If you are a user of phosphide fumigants (such as Phostoxin and Fumitoxin) for any use including control of burrowing rodents such as prairie dogs, changes in product labeling will affect you.  Because of the human health risk posed by aluminum and magnesium phosphide fumigants, the EPA and product manufacturers have agreed to the requirement that all product labels now require anyone who fumigates to develop a written Fumigation Management Plan (FMP).  The FMP requirement is part of an agreement between EPA and the registrants made in 2000 that allowed these products to continue to be registered while assuring protections for users and other individuals near the application area.  Labels were amended in the Spring of 2004.  The certified applicator is responsible for assuring an FMP is completed, kept up to date, available for review, and followed.  This requirement is on the product label and specifies what should be included on the plan.  A written plan is necessary for each site to be fumigated, whether it is a structure, rail car, semi-trailer, grain silo or field.     

The FMP provides an organized description of steps required to help ensure a safe, legal, and effective fumigation.  It is in addition to the required application record.  Plans are  required to include: emergency and applicator contact information, training and notification of personnel, site logistics, application procedures and fumigation period, steps for sealing, posting, and monitoring of site, and after-fumigation procedures.  This represents a brief list.  For the full requirements and descriptions, consult the Applicator’s Manual that comes with the products.  This is part of the label and you are required to have one if you use the products. 

Prior to writing an FMP, carefully read and review both the label and the Applicator’s Manual for the fumigant product to be used.  Assemble and organize all of the information needed to develop the plan.  Preparation is the key to a successful and safe fumigation.  Once the FMP is written, a copy of this information must be given to the appropriate personnel at the site such as the landowner, foreman, driver, etc. 

Each fumigation is different for different sites, so not all items will be necessary to record for each site.  When retreating the same site, such as a field with prairie dogs, the same fumigation plan may be used, as long as it is updated with any changes or additional information. 

Templates are available to use for FMPs.  Most manufacturers have provided templates on their websites.  State agencies and extension programs also have made templates and additional information available.   See the suggested sites below. 

These pesticides are very valuable to many operations, but can pose serious risks if not used with care.  With good planning, you will avoid preventable accidents and dangerous situations when working with aluminum and magnesium phosphide.  

Please feel free to contact the main office or your area inspector at NMDA if you have any questions about developing fumigation management plans.

Links and Templates

Fumigation Management Plan templates for Burrowing Pests from NMDA or from Another source

Templates for structures, grain elevators, rail cars, etc.  Example 1, Example 2, or Example 3