Health, safety & legislation articles for pest control

19 September 2017

Important Label and Use Changes for Aluminium Phosphide Products

The Register of Accredited Metallic Phosphide Standards in the United Kingdom (RAMPS UK) has issued label and use changes for Aluminium Phosphide products.

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RAMPS UK point out that over the past few years the regulatory framework for pesticides and biocides has changed dramatically as active substances have gone through their various review programmes. An issue identified was that in rare circumstances, a product could find itself falling under ‘multiple sets of separate regulatory rules with different outcomes emerging at different times’. The issue does present challenges to the implementation of newly labelled stock of these products.

As part of the tag label updates, a RAMPS UK bulletin said:

"An example of this is the supply of Aluminium phosphide used for invertebrate fumigation and mammalian vertebrate pest control. These products fall under both the Plant Protection Product regulations and the Biocidal Product regulations. A simple definition to explain the difference between the two product uses is as follows:

  •     Plant Protection Products are pesticides used for the protection of crops or other plants both in the field and after harvest but before processing
  •     Biocidal Products are products that are used for the control of harmful organisms for reasons other than crop protection
  •     Because metal phosphides fall under both use categories they have to carry the requirements and instructions from both sets of legislation for very similar uses"

Aluminium Phosphide Products

In the update, RAMPS UK stated:

"In order to be able to quickly issue any changes in the way these products are to be used, and with the agreement of HSE, RAMPS UK have endorsed a temporary method of ‘tagging’ the new label instructions onto products to provide updated information."

This has meant the end- users have been made aware of any changes as soon as possible. It is with a view to introducing the latest BPR Biocidal Product Authorisations that another update is required to these ‘Tag Labels’, so that end-users can again be made aware of changes at the earliest opportunity. It is planned that this temporary “tagging” measure will cease once all of the new product authorisations have been granted and newly labelled stock can then be put into production. In the meantime, RAMPS UK urges all stockists and end-users to note the new requirements on the tag labels.

BPCA Fumigation and Controlled Environments (FaCE) Forum Chair, Martin Cobbald said:

“The product manufacturers have done an excellent job to ensure we can continue to use this product for fumigation for biocidal and plant protection uses. However, the FaCE forum along with the product manufacturers have identified a number of points that do need clarification. We will continue to monitor the situation closely and report back to the membership when necessary.”

“These labels do the remarkable job of combining BPR and PPP regulations in one hit, but the result is complicated. Members are urged to read the labels really carefully to ensure correct use.”

RAMPS UK has also released additional gas monitoring requirements used for invertebrate fumigation

The new requirements have been implemented to a new level of 0.01 ppm for phosphine clearance and are required for all metallic phosphides used for invertebrate fumigation in the EU, whether for food or feed applications (as a Plant Protection Product) or as a Biocide.

RAMPS UK highlights the following phrases now applicable to all fumigation services using these materials;

  1. Engineering control of operator exposure must be used where reasonably practicable in addition to the following personal protective equipment.* Operator must wear suitable protective clothing (coveralls) suitable protective gloves and suitable protective equipment when applying the product and re-entering treated areas before the phosphine gas air concentration is below 0.01ppm. (Full face) mask to at least EN 140 with a combination filter to at least EN 14387 B2P3, or equivalent.
  2.  Keep all persons and animals out of the fumigation area and the adjacent areas into which gas might penetrate. Unprotected persons must be kept out of the treated areas until the phosphine concentration has fallen below the TLV of 0.01 ppm. There must be an airing-off period until the gas levels drop below the TLV of 0.01 ppm.
  3. As a result of these new gas monitoring requirements, RAMPS UK are encouraging all users of Aluminium phosphide to seek advice from their stockist as to the most suitable monitoring equipment to use.

Bulletin 10: Important label and use changes for aluminium phosphide products

Ramps UK August 2017 177 Kb Download
Bulletin 11: New gas monitoring requirements Ramps UK August 2017 97 Kb Download

This press release was issued by The Register of Accredited Metallic Phosphide Standards in the United Kingdom (RAMPS UK).

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