Phosphine Fumigation Program , Year 2 Program Number TO

Transcription

1 Phosphine Fumigation Program 203-5, Year 2 Program Number TO This is the second year of a 2 year program that began in 203 (Program AP). Objectives: First year To promote compliance with label requirements and mitigation measures related to the use of phosphine products (aluminum phosphide, magnesium phosphide, and phosphine gas) to stakeholders and user groups, including those involved in the storage and transport of grains, seed/feed, and other commodities, as well as rodent burrow fumigation. Second year To inspect users of phosphine products and verify compliance with label requirements. Inspections will also verify the knowledge, will and ability to comply. Additionally, inspections will verify that current mitigation measures required under the re-evaluation of the active ingredients are observed. Background Phosphine gas can be produced by three registered active ingredients, aluminum phosphide, magnesium phosphide, and phosphine gas. These products are registered to control insects in many stored commodities. These include food commodities such as grains; oilseeds; coffee beans; dried fruits; and seeds; non-food products such as clothing; cotton; wool; fur; paper; and wood products and processed foods and feeds. Commodities may be stored in mills, food processing plants and warehouses, silos, or under tarpaulins. Additionally, commodities may be fumigated in transport containers, railcars, and trucks. There are also phosphine products specifically registered to control rodents through fumigation of burrows. Re-evaluation of aluminum phosphide and magnesium phosphide was first announced publically in To date, there have been three documents released from the Pest Management Regulatory Agency regarding these actives and a fourth is coming in 204/205. This last document is expected to complete the re-evaluation. The associated reevaluation documents are: National Pesticides Compliance Program PACR : Proposed Acceptability for Continuing Registration: Re-evaluation of Aluminum and Magnesium Phosphide REV : Re-evaluation Note: Aluminum and Magnesium Phosphide Interim Measures

2 - 2 - REV200-03: Re-evaluation Note: Aluminum and Magnesium Phosphide 204/205: Re-evaluation Note to be released this year will require further restrictions. Despite the titles of the re-evaluation documents, the active ingredient, phosphine gas is included in all the re-evaluation requirements. All required label amendments apply to this active as well. Phosphine gas is a highly toxic product, and can, in fact be deadly. Based on the potential health and environmental concerns, a number of mitigation measures were proposed in Then, following review and comment, these measures were required in These changes to the labels included environmental hazards, but focussed primarily on worker and bystander safety, such as the requirement for two trained people to be present during fumigation of structures and the need to maintain visual and/or voice contact with all fumigation workers during application. Placarding of fumigated areas is now required as is gas monitoring during unloading of the fumigated commodity. If commodities are fumigated in containers, trucks, ships, railcars, etc., written notification must be provided to the receiver of the container. There are also specific requirements for use of the product in a burrow system related to proximity to buildings. In addition, all fumigations of all commodities must now be preceded with completion of a fumigation management plan. The fumigation management plan requirement was not fully implemented on labels until 200. In 200, there was a further reduction in the level of the phosphine gas exposure limit for reentry by unprotected workers from 0.3 ppm to 0. ppm. New product labels with these additional requirements, including the fumigation management plan entered the market in 20. There will be further requirements tabled as part of a Re-evaluation Decision document in 204/5. These are expected to be the final requirements. The grain industry and trained, licensed Pest Control Operators (PCOs) are responsible for a large percentage of product use. PCOs are often hired by industry to fumigate stored commodities. They are, generally, licensed provincially to use these products. The hiring company, however, also has responsibility to ensure that bystanders are not impacted by the fumigation. Treatment of a commodity in-transit requires the consignee to notify the receiver of the commodity by written notification and the receiver is responsible for aeration and documentation of monitoring. Landowners and growers also use these products. Control of ground squirrels in the Prairie Provinces, for example, occurs on-farm and the fumigants may be used by landowners. Additionally, grain stored in silos may be treated by individual growers. The requirements for a fumigation management plan, placarding, and aerating must be followed in these use situations as well.

3 - 3 - All provinces have certification/licensing associated with pesticide use and many require specific training in fumigation. Fumigants cannot be purchased or used without an appropriate pesticide applicator certificate of licence. In British Columbia (BC) and Alberta (AB), the PMRA and Regions and Program Bureau (RAPB) pesticide field staff have provided training as part of the provincial training that is associated with the certification/licensing process. Education credits can be collected over the lifetime of a PCO applicator s certificate. If sufficient credits are accumulated, through participation in educational events such as our slide presentation, the licence is renewed without further testing. We have been able to take advantage of this collaboration with provincial regulatory officials for other issues and programs related to applicators. Program Delivery Completed in 203 This program began in the third quarter (Q3) of 203 and continued into the first quarter (Q) of 204. The program was planned to run over two years. The first year involved active prevention of non-compliance through promotion of mitigation measures. Our objective for the first year was to provide users and stakeholders with an understanding of the mitigation measures required for the use of this type of product. Information was provided by means of a presentation to a variety of stakeholders. This included product users, such as PCOs who are employed to fumigate as well as the industry who employ them and whose employees may be exposed to phosphine (grain shippers and handlers or those who transport seed or feed). As well, growers who fumigate rodent burrows or stored grain, themselves, were engaged. In a number of cases, training was completed in conjunction with provincial certification/licensing courses. In addition, retailers, as well as some individual growers, received individual letters indicating key mitigation measures, employing the hand-out: Required Mitigation Measures for Aluminum Phosphide, Magnesium Phosphide and Phosphine (Hydrogen Phosphide) Gas. This hand-out was also made available at presentations. The slide show was developed to aid in these presentations, which included the mitigation measures associated with these products, as well as information detailing label restrictions. The slide show provided such information as: an introduction to pesticide regulation (the role of the PMRA). the history of phosphine re-evaluation (the toxicity of the product and the requirement to adhere to mitigation measures). the mitigation measures and changes that have been made to the labels following reevaluation. discussion of the fumigation management plan requirements. possible consequences of not adhering to label requirements - in terms of the high toxicity of the product. the need for incident reporting. possible consequences of non-compliance. Table.0, below, below provides an overview of the active prevention work completed in 203-4, the first phase of this two year program.

4 - 4 - Table.0 Regional Presentations (Year ) Region Presentations Completed Target Audiences Attendees (Approximate) Atlantic (AT) 3 Orkin Pest Control managers Braemar Pest Control managers Quebec (QC) 2 Ontario (ON) 6 In both the above instances, company managers, in turn, presented the information to all the technicians. Neither company has used phosphine recently and do not intend to use it in the future. Halifax Grain Terminal manager who oversees all fumigations (no fumigations in 2 years as infected grain is not accepted and storage is brief) Presentations to pest control operators at the Provincial association s annual meeting (Association Québécoise de la Gestion Parisitaire). Webinar/Webex presentation at the request of Canadian Grain Commission to inspection staff. Conference call and in office presentation Port of Johnstown - port workers who use or are exposed to phosphine. Armstrong Milling, Hagersville - mill workers who use or who are exposed to phosphine. Ontario Agri-Business Association, Woodstock - representatives of the crop input, grain (elevators) and feed industry including custom applicators who may use or be exposed to phosphine Orkin Pest Control, Mississauga - select group of PCOs who have been specifically trained for fumigations and who are using phosphine, including their management Abell Pest Control (via WEBINAR) - select group of PCOs who have been specifically trained for fumigations and are using phosphine, including their management The Grain Elevator and Processing Society (GEAPS) Chapter Meeting, Thunder Bay - grain elevator industry, including workers, operations management, service technicians, and PCO's from Thunder Bay who may use or be exposed to phosphine Continued

5 - 5 - Region Presentations Completed Target Audiences Attendees (Approximate) Manitoba (MB) 2* *All 2 purchasers of aluminum phosphide in Manitoba region received a letter with a list of critical mitigation measures. A fumigation management plan was incorporated into the Assiniboine Community College training manual which is required for obtaining the provincial licence to apply phosphine. 2 Saskatchewan (SK) Alberta (AB) 8 British Columbia (BC) Manitoba Weed Supervisor Association (Q, 204). Audience included growers who work with phosphine. Saskatchewan Institute of Applied Science and Technologies (SIAST), the institution responsible for training (for provincial certification) and worked with them to update their training material. Presentations (8), as part of provincial licensing training (6-20 people/session) - PCOs, new growers or growers renewing their 5 year licence. Visited retailers (including 2 municipalities) of aluminum phosphide to promote education of all purchasers in 204 regarding mitigation measures, using the Handout titled Required Mitigation Measures. Expected to continue in Presentations (2) to Canadian Grain Commission (CGC) employees, including some who apply product or are responsible for its application. This was organized by CGC s Safety and Training Officer. This work in was the active prevention stage. In 204-5, inspections will determine compliance with label requirements. Program Delivery in This year will involve inspections of various users to determine their compliance with current mitigation measures for phosphine use. The type of use varies somewhat across the country and regions will choose inspection targets accordingly. Most users will be inspected for phosphine products used to control insects in storage situation such as: grain terminals, grain elevators, flour mills, ship fumigation, and individual growers/landowners. In addition, PCOs who use phosphine for space fumigation will be inspected. In the prairie regions, there will be inspections of growers who use the product on-farm and in Alberta, this will include phosphine use for rodent control on the farm.

6 - 6 - Regional staff will work cooperatively with provincial regulators to ensure dissemination of information and collaborative efforts, where possible. Inspections will be based on the attached questionnaire. It looks at general use, training and safety (including monitoring phosphine gas levels), and use of personal protective equipment, and the production of a fumigation management plan and the information contained therein. There will be no sampling associated with this program. Table 2.0 Quarterly Regional Inspections Region Planned Inspection Targets Inspections Total Inspections Per Region Atlantic (AT) Halifax Grain Terminal 0 Quebec (QC) Ontario (ON) Manitoba (MB) Ship fumigation companies, flour mills, grain elevators PCOs that treat lumber for export, grain terminals, warehoused commodities, flour mills, space fumigation. Growers and PCO s who treat stored grain Q3 Q Saskatchewan (SK) Growers who treat stored grain Alberta (AB) Growers who treat stored grain or for rodent control British Columbia (BC) In-Transit Fumigation 0 Total per Quarter

7 - 7 - Expected Results Immediate outcomes: to be determined Intermediate outcomes: to be determined Final outcomes: to be determined Outputs: to be determined Dates Delivery Start - Compliance Promotion: October, 203 Delivery Completion Compliance Promotion: March 3, 204 Delivery Start Compliance Inspection: November, 204 Delivery Completion Inspection: March 3, 205 Regional Summaries: June 3, 205 Final Report: September 30, 205 Team lead: Ila Cornish Hogan Team members: Troy Troop/Joey Browne (AT), Bruno Sauvé (QC), David Quesnel (ON), Marcie Smerchanski (MB), Michael Fagan (SK), Julie Sisson (AB), Irene Wilkin (BC) Appendices: I. Slide Presentation II. List of Registered Products III. Required Mitigation Measures IV. Fumigation Management Plan (example from the Province of British Columbia)