In September of 2020, the US EPA released their Proposed Interim Registration Review Decision on Aluminum Phosphide, Magnesium Phosphide, and Phosphine. There is a 60-day comment period on this decision with a deadline of Tuesday, December 22, 2020.
In the review, the EPA has proposed mandatory buffer zones based on computer modeling. The proposed actions for phosphine and the metal phosphides would establish mandatory buffer zones around fumigation facilities into which bystanders may not enter during treatment or aeration of commodities post treatment. EPA is proposing a minimum of 10 feet for all fumigations and proposed buffers of 10 feet to 500 feet depending on application rate, facility, container size and other impacts of the fumigation procedures. These buffer zones could restrict your current uses of phosphine drastically, some to the point where you may no longer be able to use the fumigant.
How does this impact the almond industry? This decision impacts almonds, barley, grains, avocados, corn, cotton, lettuce, peanuts, pistachios, rice and more. Phosphine is a colorless gas used on commodities in storage and shipping to prevent losses due to insect and vertebrate (mainly rodent) pests. Phosphine is formulated as a pressurized gas stored in cylinders. It is the active component of the metal phosphides, released when pellets of metal phosphide interact with moisture in the air. Phosphine and metal phosphide products are registered for use on dried foods (e.g.: nuts, dried fruits, grains), on animal feed, and on processed foods (e.g.: candy, baking mixes, crackers, meats, dairy). Phosphine gas products are registered for use on non-food commodities, such as tobacco, clothing fibers, hair, wood, paper, tires, and beehives. Metal phosphide products are also registered for in-field (i.e.: greater than 100 feet from occupied buildings), in-burrow rodent control. Phosphine and the metal phosphides are applied as structural or space fumigants (e.g.: under tarps, in grain mills, in warehouses), vehicle fumigants (e.g.: railcars, trucks, containers), grain fumigants (e.g.: silos, farm storage, flat storage), and vessel/ship fumigants.
Data from California for the years 2013 to 2017 indicate that an average of 19,900 lbs phosphine, 160,600 lbs aluminum phosphide, and 13,200 lbs magnesium phosphide were applied annually in California. The applications for all three active ingredients (a.i.s) were made to nuts (6,900 lbs phosphine, 50,200 lbs aluminum phosphide, and 67,000 lbs magnesium phosphide). Structural use including storage facilities and processing equipment (14,900 lbs aluminum phosphide, 300 lbs magnesium phosphide) was also reported. The remaining usage data do not specify a specific commodity. Similar records of usage data are not required by other states and are not available.
Please take the time to read the below attachments and click the link to fill out the questionnaire which was developed by the manufacturer Degesch. This questionnaire should only take a few minutes to complete but is extremely valuable in responding to public comments and advocating on behalf of the industry. Time is of the essence, so we are asking for your assistance by November 30th.
Questionnaire: Click Here.
EPA Proposed Interim Registration Review Letter: Click Here.
Proposed Interim Registration Review Decision Case Document: Click Here.
Again, the industry has a deadline of December 22, 2020, to respond to the PID. Please complete your responses to the questionnaire by Monday, November 30, 2020.
Feel free to distribute this link within your organization or to others who may be able to provide feedback on the PID proposals.
If you have any questions, please call, Elaine Trevino at 209-300-7140 or Ed Hosoda at Cardinal Professional Products at 916-997-6045.
For additional information please go to the EPA website at the following link: http://www.epa.gov/pesticide-reevaluation.
