Grain Bin Fumigation Legislative Requirements and Guidelines Crystal Lafrance Ministry of the Environment London Regional Office Feb. 2014
Outline Introduction Fumigation Accidents Fumigation outreach 2010 findings Fumigation legislation and permit requirements Technical information regarding phosphine fumigations
A fumigation is: Fumigation A structural extermination using a fumigant A fumigant is: A pesticide that produces a gas, fume, vapour or smoke A fumigant gas is: A fumigant that is a gas at 20 o C and standard pressure
Fumigation Outreach Project 2010 Findings Purpose: provide information and assistance to users of fumigants in grain storages 10 visits were conducted in Southwestern Ontario Identified non-compliance including: Adequate monitoring equipment Monitoring gas levels Controlling a sufficient distance Personal Protective Equipment Record keeping Permits Sign posting Label requirements Lack of sealing
This image cannot currently be displayed. Fumigation Accidents Gas Vapours Force Ship Evacuation Crew exposed to phosphine gas used to fumigate grain 16 crew members were taken to hospital and treated for exposure to phosphine gas. Dec. 22 nd 2010 Port Colborne, Ontario
Fumigation Accidents Violations Filed Against Utah Exterminator and Pest Control Company After the Death of Two Children Used an excessive rate of Fumitoxin too close to the home when attempting to control rodents. Phosphine gas entered into the home No fumigation management plan in place Exterminator faced charges including negligent homicide for the deaths of two girls, 15 months and 4 years Feb. 5 th 2010, Layton Utah
Fumigation Accidents Misuse of Phoshine in Jerusalem Jan 20 th 2014: Two children die in Jerusalem after misuse of aluminum phosphide; two other children left in critical condition for several days. Exterminator arrested and facing charges
Legislation: Permits A permit is not required to fumigate a vehicle or specified structure if the licensed exterminator can comply with a specific list of requirements (in section 59 and 63 of O. Reg. 63/09). Specified Structures are: A shipping container; A silo, or other grain storage container; A bin, a hopper, or; Any other structure used for the purpose of an agricultural operation other than a building used primarily as a dwelling.
Legislation Requirements To qualify for a permit exemption you must meet the following 13 requirements: 1. Adequate respiratory equipment. On person at all times. Used as required by label. 2. Appropriate gas monitoring equipment. Accurate for gas being used. Used to monitor outdoor concentrations and determine completion of fumigation.
Legislation Requirements 3. Before the fumigation begins the licensed exterminator must ensure that the vehicle or structure: is capable of being sealed during the fumigation, is not contained within a larger vehicle or structure, is located at a sufficient distance from any other building, structure or area where humans may be exposed to the fumigant gas, to prevent adverse effects to humans, has all substances that are not compatible with the fumigant gas removed, and contains no person has fumigation warning signs (sign A) posted at all entrances. These signs must remain posted at all times during fumigation and aeration
Sufficient Distance The distance between the fumigated structure and nearby occupied buildings or areas where people may be exposed to the fumigant. This distance will provide the fumigation boundary. Gas concentrations at the fumigation boundary must not exceed label and regulated re-entry levels (0.1ppm). Must be kept secure so that unauthorized persons may not enter.
Legislation Requirements 4. Before introducing a fumigant gas from the outside or immediately after introducing a fumigant gas from the inside, the licensed exterminator must: Seal the vehicle or specified structure and Lock all doors of the vehicle or structure
Legislation Requirements 5. During gas introduction and airing out two licensed exterminators authorized to use the fumigant gas must be present. Phosphine Extermination
Legislation Requirements 6. Air monitoring must be conducted at all times within the sufficient distance during the fumigation 7. Records of the air monitoring must be made and kept for 2 years 8. Exterminator must ensure that no person enters the structure
Legislation Requirements 9. Structure must remain sealed and locked during fumigation 10. Exterminator must keep in his/her possession the means of unlocking the structure
Legislation Requirements 11. Monitor gas concentrations in the structure to determine if the fumigation is complete. 12. Movable structures fumigated with methyl bromide cannot be moved until airing out is complete. 13. Fumigation of ships and mobile containers carried on ships must comply with the the Canada Shipping Act, 2001 and the Cargo, Fumigation and Tackle Regulations (Canada).
Legislation Requirements Phosphine use in a moving vehicle (i.e. rail car): The means of unlocking the vehicle cannot be accessible to anyone other than the persons assisting in the fumigation or operation of the vehicle. The exterminator is not required to accompany the vehicle. A licensed exterminator must be present during gas introduction and aeration when done in Ontario.
Phosphine Movement in the Grain Bin Research has shown that gas concentrations tend to move from the bottom of the bin to the top. The chimney effect is due to convection currents in the grain mass as air warmed by the grain rises bringing the gas with it. In situations where the grain temperature is cooler then the outside air temperature, downward movement of gas may occur. Fluctuations in gas concentrations from day to night in the head space have been reported.
Where Does the Gas go? H P H H In spaces between individual grains (interstitial spaces) Into the commodity (sorbtion) Escape from the bin during fumigation (fugitive emissions) Released through aeration Interstitial spaces
Fugitive Emissions From the Bin Grain inflow Vents Penetration through cement Cracks seams Grain outflow Fan
Aeration of the Grain Mass Legislation The fumigation is not complete until airing out of the structure is completed Phosphine Phosphine
Sufficient Distance and Fumigation Boundary Loading area Shop Shed N <1 m Warehouse Office Road
Once every half hour for 2 hours 7:30 8:00 8:30 9:00 Once every hour for 2 hours 10:00 11:00 Monitoring: Phosphine as a gas Formulation Once every 4 hours until aeration 3:00 Introduction of Gas Monitor continually 6:00 to 7:00 7:00 11:00 Monitor continually during aeration
Beginning 6 hours after introduction, monitor Continuously for 1 hour 12:00 to 1:00 Monitoring: Phosphine as a Solid Formulation Once every 6 hours until aeration 7:00 Introduction of Pellets 6:00 1:00 Monitor continually during aeration
Wrap-up Review fumigation practices at your facility Monitoring Sufficient distance Personal protective equipment Record keeping Permit required? Sign posting Fumigation management plan Sealing
Crystal Lafrance Regional Pesticide Specialist crystal.lafrance@ontario.ca