clothing, respiratory protection, eye protection — Personal Protection Equipment (PPE) is specific to each product type. It is important the applicator understands the specific labels and directions for use of each product they are applying. Requirements are spelled out in the complete label, and inspection must comply with OSHA regulations.