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Memorandum of Agreement Amending Aluminum and Magnesium Phosphide RED: Status Update
Concluding two years of extensive discussions with USDA and interested stakeholders, EPA and the registrants of pesticide fumigant products containing aluminum and magnesium phosphide, or phosphine, signed a Memorandum of Agreement in November 2000 to reduce risks to workers handling these pesticides and bystanders in the vicinity of applications. Under the agreement, registrants are developing additional data and information to better characterize risks to workers and bystanders. EPA will use these new data in the future to update the current risk mitigation measures, as necessary. In addition, product labels must be amended and submitted to the Agency by spring 2004 with cautions to protect applicators and bystanders.
The Memorandum of Agreement addresses many of the risk concerns that EPA identified in its December 1998 Reregistration Eligibility Decision (RED) for Aluminum and Magnesium Phosphide. These chemicals release highly toxic phosphine gas when they react with moisture in the atmosphere. Aluminum and magnesium phosphide are used widely to control insects and rodents in facilities where raw agricultural commodities and processed foods are stored. Few viable pesticide alternatives are available for these vital agricultural uses.
Provisions of the Agreement
The Memorandum of Agreement regarding phosphine-based fumigants contains the following major provisions:
- Fumigation Management Plans... Site-specific fumigation management plans are being required prior to application. Safety measures, emergency procedures, and monitoring, as well as an evaluation of the suitability of the site for fumigation, are required. Guidelines for the fumigation management plans will be included in the Applicator's Manual, currently under development.
- Incident Reporting... Registrants have submitted their two-year incident report summaries, and the Agency is in the process of reviewing these reports. Depending on the results of this review, further reporting may be required.
- Monitoring Studies...Protocols and feasibility studies have been completed by the registrants, and the fumigant exposure monitoring studies are underway. These studies will measure exposures to fumigators, aerators, and bystanders and determine the rate of decay/ dissipation of phosphine at varying distances from fumigated sites.
- Worker Exposure Limits... EPA is reviewing the registrants' science-based literature assessment to determine whether the current worker exposure standards for phosphine should be lowered.
- Training and Certification... The registrants will work with EPA, USDA, academia, the States, and the user community in developing training modules and examination questions that can be used by the States in their applicator Certification and Training programs. The guidance prepared by registrants to assist users in developing fumigation management plans will be incorporated into the States' C&T training modules.
- Other Label Modifications... In spring 2004, product labeling must be submitted with the following amendments:
- Prohibit in-transit aeration;
- Provide specific instructions on when a certified applicator must be present;
- Enhance notification of receivers of fumigated rail cars and other containers;
- Impose a two-person rule for fumigations requiring entry into a structure; and
- Provide safety material to residents having burrows treated.
Stakeholder Involvement
In considering mitigation approaches, EPA consulted with USDA and the Phosphine Task Force, which was commissioned by USDA to discuss fumigant uses and risks and explore measures to mitigate those risks. The Agency consulted with States and Tribes through SFIREG, the State FIFRA Issues Research and Evaluation Group, and through conference calls with interested States. EPA and USDA also worked with the Phosphine Coalition, a broad-based group consisting of over 80 registrants, fumigation companies, trade organizations, and users who came together to address issues related to reregistration of phosphine fumigants.
For More Information
For information on the Aluminum and Magnesium Phosphide RED and the status of the Memorandum of Agreement, please contact Mark Hartman, Branch Chief, Special Review and Reregistration Division (7508C), Office of Pesticide Programs, US EPA, Ariel Rios Building, 1200 Pennsylvania Ave., NW, Washington, DC 20460-0001; telephone 703 308-0734; email hartman.mark@epa.gov.
For general information about EPA's pesticide regulatory programs, please contact:
Communications Services Branch
Office of Pesticide Programs (7506C)
US Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460-0001
Telephone: 703-305-5017