Beyond the Label: Fumigation Safety

Fumigation management plans are an essential tool in the safe use of fumigants


“Written certification of fit testing is required by OSHA regulation to be kept for all employees required to wear respirators, gas masks or Self Contained Breathing Apparatus [SCBAs],” Smiley explains.

A fit test consists of a medical evaluation followed by either a quantitative or qualitative test of the user’s ability to wear the required respiratory protective device:

  • Qualitative is a pass/fail that relies on the respirator wearer’s indicating whether he/she can smell, taste or sense the test agent.
  • Quantitative fit testing gives an objective measure of the quality of the seal between the wearer’s face and the face piece. A fit factor number is produced.

Annual Respirator Fit Test Kits must comply with OSHA regulations, as spelled out in the OSHA Standard 1910.134. This requires fit testing of all respirators including those with positive pressure. The respirator fit test is done to check that the mask size and mask model chosen fits the face; it confirms the mask fits the wearer’s face and that there is minimal air leakage between the face and the mask.

It is best to have the respirator manufacturer or your safety equipment supply vendor perform the training; most manufacturers will come to your location to help with fit testing.

#3 Upkeep of clearing detection and monitoring equipment

The maintenance of clearing detection equipment ensures the health of employees, customers and the general public. Clearance refers to ensuring fumigant concentrations in the commodity and the airspace around it are below the established Threshold Limit Value (TLV) for the fumigant being used; the limits are determined by the American Conference of Governmental Industrial Hygienists (ACGIH). Detectors look for minute concentrations of fumigants in the air so make sure the detection equipment is appropriate for the specific product being used.

“For safety purposes, it is considered essential to have detection equipment that will give reliable and immediate indication of toxic concentrations of fumigants,” Boyer explains.

Apart from the determination of full fumigant concentrations during actual exposure, much of the equipment may also be used to measure the success of the aeration process as indicated by the presence or absence of residual vapors. Some of the equipment may also be used for detecting leaks from the structure during treatment.

#4 Preparation of fumigant management plan

Creation of an FMP is spelled out in the complete label of the fumigant; also, consult the manual for the product being applied for a step-by-step guide.

According to Smiley: “Each state has the ability to set the requirements for fumigant use within its borders. An applicator should ‘consult with your state lead pesticide regulatory agency to determine regulatory status, requirements status, requirements and restrictions’ before creating a required written Fumigation Management Plan.”

Many examples of FMP are available on the Internet. All manufacturers stress that before any fumigation begins, the Label and the Applicator’s Manual are carefully read and reviewed. Each item on the FMP guide must be considered; however, each fumigate is different and not all items may be necessary.

“Fumigant manufacturers are very open to direct inquiries from applicators, usually via phone or e-mail,” Morgan says. “When in doubt, the applicator should seek advice from their distributor [place they bought it] or the manufacturer.”