Department of Pesticide Regulation

SULFURYL FLUORIDE LABEL INTERPRETATION

There are currently three Sulfuryl Fluoride (SF) products registered in California for structural fumigation. Given the high toxicity of sulfuryl fluoride it is important that "directions for use" are clear and consistent.

This letter addresses some of the labeling differences between structural sulfuryl fluoride products registered for use in California, including a recent change in one product's labeling regarding the handling of dental hygiene and other specific products prior to the fumigation of a structure. That product's labeling specifically allows dental hygiene products, cosmetics including lipstick, externally applied lotions and ointments, ice and water to remain in a structure during a fumigation.

The Department of Pesticide Regulation (DPR) in its Enforcement Letter 2005-05 defined toothpaste, mouthwash, and other dental hygiene products entering the mouth as a drug or medicinal. Drugs and medicinals are required to be removed or double-bagged prior to fumigation of a structure.

Therefore, unless the labeling specifies an exemption, fumigators will still be required to follow the directive of Enforcement Letter 2005-05 regarding the handling of dental hygiene products.

Please review the enclosure "Sulfuryl Fluoride Labeling Interpretation" for specifics on the handling of dental hygiene products, and key differences between the three SF products.

If you have any questions, please contact the Enforcement Branch Liaison assigned to your county.

cc:  Ms. Kelli Okuma, Executive Director, Structural Pest Control Board
       Mr. Tom Babb, DPR Agricultural Commissioner Liaison
       Enforcement Branch Liaisons