Checklist Guide for a Fumigation Management Plan

This checklist is provided to help you take into account factors that must be addressed prior to performing all
fumigations. It emphasizes safety steps to protect people and property. The checklist is general in nature and
cannot be expected to apply to all types of fumigation situations. It is to be used as a guide to prepare the
required plan. Each item must be considered, however, it is understood that each fumigation is different and not all items will be necessary for each fumigation structure and/or area.

A. PLANNING AND PREPARATION

• Determine the purpose of the fumigation.
  • TREATMENT of room enclosures
  • TREATMENT of emergency vehicles.
• Determine the type of fumigation, for example:
  • Pharmaceutical operations, clean rooms, medical device TREATMENT manufacturing
  • Laboratories, animal research facilities
  • Patient rooms, hotel rooms, school rooms, offices, recreational facilities.
  • Cruise ship rooms, In addition to the Equipment Manual, read the US Coast Guard Regulations 46CFR 147A.
  • Subways, airports, bus lines.
• Evaluate the structure or area to be fumigated, and develop a site-specific plan that includes the following points, as applicable:
  • Fire alarms and fire sprinklers! The vapor generated at effective concentrations has the ability to trigger fire alarms. Appropriate fire marshal and fire safety personnel should be on-site during the treatment application.
  • The general structure layout, construction (materials, design, age, maintenance, of the structure, fire or combustibility hazards, connecting structures and escape routes, above and below ground, and other unique hazards or structure characteristics. Meet with the owner/operator/person in charge. Draw or have a drawing or sketch of structure to be fumigated, delineating features, hazards, and other structural issues.
  • The need for buffer zones in rooms adjacent to the treated enclosure to limit access to only trained applicators. This would include adjacent rooms that could be occupied when using vHP in areas such as hotel rooms, patient rooms or offices. Additional consideration should also be given to adjacent rooms above or below the enclosure if the structure does not consist of solid construction (i.e. Floors/walls adjacent to the enclosure) that would preclude exposure if the treated enclosure was not properly sealed.
  • The number and identification of persons who routinely enter the area to be fumigated (i.e., Employees, visitors, customers, etc.).
  • Accessibility of utility service connections.
  • Nearest telephone or other means of communication, and mark the location of these items on the drawing/sketch.
  • Emergency shut-off stations for electricity water and gas. Mark the location of these items on the drawing/sketch.
  • Current emergency telephone numbers of local Health, Fire, Police, Hospital and Physician responders.
  • Name and phone number (both day and night) of appropriate company officials.
  • Checkmark and prepare the points of fumigation application.
  • Review labeling and Equipment Manual.
• Exposure time considerations.
  • Specific fumigant to be used.
  • Minimum fumigation period, as defined and described by the label use directions.
  • Down time required to be available.
  • Aeration requirements
• Determination of dosage.
  • Cubic footage or other appropriate space/location calculations.
  • Structure sealing capability and methods.
  • Label directions.
  • Past history of fumigation of structure
  • Exposure time.

B. PERSONNEL

• Confirm in writing that all personnel in and around the area to be fumigated have been notified prior to application of the fumigant. Consider using a checklist that each employee initials indicating they have been notified.
• Instruct all fumigation personnel about the hazards that may be encountered; and about the selection of personal protection devices, including detection equipment.
• Confirm that all personnel are aware of and know how to proceed in case of an emergency situation.
• Instruct all personnel on how to report any accident and/or incidents related to fumigant exposure.
• Provide a telephone number for emergency response reporting.
• Instruct all personnel to report to proper authorities any theft of fumigant and/or equipment related to fumigation.
• Establish a meeting area for all personnel in case of emergency.
• Confirm that all applicators have been trained in the use of BioClean vHP Hydrogen Peroxide Biostat and are in good standing including the required refresher training.
• Develop a Worker Health and Safety Plan as required by OSHA for applicators. The owner/operators of the facility being treated should have a Worker Health and Safety Plan as required by OSHA developed for their employees located within close proximity of the application process.

C. MONITORING

• Perimeter Safety
  • Calculation of of hydrogen peroxide concentrations must be conducted immediately adjacent to the fumigated space to prevent excessive exposure and to determine where exposure may occur. Document where monitoring will occur.
  • Keep a log or manual of monitoring records for each fumigation site. This log must at a minimum contain the timing, and target level of concentrations found in each location.
  • If monitoring for leaks is required, document there is no hydrogen peroxide present above the one ppm levels. Subsequent leak monitoring is not routinely required. However spot checks may be made, especially if conditions significantly change.
  • Monitoring must be conducted during aeration and corrective action taken if gas levels exceed the allowed levels in an area where bystanders and/or nearby residents may be exposed. 1-ppm maximum at end of aeration cycle.
• Efficacy –
  • Hydrogen peroxide readings should be taken from within the fumigated structure to ensure proper vapor concentrations. This can be safely achieved outside the structure through the use of a remote sensor reading.
  • All reading of hydrogen peroxide concentration, temperature and relative humidity must be documented.

D. NOTIFICATION

• Confirm that all appropriate local authorities (fire departments, police departments, etc.) have been notified as per label instructions, local ordinances if applicable, or instructions of the client.
• Prepare written procedure (“Emergency Response Plan”) which contains explicit instructions, names, and telephone numbers so as to be able to notify local authorities if hydrogen peroxide levels are exceeded in an area that could be dangerous to bystanders and/or domestic animals.
• In the event of a breach or leak of the enclosure where levels of hydrogen peroxide are above one ppm in adjacent areas to the enclosure, abort the application process and initiate the aeration process in the sealed enclosure. Ensure that the adjacent areas where levels have exceeded one ppm are evacuated by general personnel and that proper respiratory protection is utilized by applicators that enter the area. Continue monitoring the area until levels are below one ppm hydrogen peroxide. The treated enclosure and adjacent areas must remain unoccupied until hydrogen peroxide levels are at or below one ppm. Early reentry into the sealed treated enclosure at use concentration levels in the case of an emergency requires wearing a Self Contained Breathing Apparatus (SCBA) operated in pressure-demand mode, full hydrogen peroxide resistant body suit, gloves and boots to protect from the inhalation hazard as well as the corrosive action of hydrogen peroxide to tissues.

E. SEALING PROCEDURES (WHEN APPROPRIATE)

• Sealing must be adequate to prevent any leaks. Care should be taken to ensure that sealing materials will remain intact until the fumigation is complete. Verify effectiveness of the sealing process by conducting a smoke stick test to ensure there are no leaks where openings have been sealed in the enclosure.
• If the structure and/or area has been fumigated before, review the previous HFMP for previous sealing information.
• Make sure that construction/remodeling has not changed the building in a manner that will affect the fumigation.
• Warning placards must be placed on every possible entrance to the fumigation site.

F. APPLICATION PROCEDURES & FUMIGATION PERIOD

• Plan carefully and apply all fumigants in accordance with the label requirements.
• When entering into the area under fumigation always work with two or more people under the direct supervision of a trained applicator wearing appropriate respirators.
• Apply fumigant from outside the fumigation space (when possible).
• Provide watchmen when a fumigation site cannot otherwise be made secure from entry by unauthorized persons.
• When entering structures always follow OSHA rules for confined spaces.
• The applicator should verify compatibility of item surfaces to be treated prior to the application process.

G. POST-APPLICATION OPERATIONS

• Provide watchmen when you cannot secure the fumigation site from entry by unauthorized persons during the aeration process.
• Ventilate and aerate in accordance with structural limitations.
• Turn on ventilating or aerating fans where appropriate.
• Use a suitable vHP detector before reentry to determine fumigant concentration is less than 1-ppm.
• Keep written records of monitoring to document completion of aeration.
• Consider temperature when aerating.
• Ensure aeration is complete before moving vehicle into public roads.
• Remove warning placards when aeration is complete.
• Inform business/client that employees/other persons may return to work or otherwise be allowed to reenter the aerated structure.

H. CRITERIA FOR SUCCESSFUL FUMIGATION

• All vHP fumigation process conditions (vapor concentration, temperature, relative humidity) are achieved throughout the fumigation cycle.
• All CIs that are properly recovered and evaluated exhibit a visible color change following exposure to vHP.
• All Bis that are properly recovered (no breach of aseptic technique) are negative for growth*.

I. TRAINING AND CERTIFICATION OF APPLICATORS

• Prior to use, applicators must be adequately trained and certified by Huguenot Laboratories on the hazards and label directions for BioClean vHP Hydrogen Peroxide, on the use and operation of the vHP application equipment, hydrogen peroxide monitoring procedures and when appropriate, validation procedures.