References

For further information about the safe use of
grain fumigants and the laws that regulate use of
them, see:

"Pesticide  Fact  Sheet:   Aluminum  and
Magnesium  Phosphide".   Environmental
Protection Agency, Fact Sheet Number 118.
February 20, 1987.

Federal Insecticide, Fungicide, and Rodantlcldo
Act, as amended (7 U.S.C.  136)

"Health  Hazard Evaluation Report:  Federal
Grain Inspection  Service - USD A, Portland
Oregon.   National Institute for  Occupational
Safety and Health, NETA 83-375-1521. October
1984.

40 C.F.R, Part 152, Subpart 1. Classification of
Pesticides

For More Information:

Environmental Protection Agency
1200 Sixth Avenue, AT-083
Seattle,  Washington 98101

Federal Grain Inspection Service
U.S. Department  of Agriculture
P.O. Box 96454
Washington, D.C. 20090-6454

Occupational Safety & Health
Administration
U.S. Department of Labor
200 Constitution Avenue, N.W.
Washington, D.C. 20210

U.S. Department of Transportation
400 7th Street, S.W.
Washington, D.C. 20590
&EFA
    United States
    Environmental Protection
    Agency
Region to
1200 Sixth Avenue
Seattle Washington 98101
                                                                                                          In the Patific Northwest, ^placarded
                                                                                                          transports carrying gram treated with
                                                                                                         phosphine famigants are posing a health
                                                                                                             and safety risk to grain handlers

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 Failing to Test Commodity Temperature and Placard Fumigated Grain Transports is Jeopardizing Our Safety
Use of Phosphine Fumigants

    The only way to effectively and safely
use phosphine fumigants is to use them as
the product label directs, i It is important to
remember that these substances are toxic
and potentially harmful-fo people.  Using
approved application methods and placarding
all grain transports carrying fumigated grain
are our best means of ensuring the safety of
all grain handlers.

The Problems

Missing Placards

    Failure  to placard  fumigated grain
transports presents a great danger.  Some
applicators are not placarding grain carriers
with signs to warn inspectors, samplers, and
other grain handlers that grain contained in
the carrier has been fumigated. As a result,
inspectors, samplers,  and grain handlers
working in and around unplacarded transports
are being exposed to dangerous levels of
fumigants.

    A study conducted by the National Institute
for Occupational Safety and Health concludes
that "...since fumigated and non-fumigated
railcarshipments are identical in appearance
except  tor placarding,  workers opening
unplacarded, fumigated grain shipments will
probably not realize the grain has been treated
until after exposure has occurred."

Testing Commodity Temperature

    Aluminum phosphide labels require that
the internal commodity temperature be tested
before the fumigant is applied.  In cold weather
months, the internal commodity temperature
may be below 40 degrees F - too tow for the
phosphide tablets to react. If applied improperly
to a cold grain shipment, unspent tablets will
not begin to react until arrival in warm weather
areas such as ports in Oregon and Washington.
The phosphine gas that then is produced in a
sealed transport during shipment can cause
severe poisoning upon opening, especially if
placards are  not attached to warn grain
handlers of the danger.
The Health Hazards

    Working in or around an unplacarded
transport containing unsafe levels of phosphine
without allowing it to aerate may result in
direct inhalation of toxic fumes. Such exposure
may cause weakness, tremors, vomiting,
coughing, difficult or labored respiration, and
possibly pulmonary  edema.  For a grain
handler walking atop a railcar or trailer, these
symptoms could result in a long, dangerous
fall.

The Solutions

Testing and Placarding

    All individuals in the grain handling and
transport system must ensure each other's
safety. Grain transports must be placarded
with warnings that the contents of the carrier,
whether a barge, railcar or truck, are fumigated.
Placards on grain  transports  alert official
grain inspection personnel and grain handlers
that the grain contained in the transport has
been fumigated and must be aerated before
it can be safely handled, inspected, or sampled.

    Before  applying aluminum phosphide
fumigants,  applicators should  also  test
commodttytemperature and only apply when
the temperature is 40 degrees F or above.
This practice is particularly important when
using fumigants in cold weather months since
cold commodity temperatures will slow down
or stop the production of phosphine  gas.
Normal aeration or detection procedures may
fail in this situation. Testing for the presence
of phosphine gas will give you a false "safe"
reading because the phosphide tablets will
have failed to react. The only reliable course
of action is to withhold application until the
internal commodity temperature has risen to
40 degrees  F.
What You Can Do To Help

    Proper placarding will ensure that grain
handlers throughout the system have the
opportunity  to  take  necessary   safety
precautions before working with fumigated
grain.

    For the safety of other grain handlers,
remember to test commodity temperature
before  applying  aluminum  phosphide
fumigants. Placard fumigated transports and
date the placards as to when  fumigation
began.  If you have reason to believe that a
fumigated transport may not be completely
aerated, be sure that placards remain attached
to the transport during shipment.

Safety is the Law

    The  Environmental Protection Agency
regulates the use  of  fumigants  through
instructions on the product label. Remember
that failure to follow these instructions violates
state and federal laws. The labels on aluminum
phosphide fumigants state:

    "Do  not  fumigate  if  commodity
temperature is below 40 degrees F."

    "All entrances to a fumigated site must
be placarded. (Railroad hopper cars must be
placarded on both sides near the ladders and
on the top hatch where fumigant was applied).
A placard may only be removed after the
commodity is  completely  aerated.   To
determine whether aeration is complete, each
fumigated site or vehicle must be monitored
and shown to contain 0.3 parts per million
(ppm) or less phosphine gas in the air and
space around and, when  feasible, in the
mass of the commodity. If more than 0.3 ppm
is detected, the placard must be transferred
with  the  treated  commodity.   Persons
transferring or handling incompletely aerated
commodities must be informed of the presence
of phosphine and adequate measures must
be taken to prevent exposure to more than
0.3 ppm."

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