Aluminum Phosphide Fumigants & Fumigation Management Plans

Transcription

1 2/4/2013 1

2 Aluminum Phosphide Fumigants & Fumigation Management Plans Leilani Monson, RN Oregon OSHA 2/4/2013 2

3 Fumigants : Active Ingredients Methyl bromide Chloropicrin Metam sodium (Vapam) Metam potassium (K-Pam) Dazomet (Basamid) 1,3-Dichloropropene (Telone) Iodomethane (Midas) Dimethyl disulfide (DMDS) (Paladin) Aluminum phoshide

4 WHAT are the aluminum phosphide fumigants? Fumitoxin Phostoxin Gastoxin Phosfume Drex-PH3 Used to control insects and burrowing pests 2/4/2013 4

5 Oregon OSHA Requirements Fumigation Rules OAR Respiratory Protection OAR Hazard Communication OAR Worker Protection Standard 40 CFR 170 Permit-required Confined Space

6 Why do we have so many rules? First, what it does to the body.. 2/4/2013 6

7 The product reacts with water/moisture and makes deadly phosphine gas. Works great for pests not so good for humans and pets. 2/4/2013 7

8 As you breathe phosphine the acid in the gas dissolves your lung tissue. Your damaged lungs can t take in oxygen from the air.

9 Fluids build in your lungs Your lungs become overwhelmed and you drown in your own fluids. Pulmonary Edema

10 Heart becomes oxygen deprived Lack of oxygen stimulates heart to beat faster The heart races uncontrollably to try to save itself. The heart stops. You die quickly.

11 And If your not lucky enough to die quickly... Liver & kidney functions are overwhelmed by phosphine You are dying slowly and painfully As tissues deteriorate infections set in, Pneumonia ravages the body

12 Why all the rules? The stories speak for themselves.. 2/4/

13 Acute phosphine poisoning aboard a grain freighter- 2 children plus 29/31 crew members; 1 child dies, late 1970 s Atlantic Ocean Fumigant Intoxication during transport of grain by railroad- 3 Federal Grain inspectors sickened, Portland Oregon May 1980 Deaths Associated with Exposure to Fumigants in Railroad Cars US- 12 y/o boy- El Paso Texas 1993, 23 y/o male, Maxwell CA 1989 Drum containing 37 flasks of Fumitoxin recovered from a grain elevator fire explodes seriously injuring 1 employee, Sheridan OR /4/

14 Partially spent Fumitoxin confined in a dumpster explodes, almost ignites building. Hubbard, OR 1997 Application of Fumitoxin pellets used for gophers & ground squirrels kills Bridget Carlson, 5; sickens family. Salem, SD Two people die after handling deadly pesticide. Enterprise, Alabama. January Man pleads guilty to manslaughter in poisoning death Mitchell, SD. September 2005 Fumitoxin ignites at Syngenta Seed Plant, sickens workers in nearby building. Nampa,ID, /4/

15 2010 Utah Fatalities Rebecca, 4 years Rachel, 15 months 2/4/

16 Bugman, ex-worker plead guilty in Layton pesticide deaths By JUDY FAHYS In separate plea agreements, Nocks, 64, and the company acknowledged they broke the law by using Fumitoxin in burrows within 15 feet of an occupied structure, putting too many pellets in the burrows and failing to give the Toones a safety data sheet about the dangerous pesticide. Nocks and Bugman also admitted for the first time Tuesday that they caused the death of two minor children. 2/4/

17 Oregon OSHA Fumigation Rules OAR You MUST follow information in each of these: Product Label Application Manual And. MSDS

18 Manual and label 2/4/

19 MSDS Information Medical specific information and treatment information to physicians in case of exposure. Hospitals will ask for the MSDS and call the emergency information number on the top of the MSDS

20 cdms.net/labelsmsds

21 Where can I start? Read the Applicator s Manual. BUT, I mean really read and understand it! OR-OSHA cites from the applicator s manual.

22 Cover Page 2/4/

23 Fumigation Management Plan (FMP) An FMP is an organized, written description of the required steps necessary ensure a safe, legal and effective fumigation. Fumigations where FMPs are required Space fumigation (Bins, flat storage, vertical storage, mills, food processing plants and warehouses, railcars, ships, trucks, etc) Burrowing pests Soil fumigation- Metam Sodium, Telone, Pic, etc. 2/4/

24 Types of FMP s FUMIGATION MANAGEMENT PLANS FMP for structures: Grain bins (holding all that wheat!) fall under this plan FMP for burrowing rodents FMP for soil fumigation- Metam Sodium 2/4/

25 The Fumigation Management Plan Components Preliminary Planning and Preparation People- working with PH3 and others around Monitoring Notification Sealing procedures Application procedures & fumigation period Post-application operations 2/4/

26 Aluminum Phosphide Help?

27 FMP for Burrowing Rodents A MAP of site 2/4/

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29 FMP: Burrowing Pests Application Procedures & Fumigation Prior to treating: inhabited structure, provide an MSDS or Applicator s manual to occupant. **Distance from occupied (human/animal) structure: 100 feet POST a WARNING sign to the treated area. 2/4/

30 Fumigation signs The regular WPS Do Not Enter sign is not acceptable for use with fumigants. The one noted here is correct. Field posting now required when treating burrowing rodents. 2/4/

31 FMP: Burrowing Pests Post Application Procedures Return all unused fumigant product to an approved, locked chemical storage area. Re-inspection / Re-treatment Closed burrow systems: re-inspect after 2 days Open burrow systems: re-inspect after 1-2 days. 2/4/

32 STORING ALUMINUM PHOSPHIDE These two signs are required to be posted on the outside of the pesticide storage area. KEEP THE STORAGE AREA LOCKED! 2/4/

33 FMP s for Structures Grain bins (holding all that corn!) fall under this plan. Railcars, tanks Hay storage in buildings or covered with tarp. 2/4/

34 FMP: Preliminary planning & preparation Review label and applicator s manual. Determine the purpose of the fumigation Elimination of insect infestation Determine the type of fumigation Type of Storage: vertical silo, farm storage, flat storage, etc. 2/4/

35 FMP: Preliminary planning & preparation Nearest telephone, cell coverage or other means of communication i.e. 2-way radios. Emergency shut-off stations for electricity, water and gas. Emergency telephone numbers Fire/ EMS, Police. 2/4/

36 FMP: Preliminary planning & preparation Exposure time considerations: temperature and moisture of commodity weather- temp humidity and wind Determination of dosage: Cubic footage of space Structure sealing capability Label recommendations 2/4/

37 FMP: PERSONNEL Instruct all fumigation personnel to read the Applicator s Manual regarding the health hazards. Provide required PPE, gloves, respirators. Confirm that all personnel know how to proceed in case of an emergency. 2/4/

38 NOTIFICATION Notify all personnel around the structure prior to application of the fumigant. Notify appropriate fire departments, police departments as per label instructions. Prepare a written Emergency Response Plan which contains instructions if phosphine levels are exceeded and could be dangerous to bystanders or domestic animals. 2/4/

39 SEALING PROCEDURES Sealing must be adequate to control the pests. Warning placards must be placed on every possible entrance to the fumigation structure. Lock out entry and discharge points, i.e. spouts 2/4/

40 APPLICATION PROCEDURES & FUMIGATION PERIOD Apply the fumigant in accordance with the label requirements Apply fumigant from the outside if possible. If you must enter the area under fumigation, work with 2 or more people under the direct supervision of a certified applicator wear appropriate respirators. 2/4/

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42 APPLICATION PROCEDURES & FUMIGATION PERIOD Provide watchmen when entry into the fumigation site by unauthorized persons cannot otherwise be assured. When entering structures, follow OSHA rules for confines spaces. Turn off any electric lights in the fumigated area of the structure as well as all non-essential electrical motors. 2/4/

43 MONITORING Monitoring of fumigant concentrations must be conducted in areas to prevent excessive exposure. Keep a log of monitoring tests for each fumigation structure. Include the time and date, number of readings taken and level of concentrations found in each location. 2/4/

44 Types of monitoring equipment 2/4/

45 POST-APPLICATION OPERATIONS Aerate in accordance with structural limitations. Turn on ventilating or aeration fans where appropriate. Use a suitable gas detector (monitor) before reentry into a fumigated structure to determine fumigant concentration. 2/4/

46 POST-APPLICATION OPERATIONS Keep written records of monitoring to document completion of aeration. Remove warning placards when aeration is complete. Inform others when they may return to work, or be allowed to re-enter the structure. 2/4/

47 Deactivation methods

48 But what about contractors? If I have a commercial applicator fumigating for me, do I still have to do an FMP? Yes, the Certified Applicator will assist you, and you will maintain the FMP for your records. 2/4/

49 ELEVATORS, FLYBOYS, A PRISON AND AN EXPLOSION Pesticide Inspections Eastern Oregon Style

50 Toxic Elevators- A Game of Russian Roulette!

51 PARC Referral to OR-OSHA Grain Hauler became ill while loading his truck from a grain bin that was under active fumigation.

52 Hazards Identified Bins under fumigation are not labeled. Fill spouts are not locked out. Bins # s to pull from are via 2 way-radio. Bins numbers are hard to distinguish

53 Posting label lists fumigation ongoing from September to the following June. PPG has 20 elevators totaling 400 bins that are fumigated. Thousands of fumigations each year. Blanket notification on door of elevator FMP

54 FMP This is the Certified Applicator's record of fumigations. Throw tablets into grain stream. No tarping, just close bin and leave it for 21 days. No monitoring

55 FMP

56 FMP Do not calculate volume- just throw in tablets. No cell coverage, emergency phone inside the elevators. No policy or plan Applicators work alone

57 FMP Workers had never read label or applicators instructions. Dust masks-no respirators. Workers enter confined spaces with no monitoring

58 OSHA Citation OAR-0760(1)(c) lack of health hazard controls, Specifically, for not following the label and applicator manual.

59 Abatement FMP-completed as per manual 8 PPG EE s to fumigation training (ODA/Univar) Calculations on bins for correct dose of PH3 Calculations for ventilation done. Lock out and tags on fumigation spouts ID # s repainted contrasting color at drivers height. Bins # s to pull grain are added to the drivers Bill of Lading and invoices.

60 Abatement 10 MSA single gas monitors and 9 multi gas monitors purchased, calibrated and trained. Met with Fire Departments (12 involved) to train about fumigation hazards. Notified hospitals (4) of hazards of ph3. Central fumigation list on excel available at a moments notice.

61 WASTED! Throwing pesticide waste in the garbage does not mean the hazard is gone.

62 ONTARIO SANITARY SERVICE

63 ONE DAY AT THE RECYCLING CENTER Workers find a couple flasks after the front end loader ran over one. An unknown noxious smoke was filling up the inside of the building. Workers used water to put out the fire. This made things worse and the center was evacuated until it gassed off. 2/4/

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65 NO RECYCLING HERE- ALL SENT TO LANDFILL

66 ARIAL SPRAY CO-OP

67 RINSING

68 SECURE DISPOSAL STORAGE

69 BREAKING DOWN BOXES

70 HAPPY ENDING Ontario Sanitary Service reports they are no longer receiving questionable pesticide materials. They are able to comply with DEQ and recycle the containers and cardboard.

71 PRISON MOLES

72 MAINTENANCE USES FUMATOXIN ON THE PRISON GROUNDS TO:

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75 APPLIED TO AREAS OUTSIDE THE PERIMETER FENCING

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77 CITATION & ABATEMENT OAR (i)(c)- Did not following label or provide a fumigant management plan. Also citations for pesticide storage practices Abatement: They removed Fumatoxin from the facility, it will not be used in the future.

78 2/4/2013 An explosive Day in Pendleton! 8 4

79 2/4/2013 Deactivation container One hot day during the Pendleton Roundup, the deactivation container exploded when the applicator placed 17 pounds of partially spent socks in the container (overfilling it by several pounds per the label). Murphy s law came into play when a slow moving railroad passed by the fumigation cloud after the explosion. 4 railroad employees were exposed to the fumes. 8 5

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81 140 flask, 15ft. from railroad tracks

82 HELP!!!!! cdms.net/labelsmsds Oregon Dept. of Ag Oregon OSHA Vendor of fumigant Manufacturer of fumigant. 2/4/

83 2/4/2013 Please use fumigants safely! Rebecca, 4 years Rachel, 15 months 8 9

84 Questions????????? Leilani Monson, RN (541)

85 2/4/