Sulfuryl Fluoride Shipping Container Fumigation Requirements
This provides updates on sulfuryl fluoride fumigations of goods in shipping containers to Australia and New Zealand for the invasive species Brown Marmorated Stink Bug (BMSB, Halyomorpha halys). Current approved treatment measures for shipments of goods to these countries are heat, methyl bromide, and sulfuryl fluoride.
To meet these requirements, some businesses fumigate shipping containers with Vikane (EPA Registration No. 1015-78-AA) as allowed by the registered labeling. It was recently brought to our attention that certified applicators might be experiencing difficulty using the Vikane Fumiguide (the dosage calculator), since the Vikane product is more often used in structures and primarily for tarped structures. The use of this product for an agricultural pest in taped and sealed shipping containers is less common.
Label Requirements for Dose Calculation
As with any registered labeling, the label is the law. The current Vikane label includes the Structural Fumigation Manual as part of its labeling, which states on page 25:
The Vikane Fumiguide is used for all fumigations using Vikane. The Vikane Fumiguide is part of the labeling for this product and must be used to calculate the dose to apply.
This means that fumigators cannot use surrogate pest or other dose calculation equipment in place of the Vikane Fumiguide equipment required by the labeling. Use in conflict with the labeling would be a violation of Food and Agricultural Code (FAC) section 12973 (conflict with labeling). It is the user’s responsibility to comply with labeling requirements.
Licensing Requirements
BMSB is an agricultural pest that feeds on, and can severely damage, fruit and vegetable crops. Although BMSB adults may overwinter in a structure, such as a shipping container, they will not reproduce or cause damage inside these structures. The intent and purpose of these fumigations is to control an agricultural pest before it can be introduced into Australia and New Zealand and cause damage to their agricultural economies and unique environments.
After careful review and consideration of both FAC Division 6 and Business and Professions Code Division 3 Chapter 14, the Department of Pesticide Regulation (DPR) has determined fumigations with sulfuryl fluoride on labeled sites to control BMSB, an agricultural pest, must be conducted by a DPR-licensed pest control business. Fumigation work to control this agricultural pest cannot be done under a company registration or individual license issued by the Structural Pest Control Board.
If you have questions, please contact the Enforcement Branch Liaison assigned to your county.
Sincerely,