Pesticide Compliance & Enforcement

Burrowing Pest & Grain Fumigants

All phosphine labels require that applicators develop and follow a fumigation management plan (FMP) prior to using the labeled product.

An FMP is intended to ensure the safety of applicators, site employees, the surrounding community, and the environment. It is also designed to ensure legal and effective fumigation. An FMP is a written record that provides specific logistical, performance, and contact information to help characterize the fumigation site. The United States Environmental Protection Agency (EPA) has created management plans for each soil fumigant. To view the templates, click here.

The only way to effectively and safely use phosphine fumigants is to use them as the product label directs. It is important to remember these substances are toxic and potentially harmful to humans. Using approved application methods and placarding all storage bins containing treated grain and transports carrying fumigated grain are our best means of ensuring the safety of all grain handlers.

Direct inhalation of toxic phosphine fumes may cause weakness, tremors, vomiting, coughing, difficult or labored respiration, and possibly pulmonary edema. For safety purposes, phosphide labels require applicators and grain handlers to wear respiratory protection during exposure to grain fumigant concentration in excess of 0.3 ppm, or when concentrations are unknown.

Phosphine Fumigants Use

Commodity Temperature
Phosphide labels require the internal commodity temperature be tested before the fumigant is applied. If the internal commodity temperature is below 40 degrees F, fumigation is not to be conducted as the temperature is too low for the phosphide tablets to react. If applied to cold grain, unspent tablets will not begin to react until the temperature rises.

Phosphine gas produced in a sealed area can cause severe poisoning to an individual upon opening. This is especially true when placards are not attached to warn grain handlers of the danger with commodity shipments.

Placarding
Phosphide labels require the applicator to placard or post all entrances to the fumigated area with signs bearing:
  1. The signal word "DANGER" and the skull and crossbones symbol in red.
  2. The statement, "Area and/or commodity under fumigation, DO NOT ENTER."
  3. The statement, "This sign may only be removed after the commodity is aerated (contains 0.3 ppm or less phosphine gas). If incompletely aerated commodity is transferred to a new site, the new site must also be placarded and workers must not be exposed to more than 0.3 ppm phosphine."
  4. The date and time fumigation begins and is to be completed.
  5. Name of fumigant used.
  6. Name, address, and telephone number of the applicator.

Placards on railroad cars must be placed on both sides of the car near all ladders, hatches, and doors.

Placards may not be removed until the treated commodity is completely aerated. The commodity must be monitored until it contains 0.3 ppm, or less, phosphine gas in the air space around and, when feasible, in the mass of the commodity. If more than 0.3 ppm is detected, the placard must be transferred with the treated commodity.

Failure to properly placard fumigated areas may expose inspectors, samplers, and other grain handlers working in and around the commodity to dangerous levels of fumigants.

Because applications to commodities are not obvious if placards are not properly posted, individuals may not realize the grain has been treated until after exposure has occurred.

Vehicles under fumigation cannot be transported over public roads or highways.

Monitoring Vehicles
Various types of monitoring devices are available for determining fumigant concentrations in commodities. Accurate readings are obtained by using the instrument according to the instructions, and by selecting the appropriate monitoring tube for the fumigant being used.

Application Records
Fumigation of grain is considered a pesticide application. Therefore, in accordance with South Dakota Law, each application of a pesticide, including phosphine, to storage bins, railcars, or other sites, requires completion of commercial pesticide application records from both commercial and private applicators.