So what on earth IS happening to phosphine fumigation? Part 1
So what on earth IS happening to phosphine fumigation?
The times they are
a'changing. Phosphine fumigation restrictions are in full force. I would
like to spend a few choice paragraphs giving you the updates, the 'whys
and the hows' of food fumigation
There have been some massive changes in pest control recently and fumigation hasn’t been immune. The changes to our sector have been fundamental and it puts ever more emphasis on your fumigators really knowing their onions.
Phosphine is a toxic gas used regularly in food production to fumigate raw food ingredients such as cereals, beans, nuts and oilseeds. This not only safely lengthens the time that these products can be stored for but also kills off any insect infestations that might have been picked up during storage.
Phosphine can be used in any stage of manufacture- on farm, at the storage facility, during transport, at the food factory, in the distribution warehouse.
This is the product we always reach for when we want some penetrative insecticidal action going on. Only a handful of companies in the UK are qualified to use it and we, here at Dealey, are adept at using it safely on pretty much anything.
Lately, there have been some big changes to the Label Wording of phosphine. (For those not in the know, Label Wording isn't just instructions, it is written law on how you use insecticides. Do anything except follow the label exactly, and you are breaking the law.)
The latest change has come from BAuA in Germany. That’s the Bundesanstalt für Arbeitsschutz und Arbeitsmedizin which, of course, you know means ‘The Federal Institute of Occupational Safety and Health’ (basically the German version of the HSE).
Because the gas has always been considered as non-residual, it has always been treated with an attitude of commonplace acceptance within the global food supply chain. You see, the ability of the phosphine particle (PH3) to bind onto stuff is pretty limited except through a fairly sticky electrostatic bond.
But one day, someone in BAuA said (and I'm imagining this conversation, by the way)
Anyway, the regulatory bodies have decided to err on the side of caution until some independent scientific studies have been carried out and ratified. All of the points require a fair amount of explaination, so I'll be rolling these out one by one over the next week or so.
Some of the changes make good sense.. Some of them are scientifically iffy. You see if you can guess which are which.
This means that once a heap of grain or a silo full of beans has been fumigated and cleared, it must not be fumigated again.
This seems perfectly reasonable until you consider that there is no residual action from phosphine so, once the gas is gone, insects are free to roam back into the, now clean, product to re-infest it. This has led many food manufacturers to tactically time their fumigations to be at the last possible moment before processing, to avoid any chances of re-infestation. Product damage up to that point has to be limited in other ways (I'm not telling you what they are here, you'll have to call my office)
So you cannot fumigate a job-lot of product which has a clearance certificate attached to any of the loads mixed in.
This means that weighbridges will have to be absolutely stringent in their stewardship of products, keeping a record of any clearance certificates that come through the gates and recording where that product ends up.
Now some of these "any origin" exports have to be transported under fumigation as a contractual condition of sale. So, how to get around this? If your are complying with the spirit of the law, you should be turning away any previously fumigated loads. Does that sound like good business to you? No, me neither, but it is technically accurate.
Now if you are exporting outside of the EU then it must be mentioned that the restriction of "one batch" only applies to the EU so, you'll likely be fine. But, if you are exporting into the EU, you are really sailing close to the wind if anyone notices a 'doubled up' fumigation.
So, what is clear here is that the methods of food production, transportation, storage and export haven't really been taken into consideration when writing the new regulations. But this rule will stand until the boffins in Germany tell us what they have come up with later in 2018 or maybe 2019, and then it's just a quick 16 weeks while the authorities deliberate over it, and then it's just a few more weeks while they roll it out across the continent and a few more while the distributors change the labels...
We have come up with several novel ways of working around the restrictions, necessity being the mother of invention and all that. It has been a testing time but we have pulled together our mighty knowledge as a team and we are still fighting the good fight against infesting insects, keeping food safe.
If any of this is unclear, feel free to give me a buzz on 01359 269 713. Always happy to talk it through. I've also put together a little training course which goes through the ins and outs of phosphine awareness. Call us and have a chat.
There have been some massive changes in pest control recently and fumigation hasn’t been immune. The changes to our sector have been fundamental and it puts ever more emphasis on your fumigators really knowing their onions.
Phosphine is a toxic gas used regularly in food production to fumigate raw food ingredients such as cereals, beans, nuts and oilseeds. This not only safely lengthens the time that these products can be stored for but also kills off any insect infestations that might have been picked up during storage.
Phosphine can be used in any stage of manufacture- on farm, at the storage facility, during transport, at the food factory, in the distribution warehouse.
This is the product we always reach for when we want some penetrative insecticidal action going on. Only a handful of companies in the UK are qualified to use it and we, here at Dealey, are adept at using it safely on pretty much anything.
Lately, there have been some big changes to the Label Wording of phosphine. (For those not in the know, Label Wording isn't just instructions, it is written law on how you use insecticides. Do anything except follow the label exactly, and you are breaking the law.)
The latest change has come from BAuA in Germany. That’s the Bundesanstalt für Arbeitsschutz und Arbeitsmedizin which, of course, you know means ‘The Federal Institute of Occupational Safety and Health’ (basically the German version of the HSE).
Because the gas has always been considered as non-residual, it has always been treated with an attitude of commonplace acceptance within the global food supply chain. You see, the ability of the phosphine particle (PH3) to bind onto stuff is pretty limited except through a fairly sticky electrostatic bond.
But one day, someone in BAuA said (and I'm imagining this conversation, by the way)
To which the manufacturers (also German) replied,"Where is the proof that this is a non-residual gas?"
"Well if you know your chemistry, you know that what you are asking makes no sense."
So the BAuA guy said "Prove it then!"
And the manufacturer said, "you're asking me to prove a negative, do you think that's good science?"
and the BAuA guy said "Go on, give it a go."Now, I'm not sure if the conversation actually went like that or whether it was actually a protracted and tedious exchange of regulatory minutiae costing thousands of Euros of someone else's money, who's to say?
Anyway, the regulatory bodies have decided to err on the side of caution until some independent scientific studies have been carried out and ratified. All of the points require a fair amount of explaination, so I'll be rolling these out one by one over the next week or so.
Some of the changes make good sense.. Some of them are scientifically iffy. You see if you can guess which are which.
- Phosphine can only be used once "per batch." This is the whopper.
This means that once a heap of grain or a silo full of beans has been fumigated and cleared, it must not be fumigated again.
This seems perfectly reasonable until you consider that there is no residual action from phosphine so, once the gas is gone, insects are free to roam back into the, now clean, product to re-infest it. This has led many food manufacturers to tactically time their fumigations to be at the last possible moment before processing, to avoid any chances of re-infestation. Product damage up to that point has to be limited in other ways (I'm not telling you what they are here, you'll have to call my office)
Look, we have to take this in the spirit with which it is intended. If you were to fumigate that larger batch you would be fumigating some of that product twice. No es bueno.But what if a heap of grain is fumigated (on a farm, say) and then is mixed with a much larger batch, what then?
So you cannot fumigate a job-lot of product which has a clearance certificate attached to any of the loads mixed in.
This means that weighbridges will have to be absolutely stringent in their stewardship of products, keeping a record of any clearance certificates that come through the gates and recording where that product ends up.
Strictly, if one single load (30 tonnes) of product that has a passport with a fumigation clearance certificate attached to it, is being moved onto a bulk ship (up to 50,000 tonnes) then that ship cannot be fumigated.What happens to exports, surely these can be gassed?"
Now some of these "any origin" exports have to be transported under fumigation as a contractual condition of sale. So, how to get around this? If your are complying with the spirit of the law, you should be turning away any previously fumigated loads. Does that sound like good business to you? No, me neither, but it is technically accurate.
Now if you are exporting outside of the EU then it must be mentioned that the restriction of "one batch" only applies to the EU so, you'll likely be fine. But, if you are exporting into the EU, you are really sailing close to the wind if anyone notices a 'doubled up' fumigation.
I'll be honest here, nobody knows. Is this still the same batch? You tell me what is meant by the word "batch" and we'll talk. We have asked for clarification on this point from HSE, CRD and BAuA and nobody has been prepared to offer an explanation.But what if raw product is fumigated before it gets to the factory? Does that mean that finished, processed product can't be gassed?
So, what is clear here is that the methods of food production, transportation, storage and export haven't really been taken into consideration when writing the new regulations. But this rule will stand until the boffins in Germany tell us what they have come up with later in 2018 or maybe 2019, and then it's just a quick 16 weeks while the authorities deliberate over it, and then it's just a few more weeks while they roll it out across the continent and a few more while the distributors change the labels...
We have come up with several novel ways of working around the restrictions, necessity being the mother of invention and all that. It has been a testing time but we have pulled together our mighty knowledge as a team and we are still fighting the good fight against infesting insects, keeping food safe.
If any of this is unclear, feel free to give me a buzz on 01359 269 713. Always happy to talk it through. I've also put together a little training course which goes through the ins and outs of phosphine awareness. Call us and have a chat.
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