How does fumigation work?

Fumigation works by converting a solid into a lethal gas which is dispersed within an enclosed area and maintained at a prescribed concentration for a specified period to eliminate target pests. In Minnesota, fumigation is commonly used to treat grain infested with pests.

What are the steps to fumigate and when is it complete?

Fumigation requires several steps: 1) Prepare site and determine dose; 2) Complete a Fumigation Management Plan (FMP) if required by product label; 3) Application; 4) Lockout site; 5) Monitor and reapply to maintain lethal concentration if necessary; 6) Monitor air temperature which may affect fumigation rate; 7) Complete fumigation period; 8) Aerate fumigated space; 9) Collect and deactivate any unused fumigant; 10) Dispose of any non hazardous wastes; and 11) Clear area for reentry. The time recommended on the label is the minimum
time necessary to complete the fumigation process. The end time cannot be pre-determined because the process could slow down with conditions. End time can only be determined by monitoring fumigant levels in the container over a period of time.

Is a fumigant a pesticide?

Yes. A fumigant is a pesticide. A pesticide is defined as a substance or mixture of substances intended to prevent, destroy, repel, or mitigate a pest.

Does a person need an applicator credential to fumigate and apply other pesticides occupationally in Minnesota?

The applicator credential in Minnesota is an annual license issued by the Minnesota Department of Agriculture (MDA). The Minnesota Pesticide Control Law requires that a person obtain a Commercial Pesticide Applicator License to apply a pesticide for hire, or a Noncommercial Pesticide Applicator License to apply any pesticide classified as a restricted use pesticide (RUP) as a condition of employment. Many, but not all fumigants are classified as RUP.

How does a person determine if a pesticide is an RUP?

The words “This is a Restricted Use Pesticide” will be written near the top of the product label on the front of the container.

Does a person need a credential to fumigate on their own property?

A person using a RUP fumigant in the production of an agricultural commodity on their own property, or as one of two or fewer employees in the production of an agricultural commodity must obtain a Private Pesticide Applicator Certification. Once a person has obtained a Private Pesticide Applicator Certification, they must add a Fumigation Endorsement which allows them to purchase and use a registered RUP fumigant.

How does a person obtain a Pesticide Applicator License or Private Pesticide Applicator Certification with a Fumigation Endorsement?

A person must demonstrate that they are competent to hold an applicator credential by passing a closed book exam. A person must also complete an application form for either a Pesticide Applicator License or Private Pesticide Applicator Certification and pay the necessary application fees. A person must meet financial responsibility requirements as defined by the Law to obtain a Commercial Pesticide Applicator License. A Commercial or Noncommercial Pesticide Applicator License issued by the MDA expires on December 31 and must be renewed annually. An MDA issued Private Pesticide Applicator Certification expires on March 1 three years after issue.

See the MDA Pesticide Applicator Licensing web page for more details about license requirements. See the MDA Private Pesticide Applicator
Certification web page
for more details about certification requirements.

How does a person maintain an applicator credential?

MDA requires licensed persons attend recertification training every other year in order to renew an expired license. A certified Private Pesticide Applicator may attend an approved recertification training every three years or take an exam in order to renew their certification. Recertification for the Fumigation Endorsement is by test only.

Does each person applying RUP fumigants need a Pesticide Applicator License or Private Pesticide Applicator Certification?

The Law requires that every person obtain a license prior to applying pesticide for hire, or occupationally applying an RUP. A person who applies an RUP on their own property must obtain a private certification and a fumigation endorsement if necessary. MDA mails an ID card to persons who become licensed or certified. Lists of credentialed applicators can be found on the MDA web page.

Can a person without a license or a private certification legally apply pesticide for hire or an RUP under the supervision of a credentialed applicator?

No. The MDA does not allow a person to apply a pesticide for hire, or to apply RUP without first obtaining the proper credential.

What fumigation support activities can a person perform without a credential?

A person without a credential can help with the setup and site preparation prior to fumigation and the clean up activities after the space is cleared and the fumigation is complete. These tasks may include moving unopened product, sealing spaces and placarding in advance of the fumigation application, or breaking seals and disposal of wastes after aeration is complete.

How many persons with a Pesticide Applicator License or Private Pesticide Applicator Certification/Fumigation Endorsement are needed on-site when a fumigant application is made?

One credentialed person may apply a fumigant when no entry into a structure is necessary to complete the fumigation. Two credentialed persons must be on-site whenever fumigation requires entry into a structure. Only a person with applicator credential (Pesticide Applicator License or Private Applicator Certification with Fumigation Endorsement) is deemed properly trained to apply fumigant and perform the related tasks.

What is a Fumigant Management Plan (FMP) and when is it required?

Some fumigant labels now require a FMP. This document which the applicator completes for every fumigation describes the planned fumigation process. The US EPA and manufacturers agreed to adopt the FMP because of the human health risk posed by phosphine fumigants. Product stewardship agreements such as the FMP allow for reregistration of certain products while assuring protections for users and other individuals near the application area.

Do I need to create a FMP or can I follow a template?

Either an original or a completed template is acceptable. Templates are available on the internet. The Nebraska Department of Agriculture web page, for example, contains a document Guidance for Developing A Fumigation Management Plan (FMP).

Who must complete the FMP and what information is required?

A person credentialed as an applicator must complete the FMP. It must be specific for each treatment site, up to date, available for review, and carefully followed. Information on the plan includes emergency contact information, personnel credentials and notification, site logistics, application procedures and fumigation period, steps for sealing, posting, monitoring of site and after fumigation procedures. The product Applicator Manual contains a full list of FMP requirements.

Is a FMP the same as a pesticide application record?

No. An FMP is required by the product label. A pesticide application record is required by Minnesota law for certain licensed pesticide applicators. The 1990 Farm Bill requires private pesticide applicators keep application records of restricted use pesticides applied. Application records require different kinds of information than the FMP.

What is a pesticide application record, what information does it contain and who must complete a record?

A pesticide application record documents the application of pesticide at each site where pesticides are applied. When required, a person must complete the record as soon as possible after the application, give a copy to the customer where applicable and maintain a copy. MDA maintains samples on its web page showing the information required.

What is fumigation in transit and when is it permissible?

Commodities in railroad freight cars and ship holds may be fumigated while transported from one location to another. Fumigation is begun at the origination point, continues in transit, and concludes at the destination. The fumigation rate depends on temperature. At conclusion, monitoring shows the absence of fumigant, the container is aerated, unused product deactivated and the container cleared. Fumigation in transit is not permitted in truck trailers moving over the road.

Is notification between the shipper and receiver required when commodities undergo fumigation in transit?

Yes. The shipper/fumigator is required to notify the receiver/fumigator in advance of the shipment that in transit fumigation is underway. The notice can be in written or electronic, and must include a copy of the label, the Applicator Manual and the application record. It allows the receiver/fumigator to prepare for the arrival of the commodity and to complete the fumigation. This notice transfers the application responsibilities to the receiver/fumigator who must complete the fumigation in accordance with applicable laws and regulations, including shipments where the commodities cross state boarders.

Is acknowledgment of a transfer notice necessary?

Yes. The receiver/fumigator must acknowledge receipt of the notice. Documenting the notification and acknowledgement by both parties show each has done their due diligence.

Who is responsible for the application?

Minnesota Law holds the applicator and application company responsible for an application. In instances where the shipper and receiver may each be responsible for a portion of the application, the transfer notice and acknowledgement helps clarify responsibilities.

How is the product label and Applicator Manual sent?

The label and Applicator Manual may be sent prior to the shipment, or secured to containers holding fumigant. Documents accompanying shipments undergoing fumigation must be secured to the containers exterior near placards. Place documents on the first and last rail cars of a continuous and connected line, as long as no intermediate cars will be diverted.

What is placarding and what placarding is required for rail cars that are fumigated in transit?

Placarding is an important safety notice to persons who may not be aware the container is undergoing fumigation. A person opening a container unaware that it is holding fumigant could be seriously injured. Placards must be placed on both sides of each rail car or container holding fumigant. Placards must be placed in full view near each ladder and near each hatch. Placards may not be removed until the treated commodity is completely aerated and the application is complete.

What information is required on a placard?

A placard provides a warning that fumigation is underway. It must contain the signal word from the products label, warning symbols and a fumigation statement. A placard also records the product name, the date and time fumigation began, and the name, address and telephone number of the applicator. Placards are available from the product manufacturer or the internet.

Who should people contact with fumigation questions or for more information?

The MDA is authorized to regulate the use of pesticides in Minnesota. Contact MDA at 651-201-6615.