All new phosphine labels require anyone who fumigates grain or other commodity storages to develop a Fumigation Management Plan (FMP) for each fumigated storage site.

A FMP is a written record that provides specific logistical, performance, and contact information to help "characterize" the fumigation of a commodity storage site. The purpose of the FMP is to ensure the safety of the applicators, the storage facility employees, the surrounding community, and the environment. It is also designed to ensure a legal and effective fumigation.

Prior to writing a FMP, carefully read and review both the label and the Applicator's Manual for the fumigant product to be used. Assemble and organize all of the information needed to develop a FMP. Preparation is the key of any successful fumigation. Once the FMP has been written, a copy of this information must be given to the appropriate company officials (supervisors, foreman, safety officer, etc.) in charge of the site.

The guidance provided here is specific, yet must allow flexibility for addressing a wide range of potential fumigation sites. Each item in the list below must be considered. However, it is understood that each fumigation is different and not all items will be necessary to record for each fumigation site.

Checklist for Developing a FMP

1. Preliminary Planning Facility and Commodity Details
   1. Determine the purpose of the fumigation (elimination of insect infestation, elimination of vertebrate pests, plant pest quarantine).
   2. Determine the type of fumigation (space, vehicle, container, vessel, etc.).
   3. Fully acquaint yourself with the structure and commodity to be fumigated to determine its suitability for fumigation, including:
      1. The general structure layout, construction (materials, design, age, maintenance), fire or combustibility hazards, connecting structures and escape routes, above and below ground, and other unique hazards or structural characteristics. Prepare, with the owner/operator/person in charge, a drawing or sketch of structure to be fumigated, delineating features, hazards, and other structural characteristics.
      2. The number and identification of persons who routinely enter the area to be fumigated (i.e., employees, visitors, customers, etc.).
      3. The specific commodity to be fumigated, its mode of storage, and its condition.
      4. The previous treatment history of the commodity, if available.
      5. Accessibility of utility service connections.
      6. Nearest telephone or other means of communication. Mark the location of these items on the drawing/sketch.
      7. Emergency shut-off stations for electricity, water, and gas. Mark the location of these items on the drawing/sketch.
      8. Current emergency telephone numbers of local Health, Fire, Police, Hospital, and Physician responders.
      9. Name and phone number (both day and night) of appropriate company officials.
      10. Check, mark, and prepare the points of fumigant application locations if the job involves entry into the structure for fumigation.
      11. Exposure time considerations:
          1. Minimum fumigation period, as defined and described by the label use directions.
          2. Down time required to be available.
          3. Aeration requirements.
          4. Cleanup requirements, including dry or wet deactivation methods, equipment, and personnel needs, if necessary.
          5. Measured and recorded commodity temperature and moisture.
      12. Determination of dosage:
          1. Cubic footage or other appropriate space/location calculations.
          2. Structure sealing capability and methods.
          3. Label recommendations.
          4. Past history of fumigation of structure.
2. Personnel - Training and Notification
   1. Confirm in writing that all personnel in and around the structure and/or area to be fumigated have been notified prior to application of the fumigant. Consider using a checklist that each employee initials indicating they have been notified.
   2. Instruct all fumigation personnel to read the Applicator's Manual concerning the hazards that may be encountered and the selection of personal protection devices, including detection equipment.
   3. Confirm that all personnel are aware of and know how to proceed in case of an emergency situation.
   4. Instruct all personnel on how to report any accident and/or incidents related to fumigant exposure. Provide a telephone number for emergency response reporting.
   5. Establish a meeting area for all personnel in case of an emergency.
3. Notification of Authorities
   1. Confirm the appropriate local authorities (fire departments, police departments, etc.) have been notified as per label instructions, local ordinances, or instructions of the client.
   2. Prepare written procedure ("Emergency Response Plan") which contains explicit instructions, names, and telephone numbers so as to be able to notify local authorities if phosphine levels are exceeded in an area that could be dangerous to bystanders and/or domestic animals.
   3. Confirm that the receiver of in transit vehicles under fumigation have been notified and are trained according to the Application Manual.
4. Sealing Procedures
   1. Sealing must be adequate to control the pests. Care should be taken to insure that sealing materials would remain intact until the fumigation is complete.
   2. If the structure has been fumigated before, review the previous FMP for previous sealing information.
   3. Make sure that construction/remodeling has not changed the building in a manner that will effect the fumigation.
   4. Warning placards must be placed on every possible entrance to the fumigation structure. Confirm the placement of placards.
5. Application Procedures and Fumigation Period
   1. Confirm the required safety equipment is in place and the necessary manpower is available to complete a safe and effective fumigation.
   2. When entering into the area under fumigation, always work with two or more people under the direct supervision of a certified applicator wearing appropriate respirators.
   3. Provide watchmen when the possibility of entry into the fumigation site by unauthorized person cannot otherwise be assured.
   4. When entering structure, always follow OSHA rules for confined spaces.
   5. Turn off any electric lights in the fumigated area of the structure as well as all nonessential electrical motors.
6. Monitoring
   1. Safety
      1. Monitoring of phosphine concentrations must be conducted to confirm that nearby workers and bystanders are not exposed to levels above the allowed limits. Document where monitoring will occur.
      2. Keep a log or manual of monitoring records for each fumigation structure and/or area. This log must at a minimum contain the timing, number of readings taken, and level of concentration found in each location.
      3. When monitoring, document (even if there is no phosphine present above the safe levels).
      4. Monitoring must be conducted during aeration and corrective action must be taken if gas levels exceed the allowed levels in an area where bystanders and/or nearby residents or domestic animals may be exposed.
   2. Efficacy
      1. Phosphine readings should be taken from within the fumigated structure to insure proper gas concentrations. If the phosphine concentrations have fallen below the targeted level, the fumigators may reenter the structure, following proper entry procedures, and add additional product.
      2. All phosphine readings should be documented.
7. Post-Application Operations
   1. Provide watchmen when the fumigation structure cannot be secured from entry by unauthorized persons during the aeration process.
   2. Aerate in accordance with structural limitations.
   3. Consider temperature when aerating.
   4. Turn on ventilating or aeration fans where appropriate.
   5. Use a suitable gas detector before reentry into a fumigated structure to determine fumigant concentration.
   6. Keep written records of monitoring to document completion of aeration.
   7. Ensure that aeration is complete before moving a treated vehicle onto public roads.
   8. Remove warning placards when aeration is complete.
   9. Inform business/client that employees/other person may return to work or otherwise be allowed to reenter the aerated structure.

These factors must be considered in putting a FMP together. It is important to note that some plans will be more comprehensive than others.

The FMP and related documentation, including monitoring records, must be maintained for a minimum of two years (three in Nebraska).

Sample Fumigation Management

Sample Document #1
Sample Document #2
FMP for Burrowers