Huguenot Fumigation Management Plan

The Huguenot Laboratories trained applicator is responsible for working with the owners and/or responsible
employees of the site to be fumigated to develop a site specific Huguenot Fumigation Management Plan (HFMP) for each site that will be treated with vHP. The applicator is responsible for all tasks of the fumigation process unless otherwise noted in the HFMP and must be on site for the entire fumigation treatment process. The HFMP must address characterization of the site, and include appropriate monitoring and notification requirements, consistent with, but not limited to, the following:

1. Inspect the structure and or area to determine its suitability for fumigation.
2. When sealing is required, consult previous records for any changes to the structure, seal leaks, and monitor any occupied adjacent rooms and/or buildings to ensure safety.
3. Prior to each fumigation, review any existing HFMP, SDS, Equipment Manual and other relevant safety
procedures with company officials and appropriate employees.
4. Consult with company officials in the development of procedures and appropriate safety measures for nearby workers who will be in and around the area during application and aeration.
5. Consult with company officials to develop an appropriate monitoring plan that will confirm that nearby workers and bystanders are not exposed to levels above the allowed limits during application, fumigation and aeration. This plan must also demonstrate that nearby residents will not be exposed to concentrations above the allowable limits.
6. Consult with owners and or responsible employees at the site who will be responsible for development of
procedures for local authorities to notify nearby residents in the event of an emergency.
7. Confirm the placement of placards to secure entrance into any area under fumigation.
8. Confirm the required safety equipment is in place and the necessary manpower is available to complete
fumigation.

These factors must be considered in putting a HFMP together. It is important to note that some plans will be more comprehensive than others. All plans should reflect the experience and expertise of the applicator and circumstances at and around the structure and/or area.

In addition to the plan, the applicator must read the entire label and equipment manual and follow all directions
carefully. If the applicator has any questions about the development of an HFMP, contact Huguenot Laboratories for further assistance. An HFMP must be developed for each treated site. In the event of an emergency application, a generic HFMP which can be updated may be used and updated after fumigation. The Huguenot Laboratories trained applicator must sign the plan indicating it was followed. The signed HFMP and related documentation, including monitoring records, should be maintained by the applicator for a minimum of 2 years and a copy provided to the owner of the treated site.

GUIDANCE FOR PREPARATION OF A FUMIGATION MANAGEMENT PLAN

A Huguenot Fumigation Management Plan (HFMP) is an organized, written description of the required steps involved to help ensure effective fumigation. It will also assist you and others in complying with labeling requirements. The guidance that follows is designed to help assist you in addressing all the necessary factors involved in preparing for and fumigating a structure and/or area.

This guidance is intended to help you plan any fumigation that you might perform PRIOR TO ACTUAL
TREATMENT. It is meant to be somewhat prescriptive, yet flexible enough to allow the experience and
expertise of the fumigator to make changes based on circumstances that may exist in the field. By following a
step-by-step procedure, yet allowing for flexibility, an effective fumigation can be performed.

Before any fumigation begins, carefully read and review the label and the Equipment Manual. This information
must also be given to the appropriate company officials (supervisors, foreman, safety officer, etc.) in charge of
the structure and/or area. Preparation is the key to any successful fumigation. If the type of fumigation that you
are to perform is not listed in this Guidance Document you will want to construct a similar set of procedures.

Finally, before any fumigation begins you must be familiar with and comply with all applicable state and local
laws. The success of the fumigation is not only dependent on your ability to do your job but also upon carefully
following all rules, regulations, and procedures required by governmental agencies.