3.6 Utah Minimum Standards for Fumigant Applications (R68-7-18)
Key Takeaways
- A written Fumigation Management Plan is required in advance whenever the label calls for one, and it must supply the details the label prescribes.
- At least two people must be present when the fumigant is released and during initial ventilation, one of whom is a certified applicator with the fumigation category.
- Occupied dwellings or businesses within 100 feet must be notified in writing in advance, and premises within 10 feet must be vacated during fumigation and aeration.
- Warning signs must be at least 8.5 by 11 inches, in a bright conspicuous color, showing the word POISON, the skull and crossbones, the fumigant name, and the applicator's name, address, and phone.
- Only the certified applicator may re-enter first, and only after personally verifying with a gas mask and an appropriate chemical test that the space is safe.
3.6 Utah Minimum Standards for Fumigant Applications (R68-7-18)
Fumigants are gases. They move through cracks, wall voids, and soil; they reach every part of an enclosed space; and they give no reliable warning at dangerous concentrations. Utah reflects that risk in two places: fumigation is its own certification category — R68-7-7(13) with subcategories for (a) Stored Commodities, (b) Structural, and (c) Soil — and R68-7-18 imposes state minimum standards on top of the label. Failing to perform fumigations to those standards is an unlawful act under R68-7-20(25).
Even applicators who will never hold the fumigation category see this material on the core exam, because it illustrates label-driven planning, notification duties, and respiratory protection at their strictest.
1. The Fumigation Management Plan (FMP)
Fumigant applications require strict adherence to the label, and when the label requires it, a verified, written Fumigation Management Plan must be prepared in advance of the treatment. The FMP provides the details the label prescribes — it is not a generic form, and writing it after the fact defeats its purpose.
2. Utah Standards for Fumigating Occupiable Space
When the space to be fumigated can be occupied by a person or non-target species, R68-7-18(1) requires:
| Standard | Requirement |
|---|---|
| Two-person rule | At least two persons present at the time the fumigant is released and during initial ventilation; one must be a certified applicator holding the fumigation category. In the interim the premises must be adequately safeguarded against entry by anyone else |
| First-responder notification | Notify the local fire department or first responder before fumigating any building or enclosed space other than a fumigating vault, giving the address, the time of gas release, the kind of gas, and the beginning time of aeration |
| Sealing | The premises must be sealed so the fumigant is confined to the space intended to be fumigated |
| Pre-release inspection | Immediately before release, the certified applicator conducts a thorough inspection to verify no person or non-target animal remains and that precautions for neighboring buildings are in place |
| Apartment fumigation | Units in a multiple-unit building may be fumigated only after being vacated and properly sealed; adjacent units must be properly ventilated during the entire exposure period |
| Notification radius | Dwellings or places of business within 100 feet of the building being fumigated must be notified in writing in advance |
| Evacuation radius | Premises within 10 feet must be vacated during the fumigation and aeration periods |
Warning Signs
Signs must be posted conspicuously at the entrances of the premises to be fumigated and at the entrances of adjacent multiple units and structures within ten feet, and kept there for the entire fumigation and ventilation period. Each sign must be:
- in a bright and conspicuous color;
- a minimum of 8 1/2 inches by 11 inches;
- bearing the word "poison";
- displaying the skull and crossbones;
- naming the fumigant used; and
- giving the name, address, and telephone number of the certified applicator.
Before the fumigant is released, entrances leading directly to the fumigated space must be closed, sealed, and locked, except the exits used by the fumigating crew — and those are closed, sealed, and locked promptly after release.
Respiratory Protection
Each member of the fumigating crew must be equipped with a serviceable mask of a type approved by the U.S. Mine Safety and Health Administration, with the correct canister for the type of gas used. Masks must be worn while in the enclosed space during and after release, and until initial ventilation is complete.
Re-Entry Clearance
No one other than the certified applicator may re-enter until the certified applicator has personally inspected the space, wearing a gas mask and using an appropriate chemical test, and determined the premises are safe for occupancy. Aeration is conducted according to the labeling, and re-entry is allowed at the levels the label specifies. This is the exam's key point: clearance is a measurement, not a waiting period.
3. Spot and Outdoor Fumigations
Subsections (1)(a) through (1)(i) may not apply to fumigants used to control pests outside buildings, to spot fumigations, or to restrictive treatments inside a building such as grain bins. Three conditions still attach:
- Strict adherence to label instructions.
- During the ventilation period of a spot or restrictive fumigation, the premises shall not be occupied by anyone except the certified applicator.
- A warning gas is recommended where the fumigant is comparatively odorless.
4. Burrowing Rodent Fumigation
Fumigating burrowing rodents requires strict label adherence and an FMP containing:
- the purpose of the application, naming the exact pest and the type of burrow system;
- the pesticide name, EPA registration number, and dosage used;
- the property or facility name and address, with the manager's or owner's name and contact information;
- the certified applicator's name, company, license number, and phone numbers, verified with government-issued identification;
- emergency contacts — nearest hospital, fire department, police department, poison control center, and the registrant of the fumigant; and
- written signatures verifying that personnel were instructed to report exposure accidents and incidents with an emergency phone number, report theft of fumigant or fumigation equipment to the proper authorities, and follow label directions with particular attention to the Monitoring, Notification, Sealing, Application Procedures, Fumigation Period, and Use Restrictions sections.
Recordkeeping goes beyond the ordinary rules: in addition to the requirements in R68-7-11 and R68-7-12, the applicator must keep a scaled diagram of the property showing its dimensions, any structures present, and each burrow treated marked on the diagram.
5. The Related Termiticide Record Rule
A parallel drafting requirement applies to termite work under R68-7-17: the applicator must retain a diagram of the structure treated, including its dimensions and the depth to the footer the foundation rests on. For post-construction treatments the diagram must also show where termites or termite activity were found. Records are kept two years and organized separately for each individual structure. If a termiticide distribution system is used, it must meet the label's standards and be permitted by the label and manufacturer — and if the label does not mention such a system, one may not be used.
Under R68-7-18, who must be present when a fumigant is released into an occupiable structure in Utah?
A structural fumigation is planned in a Utah neighborhood. What do the 100-foot and 10-foot distances in R68-7-18 require?
After the aeration period, when may workers other than the certified applicator re-enter a fumigated structure?
Which additional record must a Utah applicator keep for a burrowing-rodent fumigation beyond the ordinary application records?