2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
COMMODITY
STORAGE
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
Methyl
Bromide
Technical
Options
Committee
(
MBTOC),
the
United
States
(
U.
S.)
has
organized
this
version
of
its
Critical
Use
Exemption
Nomination
in
a
manner
that
would
enable
a
holistic
review
of
relevant
information
by
each
individual
sector
team
reviewing
the
nomination
for
a
specific
crop
or
use.
As
a
consequence,
this
nomination
for
commodity
storage,
like
the
nomination
for
all
other
methyl
bromide
uses
included
in
the
U.
S.
request,
includes
general
background
information
that
the
U.
S.
believes
is
critical
to
enabling
review
of
our
nomination
in
a
manner
that
meets
the
requirements
of
the
Parties'
critical
use
decisions.
With
that
understanding,
the
fully
integrated
U.
S.
nomination
for
commodity
storage
follows.

2.
Background
In
1997,
the
Parties
to
the
Montreal
Protocol
adjusted
Article
2H
of
the
Protocol,
and
agreed
to
accelerate
the
reduction
in
the
controlled
production
and
consumption
of
methyl
bromide.
This
adjustment
included
a
provision
calling
for
a
phaseout
of
methyl
bromide
by
the
year
2005
"
save
to
the
extent
that
the
Parties
decide
to
permit
the
level
of
production
or
consumption
that
is
necessary
to
satisfy
uses
agreed
by
them
to
be
critical
uses."
At
the
same
time,
the
Parties
adopted
decision
IX/
6,
the
critical
use
exemption
decision,
which
laid
out
the
terms
under
which
critical
use
exemptions
under
Article
2H
would
be
granted.

3.
Criteria
for
Critical
Uses
under
the
Montreal
Protocol
In
crafting
Decision
IX/
6
outlining
the
criteria
for
a
critical
use
exemption,
the
Parties
recognized
the
significant
differences
between
methyl
bromide
uses
and
uses
of
other
ozone­
depleting
chemicals
previously
given
scrutiny
under
the
Protocol's
distinct
and
separate
Essential
Use
exemption
process.
The
U.
S.
believes
that
it
is
vitally
important
for
MBTOC
to
take
into
account
the
significant
differences
between
the
critical
use
exemption
and
the
essential
use
exemption
in
the
review
of
all
methyl
bromide
critical
use
nominations.

During
the
debate
leading
up
to
the
adoption
of
the
critical
use
exemption
Decision
IX/
6,
an
underlying
theme
voiced
by
many
countries
was
that
the
Parties
wanted
to
phase
out
methyl
bromide,
but
not
adversely
affect
agriculture.
This
theme
was
given
life
in
various
provisions
of
the
critical
use
exemption,
and
in
the
differences
in
approach
taken
between
the
critical
use
exemption
and
the
essential
use
exemption.
Those
differences
are
outlined
below.

The
Protocol's
negotiated
criteria
for
the
Critical
Use
Exemptions
for
methyl
bromide
are
much
different
from
the
criteria
negotiated
for
"
Essential
Uses"
for
other
chemicals.

Under
the
Essential
Use
provisions,
in
order
to
even
be
considered
for
an
exemption,
it
was
necessary
for
each
proposed
use
to
be
"
critical
for
health,
safety
or
the
functioning
of
society."
This
high
threshold
differs
significantly
from
the
criteria
established
for
the
methyl
bromide
Critical
Use
exemption.
Indeed,
for
methyl
bromide,
the
Parties
left
it
solely
to
the
nominating
governments
to
find
that
the
absence
of
methyl
bromide
would
create
a
significant
market
disruption.

For
the
U.
S.
nomination
for
commodity
storage,
following
detailed
technical
and
economic
review,
the
U.
S.
has
determined
that
some
use
of
methyl
bromide
in
commodity
storage
is
critical
to
ensuring
that
there
is
no
significant
market
disruption.
The
detailed
analysis
of
technical
and
economic
viability
of
the
alternatives
listed
by
TEAP
for
use
in
commodity
storage
is
discussed
later
in
this
nomination,
as
is
the
basis
for
the
U.
S.
estimate
of
the
amount
of
methyl
bromide
needed
within
this
sector.

In
the
case
of
methyl
bromide,
the
Parties
recognized
many
agricultural
fumigants
were
inherently
toxic,
and
therefore
there
was
a
strong
desire
not
to
replace
one
environmentally
problematic
chemical
with
another
even
more
damaging.

The
critical
use
exemption
language
explicitly
requires
that
an
alternative
should
not
only
be
technically
and
economically
feasible,
it
must
also
be
acceptable
from
the
standpoint
of
human
health
and
the
environment.
This
is
particularly
important
given
the
fact
that
most
chemical
alternatives
to
methyl
bromide
are
toxic
and
pose
some
risk
to
human
health
or
the
environment;
in
some
cases,
a
chemical
alternative
may
pose
risks
even
greater
than
methyl
bromide.

In
the
case
of
methyl
bromide,
the
Parties
recognized
that
evaluating,
commercializing
and
securing
national
approval
of
alternatives
and
substitutes
is
a
lengthy
process.

In
fact,
even
after
an
alternative
is
tested
and
found
to
work
against
some
pests
in
a
controlled
setting,
adequate
testing
in
large­
scale
commercial
operations
in
the
many
regions
of
the
U.
S.
can
take
many
years
before
the
viability
of
the
alternative
can
be
adequately
demonstrated.
In
addition,
the
process
of
securing
national
and
sub­
national
approval
of
the
use
of
alternatives
requires
extensive
analysis
of
environmental
consequences
and
risks
to
human
health.
The
average
time
for
the
national
review
of
scientific
information
in
support
of
a
new
pesticide,
starting
from
the
date
of
submission
to
registration,
is
approximately
38
months.
In
most
cases,
the
company
submitting
the
information
has
spent
approximately
7­
10
years
developing
the
toxicity
data
and
other
environmental
data
necessary
to
support
the
registration
request.

The
Parties
to
the
Protocol
recognized
that
unlike
other
chemicals
controlled
under
the
Montreal
Protocol,
the
use
of
methyl
bromide
and
available
alternatives
could
be
site
specific
and
must
take
into
account
the
particular
needs
of
the
user.

The
Essential
Use
exemption
largely
assumed
that
an
alternative
used
in
one
place
could,
if
approved
by
the
government,
be
used
everywhere.
Parties
clearly
understood
that
this
was
not
the
case
with
methyl
bromide
because
of
the
large
number
of
variables
involved,
such
as
crop
type,
soil
types,
pest
pressure
and
local
climate.
That
is
why
the
methyl
bromide
Critical
Use
exemption
calls
for
an
examination
of
the
feasibility
of
the
alternative
from
the
standpoint
of
the
user,
and
in
the
context
of
the
specific
circumstances
of
the
nomination,
including
use
and
geographic
location.
In
order
to
effectively
implement
this
last,
very
important
provision,
we
believe
it
is
critical
for
MBTOC
reviewers
to
understand
the
unique
nature
of
U.
S.
agriculture,
as
well
as
U.
S.
efforts
to
minimize
the
use
of
methyl
bromide,
to
research
alternatives,
and
to
register
alternatives
for
methyl
bromide.
4.
U.
S.
Consideration/
Preparation
of
the
Critical
Use
Exemption
for
Commodity
Storage
Work
on
the
U.
S.
critical
use
exemption
process
began
in
early
2001.
At
that
time,
the
U.
S.
Environmental
Protection
Agency
(
US
EPA)
initiated
open
meetings
with
stakeholders
both
to
inform
them
of
the
Protocol
requirements,
and
to
understand
the
issues
being
faced
in
researching
alternatives
to
methyl
bromide.
During
those
meetings,
which
were
attended
by
State
and
association
officials
representing
thousands
of
methyl
bromide
users,
the
provisions
of
the
critical
use
exemption
Decision
IX/
6
were
reviewed
in
detail,
and
questions
were
taken.
The
feedback
from
these
initial
meetings
led
to
efforts
by
the
U.
S.
to
have
the
Protocol
Parties
establish
international
norms
for
the
details
to
be
in
submissions
and
to
facilitate
standardization
for
a
fair
and
adequate
review.
These
efforts
culminated
in
decision
XIII/
11
which
calls
for
specific
information
to
be
presented
in
the
nomination.

Upon
return
from
the
Sri
Lanka
meeting
of
the
Parties,
the
U.
S.
took
a
three
track
approach
to
the
critical
use
process.
First,
we
worked
to
develop
a
national
application
form
that
would
ensure
that
we
had
the
information
necessary
to
answer
all
of
the
questions
posed
in
decision
XIII/
11.
At
the
same
time,
we
initiated
sector
specific
meetings.
This
included
meetings
with
representatives
of
the
post
harvest
commodity
sector
across
the
U.
S.
to
discuss
their
specific
issues,
and
to
enable
them
to
understand
the
newly
detailed
requirements
of
the
critical
use
application.
These
sector
meetings
allowed
us
to
fine
tune
the
application
so
we
could
submit
the
required
information
to
the
MBTOC
in
a
meaningful
fashion.

Finally,
and
concurrent
with
our
preparation
phase,
we
developed
a
plan
to
ensure
a
robust
and
timely
review
of
any
and
all
critical
use
applications
we
might
receive.
This
involved
the
assembly
of
more
than
45
PhDs
and
other
qualified
reviewers
with
expertise
in
both
biological
and
economic
issues.
These
experts
were
divided
into
interdisciplinary
teams
to
enable
primary
and
secondary
reviewers
for
each
application/
crop.
As
a
consequence,
each
nomination
received
by
the
U.
S.
was
reviewed
by
two
separate
teams.
In
addition,
the
review
of
these
interdisciplinary
teams
was
put
to
a
broader
review
of
experts
on
all
other
sector
teams
to
enable
a
third
look
at
the
information,
and
to
ensure
consistency
in
review
between
teams.
The
result
was
a
thorough
evaluation
of
the
merits
of
each
request.
A
substantial
portion
of
requests
did
not
meet
the
criteria
of
decision
IX/
6,
and
a
strong
case
for
those
that
did
meet
the
criteria
has
been
included.

Following
our
technical
review,
discussions
were
held
with
senior
risk
management
personnel
of
the
U.
S.
government
to
go
over
the
recommendations
and
put
together
a
draft
package
for
submission
to
the
parties.
As
a
consequence
of
all
of
this
work,
it
is
safe
to
say
that
each
of
the
sector
specific
nominations
being
submitted
is
the
work
of
well
over
150
experts
both
in
and
outside
of
the
U.
S.
government.

5.
Overview
of
Commodity
Storage
in
the
U.
S.

Post­
harvest
commodity
storage
is
a
critical
component
of
the
food
supply
system.
Critical
use
exemption
applicants
in
this
category
represent
fruits,
nuts,
beans,
and
meat
warehouses.
Because
the
growing
season
is
separated
from
the
peak
demand
season
by
several
months
for
most
of
these
products,
it
is
imperative
for
these
industries
to
have
reliable
means
for
storing
and
maintaining
the
quality
of
these
commodities
so
they
will
be
marketable.
Dried
fruits:
California
produces
almost
all
of
the
prunes,
raisins
and
figs
in
the
U.
S.,
and
70
percent,
40
percent
and
20
percent
of
the
world's
production
of
these
fruits,
respectively.
This
business
represents
approximately
US$
350
million
in
revenue.

Nuts:
This
sub­
sector
consists
of
walnuts
and
pistachios.
The
walnut
cooperative
facility
includes
approximately
50
percent
of
the
U.
S.
walnut
industry,
with
an
estimated
US$
280
million
in
revenues
generated
for
California.
The
businesses
representing
the
pistachio
sector
encompass
approximately
30
percent
of
global
pistachio
production
and
generate
an
estimated
US$
180
million
in
revenue.

Black­
eye
and
Garbanzo
beans:
This
sub­
sector
consists
of
stored
black­
eyed
peas
and
garbanzo
beans,
as
well
as
barley,
wheat
and
oats.
This
business
represents
an
estimated
US$
7
million
in
revenues,
accounting
for
72
percent
of
domestic
black­
eyed
bean
output
and
12
percent
of
domestic
garbanzo
bean
output,
along
with
significant
returns
from
exports.

Meats:
This
sub­
sector
consists
of
stored
hams.
This
nomination
is
for
a
single
company
in
this
sector
represents
US$
47.8
million
in
revenues
and
US$
1.7
million
in
earnings
before
taxes.
The
U.
S.
government
is
expecting
an
increased
number
of
applications
from
this
sub­
sector
next
year,
as
there
are
currently
no
alternatives
registered
for
use
on
hams
in
the
U.
S.

6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Commodity
Storage
Sector
6a.
Target
Pests
Controlled
with
Methyl
Bromide
Numerous
insects
infest
stored
dry
fruits,
nuts,
and
beans.
Major
insect
pests
of
dry
fruits
include
the
raisin
moth
(
Cadra
figulilella),
Indian
meal
moth
(
Plodia
interpunctella),
dried
fruit
beetle
(
Carpophilus
hemipterus),
vinegar
flies
(
Drosophila
spp.),
sawtoothed
grain
beetle
(
Oryzaephilus
surinamensis),
and
navel
orangeworm
(
Amyelois
transitella).
The
main
insects
attacking
walnuts
include
the
codling
moth
(
Cydia
pomonella),
navel
orangeworm,
sawtoothed
grain
beetle,
merchant
grain
beetle
(
Oryzaephilus
mercator),
warehouse
beetle
(
Trogoderma
variabile),
red
and
confused
flour
beetles
(
Tribolium
spp.),
dried
fruit
beetle,
cadelle
(
Tenebroides
mauritanicus),
Indian
meal
moth,
almond
moth
(
Ephestia
cautella),
and
raisin
moth.
Pests
of
stored
pistachios
are
primarily
the
Indian
meal
moth,
navel
orangeworm,
red
flour
and
confused
beetles,
and
the
warehouse
beetle.
Main
pests
of
dry
beans
include
the
cowpea
weevil
(
Callosobruchus
maculatus),
Indian
meal
moth,
sawtoothed
grain
beetle,
bean
weevil
(
Acanthoscelides
obtectus),
confused
flour
beetle,
granary
weevil,
(
Sitophilus
granarius),
and
lesser
grain
borer
(
Rhizopertha
dominica).
Principal
ham
pests
include
the
red­
legged
ham
beetle
(
Necrobia
rufipes),
ham
skipper
(
Piophila
sp.),
dermestid
beetles
(
Dermestes
spp.),
and
mites.

In
the
U.
S.,
the
Food
and
Drug
Administration
(
FDA)
regulates
the
maximum
levels
of
live
or
dead
insects
or
insect
parts
that
may
be
present
in
stored
food
products.
Food
commodities
that
exceed
maximum
limits
allowed
are
considered
adulterated
by
FDA
and
thus
unfit
for
human
consumption.

An
emphasis
in
the
U.
S.
on
maintaining
high
quality
food
is
codified
in
several
health
and
consumer
safety
laws
that
are
implemented
by
the
U.
S.
Food
and
Drug
Administration
(
U.
S.
FDA).
These
laws
ensure
that
human
and
animal
foods
are
safe
and
properly
labeled
(
the
Federal
Food,
Drug
and
Cosmetic
Act
(
FFDCA).
The
U.
S.
FDA
defines
unacceptable
standards
for
hazards
and
filth
in
human
and
animal
foods,
called
"
defect
action
levels
(
DALs).
These
DALs
define
how
much
filth
is
allowed
in
a
food.
Food
inspected
for
filth
levels.
Filth
may
include
health
hazards
for
children
and
pets,
such
as
barbed
hairs
from
the
dermestid
beetle
immatures
because
they
are
a
choking
hazard,
and
contaminants
that
render
the
food
"
adulterated",
but
are
not
actually
hazardous,
such
as
body
parts
of
pests
(
legs,
wings,
scales),
as
well
as
their
excreta
(
feces,
urine).
In
addition,
U.
S.
consumers
have
very
high
standards
for
their
food,
and
are
likely
to
sue
companies
if
any
flaws
are
detected.
For
this
reason,
food
processing
and
storage
companies
invest
substantial
resources
in
having
a
clean
final
product.

The
United
States'
enormous
and
wide
ranging
agricultural
sector
and
food
production
industry
has
enabled
the
U.
S.
to
feed
its
citizens,
and
meet
their
high
expectations
for
quality
food,
as
well
as
meeting
the
needs
of
many
other
countries.
The
food
processing
and
storage
industry
in
the
U.
S.
prides
itself
on
manufacturing
and
exporting
approximately
US$
130
billion
worth
of
high
quality
products.
Both
domestically
and
internationally,
companies
meet
stringent
standards
for
food
quality
by
relying
of
methyl
bromide.
Therefore,
as
evidenced
by
the
U.
S.
nomination
for
critical
uses
of
methyl
bromide,
the
phaseout
of
methyl
bromide
can
have
a
very
significant
impact
on
both
the
technical
and
economic
viability
of
the
food
processing
and
storage
sector.

The
United
States'
post­
harvest
food
industry
has
relied
heavily
on
mechanization
and
other
non­
labor
inputs
to
compensate
for
a
high
cost
of
labor.
As
a
result,
U.
S.
post­
harvest
practices
are
highly
reliant
on
pesticides
such
as
methyl
bromide
and
other
non­
labor
inputs.
The
extent
of
mechanization
and
reliance
on
non­
labor
inputs
can
be
best
demonstrated
by
noting
the
very
low
levels
of
labor
inputs.
Furthermore,
according
to
estimates
by
the
U.
S.
Department
of
Labor's
Bureau
of
Labor
Statistics,
employment
in
the
commodity
storage
sector
is
expected
to
decrease
by
approximately
11%
between
2000
and
2010,
largely
due
to
the
increased
mechanization
of
the
industry.
Total
employment
is
approximately
1.684
million
people
in
the
U.
S.
food
processing
industry,
and
approximately
22,000
employees
in
the
preserved
fruit
and
vegetable
market.

Post­
harvest
food
storage
is
a
critical
component
of
the
food
supply
system.
CUE
applicants
in
this
category
represent
fruits,
nuts,
beans,
and
meats
warehouses.
Because
the
growing
season
is
separated
from
the
peak
demand
season
by
several
months
for
most
of
these
products,
it
is
imperative
for
these
industries
to
have
reliable
means
for
storing
and
maintaining
the
quality
of
these
commodities.

6b.
Technical
and
Economic
Assessment
of
Alternatives
Dried
Fruit.
The
state
of
California
is
by
far
the
main
raisin,
prune,
and
fig
producing
state
in
the
U.
S.
In
California,
raisins
are
harvested
in
the
fall
and
dried
on
paper
trays
in
the
field,
where
they
often
become
infested
with
various
insects.
Subsequently,
raisins
are
washed,
sorted,
graded,
and
packed
into
boxes
for
storage
in
warehouses,
where
they
may
be
fumigated
several
times
a
year.
Raisins
are
taken
from
storage
throughout
the
year
for
processing.
Although
it
takes
about
three
to
five
days
to
fumigate
these
commodities
with
phosphine
and
only
12
to
24
hours
to
fumigate
them
with
methyl
bromide,
approximately
80
percent
of
dry
fruit
fumigation
uses
phosphine
(
Throne,
2002a).
Methyl
bromide
is
used
mainly
during
the
fall,
when
quick
fumigations
are
needed
as
production
and
rush
orders
peak.
Prunes,
unlike
raisins,
are
mechanically
dried,
a
process
that
kills
any
insect
that
may
be
present,
and
then
stored.
In
storage,
prunes
are
fumigated
once
or
twice
during
the
year
to
control
new
infestations.
Figs,
half
of
which
are
usually
infested
when
harvested,
are
fumigated
once,
immediately
after
harvest,
and
two
to
three
more
times
during
the
year.
In
some
cases,
figs
become
re­
infested
during
storage
and
grading.
A
substantial
portion
of
the
fig
market
is
for
the
holidays,
making
the
duration
of
fumigation
a
time­
sensitive
issue.
Stored
dry
fruits
must
be
fumigated
periodically,
otherwise
pest
populations
will
build
up,
affecting
their
quality
and
marketability.

Walnuts.
California
produces
over
99
percent
of
the
U.
S.
walnut
crop
(
NCFAP,
2002).
The
walnut
industry
in
California
is
dependent
on
methyl
bromide
to
disinfest
walnuts
as
they
are
harvested,
to
disinfest
nuts
as
they
become
infested
during
processing,
and
as
a
fumigation
treatment
for
nuts
held
in
storage.
A
typical
walnut
facility
receives
two
to
eight
million
pounds
(
907,184
to
3,628,736
kilograms)
of
walnuts
over
a
75
day
period,
starting
in
September
(
Throne,
2002b).
As
was
the
case
for
dried
fruits,
the
industry
has
replaced
most
some
of
their
methyl
bromide
fumigations
with
phosphine.
However,
walnuts
that
are
processed
for
immediate
sale
are
fumigated
with
methyl
bromide
in
a
vacuum
fumigation
chamber.
Walnuts
that
are
to
be
processed
later
are
placed
in
storage
bins.
Packaged
walnuts
are
also
fumigated
with
methyl
bromide
before
sale
to
meet
phytosanitary
or
quarantine
requirements.
In
the
fall,
when
walnuts
need
to
be
moved
quickly
to
European
and
domestic
markets
in
time
for
the
holidays,
phosphine
fumigation
is
too
slow
to
keep
up
with
the
rapid
turnover
required,
and
methyl
bromide
is
the
fumigant
of
choice
during
that
critical
period.
Walnuts
bound
for
Europe,
especially
for
the
St.
Nicholas
holiday
on
December
6,
must
be
on
board
ship
by
November
1
(
NCFAP,
2002).
Methyl
bromide
is
utilized
to
meet
the
requirement
of
having
no
live
insects.
The
California
walnut
industry
has
developed
both
export
and
domestic
markets
that
rely
on
high
quality
standards.

Pistachios.
California
produces
99
percent
of
U.
S.
pistachios.
During
peak
production
season,
California
processes
approximately
one
million
pounds
of
pistachios
per
week
(
Fuentes,
2002).
As
with
walnuts,
the
large
volume
and
limited
silo
availability
require
that
fumigation
be
done
rapidly
and
during
this
peak
season
the
industry
relies
on
methyl
bromide
fumigation.

Black­
eye
and
garbanzo
beans.
California
is
the
main
black­
eye
and
garbanzo
bean
producing
state
in
the
U.
S.
Weevils
are
found
in
the
harvested
crop
as
it
arrives
from
the
field
in
mid­
to
late­
summer.
To
ensure
that
the
product
is
pest­
free,
it
is
fumigated
with
methyl
bromide
upon
arrival,
and
again
as
needed
during
storage,
until
the
commodity
is
shipped
to
the
packaging
facility.
Currently,
methyl
bromide
is
the
only
chemical
listed
by
the
California
Department
of
Pesticide
Regulation
for
control
of
the
cowpea
weevil,
one
of
the
major
pests
of
stored
beans.
Approximately
60
percent
to
90
percent
of
all
black­
eye
beans
are
consumed
during
the
New
Year
holiday
in
the
U.
S.,
specifically
in
the
Southeast.
Often
shipments
are
based
on
customers'
demand
with
only
a
2­
day
notification
period
from
the
buyer.
This
very
short
turnaround
time
necessitates
a
completed
fumigation
within
12­
hours.
Buyers
often
request
a
copy
of
the
fumigation
records
showing
that
the
product
was
fumigated
just
prior
to
shipment
and
will
not
accept
a
product
that
cannot
verify
a
recent
(
15
day)
fumigation.
It
takes
12
hours
to
complete
a
fumigation
of
beans
with
methyl
bromide.

Meats.
A
single
curing
and
ham
storage
operation
can
typically
process
10,307,878
kilograms
(
11,362.5
U.
S.
tons)
of
salted
hams,
jowls,
shoulders,
and
bacon
bellies
each
year.
The
curing
facilities
are
fumigated
with
methyl
bromide
when
pests
are
detected
in
the
product
or
the
smokehouses.
This
fumigation
typically
occurs
about
three
to
five
times
during
a
typical
year.
During
this
process,
the
smokehouse,
typically
small
building
(
e.
g.
four
stories),
is
covered
with
tarp
and
fumigated
while
full
of
hams.

Summary
of
Technical
Feasibility
The
results
of
the
U.
S.
interdisciplinary
team
review
of
the
MBTOC
listed
alternatives
are
summarized
in
Tables
1
and
2.
The
best
methyl
bromide
alternative
for
the
control
of
stored
commodity
pests
is
phosphine,
alone
or
in
combination.
Phosphine
is
currently
being
used
by
the
dried
fruit
and
nut
industry
when
production
and
marketing
"
timing"
conditions
allow
it.
Phosphine
is
not
a
feasible
replacement
for
methyl
bromide
when
rapid
commodity
turnover
situations
require
a
faster
treatment
than
3
to
5
days.
Phosphine
treatment
would
also
disrupt
(
i.
e.
the
ham
will
not
cure
properly)
the
ham
curing
process
and
for
this
reason
it
is
not
a
feasible
alternative
for
this
commodity.
Furthermore,
adoption
of
phosphine
fumigation
would
require
a
substantial
capital
investment
for
fumigation
chambers
or
gas­
tight
bins.
In
addition,
pest
resistance
and
corrosion
problems
(
e.
g.
corrosion
of
copper
alloys,
electrical
wiring,
equipment,
and
lights)
associated
with
phosphine
fumigation
for
stored
commodities
would
limit
the
long
term
usefulness
of
this
fumigant.
The
corrosion
problems
and
development
of
resistance
in
target
pests
could
be
reduced
by
using
low
phosphine­
high
carbon
dioxidehigh
temperature
combination
treatments,
but
adopting
this
method
would
require
a
high
degree
of
technical
skills
which
is
not
widely
available.
This
fumigation
method
requires
that
the
concentrations
of
carbon
dioxide
and
phosphine
and
temperature
be
constantly
monitored
and
adjusted,
that
the
gases
be
uniformly
distributed,
that
unexposed
pockets
do
not
occur,
and
that
the
analytical
equipment
used
for
these
determinations
be
properly
maintained,
calibrated,
and
properly
installed.
Methyl
bromide
appears
to
be
the
only
treatment
that
consistently
provides
the
high
degree
of
insect
and
mite
control
required
in
stored
commodities
which
depend
on
rapid
fumigation
methods.
Table
1.
Methyl
bromide
alternatives
identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
for
dried
fruit,
nuts,
and
stored
beans
Methyl
bromide
Alternatives
Technical
Feasibility
Economic
Feasibility
1
Phosphine,
alone
Yes*
No
2
Phosphine,
in
combination
Yes*
No
3
Propylene
oxide
No
No
4
Sulfuryl
fluoride
Not
registered
in
the
U.
S.
N/
A
5
Pesticides
(
contact
and
low
volatility
insecticides)
No
No
6
High
pressure
carbon
dioxide
No
No
7
Cold
treatment
No
No
8
Heat
treatment
No
No
9
Integrated
pest
management
(
IPM)
No
No
10
Biological
agents
No
No
11
Irradiation
No
No
12
Pest
resistant
packaging
No
No
13
Controlled
and
modified
atmospheres
No
No
14
Physical
removal/
cleaning/
sanitation
No
No
*
Although
these
alternatives
can
control
pests,
practical
implementation
in
many
cases
is
complicated
by
corrosivity
and
damage
to
electronic
equipment,
building
construction,
pest
resistance
and
regulatory
limitations.

Table
2.
Methyl
bromide
alternatives
identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
for
fish
and
meats
(
ham)
Methyl
bromide
Alternatives
Technical
Feasibility
Economic
Feasibility
1
Phosphine,
alone
Yes
No
2
Phosphine,
in
combination
Yes
No
3
Propylene
oxide
Not
registered
in
the
U.
S.
N/
A
4
Sulfuryl
fluoride
Not
registered
in
the
U.
S.
N/
A
5
Pesticides
(
contact
and
low
volatility
insecticides)
No
No
11
Irradiation
No
No
6c.
Technical
Feasibility
of
In
Kind
Alternatives
Phosphine
alone
is
a
technically
feasible
alternative,
but
cannot
be
adopted
in
all
cases
because:
(
1)
It
takes
too
long
to
use
in
some
circumstances;
(
2)
it
is
corrosive
of
metals;
and
(
3)
some
pests
are
developing
a
resistance.
Exposure
to
phosphine
gas
will
control
insects
in
stored
food
commodities.
However,
it
takes
about
three
to
five
days
to
fumigate
with
phosphine
gas,
compared
to
only
12
to
24
hours
with
methyl
bromide.
The
U.
S.
dried
fruit
industry
has
already
replaced
80
percent
of
their
methyl
bromide
fumigations
with
phosphine
for
situations
when
rapid
commodity
turnover
is
not
required
(
Throne,
2002a).
Phosphine
does
not
act
fast
enough
when
stored
commodities
must
be
moved
quickly
to
meet
marketing
schedules.
The
several
days
required
for
phosphine
fumigation
would
also
interfere
with
the
ham
curing
process
(
smoking).
Phosphine
is
corrosive
to
metals,
such
as
copper
in
electrical
connections,
printed
circuits,
and
sensitive
equipment,
and
cannot
be
used
in
many
warehouses
and
processing
plants.
Several
stored
grain
insects
have
already
developed
resistance
to
phosphine
(
Bell,
2000),
and
it
is
likely
that
resistance
will
continue
to
develop
in
other
stored
commodity
pests,
making
its
use
a
short­
term
solution.

Phosphine,
in
combination
may
be
a
technically
feasible
alternative,
but
cannot
be
widely
adopted
because:
(
1)
This
technology
is
not
widely
available
throughout
the
country;
(
2)
there
are
uncertainties
as
to
the
effectiveness
of
this
approach
for
large­
scale
commodity
treatment;
(
3)
it
takes
too
long
to
use
in
some
circumstances;
(
4)
it
is
corrosive
of
metals,
although
less
than
phosphine
alone;
and
(
5)
it
may
accelerate
the
development
of
pest
resistance
to
phosphine.

There
is
some
indication
that
reduced
concentrations
of
phosphine
in
combination
with
carbon
dioxide
and
heat
may
be
able
to
extend
the
life
of
the
metals.
However,
efficacy
data
for
this
technique
is
lacking
in
the
U.
S.
Studies
of
the
efficacy
of
this
combination,
as
well
as
the
rate
of
metal
corrosion,
are
needed.
Using
lower
concentrations
of
phosphine
with
resistance
already
developing
in
the
pest
populations
will
select
for
resistant
populations
much
quicker
and,
therefore,
is
not
recommended.
Combined
treatment
(
phosphine,
heat,
carbon
dioxide)
reduces
phosphine
corrosion
and,
if
properly
calibrated,
can
be
effective
against
all
insect
life
stages
within
24
hours
of
exposure.
Fumigation
with
this
combination
requires
experience
in
chemical
monitoring,
gas
movement,
and
the
interaction
between
temperature
and
gas
concentration
and
insect
mortality.
Although
this
method
addresses
the
corrosion
problems
associated
with
phosphine,
pest
control
results
can
vary
widely
depending
on
who
is
doing
the
application,
thus
increasing
the
risk
of
total
product
loss
if
it
cannot
be
certified
as
insect
free.

Propylene
oxide
is
not
technically
feasible
because:
(
a)
Propylene
oxide
is
not
labeled
for
use
on
in­
shell
nuts
in
the
U.
S.;
(
b)
it
is
volatile
and
flammable
and
needs
to
be
applied
under
vacuum
conditions
for
safety;
(
c)
its
use
would
require
the
construction
of
large
treatment
facilities
(
vacuum
chambers);
(
d)
some
importing
countries
will
not
accept
nuts
treated
with
this
fumigant;
and
(
e)
its
use
may
cause
rancidity
to
nuts.
Although
complete
pest
control
with
this
fumigant
can
be
achieved
in
four
hours,
it
is
registered
in
the
U.
S.
as
a
package
fumigant
for
treatment
of
prunes
and
processed
nuts.

Sulfuryl
fluoride
is
not
currently
registered
for
use
on
food
products
in
the
U.
S.
This
chemical
has
been
found
to
be
effective
against
all
insects
stages,
except
the
eggs
(
Bell,
2000).
Recently,
EPA
granted
temporary
tolerances
for
sulfuryl
fluoride
for
the
post­
harvest
fumigation
of
stored
walnuts
and
raisins.
The
temporary
tolerances
support
a
three
year
experimental
use
permit
that
expires
in
March
2005.
This
fumigant's
main
efficacy
related
drawback,
assuming
full
EPA
registration
is
eventually
granted,
will
be
its
lack
of
effectiveness
against
insect
eggs,
which
would
limit
its
utility
for
routine
and
pre­
export
fumigation.

Irradiation
is
not
technically
feasible
because:
(
a)
Irradiation
does
not
readily
kill
exposed
insects,
but
rather
prevents
further
feeding
and
reproduction.
Although
unable
to
feed
or
reproduce,
the
surviving
insects
would
still
create
phytosanitary
problems.
The
high
doses
required
to
kill
exposed
insects
may
affect
product
quality.
(
b)
Consumer
acceptance
of
irradiated
food
would
further
hinder
the
adoption
of
this
method.
(
c)
Food
irradiation
is
prohibitively
expensive,
especially
for
processing
large
volumes
of
commodities.
6d.
Economic
Feasibility
of
In­
Kind
Alternatives
The
economic
assessment
of
feasibility
for
post­
harvest
uses
of
methyl
bromide
included
an
evaluation
of
economic
losses
due
to
three
major
economic
measures,
with
the
first
measure
being
sub­
divided
further
into
three
contributing
factors:

(
1)
absolute
losses
per
facility,
are
aggregate
potential
economic
losses
from:

(
1a)
direct
pest
control
costs,
because
alternatives
to
methyl
bromide
tend
to
be
more
expensive,
not
only
in
terms
of
the
price
of
the
fumigant
or
treatment
type,
but
also
for
an
increased
number
of
treatments.

(
1b)
capital
expenditures,
which
are
often
large
amounts
required
to
adopt
an
alternative,
such
as
investments
for
accelerated
replacement
of
plant
and
equipment
due
to
corrosive
nature
of
phosphine.

(
1c)
production
delays,
which
are
often
related
to
additional
production
downtime
for
the
use
of
alternatives.
Many
facilities
are
operating
at
or
near
production
capacity
in
"
just­
in­
time"
environments.
Alternatives
that
take
longer
than
methyl
bromide
or
require
more
frequent
application
can
result
in
manufacturing
slowdowns,
shutdowns,
or
shipping
delays.
Slowing
down
production
will
result
in
additional
costs
incurred
throughout
channels
of
distribution.

(
2)
Economic
loss
as
a
percent
of
net
revenue.
This
measure
is
calculated
by
dividing
the
absolute
loss
by
the
net
revenue.

(
3)
Economic
loss
as
per
kilogram
of
methyl
bromide
requested.
This
measure
is
calculated
by
dividing
the
loss
per
facility
by
the
kilograms
active
ingredient
requested
per
facility.

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
use
for
commodity
storage.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.

Technically
feasible
alternatives
to
methyl
bromide
in
commodity
storage
are
phosphine
alone
and
phosphine
in
combination.
Implementation
of
these
alternatives
would
have
substantial
economic
implications
for
the
sub­
sectors
of
the
commodity
storage
industry
in
this
initial
U.
S.
nomination.
Significant
financial
impacts
likely
will
result
from
increased
operating
costs
for
materials
and
labor,
capital
expenditures,
and
increased
production
downtime.

Phosphine
alone
The
potential
economic
losses
associated
with
the
use
of
phosphine
alone
mostly
arise
from
production
delay
costs
and
capital
expenditures.
Estimated
economic
losses
from
a
shift
to
phosphine
alone
treatment
are
summarized
in
Table
3.
The
estimated
economic
loss
as
a
percentage
of
net
revenue
ranges
from
12
percent
to
154
percent.
The
range
is
particularly
large
because
the
commodities
analyzed
are
not
homogeneous.
The
industries
that
use
methyl
bromide
for
storage
fumigation
are
subject
to
limited
pricing
power
because
companies
within
these
industries
operate
in
a
highly
competitive
global
marketplace
characterized
by
high
sales
volume
and
low
profit
margins.
The
potential
economic
losses
of
using
the
phosphine
alone
for
commodity
storage
would
significantly
reduce
their
low
profit
margins.
Four
of
the
five
commodity
storage
uses
of
methyl
bromide
occur
almost
exclusively
in
California
due
to
the
state's
unique
climate
and
access
to
ports
for
exporting.

For
the
walnut
sector,
using
phosphine
would
drastically
hinder
market
demand
for
the
product,
especially
shipments
to
Europe
during
the
holiday
season.
All
existing
fumigation
space
is
currently
used
to
pack
for
the
pre­
Christmas
market.
It
is
estimated
that
for
independent
handlers,
who
typically
move
walnuts
through
atmospheric
methyl
bromide
fumigation
every
24
hours,
that
packing
capacity
would
be
reduced
to
one­
fifth
of
current
levels
if
five
days
are
required
for
fumigation.
In
addition,
handlers
would
lose
early­
season
revenue
needed
to
finance
operations,
and
this
cash
flow
impact
would
further
contribute
to
market
disruptions
and
losses.
Furthermore,
if
there
is
a
year
with
excessively
high
pest
pressures,
the
un­
fumigated
walnuts
could
easily
sustain
so
much
damage
in
storage
that
these
lots
would
not
be
worth
processing,
as
the
yield
of
useable
nuts
would
be
too
low
to
justify
sorting
costs.
Even
if
all
of
the
walnuts
could
be
stored
and
processed
on
a
steady
basis
throughout
the
year,
prices
paid
to
growers
would
be
depressed
by
the
increased
supply
that
would
be
forced
onto
the
domestic
market.
The
same
issue
of
longer
exposure
times
resulting
in
lost
revenue
is
also
applicable
to
the
pistachio
sector.

With
regard
to
the
bean
sector,
rapid
turnaround
time
is
essential
during
peak
seasons.
An
average
of
10­
15
truckloads
of
beans
are
delivered
daily
to
each
warehouse.
Fumigation
with
methyl
bromide
begins
at
4:
00pm
each
day,
and
concludes
12
hours
later.
The
12­
hour
time
used
to
fumigate
with
methyl
bromide
is
critical
to
keep
up
with
the
truckloads
of
beans
arriving
from
harvest
on
a
daily
basis.
With
a
72­
hour
fumigant
such
as
phosphine,
there
would
be
a
tremendous
backlog
and
similar
to
the
walnut
case,
the
high
pest
pressure
would
likely
deem
the
crop
unfit
for
consumption,
thus
resulting
in
lost
revenues.
In
addition,
methyl
bromide
is
the
only
product
listed
by
the
California
Department
of
Pesticide
Regulation
as
suitable
for
controlling
the
cowpea
weevil,
a
major
pest
in
bean
warehouses.

Phosphine
is
not
economically
feasible
for
use
in
areas
of
the
dried
fruit
sector
(
especially
prunes
and
figs),
as
current
warehouses
have
too
much
equipment
that
would
corrode.
Higher
equipment
maintenance
costs
might
require
construction
of
additional
chambers,
which
would
be
cost­
prohibitive.
In
addition,
longer
exposure
time
reduces
flexibility
of
handling
figs
and
prunes,
which
may
lead
to
worse
quality
commodities
and
subsequent
lost
revenues.

Phosphine
in
combinations
with
heat
Phosphine
in
combination
is
likely
to
be
even
more
costly
than
phosphine
alone
because
implementation
of
this
treatment
also
require
retrofitting
the
facility
for
heat.
See
phosphine
alone
discussion
above
for
summary
of
economic
impacts
of
moving
to
phosphine.
Table
3.
Summary
of
Estimated
Economic
Losses
in
the
Absence
of
Methyl
Bromide
Economic
Loss
Measures
Beans
in
storage
(
Represen
tative
size:
8,495
m3)
Prunes,
figs,
&
raisins
(
Representati
ve
size:
14,159
m3)
Pistachios
(
Representativ
e
size:
31,149
m3)
Walnuts
(
Representative
size:
8,495
m3)
Ham
(
Representat
i
ve
size:
5,663
m3)

Absolute
loss
per
average
facility
Direct
pest
control
costs
$
38,000
$
14,000
($
10,000)
($
81,000)
NA1
Capital
expenditures
$
42,000
$
32,000
$
18,000
$
519,000
NA
Production
delays
$
8,000
$
92,000
$
1,510,000
$
1,308,000
NA
Total
$
88,000
$
141,000
$
1,518,000
$
1,746,000
NA
Economic
loss
as
a
percentage
of
net
revenue
154%
20%
48%
12%
NA
Economic
loss
as
per
kilogram
of
methyl
bromide
requested
$
218
$
414
$
608
$
79
NA
1Not
available
because
no
alternative
is
identified
as
technically
feasible.

6e.
Technical
Feasibility
of
Not
In
Kind
Alternatives
Carbon
dioxide
(
high
pressure)
is
not
technically
feasible
because:
(
a)
Only
small
quantities
of
dry
fruits
can
be
treated
at
a
time
since
only
small
chambers
that
can
withstand
high
pressure
are
available.
Unavailability
of
large
scale
pressure
chambers
restrict
its
widespread
use
(
California
Walnut
Commission,
2002).
b)
Carbon
dioxide
is
marginally
effective
against
some
insect
stages.
For
example
in
almond
moth
Ephestia
cautella
(
Walker)
the
adults
are
two
to
four
times
more
sensitive
to
carbon
dioxide
concentrations
than
the
eggs
and
pupae,
respectively
(
Navarro
et.
al,
1999).

Cold
treatment
is
not
technically
feasible
because
this
method
requires
either
a
long
time
for
treatment
at
moderately
cold
temperatures
or
extreme
cold
temperatures
for
a
short
period
of
time.
Effective
treatment
requires
maintaining
a
temperature
of
minus
18_
C
(
0_
F)
for
several
hours,
minus
10_
C
(
14_
F)
for
between
7
and
62
hours,
or
between
0
and
10_
C
(
32
to
50_
F)
for
a
minimum
of
two
weeks
(
California
Walnut
Commission
&
Walnut
Marketing
Board,
2002).
Cold
treatment
drawbacks
include
the
following:
a)
The
slowness
of
the
process
would
interfere
with
the
rapid
movement
of
products,
especially
during
harvest
in
fall,
and
would
affect
the
industry's
capacity
to
meet
the
demands
of
the
European
market,
delaying
shipments
by
1­
3
weeks.
b)
The
application
of
this
alternative
would
require
major
investment
of
capital
for
construction
of
specialized
cold
chambers
or
retrofitting
of
existing
facilities.
c)
Energy
costs
to
quickly
cool
large
masses
of
commodity
would
be
prohibitive.

Heat
treatment
is
not
technically
feasible
because
there
is
little
information
on
how
exposure
to
heat
would
affect
the
treated
commodity,
considering
that
the
effect
of
high
temperatures
on
the
quality
of
dried
fruit
and
nuts
varies
with
the
commodity,
temperature,
length
of
treatment,
and
other
factors.
For
instance,
except
for
pistachios,
there
is
rapid
quality
deterioration
when
nuts
are
stored
above
ambient
temperatures.
Although
exposure
to
extreme
heat
will
control
stored
food
pests
in
flour
mills
and
food
processing
facilities,
no
research
has
been
conducted
in
the
U.
S.
that
demonstrates
the
effectiveness
of
this
method
with
large
volumes
of
dry
fruit,
nuts,
or
beans.
Similarly,
In
the
absence
of
reliable
information
on
these
issues,
large­
scale
heat
treatment
of
stored
commodities
is
not
an
option
at
this
time.

Integrated
pest
management
(
IPM)
is
not
technically
feasible
by
itself
because
it
is
not
designed
to
completely
eliminate
pests
from
any
given
commodity
nor
to
ensure
that
such
commodity
remains
free
from
infestation.
The
IPM
approach
to
pest
control
seeks
to
manage
pests
at
economically
tolerable
levels
by
making
use
of
all
available
chemical,
cultural,
biological,
and
mechanical
pest
control
practices
so
as
to
avoid
or
reduce
the
frequency
of
fumigations.
IPM
techniques,
such
as
sanitation,
destruction
of
infested
materials,
pest
monitoring,
trapping,
and
chemical
control
are
routinely
used
by
the
industry.
Because
of
the
zero
tolerance
for
insects
imposed
by
market
demands
and
regulatory
requirements,
IPM
is
not
an
acceptable
alternative
to
methyl
bromide
fumigation.

Biological
agents:
Biocontrol
is
not
currently
designed
to
provide
the
degree
of
pest
control
that
market
and
regulatory
agencies
demand
in
stored
food
products.
Furthermore,
the
use
of
biological
control
agents
for
control
of
stored
product
pests
is
still
in
its
infancy.
Biological
agents
are
slow
to
act,
are
species­
specific,
and
would
only
reduce,
not
eliminate,
pest
populations
in
an
infested
commodity.
Moreover,
the
use
of
insect
predators
and
parasitoids
would
add
insect
parts
to
the
product,
and
their
presence
would
be
subject
to
FDA
regulations
just
like
other
insects.

Pest
resistant
packaging:
This
alternative
is
not
feasible
for
treating
bulk
commodity.

Controlled
and
modified
atmospheres
are
not
technically
feasible
by
themselves
because
some
combinations,
such
as
carbon
dioxide
with
high
heat,
have
been
shown
to
be
effective
in
disinfesting
dried
fruit
and
nuts.
However,
the
adoption
of
this
method
requires,
depending
upon
temperature,
a
minimum
of
2­
5
days
of
pest
exposure
for
control,
which
is
too
long
for
the
high
commodity
output
in
the
U.
S.,
especially
during
harvest.
For
instance,
Diamond
Walnut
alone
processes
3,628,739
kilograms
(
4,000
tons)
at
its
Stockton
plant.
In
addition,
adoption
of
this
method
for
rapid
disinfestation
would
require
major
capital
investment
for
equipment
and
retrofitting
of
existing
structures
(
California
Walnut
Commission
&
Walnut
Marketing
Board,
2002).
In
addition,
eggs
and
pupae
are
less
sensitive
to
this
control
method
than
are
the
adults
(
Navarro
et.
al,
1999).

Physical
removal/
cleaning/
sanitation:
This
technique
is
already
being
used.
By
itself,
this
approach
is
not
designed
to
disinfest
a
commodity,
but
only
to
temporarily
reduce
the
build­
up
of
pest
populations.

Pesticides
(
contact
and
low
volatility
insecticides):
Insecticides
are
not
registered
for
use
on
dry
fruit
or
ham
in
the
U.
S.
and,
at
present,
only
pyrethrins
­
piperonyl
butoxide
aerosol
formulations
are
registered
for
use
on
other
stored
commodities.
These
formulations,
used
as
space
sprays,
fogs,
or
mists,
are
designed
to
control
exposed
insects
and
do
not
penetrate
into
the
treated
commodities.
Insecticide
applications
would
only
temporarily
control
exposed
insects,
while
having
no
effect
on
those
feeding
inside
the
infested
commodities.
Thus,
insecticide
treatment
would
not
provide
the
degree
of
control
required
to
satisfy
market
and
regulatory
standards
(
California
Walnut
Commission
&
Walnut
Marketing
Board,
2002).
7.
Critical
Use
Exemption
Nomination
for
Commodity
Storage
The
U.
S.
interdisciplinary
review
team
found
a
critical
need
for
methyl
bromide
for
commodity
storage
of
dry
fruit
(
raisins,
figs,
prunes),
walnut,
pistachios,
black­
eye
and
garbanzo
beans
in
California,
and
for
dried/
cured
pork
products
in
Virginia.
These
are
likely
to
be
only
the
initial
requests
for
commodity
storage.
Twelve
of
fourteen
alternatives
identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
were
regarded
by
reviewers
as
technically
and
economically
infeasible
for
post­
harvest
management
of
the
main
insect
pests
affecting
dried
fruit
and
nuts.
Phosphine
was
the
only
alternative
found
to
be
suitable
for
use
on
nuts
and
beans,
except
during
high
production
and/
or
marketing
periods,
when
commodities
need
to
be
fumigated
rapidly
to
keep
up
with
production
pressures
and
market
demands.
Five
of
five
"
not­
in­
kind"
alternatives
identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
were
regarded
by
reviewers
as
technically
or
economically
infeasible
for
post­
harvest
management
of
the
main
insect
pests
affecting
and
meats
(
ham).

The
actual
amount
of
methyl
bromide
requested,
the
proposed
volumes
to
be
treated,
and
the
treatment
rates
for
each
commodity
are
summarized
in
Tables
4­
8.

Table
4.
Methyl
Bromide
Usage
and
Requests
for
Stored
Black­
Eye
and
Garbanzo
Beans
in
California.
1997
1998
1999
2000
2001
2005
2006
2007
kg
9,457
8,883
14,734
10,620
4,286
12,088
12,088
12,088
1,000
cu
meters
183
178
297
217
178
255
255
255
rate
(
kg/
1,000
cu
meters)
51.7
50.0
49.5
48.9
24.0
47.4
47.4
47.4
The
representative
user
for
this
sector
is
a
warehouse
operation
that
handles
the
crop
as
it
is
brought
in
from
the
field.
Five
warehouses
represent
42,827
cubic
meters
of
storage
for
grain
crops
including
black­
eye
beans,
garbanzo
beans,
black
beans,
wheat,
oats,
and
barley.
The
product
is
typically
treated
as
it
arrives
from
the
field,
or
when
the
pest
is
detected.
Following
the
initial
fumigation,
the
commodities
are
usually
fumigated
once
every
30
days
during
the
months
of
April
to
September.
In
addition,
it
is
common
for
buyers
to
request
a
copy
of
the
fumigation
records
to
show
that
the
product
was
fumigated
prior
to
shipment;
some
buyers
do
not
accept
a
product
that
cannot
verify
a
recent
15­
day
fumigant.
However,
in
some
cases
fumigation
can
vary
according
to
pest
pressure.

Table
5.
Methyl
Bromide
Usage
and
Requests
for
Dry
Fruits
(
Prunes,
Figs,
Raisins)
in
California.
1997
1998
1999
2000
2001
2005
2006
2007
kg
8,501
19,862
17,001
16,251
16,251
20,412
20,412
20,412
1,000
cu
meters
496
1,614
1,109
684
684
850
850
850
rate
(
kg/
1,000
cu
m)
17.1
12.3
15.3
23.8
23.8
24
24
24.0
The
above
table
represents
the
historical
usage
for
approximately
85%
of
this
industry.
Application
rates
have
increased
since
1997,
but
have
not
fluctuated
in
recent
years.
However,
raisins
are
now
fumigated
with
phosphine
on
a
regular
basis,
which
subsequently
allows
for
the
use
of
alternatives
requiring
a
longer
exposure
time,
such
as
phosphine.
Presently,
the
sector
is
researching
sulfuryl
fluoride
as
a
potential
replacement
for
methyl
bromide.

Table
6.
Methyl
Bromide
Usage
and
Requests
for
Pistachios
in
California.
1997
1998
1999
2000
2001
2005
2006
2007
kg
3,031
5,670
4,025
3,946
3,946
4,536
4,536
4,536
1,000
cu
meters
57
57
57
57
57
57
57
57
rate
(
kg/
1,000
cu
m)
53.5
100.0
71.1
69.7
69.7
80.1
80.1
80.1
Pistachio
plants
vary
somewhat
in
size;
an
average
was
taken
in
the
table
above.
The
largest
processor
handles
over
45,360,000
kg
of
pistachios
per
year,
as
California
produces
the
majority
of
pistachios
for
consumption
in
the
U.
S.
Consortium
members
use
methyl
bromide
because
of
particular
characteristics
in
the
fumigant
that
are
not
present
in
other
registered
fumigants,
as
well
as
its
efficacy.
Although
the
application
rate
has
not
fluctuated
extensively
since
1997,
the
pistachio
industry
has
reduced
its
dependence
on
methyl
bromide
by
using
phosphine
whenever
possible;
the
sector
is
also
lobbying
for
the
registration
of
sulfuryl
fluoride.

Table
7.
Methyl
Bromide
Usage
and
Requests
for
Walnuts
in
California
1997
1998
1999
2000
2001
2005
2006
2007
kg
77,018
64,992
81,025
68,428
65,022
97,704
87,362
108,046
1,000
cu
meters
762
643
801
677
864
1,220
1,091
1,349
rate
(
kg/
1,000
cu
m)
101.1
101.1
101.1
101.1
75.3
80.1
80.1
80.1
A
typical
walnut
facility
processes
approximately
113,400,000
kg
of
walnuts
every
year.
Independent
handlers
process
a
slightly
smaller
volume,
but
all
product
must
clear
fumigation
before
the
following
day's
shipment
arrives,
during
peak
seasons.
The
average
handlers
receive
approximately
907,200­
3,628,800
kg
of
walnuts
per
day,
for
75
days,
beginning
in
September.
During
this
peak
season
methyl
bromide
must
be
used
in
order
to
keep
up
with
market
demand.
However,
during
off­
seasons,
several
processors
have
switched
to
Phosphine
in
combination,
which
takes
three
days
to
affect
an
insect
kill.

Table
8.
Methyl
Bromide
Usage
and
Requests
for
Meats
in
Virginia.
1997
1998
1999
2000
2001
2005
2006
2007
kg
726
726
363
544
726
907
907
907
1,000
cubic
meters
62
62
62
62
62
62
62
62
rate
(
kg/
1,000
cu
m)
11.6
11.6
5.8
8.7
11.6
14.6
14.6
14.6
This
facility
produces
10,308,060
kg
of
the
following
products
per
year:
dry
cured
salted
hams,
shoulders,
jowls,
and
bacon
bellies.
The
facilities
are
only
treated
when
pests
are
present
through
the
inspection
of
the
product
and
of
the
smokehouses.
As
demonstrated
in
the
above
table,
application
frequency
fluctuates
according
to
pest
growth
and
pest
pressure
during
any
given
season.
Typically,
methyl
bromide
is
applied
3­
5
times
throughout
the
year,
but
this
operation
has
attempted
to
reduce
dependence
on
methyl
bromide
by
using
pyrethrins,
traps
for
flies,
and
pheromone
jars.

The
U.
S.
nomination
has
been
determined
based
on
consideration
of
the
requests
we
received
and
an
evaluation
of
the
supporting
material.
This
evaluation,
which
resulted
in
a
reduction
in
the
amount
being
nominated,
included
careful
examination
of
issues
including
the
area
infested
with
the
key
target
(
economically
significant)
pests
for
which
methyl
bromide
is
required,
the
extent
of
regulatory
constraints
on
the
use
of
registered
alternatives,
and
historic
use
rates,
among
other
factors.

Table
9.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
the
Commodity
Sector.
Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)
2005
135,828
87,753
8.
Availability
of
Methyl
Bromide
from
Recycled
or
Stockpiled
Sources
In
accordance
with
the
criteria
of
the
critical
use
exemption,
the
Parties
must
discuss
the
potential
that
the
continued
need
for
methyl
bromide
can
be
met
from
recycled
or
stockpiled
sources.
With
regard
to
recycling
of
methyl
bromide,
it
is
fair
to
say
that
the
U.
S.
concurs
with
earlier
TEAP
conclusions
that
recycling
of
methyl
bromide
used
in
commodity
storage
facilities
is
not
currently
feasible.
Facilities
in
the
U.
S.
are
very
large
and
not
able
to
be
sealed
tightly
enough
to
allow
methyl
bromide
to
be
captured
and
recycled.
Recycling
systems
are
under
development
for
port
fumigation
but
the
issues
of:
trapping
efficacy,
worker
and
bystander
safety,
liability
for
the
captured
fumigant,
and
design
of
facilities
to
extract
the
captured
methyl
bromide
have
slowed
the
development
of
this
approach.
The
U.
S.
has
been
investigating
the
level
of
the
existing
stockpile,
and
we
believe
that
whatever
stock
pile
may
now
exist
will
likely
be
fully
depleted
by
2005
when
the
need
for
the
critical
use
exemption
will
start.

9.
Minimizing
Use/
Emissions
of
Methyl
Bromide
in
the
U.
S.

In
accordance
with
the
criteria
of
the
critical
use
exemption,
we
will
now
describe
ways
in
which
we
strive
to
minimize
use
and
emissions
of
methyl
bromide.
While
each
sector
based
nomination
includes
information
on
this
topic,
we
thought
it
would
be
useful
to
provide
some
general
information
that
is
applicable
to
most
methyl
bromide
uses
in
the
country
The
use
of
methyl
bromide
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
is
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.

In
terms
of
compliance,
in
general,
the
United
States
has
used
a
combination
of
tight
production
and
import
controls,
and
the
related
market
impacts
to
ensure
compliance
with
the
Protocol
requirements
on
methyl
bromide.
Indeed,
over
the
last
 
years,
the
price
of
methyl
bromide
has
increased
substantially.
As
Chart
1
in
Appendix
D
demonstrates,
the
application
of
these
policies
has
led
to
a
more
rapid
U.
S.
phasedown
in
methyl
bromide
consumption
than
required
under
the
Protocol.
This
accelerated
phasedown
on
the
consumption
side
may
also
have
enabled
methyl
bromide
production
to
be
stockpiled
to
some
extent
to
help
mitigate
the
potentially
significant
impacts
associated
with
the
Protocol's
70
percent
reduction
in
2003
and
2004.
We
are
currently
uncertain
as
to
the
exact
quantity
of
existing
stocks
going
into
the
2003
season
that
may
be
stockpiled
in
the
U.
S.
We
currently
believe
that
the
limited
existing
stocks
are
likely
to
be
depleted
during
2003
and
2004.
This
factor
is
reflected
in
our
requests
for
2005
and
beyond.

At
the
same
time
we
have
made
efforts
to
reduce
emissions
and
use
of
methyl
bromide,
we
have
also
made
strong
efforts
to
find
alternatives
to
methyl
bromide.
The
section
that
follows
discusses
those
efforts.

10.
U.
S.
Efforts
to
Find,
Register
and
Commercialize
Alternatives
to
Methyl
Bromide
Over
the
past
ten
years,
the
United
States
has
committed
significant
financial
and
technical
resources
to
the
goal
of
seeking
alternatives
to
methyl
bromide
that
are
technically
and
economically
feasible
to
provide
pest
protection
for
a
wide
variety
of
crops,
soils,
and
pests,
while
also
being
acceptable
in
terms
of
human
health
and
environmental
impacts.
The
U.
S.
pesticide
registration
program
has
established
a
rigorous
process
to
ensure
that
pesticides
registered
for
use
in
the
United
States
do
no
present
an
unreasonable
risk
of
health
or
environmental
harm.
Within
the
program,
we
have
given
the
highest
priority
to
rapidly
reviewing
methyl
bromide
alternatives,
while
maintaining
our
high
domestic
standard
of
environmental
protection.
A
number
of
alternatives
have
already
been
registered
for
use,
and
several
additional
promising
alternatives
are
under
review
at
this
time.
Our
research
efforts
to
find
new
alternatives
to
methyl
bromide
and
move
them
quickly
toward
registration
and
commercialization
have
allowed
us
to
make
great
progress
over
the
last
decade
in
phasing
out
many
uses
of
methyl
bromide.
However,
these
efforts
have
not
provided
effective
alternatives
for
all
crops,
soil
types
and
pest
pressures,
and
we
have
accordingly
submitted
a
critical
use
nomination
to
address
these
limited
additional
needs.

Research
Program
When
the
United
Nations,
in
1992,
identified
methyl
bromide
as
a
chemical
that
contributes
to
the
depletion
of
the
ozone
layer
and
the
Clean
Air
Act
committed
the
U.
S.
to
phase
out
the
use
of
methyl
bromide,
the
U.
S.
Department
of
Agriculture
(
USDA)
initiated
a
research
program
to
find
viable
alternatives.
Finding
alternatives
for
agricultural
uses
is
extremely
complicated
compared
to
replacements
for
other,
industrially
used
ozone­
depleting
substances
because
many
factors
affect
the
efficacy
such
as:
crop
type,
climate,
soil
type,
and
target
pests,
which
change
from
region
to
region
and
among
localities
within
a
region.

Through
2002,
the
USDA
Agricultural
Research
Service
(
ARS)
alone
has
spent
US$
135.5
million
to
implement
an
aggressive
research
program
to
find
alternatives
to
methyl
bromide
(
see
Table
1
below).
Through
the
Cooperative
Research,
Education
and
Extension
Service,
USDA
has
provided
an
additional
$
11.4m
since
1993
to
state
universities
for
alternatives
research
and
outreach.
This
federally
supported
research
is
a
supplement
to
extensive
sector
specific
private
sector
efforts,
and
that
all
of
this
research
is
very
well
considered.
Specifically,
the
phaseout
challenges
brought
together
agricultural
and
forestry
leaders
from
private
industry,
academia,
state
governments,
and
the
federal
government
to
assess
the
problem,
formulate
priorities,
and
implement
research
directed
at
providing
solutions
under
the
USDA's
Methyl
Bromide
Alternatives
program.
The
ARS
within
USDA
has
22
national
programs,
one
of
which
is
the
Methyl
Bromide
Alternatives
program
(
Select
Methyl
Bromide
Alternatives
at
this
web
site:
http://
www.
nps.
ars.
usda.
gov
).
The
resulting
research
program
has
taken
into
account
these
inputs,
as
well
as
the
extensive
private
sector
research
and
trial
demonstrations
of
alternatives
to
methyl
bromide.
While
research
has
been
undertaken
in
all
sectors,
federal
government
efforts
have
been
based
on
the
input
of
experts
as
well
as
the
fact
that
nearly
80
percent
of
preplant
methyl
bromide
soil
fumigation
is
used
in
a
limited
number
of
crops.
Accordingly,
much
of
the
federal
government
pre­
plant
efforts
have
focused
on
strawberries,
tomatoes,
ornamentals,
peppers
and
nursery
crops,
(
forest,
ornamental,
strawberry,
pepper,
tree,
and
vine),
with
special
emphasis
on
tomatoes
in
Florida
and
strawberries
in
California
as
model
crops.

Table
1:
Methyl
Bromide
Alternatives
Research
Funding
History
Year
Expenditures
by
the
U.
S.
Department
of
Agriculture
(
US$
Million)
1993
$
7.255
1994
$
8.453
1995
$
13.139
1996
$
13.702
1997
$
14.580
1998
$
14.571
1999
$
14.380
2000
$
14.855
2001
$
16.681
2002
$
17.880
The
USDA/
ARS
strategy
for
evaluating
possible
alternatives
is
to
first
test
the
approaches
in
controlled
experiments
to
determine
efficacy,
then
testing
those
that
are
effective
in
field
plots.
The
impact
of
the
variables
that
affect
efficacy
is
addressed
by
conducting
field
trials
at
multiple
locations
with
different
crops
and
against
various
diseases
and
pests.
Alternatives
that
are
effective
in
field
plots
are
then
tested
in
field
scale
validations,
frequently
by
growers
in
their
own
fields.
University
scientists
are
also
participants
in
this
research.
Research
teams
that
include
ARS
and
university
scientists,
extension
personnel,
and
grower
representatives
meet
periodically
to
evaluate
research
results
and
plan
future
trials.

Research
results
submitted
with
the
CUE
request
packages
(
including
published,
peer­
reviewed
studies
by
(
primarily)
university
researchers,
university
extension
reports,
and
unpublished
studies)
include
trials
conducted
to
assess
the
effectiveness
of
the
most
likely
chemical
and
non­
chemical
alternatives
to
methyl
bromide,
including
some
potential
alternatives
that
are
not
currently
included
in
the
MBTOC
list.

As
demonstrated
by
the
table
above,
U.
S.
efforts
to
research
alternatives
for
methyl
bromide
have
been
substantial,
and
they
have
been
growing
in
size
as
the
phaseout
has
approached.
The
United
States
is
committed
to
sustaining
these
research
efforts
in
the
future
to
continue
to
aggressively
search
for
technically
and
economically
feasible
alternatives
to
methyl
bromide.
We
are
also
committed
to
continuing
to
share
our
research,
and
enable
a
global
sharing
of
experience.
Toward
that
end,
for
the
past
several
years,
key
U.
S.
government
agencies
have
collaborated
with
industry
to
host
an
annual
conference
on
alternatives
to
methyl
bromide.
This
conference,
the
Methyl
Bromide
Alternatives
Outreach
(
MBAO),
has
become
the
premier
forum
for
researchers
and
others
to
discuss
scientific
findings
and
progress
in
this
field.

The
post­
harvest
commodity
sector
has
invested
substantial
time
and
funding
into
research
and
development
of
technically
and
economically
feasible
alternatives
to
methyl
bromide.
Past
and
current
research
focuses
on
the
biology
and
ecology
of
the
pests,
primarily
insects.
To
implement
non­
chemical
controls
and
reduce
methyl
bromide
use
requires
a
thorough
understanding
of
the
pests
in
order
to
exploit
their
weaknesses.
Some
of
these
studies
have
focused
on
the
effects
of
temperature
and
humidity
on
the
fecundity,
development,
and
longevity
of
a
specific
species.
Other
studies
have
addressed
the
structural
preferences
and
microhabitat
requirements
of
a
species.
Studies
of
factors
affecting
population
growth
(
interactions
within
and
among
species)
have
been
conducted.
IPM
and
sanitation
methods
are
also
under
investigation.
This
includes
storage
facility
design
and
engineering
modifications
for
pest
exclusion.
Another
area
of
study
is
insect­
resistant
packaging.
In
fact,
new
research
is
demonstrating
a
potential
to
incorporate
chemical
repellents
into
packaging
materials
(
Arthur
and
Phillips
2003).
Further
studies
with
pheromones
and
trapping
strategies
are
helping
to
improve
IPM
in
commodity
storage
facilities.

The
number
of
available
insecticides
that
can
be
used
in
commodity
storage
facilities
in
the
U.
S.
has
declined
in
recent
years.
Sulfuryl
fluoride
is
toxic
to
stored­
product
pests
but
requires
long
exposures
to
kill
insect
eggs
(
Arthur
and
Phillips
2003).
The
research
and
development
of
chemical
alternatives
to
be
used
by
this
sector
is
a
critical
need
in
the
U.
S.

The
resulting
research
program
has
taken
into
account
these
inputs,
as
well
as
an
estimated
US$
20
million
spent
by
the
private
sector
to
fund
research
and
trial
demonstrations
of
alternatives
to
methyl
bromide.
For
the
post­
harvest
commodity
storage
sector,
the
following
studies
are
government­
funded:

Biology
and
Management
of
Food
Pests
(
Oct
2002­
Sep
2007)
 
The
objectives
of
this
study
are
to:
1)
Examine
the
reproductive
biology
and
behavior
of
storage
weevils,
Indian
meal
moth,
and
red
and
confused
flour
beetles.
2)
Determine
the
influence
of
temperature
on
the
population
growth,
mating
and
development
of
storage
pests,
specifically
storage
weevils,
Indian
meal
moth,
and
red
and
confused
flour
beetles.
3)
Examine
the
use
of
CO2
concentrations
within
a
grain
mass
to
predict
storage
weevils
and
flour
beetle
population
growth.
4).
Examine
the
use
of
alternative
fumigants
on
insect
mortality
(
ozone,
sagebrush,
Profume).

Postharvest
Pest
Management
with
Novel
Heating
Techniques
(
Sep
2000
­
Sep
2004)
­
This
study
aims
to
replace
postharvest
fumigation
by
scientifically
sound,
environmentally
friendly,
economically
feasible,
consumer
acceptable
pest
control
methods
for
US
agriculture
products.
Goals
include
studying
fundamental
kinetics
for
thermal
mortality
of
most
commonly
encountered
pest
arthropods
in
nuts
and
fruits,
such
as
codling
moths,
navel
orangeworms,
Indian
meal
moths
and
spider
mites,
in
order
to
develop
a
practical
thermal
method
to
replace
chemical
fumigation
by
using
electromagnetic
energy
at
radio
and
microwave
frequencies.

Chemically
Based
Alternatives
to
Methyl
Bromide
for
Postharvest
and
Quarantine
Pests
(
Jul
2000
­
Dec
2004)
 
This
study
will
focus
on
developing
quarantine/
postharvest
control
strategies
using
chemicals
to
reduce
arthropod
pests
in
durable
and
perishable
commodities.
Objectives
include:
1)
Develop
new
fumigants
and/
or
strategies
to
reduce
methyl
bromide
use.
2)
Develop
technology
and
equipment
to
reduce
methyl
bromide
emissions
to
the
atmosphere.
3)
Develop
system
approaches
for
control
using
chemicals
combined
with
non­
chemical
methodologies
which
will
yield
integrated
pest
control
management
programs.
4)
Develop
methods
to
detect
insect
infestations.

Indian
Meal
Moth
Granulosis
Virus
As
An
Alternative
to
Mb
for
Protection
of
Dried
Fruits
and
Nuts
(
Mar
2001
­
Oct
2002)
 
This
study
will
determine
the
efficacy
and
persistence
of
the
Indian
meal
moth
granulosis
virus
applied
topically
or
with
complete
coverage
as
a
protectant
for
walnuts,
raisins,
almonds,
pistachios
and
dried
lima
beans.
Determine
inactivation
by
high
temperatures
and
existing/
candidate
fumigants.
Determine
attractancy
and
survival
of
larvae
to
the
complete
formulation
and
components.

Vacuum­
Hermetic
Fumigation
As
An
Alternative
to
Methyl
Bromide
for
Control
of
Postharvest
Pests
(
Oct
2001
­
Dec
2002)
 
The
objective
of
this
study
is
to
determine
the
effectiveness
of
vacuum­
hermetic
fumigation
for
controlling
Post­
harvest
pests
by
developing
a
treatment
schedule
that
is
lethal
to
pests
and
innocuous
to
Post­
harvest
commodities.

Non­
Chemical
Pest
Control
in
Fruits
and
Nuts
Using
Electromagnetic
Energy
(
Sep
2000
­
Sep
2004)
­­
The
objective
of
this
study
is
to
develop
an
economical
system
using
microwaves
or
radio­
frequency
heating
to
disinfest
post­
harvest
walnuts
of
insect
pests.
Project
also
will
demonstrate
the
efficacy
of
the
system
to
processors,
and
document
the
effect
of
the
method
on
product
quality.

Research
results
submitted
with
the
CUE
request
packages,
including
published,
peer­
reviewed
studies,
university
extension
reports,
and
unpublished
studies
include
trials
conducted
to
assess
the
effectiveness
of
the
most
likely
chemical
and
non­
chemical
alternatives
to
methyl
bromide,
including
potential
alternatives
not
currently
included
in
the
MBTOC
list.

Modern
studies
on
stored­
product
fumigant
efficacy
entail
more
than
simply
establishing
a
mortality
dosage.
For
example,
with
regard
to
improving
fumigant
efficacy,
topics
researchers
are
presently
investigating
include
minimizing
dosages
and
studying
the
manner
in
which
compounds
work,
how
they
are
affected
by
physical
conditions,
and
how
to
avoid
or
counter
pest
resistance.
Resistance
is
also
a
pertinent
topic,
as
many
pests
have
recently
begun
to
develop
resistance
to
phosphine,
a
technically
feasible
alternative
to
methyl
bromide.
For
phosphine,
the
tolerance
spectrum
among
susceptible
strains
is
quite
wide.
While
there
has
been
substantial
industry­
wide
research
to
improve
and
maintain
safe
storage
practices,
consumer
demands
for
food
safety
and
quality
are
very
high
in
the
U.
S.
Further,
technology
upgrades
require
substantial
capital
outlays.
Although
fumigation
is
still
heavily
relied
upon
in
order
to
combat
and
prevent
pest
outbreaks
and
infestations
in
stored
commodities,
the
U.
S.
commodity
storage
industries
are
committed
to
further
investigations
for
alternatives
to
methyl
bromide.

Recent
research
has
shown
that
combination
methods
of
fumigation
involving
low
phosphine
levels,
high
temperatures,
and
high
carbon
dioxide
levels
for
24
hour
periods
in
sealed
structures
have
the
potential
for
replacing
some
methyl
bromide
treatments
of
stored
food
products.

Studies
carried
out
at
the
University
of
Purdue
in
the
mid
1990s
by
David
K.
Mueller
revealed
that
exposure
to
low
phosphine
levels
(
65­
100
parts
per
million
or
9%
­
19%
of
standard
phosphine
concentration),
heat
(
32­
37EC),
and
4%
­
6%
carbon
dioxide
produced
100%
mortality
in
test
stored
product
insects
(
eggs,
larvae,
and
pupae
of
Angoumois
grain
moth,
red
flour
beetle,
warehouse
beetle,
and
rice
weevil).
The
process
relies
on
heat
and
carbon
dioxide
to
increase
the
susceptibility
of
insects
to
phosphine
by
interfering
with
insect
metabolism.
Using
low
concentrations
of
phosphine
reduces
the
chance
of
corrosion
of
copper
in
electric
connections
and
equipment,
a
common
problem
associated
with
phosphine
use.
Heat
and
carbon
dioxide
help
reduce
moisture,
which
tends
to
contribute
to
corrosion.
This
treatment
requires
a
high
level
of
precision
in
order
to
maintain
the
desired
phosphine
and
carbon
dioxide
concentrations
and
heat
levels.
This
area
of
research
continues.

Additional
proceedings
from
the
6th
International
Working
Conference
on
Stored­
product
Protection
claim
that
carbon
dioxide
with
high
pressure
followed
by
sudden
pressure
loss
provides
a
safe
means
of
insect
control
leaving
no
residues,
however,
further
research
is
needed
to
determine
the
relationship
between
time
and
pressure,
the
efficacy
of
this
technique
on
immature
stages
of
different
species,
and
quality
effects
on
various
commodities,
specifically
walnuts.
(
Appendix
1).

The
California
walnut
industry
has
spent
US$
958,000
since
1992
researching
alternatives
to
methyl
bromide.
Industry
leadership
meets
several
times
annually
to
determine
future
directions
for
research,
as
well
as
to
discuss
general
trends
with
respect
to
post
harvest
alternatives.
Numerous
studies
on
alternatives
such
as
controlled
atmospheres,
Phosphine
in
combination,
magtoxin,
phostoxin,
the
IMM
granulosis
virus,
and
sulfuryl
fluoride
have
been
financed
and
conducted
since
1992.
Magtoxin
has
proven
to
be
more
effective
that
phostoxin,
as
phostoxin
creates
odors
in
walnuts
due
to
absorption;
phosphine
"
may
not
be
an
effective
commodity
disinfestation
treatment
on
certain
whole
nuts
because
it
is
highly
and
rapidly
sorbed
by
the
nuts
and
results
in
insufficient
phosphine
concentration
for
insect
control".

Within
the
next
two
years,
radio
frequence
waves
will
be
tested,
and
according
to
Mitcham
et
al,
"
if
this
method
can
be
economically
integrated
into
the
packing
process,
it
would
appear
to
have
excellent
potential
as
a
disinfestation
method
for
in­
shell
walnuts."
This
treatment
requires
only
a
few
minutes
of
exposure,
does
not
involve
chemical
applications,
and
there
are
no
foreseen
consumer
marketing
issues.
However,
studies
to
date
have
not
yet
been
conducted
on
commercial
production
scales,
and
economic
analysis
of
the
additional
cost
per
unit
mass
basis
is
warranted
to
determine
this
alternative's
economic
feasibility.
A
demonstration
of
radio
frequency
waves
to
industry
leaders
is
scheduled
for
February
2002,
to
further
determine
the
possibility
of
implementation
on
a
commercial
scale.
The
walnut
industry
has
also
reduced
its
reliance
on
methyl
bromide
using
Phosphine
in
combination
where
possible,
once
the
receiving
process
has
been
complete.
Phosphine
in
combination
takes
three
days
to
effect
insect
kill.
One
other
helpful
alternative,
also
relevant
to
the
pistachio
sector,
is
the
increased
availability
of
the
contact
pesticide
granulosis
virus,
to
control
outbreaks
of
the
Indian
meal
moth.
Additionally,
the
walnut
industry
collaborates
extensively
with
the
USDA,
is
supportive
of
efforts
of
chemical
companies
to
conduct
more
trials
using
sulfuryl
fluoride
on
foods,
and
pending
the
registration
of
sulfuryl
fluoride.

The
California
pistachio
industry
has
also
funded
efficacy
and
residue
studies
for
sulfuryl
fluoride,
a
fumigant
that
effectively
controls
many
adult
insect
pests
of
stored
products.
However,
its
low
effectiveness
against
insect
eggs
will
limit
its
potential
as
a
methyl
bromide
replacement.
Like
the
walnut
sector,
the
pistachio
industry
also
collaborates
extensively
with
the
USDA
in
Parlier,
CA
and
the
University
of
California
at
Davis
in
order
to
research
alternatives
to
methyl
bromide,
specifically
sulfuryl
fluoride.
Although
sulfuryl
fluoride
is
effective
against
adult
pests
and
de­
gasses
rapidly,
it
does
not
kill
eggs
and
is
not
yet
registered
for
use
on
food
products
in
the
U.
S.
Presently,
the
pistachio
sector
has
spent
US$
20,000
on
this
research.
In
addition,
the
industry
is
currently
testing
the
biological
control
agent
IMM
granulosis
virus;
laboratory
tests
have
demonstrated
positive
results
but
efficacy
in
a
commercial
setting
has
not
yet
been
demonstrated.
However,
this
biological
control
agent
is
expected
to
be
used
extensively
by
organic
growers.
The
applicant
also
donated
1
ton
of
pistachios
to
USDA
for
this
research,
and
the
tests
are
expected
to
be
completed
by
approximately
September
2003.
Scientists
from
UC
Davis
are
presently
developing
a
proposal
to
research
radio
frequency
waves
as
another
alternative.
This
research
is
expected
to
conclude
in
approximately
two
years.

In
order
to
further
research
alternatives
to
methyl
bromide,
the
pistachio
sector
plans
to
investigate
the
following
options:

·
Improve
fumigant
efficacy
·
Develop
cost­
effective
gas
application
technology
 
Improve
the
feasibility
and
economic
viability
of
controlled
atmospheres,
heat
and
cold
treatments,
and
other
physical
control
techniques
 
Further
develop
potential
for
recapture/
recovery
systems
for
methyl
bromide
which
could
eliminate
or
substantially
reduce
the
release
of
methyl
bromide
into
the
atmosphere.
 
Reducing
the
dosage
of
methyl
bromide,
phosphine,
and
other
alternative
chemical
treatments
through
the
addition
of
synergists
or
displaced
fumigation
techniques.

Obviously
further
research
into
the
above­
mentioned
alternatives
will
warrant
significant
funding,
but
the
California
pistachio
industry
continues
to
support
technically
and
economically
feasible
alternatives.

The
California
bean
industry
intends
to
collaborate
extensively
with
the
University
of
California
Agricultural
Extension
program
in
the
near
future.
The
industry
also
tends
to
follow
recommendations
of
the
Dried
Bean
Board
when
deciding
what
effective
alternatives
to
implement.
Presently,
the
industry
uses
phostoxin
when
time
is
not
a
critical
factor,
but
because
of
the
extreme
need
for
a
12­
hour
fumigant
during
harvest
time,
future
research
must
focus
on
the
need
for
a
fast­
acting
fumigant
that
achieves
a
100%
mortality
rate.
California's
dried
fruit
industry
has
spent
approximately
US$
1,000,000
on
researching
alternatives
to
methyl
bromide.
Industry
also
supplies
commodities,
facilities,
equipment,
and
labor
as
needed,
though
some
of
the
research
is
carried
out
by
the
USDA.
The
following
studies
are
planned
for
2003:

 
Physical
treatments
for
postharvest
insects:
Determine
heat
tolerance
for
moth
species,
identify
stage
and
pest
species
most
tolerant
to
vacuums,
describe
response
of
cowpea
weevil
eggs
to
commercial
cold
storage
temperatures.
 
Navel
orangeworm
phenology
and
movement:
Determine
seasonal
prevalence
and
spatial
variation
during
the
first
crop
year.
 
Pheromone­
based
control
methods
in
the
orchard:
Begin
navel
orangeworm
mating
destruction
and
nitidulid
attract­
and­
kill.
 
Low
temperature
storage
as
a
component
of
integrated
postharvest
systems:
Complete
low
temperature
studies
for
eggs
of
Indian
meal
moth
and
navel
orangeworm
 
Potential
of
insect
pathogens:
Continue
walnut
GMO
work;
begin
gregarine
studies;
identify
multi­
host
pathogens.
 
Parasitoids
as
stored­
product
insects:
Document
reduction
of
insect
fragments
with
parasitoids.
 
Optimization
of
Indian
meal
moth
pheromone
trapping:
Obtain
purified
components
of
sex
pheromone,
begin
comparison
of
trap
baits.
 
Efficacy
of
chemicals
of
alternative
fumigants:
Determine
the
efficacy
of
propylene
oxide
and
carbon
dioxide
mixtures
against
a
variety
of
stored
product
insects.
 
Trapping
of
fumigants:
Determining
the
load
of
methyl
bromide
on
activated
carbon
after
repeated
use
and
the
effect
of
high
moisture
of
the
sorption
process.
 
Insect/
plant
volatiles
and
chemical
detection
of
infestations:
Test
and
calibrate
various
adsorbents
for
collection
efficiencies
for
commodity
and
insect
volatiles.
Begin
analyzing
volatiles
for
signature
patterns
from
insects
and
commodity.
 
Integration
of
chemical/
non­
chemical
techniques:
Integrate
technologies
developed
with
non­
chemical
alternatives
to
form
a
systems
approach.

The
California
dried
fruit
industry
also
funds
pre­
plant
studies
for
fruit,
nut,
and
vine
crops.

While
the
U.
S.
government's
role
to
find
alternatives
is
primarily
in
the
research
arena,
we
know
that
research
is
only
one
step
in
the
process.
As
a
consequence,
we
have
also
invested
significantly
in
efforts
to
register
alternatives,
as
well
as
efforts
to
support
technology
transfer
and
education
activities
with
the
private
sector.

Registration
Program
The
United
States
has
one
of
the
most
rigorous
programs
in
the
world
for
safeguarding
human
health
and
the
environment
from
the
risks
posed
by
pesticides.
While
we
are
proud
of
our
efforts
in
this
regard,
related
safeguards
do
not
come
without
a
cost
in
terms
of
both
money
and
time.
Because
the
registration
process
is
so
rigorous,
it
can
take
a
new
pesticide
several
years
(
3­
5)
to
get
registered
by
EPA.
It
also
takes
a
large
number
of
years
to
perform,
draft
results
and
deliver
the
large
number
of
health
and
safety
studies
that
are
required
for
registration.
U.
S.
registration
decisions
are
often
the
basis
for
other
countries'
pesticide
regulations,
which
means
that
the
benefits
from
assuring
human
and
environmental
safety
accrue
globally.
Few
countries,
particularly
in
the
developing
world,
have
the
resources
to
conduct
and
review
these
studies
nor
the
market
power
to
leverage
chemical
companies
to
perform
and
submit
the
necessary
data.
In
recognition
of
this
factor
the
USDA
has
provided
some
funding
to
help
enable
registration,
and
the
U.
S.
EPA
has
introduced
an
accelerated
review
process
for
chemicals
that
are
potential
alternatives
to
uses
of
methyl
bromide.
This
has
involved
a
significant
commitment
of
resources,
and
has
resulted
in
fast
track
review
of
methyl
bromide
alternatives,
such
as
sulfuryl
fluoride.
However,
much
work
remains
to
be
done.

The
U.
S.
EPA
regulates
the
use
of
pesticides
under
two
major
federal
statutes:
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA),
both
significantly
amended
by
the
Food
Quality
Protection
Act
of
1996
(
FQPA).
Under
FIFRA,
EPA
registers
pesticides
provided
its
use
does
not
pose
unreasonable
risks
to
humans
or
the
environment.
Under
FFDCA,
the
Agency
is
responsible
for
setting
tolerances
(
maximum
permissible
residue
levels)
for
any
pesticide
used
on
food
or
animal
feed.
With
the
passage
of
FQPA,
the
Agency
is
required
to
establish
a
single,
health­
based
standard
for
pesticides
used
on
food
crops
and
to
determine
that
establishment
of
a
tolerance
will
result
in
a
"
reasonable
certainty
of
no
harm"
from
aggregate
exposure
to
the
pesticide.

The
process
by
which
EPA
examines
the
ingredients
of
a
pesticide
to
determine
if
they
are
safe
is
called
the
registration
process.
The
Agency
evaluates
the
pesticide
to
ensure
that
it
will
not
have
any
adverse
effects
on
humans,
the
environment,
and
non­
target
species.
Applicants
seeking
pesticide
registration
are
required
to
submit
a
wide
range
of
health
and
ecological
effects
toxicity
data,
environmental
fate,
residue
chemistry
and
worker/
bystander
exposure
data
and
product
chemistry
data.
A
pesticide
cannot
be
legally
used
in
the
U.
S.
if
it
has
not
been
registered
by
EPA,
unless
it
has
an
exemption
from
regulation
under
FIFRA.

Since
1997,
the
Agency
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
Agency
currently
has
more
applications
pending
in
its
review
than
the
resources
to
evaluate
them,
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
EPA
to
initiate
its
review.
Once
the
review
process
begins,
it
takes
an
average
of
38
months
to
complete
the
registration.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
Agency
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
Agency's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
Agency
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
Agency
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized
The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
Methyl
Bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
The
work
group
conducted
six
workshops
in
Florida
and
California
(
states
with
the
highest
use
of
methyl
bromide)
with
growers
and
researchers
to
identify
potential
alternatives,
critical
issues,
and
grower
needs
covering
the
major
methyl
bromide
dependent
crops
and
post
harvest
uses.

This
coordination
has
resulted
in
key
registration
issues
(
such
as
worker
and
bystander
exposure
through
volatilization,
township
caps
and
drinking
water
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
US$
15
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
EPA's
participation
in
the
evaluation
of
research
grant
proposals
each
year
for
USDA's
US$
2.5
million
per
year
methyl
bromide
alternatives
research
has
further
ensured
close
coordination
between
the
U.
S.
government
and
the
research
community.
Since
1997,
the
U.
S.
EPA
has
registered
the
following
chemical/
use
combinations
as
part
of
its
commitment
to
expedite
the
review
of
methyl
bromide
alternatives:

 
2000:
Phosphine
in
combination
to
control
stored
product
insect
pests
 
2001:
Indian
Meal
Moth
Granulosis
Virus
to
control
Indian
meal
moth
in
stored
grains
EPA
is
currently
reviewing
several
additional
applications
for
registration
as
methyl
bromide
alternatives,
with
several
registration
eligibility
decisions
expected
in
the
next
several
years,
including:

 
Sulfuryl
fluoride
as
a
post­
harvest
fumigant
for
stored
commodities
While
these
activities
appear
promising,
it
must
be
noted
that
concerns
about
toxicity,
drinking
water
contamination,
and
the
release
of
air
pollutants
regarding
some
alternatives
presents
another
difficulty
that
may
restrict
use
since
some
of
the
affected
facilities
may
be
in
sensitive
areas
such
as
those
in
close
proximity
to
schools
and
homes.

It
must
be
emphasized,
however,
that
finding
potential
alternatives,
and
even
registering
those
alternatives
is
not
the
end
of
the
process.
Alternatives
must
be
tested
by
users
and
found
technically
and
economically
feasible
before
widespread
adoption
will
occur.
As
noted
by
TEAP,
a
specific
alternative,
once
available
may
take
two
or
three
cropping
seasons
of
use
before
efficacy
can
be
determined
in
the
specific
circumstance
of
the
user.
In
an
effort
to
speed
adoption
the
U.
S.
government
has
also
been
involved
in
these
steps
by
promoting
technology
transfer,
experience
transfer,
and
private
sector
training.

11.
Conclusion
and
Policy
Issues
Associated
with
the
Nomination
In
summary,
a
review
of
the
critical
use
exemption
criteria
in
Decision
IX/
6
demonstrates
that
the
Parties
clearly
understood
the
many
issues
that
make
methyl
bromide
distinctly
different
from
the
industrial
chemicals
previously
addressed
by
the
Parties
under
the
essential
use
process.
It
is
now
the
challenge
of
the
MBTOC,
TEAP
and
the
Parties
to
consider
the
national
submission
of
critical
use
nominations
in
the
context
of
that
criteria,
and
the
information
requirements
established
under
Decision
XIII/
11.

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
MBTOC
listed
potential
alternatives
for
the
commodity
sector
are
not
currently
technically
or
economically
feasible
from
the
standpoint
of
the
U.
S.
commodity
industry
covered
by
this
exemption
nomination.

In
addition,
we
have
demonstrated
that
we
have
and
will
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives
to
the
use
of
methyl
bromide
for
treating
stored
commodities.
It
must
be
stressed
that
the
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
an
unreasonable
adverse
effect
to
human
health
and
the
environment,
is
long
and
rigorous.
The
U.
S.
need
for
methyl
bromide
for
the
protection
of
stored
commodities
will
be
maintained
for
the
period
being
requested.

In
reviewing
this
nomination,
we
believe
that
it
is
important
for
the
MBTOC,
the
TEAP
and
the
Parties
to
understand
some
of
the
policy
issues
associated
with
our
request.
A
discussion
of
those
follows:

a.
Request
for
Aggregate
Exemption
for
All
Covered
Methyl
Bromide
Uses:
As
mandated
by
Decision
XIII/
11,
the
nomination
information
that
is
being
submitted
with
this
package
includes
information
requested
on
historic
use
and
estimated
need
in
individual
sectors.
That
said,
we
note
our
agreement
with
past
MBTOC
and
TEAP
statements
which
stress
the
dynamic
nature
of
agricultural
markets,
uncertainty
of
specific
production
of
any
one
crop
in
any
specific
year,
the
difficulty
of
projecting
several
years
in
advance
what
pest
pressures
might
prevail
on
a
certain
crop,
and,
the
difficulty
of
estimating
what
a
particular
market
for
a
specific
crop
might
look
like
in
a
future
year.
We
also
concur
with
the
MBTOC's
fear
that
countries
that
have
taken
significant
efforts
to
reduce
methyl
bromide
use
and
emissions
through
dilution
with
chloropicrin
may
be
experiencing
only
short
term
efficacy
in
addressing
pest
problems.
On
the
basis
of
those
factors,
we
urge
the
MBTOC
and
the
TEAP
to
follow
the
precedent
established
under
the
essential
use
exemption
process
for
Metered
Dose
Inhalers
(
MDIs)
in
two
key
areas.

First,
because
of
uncertainties
in
both
markets
and
the
future
need
for
individual
active
moieties
of
drugs,
the
TEAP
has
never
provided
a
tonnage
limit
for
each
of
the
large
number
of
active
moieties
found
in
national
requests
for
a
CFC
essential
use
exemption
for
MDIs,
but
has
instead
recommended
an
aggregate
tonnage
exemption
for
national
use.
This
has
been
done
with
an
understanding
that
the
related
country
will
ensure
that
the
tonnage
approved
for
an
exemption
will
be
used
solely
for
the
group
of
active
moieties/
MDIs
that
have
been
granted
the
exemption.
We
believe
that
the
factors
of
agricultural
uncertainty
surrounding
both
pest
pressures
in
future
year
crops,
and
efficacy
of
reduced
methyl
bromide
application
provide
an
even
stronger
impetus
for
using
a
similar
approach
here.
The
level
of
unpredictability
in
need
leads
to
a
second
area
of
similarity
with
MDIs,
the
essential
need
for
a
review
of
the
level
of
the
request
which
takes
into
account
the
need
for
a
margin
of
safety.
b.
Recognition
of
Uncertainty
in
Allowing
Margin
for
Safety:
With
MDIs,
it
was
essential
to
address
the
possible
change
in
patient
needs
over
time,
and
in
agriculture,
this
is
essential
to
address
the
potential
that
the
year
being
requested
for
could
be
a
particularly
bad
year
in
terms
of
weather
and
pest
pressure.
In
that
regard,
the
TEAP's
Chart
2
in
Appendix
D
demonstrates
the
manner
in
which
this
need
for
a
margin
of
safety
was
addressed
in
the
MDI
area.
Specifically,
Chart
2
in
Appendix
D
tracks
national
CFC
requests
for
MDIs
compared
with
actual
use
of
CFC
for
MDIs
over
a
number
of
years.

Chart
2
in
Appendix
D
demonstrates
several
things.
First,
despite
the
best
efforts
of
many
countries
to
predict
future
conditions,
it
shows
that
due
to
the
acknowledged
uncertainty
of
out­
year
need
for
MDIs,
Parties
had
the
tendency
to
request,
the
TEAP
recommended,
and
the
Parties
approved
national
requests
that
turned
out
to
include
an
appreciable
margin
of
safety.
In
fact,
this
margin
of
safety
was
higher
at
the
beginning
 
about
40%
above
usage
 
and
then
went
down
to
30%
range
after
4
years.
Only
after
5
years
of
experience
did
the
request
come
down
to
about
10%
above
usage.
While
our
experience
with
the
Essential
Use
process
has
aided
the
U.
S.
in
developing
its
Critical
Use
nomination,
we
ask
the
MBTOC,
the
TEAP
and
the
Parties
to
recognize
that
the
complexities
of
agriculture
make
it
difficult
to
match
our
request
exactly
with
expected
usage
when
the
nomination
is
made
two
to
three
years
in
advance
of
the
time
of
actual
use.

Chart
2
in
Appendix
D
also
demonstrates
that,
even
though
MDI
requests
included
a
significant
margin
of
safety,
the
nominations
were
approved
and
the
countries
receiving
the
exemption
for
MDIs
did
not
produce
the
full
amount
authorized
when
there
was
not
a
patient
need.
As
a
result,
there
was
little
or
no
environmental
consequence
of
approving
requests
that
included
a
margin
of
safety,
and
the
practice
can
be
seen
as
being
normalized
over
time.
In
light
of
the
similar
significant
uncertainty
surrounding
agriculture
and
the
out
year
production
of
crops
which
use
methyl
bromide,
we
wish
to
urge
the
MBTOC
and
TEAP
to
take
a
similar,
understanding
approach
for
methyl
bromide
and
uses
found
to
otherwise
meet
the
critical
use
criteria.
We
believe
that
this
too
would
have
no
environmental
consequence,
and
would
be
consistent
with
the
Parties
aim
to
phaseout
methyl
bromide
while
ensuring
that
agriculture
itself
is
not
phased
out.

c.
Duration
of
Nomination:
It
is
important
to
note
that
while
the
request
included
for
the
use
above
appears
to
be
for
a
single
year,
the
entire
U.
S.
request
is
actually
for
two
years
 
2005
and
2006.
This
multi­
year
request
is
consistent
with
the
TEAP
recognition
that
the
calendar
year
does
not,
in
most
cases,
correspond
with
the
cropping
year.
This
request
takes
into
account
the
facts
that
registration
and
acceptance
of
new,
efficacious
alternatives
can
take
a
long
time,
and
that
alternatives
must
be
tested
in
multiple
cropping
cycles
in
different
geographic
locations
to
determine
efficacy
and
consistency
before
they
can
be
considered
to
be
widely
available
for
use.
Finally,
the
request
for
multiple
years
is
consistent
with
the
expectation
of
the
Parties
and
the
TEAP
as
evidenced
in
the
Parties
and
MBTOC
request
for
information
on
the
duration
of
the
requested
exemption.
As
noted
in
the
Executive
Summary
of
the
overall
U.
S.
request,
we
are
requesting
that
the
exemption
be
granted
in
a
lump
sum
of
9,920,965
kilograms
for
2005
and
9,445,360
kilograms
for
2006.
While
it
is
our
hope
that
the
registration
and
demonstration
of
new,
cost
effective
alternatives
will
result
in
even
speedier
reductions
on
later
years,
the
decrease
in
our
request
for
2006
is
a
demonstration
of
our
commitment
to
work
toward
further
reductions
in
our
consumption
of
methyl
bromide
for
critical
uses.
At
this
time,
however,
we
have
not
believed
it
possible
to
provide
a
realistic
assessment
of
exactly
which
uses
would
be
reduced
to
account
for
the
overall
decrease.
12.
Contact
Information
For
further
general
information
or
clarifications
on
material
contained
in
the
U.
S.
nomination
for
critical
uses,
please
contact:

John
E.
Thompson,
Ph.
D.
Office
of
Environmental
Policy
US
Department
of
State
2201
C
Street
NW
Rm
4325
Washington,
DC
20520
tel:
202­
647­
9799
fax:
202­
647­
5947
e­
mail:
ThompsonJE2@
state.
gov
Alternate
Contact:
Denise
Keehner,
Director
Biological
and
Economic
Analysis
Division
Office
of
Pesticides
Programs
US
Environmental
Protection
Agency,
7503C
Washington,
DC
20460
tel:
703­
308­
8200
fax:
703­
308­
8090
e­
mail:
methyl.
bromide@
epa.
gov
13.
References
Agricultural
Statistics
Service,
California
Walnut
Commission,
2001.

Arthur,
F.
and
T.
W.
Phillips.
2003.
Stored­
Product
Insect
Pest
Management
and
Control.
In:
Y.
H.
Hui,
B.
L
Bruinsma,
J.
R.
Gorham,
Wai­
Kit
Nip,
P.
S.
Tong,
and
P.
Ventresca,
eds.
Food
Plant
Sanitation.
Marcel
Dekker,
New
York.
pp.
341­
358.

Bell,
C.
H.
2000.
Fumigation
in
the
21st
Century.
Crop
Protection,
19:
563­
69..

California
Walnut
Commission.
California
Walnut
Acreage
and
Crop
Value.
California
Agricultural
Statistics
Service,
California
Walnut
Commission,
2001.

California
Walnut
Commission
&
Walnut
Marketing
Board
Methyl
Bromide
Critical
Use
Exemption
Request,
September
6,
2002.

Carpenter,
Janet,
Leonard
Gianessi,
and
Lori
Lynch.
The
Economic
Impact
of
the
Scheduled
U.
S.
Phase­
out
of
Methyl
Bromide.
National
Center
for
Food
and
Agricultural
Policy.
2000.

Fields,
P.
G.
1992.
The
Control
of
Stored­
Product
Insects
and
Mites
with
Extreme
Temperatures.
J.
Stored
Products
Res.
28:
89­
118.
Frate,
C.,
K.
Klonsky
and
R.
DeMoura.
"
Sample
Costs
to
Produce
Blackeye
Beans,
Single
Crop."
University
of
California
Cooperative
Extension,
Davis,
California,
2001.

Fuentes,
C.
2002.
Biologist
Review
of
the
Methyl
Bromide
Critical
Use
Exemption
Application
(
CUE
02­
0019)
for
California
Pistachio
Processors.

Green,
Richard
D.
"
Demand
for
California
Agricultural
Commodities."
UC
Davis,
Winter,
1999.

Industrial
Economics,
Inc.
Financial
Profile
analyses
for
the
critical
use
exemption
application
for
structural
uses.
Summary
Report
Prepared
for
the
U.
S.
EPA.
November,
2002.

Leesch,
J.
G.
2002a.
Biologist
Review
of
the
Methyl
Bromide
Critical
Use
Exemption
Application
(
CUE
02­
0002)
for
Dried
(
Black­
eye)
and
Garbanzo.

Leesch,
J.
G.
2002b.
Biologist
Review
of
the
Methyl
Bromide
Critical
Use
Exemption
Application
(
CUE
02­
0033)
for
Gwaltney
of
Smithfield
(
Cured
Hams).

Lynch,
Lori
and
Janet
Carpenter.
The
Economic
Impact
of
Banning
Methyl
Bromide:
Where
Do
We
Need
More
Research.
in
Proceedings
of
the
1999
Annual
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reduction.

Lynch,
Lori
and
Bruce
McWilliams,
and
David
Zilberman.
Economic
Implications
of
Banning
Methyl
Bromide:
How
have
They
Changed
with
Recent
Development?.
in
Proceedings
of
the
1997
Annual
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reduction.

Navarro,
S.,
E.
Donahaye,
G.
Sabio,
M.
Rinder,
R.
Dias,
and
A.
Azrieli.
Reducing
MB
dosage
or
exposure
time
using
CO2
with
MB
or
CO2
with
heat.
1999
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions
Throne,
J.
2002a.
Biologist
Review
of
the
Methyl
Bromide
Critical
Use
Exemption
Application
(
CUE
02­
0015)
for
Dried
Fruits
(
Prunes,
Figs,
and
Raisins).

Throne,
J.
2002b.
Biologist
Review
of
the
Methyl
Bromide
Critical
Use
Exemption
Application
(
CUE
02­
0030)
for
California
Walnut
Commission
and
Walnut
Marketing
Board.

U.
S.
Department
of
Agriculture.
World
Pistachio
in
Millions
of
Lbs.
Economic
Research
Service.
2002.

U.
S.
Department
of
Agriculture.
Economic
Implications
of
the
Methyl
Bromide
Phaseout.
An
Economic
Research
Report.
Economic
Research
Service.
2000.

VanSickle,
John
J.,
Chalene
Brewster,
and
Thomas
H.
Spreen.
Impact
of
a
Methyl
Bromide
Ban
on
the
U.
S.
Vegetable
Industry.
University
of
Florida,
2000.

14.
Appendices
Appendix
A.
List
of
Critical
Use
Exemption
(
CUE)
requests
for
the
Commodity
Sector
in
the
U.
S.

CUE
02­
0002,
California
Bean
Shippers
Associations
in
Storage
CUE
02­
0015,
California
Dry
Prune
Board
CUE
02­
0019,
California
Pistachio
Processors
CUE
02­
0030,
California
Walnut
Commission
CUE
02­
0033,
Gwaltney
of
Smithfield
(
Ham)
Appendix
B:
Spreadsheets
Supporting
Economic
Analyses
This
appendix
presents
the
calculations,
for
each
sector,
that
underlie
the
economic
analysis
presented
in
the
main
body
of
the
nomination
chapter.
As
noted
in
the
nomination
chapter,
each
sector
is
comprised
of
a
number
of
applications
from
users
of
methyl
bromide
in
the
United
States,
primarily
groups
(
or
consortia)
of
users.
The
tables
below
contain
the
analysis
that
was
done
for
each
individual
application,
prior
to
combining
them
into
a
sector
analysis.
Each
application
was
assigned
a
unique
number
(
denoted
as
CUE
#),
and
an
analysis
was
done
for
each
application
for
technically
feasible
alternatives.
Some
applications
were
further
sub­
divided
into
analyses
for
specific
sub­
regions
or
production
systems.
A
baseline
analysis
was
done
to
establish
the
outcome
of
treating
with
methyl
bromide
for
each
of
these
scenarios.
Therefore,
the
rows
of
the
tables
correspond
to
the
production
scenarios,
with
each
production
scenario
accounting
for
row
and
the
alternative(
s)
accounting
for
additional
rows.

The
columns
of
the
table
correspond
to
the
estimated
impacts
for
each
scenario.
(
The
columns
of
the
table
are
spread
over
several
pages
because
they
do
not
fit
onto
one
page.)
The
impacts
for
the
methyl
bromide
baseline
are
given
as
zero
percent,
and
the
impacts
for
the
alternatives
are
given
relative
to
this
baseline.
Loss
estimates
include
analyses
of
yield
and
revenue
losses,
along
with
estimates
of
increased
production
costs.
Losses
are
expressed
as
total
losses,
as
well
as
per
unit
treated
and
per
kilogram
of
methyl
bromide.
Impacts
on
profits
are
also
provided.

After
the
estimates
of
economic
impacts,
the
tables
contain
basic
information
about
the
production
systems
using
methyl
bromide.
These
columns
include
data
on
output
price,
output
volume,
and
total
revenue.
There
are
also
columns
that
include
data
on
methyl
bromide
prices
and
amount
used,
along
with
data
on
the
cost
of
alternatives,
and
amounts
used.
Additional
columns
describe
estimates
of
other
production
(
operating)
costs,
and
fixed/
overhead
costs.

The
columns
near
the
end
of
the
tables
combine
individual
costs
into
an
estimate
of
total
production
costs,
and
compare
total
costs
to
revenue
in
order
to
estimate
profits.
Finally,
the
last
several
columns
contain
the
components
of
the
loss
estimates.
Commodity
(
CM)
Part
A
Sector
Summary
of
Economic
Estimates
Absolute
Loss
Per
Representative
Facility
CUE
#

02­
00
Secto
r

Applicant
Alternative
Technically
Feasible?
Representative
Facility
Size
Direct
Pest
Control
Costs
($
USD)
Capital
Expenditure
($
USD)
Production
Delays
($
USD)
Total
($
USD)
Loss
as
a
Percentage
of
Net
Revenue
Loss
as
per
Kilogram
of
Methyl
Bromide
Requested
($
USD)

2
CM
Bean
Shippers
Assn
methyl
bromide
0.3
million
cubic
feet
2
CM
Bean
Shippers
Assn
Phosphine
Y
0.3
million
cubic
feet
$
38,000
$
42,000
$
8,000
$
88,000
154%
$
218
15
CM
CA
Dried
Plum
Board
methyl
bromide
0.5
million
cubic
feet
15
CM
CA
Dried
Plum
Board
Phosphine
Y
0.5
million
cubic
feet
$
14,000
$
32,000
$
92,000
$
141,000
20%
$
414
19
CM
CA
Pistachio
methyl
bromide
1.1
million
cubic
feet
19
CM
CA
Pistachio
Phosphine
Y
1.1
million
cubic
feet
­$
10,000
$
18,000
$
1,510,000
$
1,518,000
48%
$
607
30
CM
CA
Walnut
methyl
bromide
0.3
million
cubic
feet
30
CM
CA
walnut
Phosphine
Y
0.3
million
cubic
feet
­$
81,000
$
519,000
$
1,308,000
$
1,746,000
12%
$
80
33
CM
Gwaltney
(
Ham)
methyl
bromide
Phosphine
N
Commodity
(
CM)
Part
B
Sector
Summary
of
Economic
Estimates
Methyl
Bromide
or
Alternative
Costs
CUE
#

02­
00
Secto
r

Applicant
Alternative
Revenue
per
facility
($
USD)
Kg
ai
that
would
be
applied
per
facility
Units
of
product
applied
per
facility
Unit
Methyl
Bromide
cost
per
facility
($
USD)
Methyl
Bromide
cost
per
kgs
($
USD)
Appli­

cation
&

other
costs
($
USD)
Annual
cost
per
facility
($
USD)
Cost
of
Goods
Sold
($
USD)
Net
Revenue
($
USD)
Loss
as
a
%
of
Net
Revenue
Loss
per
kilograms
of
Methyl
Bromide
($
USD)

2
CM
Bean
Shippers
Assn
methyl
bromide
$
2,174,000
888
404
kg
ai
$
3,019.20
$
7.47
$
112,211
$
115,230
$
2,001,602
$
57,168
0%
$
0
2
CM
Bean
Shippers
Assn
Phosphine
$
2,174,000
$
153,000
$
2,001,602
­$
30,832
154%
$
218
15
CM
CA
Dried
Plum
Board
methyl
bromide
$
11,300,000
750
341
kg
ai
$
2,250.00
$
6.60
$
8,150
$
10,400
$
10,599,400
$
690,200
0%
$
0
15
CM
CA
Dried
Plum
Board
Phosphine
$
11,300,000
$
20,800
$
10,599,400
$
549,200
20%
414
19
CM
CA
Pistachio
methyl
bromide
$
178,200,000
5,500
2,500
kg
ai
$
16,500.00
$
6.60
$
80,025
$
96,525
$
174,992,400
$
3,111,075
0%
$
0
19
CM
CA
Pistachio
Phosphine
$
178,200,000
$
86,525
$
174,992,400
$
1,593,075
49%
$
607
30
CM
CA
Walnut
methyl
bromide
$
237,700,000
48,221
21,919
kg
ai
$
65,755.91
$
3.00
$
646,244
$
712,000
$
222,249,500
$
14,738,500
0.00%
$
0
30
CM
CA
walnut
Phosphine
$
237,700,000
$
631,000
$
222,249,500
$
12,992,500
12%
$
80
33
CM
Gwaltney
(
Ham)
methyl
bromide
Phosphine
34
Appendix
C:
U.
S.
Technical
and
Economic
Review
Team
Members
Christine
M.
Augustyniak
(
Technical
Team
Leader).
Christine
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1985.
She
has
held
several
senior
positions,
both
technical
and
managerial,
including
Special
Assistant
to
the
Assistant
Administrator
for
Prevention,
Pesticides,
and
Toxic
Substances,
Chief
of
the
Analytical
Support
Branch
in
EPA's
office
of
Environmental
Information
and
Deputy
Director
for
the
Environmental
Assistance
Division
in
the
Office
of
Pollution
Prevention
and
Toxics.
She
earned
her
Ph.
D.
(
Economics)
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Augustyniak
is
a
1975
graduate
of
Harvard
University
(
Cambridge)
cum
laude
(
Economics).
Prior
to
joining
EPA,
Dr.
Augustyniak
was
a
member
of
the
economics
faculty
at
the
College
of
the
Holy
Cross
(
Worcester).

William
John
Chism
(
Lead
Biologist).
Bill
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2000.
He
evaluates
the
efficacy
of
pesticides
for
weed
and
insect
control.
He
earned
his
Ph.
D.
(
Weed
Science)
from
Virginia
Polytechnic
Institute
and
State
University
(
Blacksburg),
a
Master
of
Science
(
Plant
Physiology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Agriculture)
from
California
Polytechnic
State
University
(
San
Luis
Obispo).
Dr.
Chism
is
a
1978
graduate
of
The
University
of
California
(
Davis).
For
ten
years
prior
to
joining
the
EPA
Dr.
Chism
held
research
scientist
positions
at
several
speciality
chemical
companies,
conducting
and
evaluating
research
on
pesticides.

Technical
Team
Jonathan
J.
Becker
(
Biologist)
Jonathan
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
has
held
several
technical
positions
and
currently
serves
as
a
Senior
Scientific
Advisor
within
the
Office
of
Pesticides
Programs.
In
this
position
he
leads
the
advancement
of
scientific
methods
and
approaches
related
to
the
development
of
pesticides
use
information,
the
assessment
of
impacts
of
pesticides
regulations,
and
the
evaluation
of
the
benefits
from
the
use
of
pesticides.
He
earned
his
Ph.
D.
(
Zoology)
from
The
University
of
Florida
(
Gainesville)
and
a
Masters
of
Science
(
Biology/
Zoology)
from
Idaho
State
University
(
Pocatello).
Dr.
Becker
is
a
graduate
of
Idaho
State
University.
Prior
to
joining
EPA,
Dr.
Becker
worked
as
a
senior
environmental
scientist
with
an
environmental
consulting
firm
located
in
Virginia.

Diane
Brown­
Rytlewski
(
Biologist)
Diane
is
the
Nursery
and
Landscape
IPM
Integrator
at
Michigan
State
University,
a
position
she
has
held
since
2000.
She
acts
as
liaison
between
industry
and
the
university,
facilitating
research
partnerships
and
cooperative
relationships,
developing
outreach
programs
and
resource
materials
to
further
the
adoption
of
IPM.
Ms.
Rytlewski
holds
a
Master
of
Science
(
Plant
Pathology)
and
a
Bachelor
of
Science
(
Entomology),
both
from
the
University
of
Wisconsin
(
Madison).
She
has
over
twenty
year
experience
working
in
the
horticulture
field,
including
eight
years
as
supervisor
of
the
IPM
program
at
the
Chicago
Botanic
Garden.

Greg
Browne
(
Biologist).
Greg
has
been
with
the
Agricultural
Research
Service
of
the
U.
S.
Department
of
Agriculture
since
1995.
Located
in
the
Department
of
Plant
Pathology
of
the
University
of
California
(
Davis),
Greg
does
research
on
soilborne
diseases
of
crop
systems
that
currently
use
methyl
bromide
for
disease
control,
with
particular
emphasis
on
diseases
caused
by
Phytophthora
species.
He
is
the
author
of
numerous
articles
on
the
use
of
alternatives
to
methyl
bromide
for
the
control
of
diseases
in
fruit
and
nut
crops
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
the
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
the
same
institution.
Dr.
Browne
is
a
graduate
of
The
University
of
California
(
Davis).
Prior
to
joining
USDA
was
a
farm
advisor
in
Kern
County.

Nancy
Burrelle
(
Biologist).
Nancy
Burelle
is
a
Research
Ecologist
with
USDA's
Agricultural
Research
Service,
currently
working
on
preplant
alternatives
to
methyl
bromide.
She
earned
both
her
Ph.
D.
and
Master
of
Science
degrees
(
both
in
Plant
Pathology)
from
Auburn
University
(
Auburn).
35
Linda
Calvin
(
Economist).
Linda
Calvin
is
an
agricultural
economist
with
USDA's
Economic
Research
Service,
specializing
in
research
on
topics
affecting
fruit
and
vegetable
markets.
She
earned
her
Ph.
D.
(
Agricultural
Economics)
from
The
University
of
California
(
Berkeley).

Kitty
F.
Cardwell
(
Biologist).
Kitty
has
been
the
National
Program
Leader
in
Plant
Pathology
for
the
U.
S.
Department
of
Agriculture
Cooperative
State
Research,
Extension
and
Education
Service
since
2001.
In
this
role
she
administrates
all
federally
funded
research
and
extension
related
to
plant
pathology,
of
the
Land
Grant
Universities
throughout
the
U.
S.
She
earned
her
Ph.
D.
(
Phytopathology)
from
Texas
A&
M
University
(
College
Station).
Dr.
Cardwell
is
a
1976
graduate
of
The
University
of
Texas
(
Austin)
cum
laude
(
Botany).
For
twelve
years
prior
to
joining
USDA
Dr.
Cardwell
managed
multinational
projects
on
crop
disease
mitigation
and
food
safety
with
the
International
Institute
of
Tropical
Agriculture
in
Cotonou,
Bénin
and
Ibadan,
Nigeria.

William
Allen
Carey
(
Biologist).
Bill
is
a
Research
Fellow
in
pest
management
for
southern
forest
nurseries
,
supporting
the
Auburn
University
Southern
Forest
Nursery
Management
Cooperative.
He
is
the
author
of
numerous
articles
on
the
use
of
alternative
fumigants
to
methyl
bromide
in
tree
nursery
applications.
He
earned
his
Ph.
D.
(
Forest
Pathology)
from
Duke
University
(
Durham)
and
a
Master
of
Science
(
Plant
Pathology
)
from
The
University
of
Florida
(
Gainesville).
Dr.
Carey
is
a
nationally
recognized
expert
in
the
field
of
nursery
pathology.

Margriet
F.
Caswell
(
Economist).
Margriet
has
been
with
the
USDA
Economic
Research
Service
since
1991.
She
has
held
both
technical
and
managerial
positions,
and
is
now
a
Senior
Research
Economist
in
the
Resource,
Technology
&
Productivity
Branch,
Resource
Economics
Division.
She
earned
her
Ph.
D.
(
Agricultural
Economics)
from
the
University
of
California
(
Berkeley).
Dr.
Caswell
also
received
a
Master
of
Science
(
Resource
Economics)
and
Bachelor
of
Science
(
Natural
Resource
Management)
from
the
University
of
Rhode
Island
(
Kingston).
Prior
to
joining
USDA,
Dr.
Caswell
was
a
member
of
both
the
Environmental
Studies
and
Economics
faculties
at
the
University
of
California
at
Santa
Barbara.

Tara
Chand­
Goyal
(
Biology).
Tara
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
a
plant
pathologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
risk
reduction.
He
earned
his
Ph.
D.
(
Mycology
and
Plant
Pathology)
from
The
Queen's
University
(
Belfast)
and
a
Master
of
Science
(
Plant
Pathology
and
Mycology)
from
Punjab
University
(
Ludhiana).
Dr.
Chand­
Goyal
is
a
graduate
of
Punjab
University.
Prior
to
joining
EPA
Dr.
Chand­
Goyal
was
a
member
of
the
faculty
of
The
Oregon
State
University
(
Corvallis)
and
of
The
University
of
California
(
Riverside).
His
areas
of
research
and
publication
include:
the
biology
of
viral,
bacterial
and
fungal
diseases
of
plants;
biological
control
of
plant
diseases;
and,
genetic
manipulation
of
microorganisms.

Daniel
Chellemi
(
Biologist).
Dan
has
been
a
research
plant
pathologist
with
the
U.
S.
Department
of
Agriculture
since
1997.
His
research
speciality
is
the
ecology,
epidemiology,
and
management
of
soilborne
plant
pathogens.
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
The
University
of
Hawaii
(
Manoa).
Dr.
Chellemi
is
a
1982
graduate
of
the
University
of
Florida
(
Gainesville)
with
a
degree
in
Plant
Science.
He
is
the
author
of
numerous
articles
in
the
field
of
plant
pathology.
In
2000
Dr.
Chellemi
was
awarded
the
ARS
"
Early
Career
Research
Scientist
if
the
Year".
Prior
to
joining
USDA,
Dr.
Chellemi
was
a
member
of
the
plant
pathology
department
of
The
University
of
Florida
(
Gainesville).

Angel
Chiri
(
Biologist).
Angel
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.
He
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Biology/
Entomology)
from
California
State
University
(
Long
Beach).
Dr.
Chiri
is
a
graduate
of
California
State
University
(
Los
Angeles).
Prior
to
joining
EPA
Dr.
Chiri
was
a
pest
and
pesticide
management
advisor
for
the
U.
S.
Agency
for
International
Development
working
mostly
in
Latin
America
on
IPM
issues.
36
Colwell
Cook
(
Biologist).
Colwell
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2000.
She
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.
She
earned
her
Ph.
D.
(
Entomology)
from
Purdue
University
(
West
Lafayette)
and
has
a
Master
of
Science
(
Entomology)
from
Louisiana
State
University
(
Baton
Rouge).
Dr.
Cook
is
a
1979
graduate
of
Clemson
University.
Prior
to
joining
EPA
Dr.
Cook
held
several
faculty
positions
at
Wabash
College
(
Crawfordsville)
and
University
of
Evansville
(
Evansville).

Julie
B.
Fairfax
(
Biologist)
Julie
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
currently
serves
as
a
senior
biologist
in
the
Biological
and
Economics
Analysis
Division,
and
has
previously
served
as
a
Team
Leader
in
other
divisions
within
the
Office
of
Pesticides
Programs.
She
has
held
several
technical
positions
specializing
in
the
registration,
re­
registration,
special
review
and
regulation
of
fungicidal,
antimicrobial,
and
wood
preservative
pesticides.
Ms.
Fairfax
is
a
1989
graduate
of
James
Madison
University
(
Harrisonburg,
VA)
where
she
earned
her
degree
in
Biology.
Prior
to
joining
EPA,
Julie
worked
as
a
laboratory
technician
for
the
Virginia
Poultry
Industry.

John
Faulkner
(
Economist)
John
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
1989.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
imposed
by
the
regulation
of
pesticides.
He
earned
his
Ph.
D.
(
Economics)
from
the
University
of
Colorado
(
Boulder)
and
holds
a
Master's
of
Business
Administration
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Faulkner
is
a
1965
graduate
of
the
University
of
Colorado
(
Boulder).
Prior
to
joining
EPA
was
a
member
of
the
economics
faculty
of
the
Rochester
Institute
of
Technology
(
Rochester),
The
University
of
Colorado
(
Boulder)
and
of
the
Colorado
Mountain
College
(
Aspen).

Clara
Fuentes
(
Biologist).
Clara
has
been
with
the
U.
S.
Environmental
Protection
agency
since
1999,
working
in
the
Philadelphia,
Pennsylvania
(
Region
III)
office.
She
specializes
in
reviewing
human
health
risk
evaluations
to
pesticides
exposures
and
supporting
the
state
pesticide
programs
in
Region
III.
She
earned
her
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
a
Master
of
Science
(
Zoology)
from
Iowa
State
University
(
Ames).
Prior
to
joining
EPA,
Dr.
Fuentes
worked
as
a
research
assistant
at
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
(
ARS)
(
Beltsville),
Maryland,
and
as
a
faculty
member
of
the
Natural
Sciences
Department
at
InterAmerican
University
of
Puerto
Rico.
Her
research
interest
is
in
the
area
of
Integrated
Pest
Management
in
agriculture.

James
Gilreath
(
Biologist).
Jim
has
been
with
the
University
of
Florida
Gulf
Coast
Research
and
Education
Center
since
1981.
In
this
position
his
primary
responsibilities
are
to
plan,
implement
and
publish
the
results
of
investigations
in
weed
science
in
vegetable
and
ornamental
crops.
One
main
focus
of
the
research
is
the
evaluation
and
development
of
weed
amangement
programs
for
specific
weed
pests.
He
earned
his
Ph.
D.
(
Horticulture)
from
The
University
of
Florida
(
Gainesville)
and
a
Master
of
Science,
also
in
Horticulture,
from
Clemson
University
(
Clemson).
Dr.
Gilreath
is
a
1974
graduate
of
Clemson
University
(
Clemson)
with
a
degree
in
Agronomy
and
Soils.

Arthur
Grube
(
Economist).
Arthur
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1987.
He
is
now
a
Senior
Economist
in
the
Biological
and
Economics
Analysis
Division,
Office
of
Pesticide
Programs.
He
earned
his
Ph.
D.
(
Economics)
from
North
Carolina
State
University
(
Raleigh)
and
a
Masters
of
Arts
(
Economics)
also
from
North
Carolina
State
University.
Dr.
Grube
is
a
1970
graduate
of
Simon
Fraser
University
(
Vancouver)
where
his
Bachelor
of
Arts
degree
(
Economics)
was
earned
with
honors.
Prior
to
joining
EPA
Dr.
Grube
conducted
work
on
the
costs
and
benefits
of
pesticide
use
at
the
University
of
Illinois
(
Urbana).
Dr.
Grube
has
been
a
co­
author
of
a
number
of
journal
articles
in
various
areas
of
pesticide
economics
LeRoy
Hansen
(
Economist).
LeRoy
Hansen
is
currently
employed
as
an
Agricultural
Economist
for
the
USDA
Economic
Research
Service,
Resource
Economics
Division
in
the
Resources
and
Environmental
Policy
Branch.
37
He
received
his
Ph.
D.
in
resource
economics
from
Iowa
State
University
(
Ames)
in
1986.
During
his
16
years
at
USDA,
Dr.
Hansen
has
published
USDA
reports,
spoken
at
profession
meetings,
and
appeared
in
television
and
radio
interviews.

Frank
Hernandez
(
Economist).
Frank
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1991.
He
is
a
staff
economist
at
the
Biological
and
Economic
Analysis
Division
of
the
Office
of
Pesticide
Programs.
He
holds
degrees
in
Economics
and
Political
Science
from
the
City
University
of
New
York.

Arnet
W.
Jones
(
Biologist).
Arnet
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1990.
He
has
had
several
senior
technical
and
management
positions
and
currently
serves
as
Chief
of
the
Herbicide
and
Insecticide
Branch,
Biological
and
Economic
Analysis
Division,
Office
of
Pesticide
Programs.
Prior
to
joining
EPA
he
was
Senior
Agronomist
at
Development
Assistance
Corporation,
a
Washington,
D.
C.
firm
that
specialized
in
international
agricultural
development.
He
holds
a
Master
of
Science
(
Agronomy)
from
the
University
of
Maryland
(
College
Park).

Hong­
Jin
Kim
(
Economist).
Jin
has
been
an
economist
at
the
National
Center
for
Environmental
Economics
at
the
U.
S.
Environmental
Protection
Agency
(
EPA)
since
1998.
His
primary
areas
of
research
interest
include
environmental
cost
accounting
for
private
industries
He
earned
his
Ph.
D.
(
Environmental
and
Resource
Economics)
from
The
University
of
California
(
Davis)
and
holds
a
Master
of
Science
from
the
same
institution.
Dr.
Kim
is
a
1987
graduate
of
Korea
University
(
Seoul)
with
a
Bachelor
of
Arts
(
Economics).
Prior
to
joining
the
U.
S.
EPA,
Dr.
Kim
was
an
assistant
professor
at
the
University
of
Alaska
(
Anchorage)
and
an
economist
at
the
California
Energy
Commissions.
Dr.
Kim
is
the
author
of
numerous
articles
in
the
fields
of
resource
and
environmental
economics.

James
Leesch
(
Biologist).
Jim
has
been
a
research
entomologist
with
the
Agricultural
Resarch
Service
of
the
U.
S.
Department
of
Agriculture
since
1971.
His
main
area
of
interest
is
post­
harvest
commodity
protection
at
the
San
Joaquin
Valle.
He
earned
his
Ph.
D.
(
Entomology/
Insect
Toxicology)
from
The
University
of
California
(
Riverside)
Dr.
Leesch
received
a
B.
A.
degree
in
Chemistry
from
Occidental
College
in
Los
Angeles,
CA
in
1965.
He
is
currently
a
Research
entomologist
for
the
Agricultural
Research
Service
(
USDA)
researching
Agricultural
Sciences
Center
in
Parlier,
CA.
He
joined
ARS
in
June
of
1971.

Sean
Lennon
(
Biologist).
Sean
is
a
Biologist
interning
with
the
Office
of
Pesticide
Programs
of
the
U.
S.
Environmental
Protection
Agency.
He
will
receive
his
M.
S.
in
Plant
and
Environmental
Science
in
December
2003
from
Clemson
University
(
Clemson).
Mr.
Lennon
is
a
graduate
of
Georgia
College
&
State
University
(
Milledgeville)
where
he
earned
a
Bachelor
of
Science
(
Biology).
Sean
is
conducting
research
in
Integrated
Pest
Management
of
Southeastern
Peaches.
He
has
eight
years
of
experience
in
the
commercial
peach
industry.

Nikhil
Mallampalli
(
Biologist).
Nikhil
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2001.
He
is
an
entomologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
variety
of
crops,
and
analysis
of
the
impacts
of
risk
mitigation
on
pest
management.
Dr.
Mallampalli
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
holds
a
Master
of
Science
(
Entomology)
from
the
samr
institution.
Prior
to
joining
the
EPA,
he
worked
as
a
postdoctoral
research
fellow
at
Michigan
State
University
(
East
Lansing)
on
IPM
projects
designed
to
reduce
reliance
on
pesticides
in
small
fruit
production.

Tom
Melton
(
Biologist).
Tom
has
been
a
member
of
the
Plant
Pathology
faculty
at
North
Carolina
State
University
since
1987.
Starting
as
an
assistant
professor
and
extension
specialist,
Tom
has
become
the
Philip
Morris
Professor
at
North
Carolina
State
University.
His
primary
responsibilities
are
to
develop
and
disseminate
disease
management
strategies
for
tobacco.
Dr.
Melton
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
Illinois
(
Urbana­
Champaign)
and
holds
a
Master
of
Science
(
Pest
Management)
degree
from
North
Carolina
State
University
(
Raleigh).
He
is
a
1978
graduate
of
Norht
Carolina
State
University
(
Raleigh)
38
Prior
to
joining
the
North
Carolina
State
faculty,
Dr.
Melton
was
a
member
of
the
faculty
at
The
University
of
Illinois
(
Urbana­
Champaign).

Richard
Michell
(
Biologist).
Rich
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1972.
He
is
a
nematologist/
plant
pathologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
variety
of
crops,
with
special
emphasis
on
fungicide
and
nematicide
use
and
the
development
of
risk
reduction
options
for
fungicides
and
nematicides.
Dr.
Michell
earned
his
Ph.
D.
(
Plant
Pathology/
Nematology)
from
The
University
of
Illinois
(
Urbana­
Champaign)
and
holds
a
Master
of
Science
degree
(
Plant
Pathology/
Nematology)
from
The
University
of
Georgia
(
Athens).

Lorraine
Mitchell
(
Economist).
Lorraine
has
been
an
agricultural
economist
with
the
U.
S.
Department
of
Agriculture,
Economic
Research
Service
since
1998.
She
works
on
agricultural
trade
issues,
particularly
pertaining
to
consumer
demand
in
the
EU
and
emerging
markets.
Dr.
Mitchell
earned
her
Ph.
D.
(
Economics)
from
The
University
of
California
(
Berkeley).
Prior
to
joining
ERS,
Dr.
Mitchell
was
a
member
of
the
faculty
of
the
School
of
International
Service
of
The
American
University
(
Washington)
and
a
research
assistant
at
the
World
Bank.

Thuy
Nguyen
(
Chemist).
Thuy
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997,
as
a
chemist
in
the
Office
of
Pesticides
Program.
She
assesses
and
characterizes
ecological
risk
of
pesticides
in
the
environment
as
a
result
of
agricultural
uses.
She
earned
her
degrees
of
Master
of
Science
(
Chemistry)
from
the
University
of
Delaware
and
Bachelor
of
Science
(
Chemistry
and
Mathematics)
from
Mary
Washington
College
(
Fredericksburg,
VA).
Prior
to
joining
the
EPA,
Ms
Nguyen
held
a
research
and
development
scientist
position
at
Sun
Oil
company
in
Marcus
Hook,
PA,
then
managed
the
daily
operation
of
several
EPA
certified
laboratories
for
the
analyses
of
pesticides
and
other
organic
compounds
in
air,
water,
and
sediments.

Jack
Norton(
Biologist).
Jack
has
worked
for
the
U.
S.
Department
of
Agriculture
Interregional
research
Project
#
4
(
IR­
4)
as
a
consultant
since
1998.
The
primary
focus
of
his
research
is
the
investigation
of
potential
methyl
bromide
replacement
for
registration
on
minor
crops.
He
is
an
active
member
of
the
USDA/
EPA
Methyl
Bromide
Alternatives
Working
Group.
Dr,
Norton
earned
his
Ph.
D.
(
Horticulture)
from
Texas
A&
M
University
(
College
Station)
and
holds
a
Master
of
Science
(
Horticultural
Science)
from
Oklahoma
State
University(
Stillwater).
He
is
a
graduate
of
Oklahoma
State
University
(
Stillwater).
Prior
to
joining
the
IR­
4
program,
Dr.
Norton
worked
in
the
crop
protection
industry
for
27
years
where
he
was
responsible
for
the
development
and
registration
of
a
number
of
important
products.

Olga
Odiott
(
Biologist)
Olga
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
has
held
several
technical
positions
and
currently
serves
as
a
Senior
Biologist
within
the
Office
of
Science
Coordination
and
Policy.
In
this
position
she
serves
as
Designated
Federal
Official
and
liaison
on
behalf
of
the
Office
of
Pesticide
Programs
and
the
FIFRA
Scientific
Advisory
Panel,
an
independent
peer
review
body
that
provides
advice
to
the
Agency
on
issues
concerning
the
impact
of
pesticides
on
health
and
the
environment.
She
holds
a
Masters
of
Science
(
Plant
Pathology)
from
the
University
of
Puerto
Rico
(
San
Juan).
Prior
to
joining
EPA,
Ms.
Odiott
worked
for
the
U.
S.
Department
of
Agriculture.

Craig
Osteen(
Economist).
Craig
has
been
with
the
U.
S.
Department
of
Agriculture
for
over
20
years.
He
currently
is
with
the
Economic
Research
Service
in
the
Production
Management
and
Technology
Branch,
Resource
Economics
Division.
He
primary
areas
of
interest
relate
to
issues
of
pest
control,
including
pesticide
regulation,
integrated
pest
management,
and
the
methyl
bromide
phase
out.
Dr.
Osteen
earned
his
Ph.
D.
(
Natural
Resource
Economics)
from
Michigan
State
University
(
East
Lansing).

Elisa
Rim
(
Economist).
Elisa
is
an
Agricultural
Economist
interning
with
the
Office
of
Pesticide
Programs
of
the
U.
S.
Environmental
Protection
Agency.
She
earned
her
Master
of
Science
(
Agricultural
Economics)
from
The
Ohio
State
University
(
Columbus)
and
holds
a
Bachelor
of
Arts
(
Political
Science)
from
the
same
39
institution.
She
has
conducted
research
in
environmental
economics
and
developed
a
cost
analysis
optimization
model
for
stream
naturalization
projects
in
northwest
Ohio.

Erin
Rosskopf
(
Biologist).
Erin
received
her
PhD
from
the
Plant
Pathology
Department,
University
of
Florida,
Gainesville
in
1997.
She
is
currently
a
Research
Microbiologist
with
the
USDA,
ARS
and
has
served
in
this
position
for
5
years.

Carmen
L.
Sandretto
(
Agricultural
Economist).
Carmen
has
been
with
the
Economic
Research
Service
of
the
U.
S.
Department
of
Agriculture
for
over
30
years
in
a
variety
of
assignments
at
several
field
locations,
and
since
1985
in
Washington,
DC.
He
has
worked
on
a
range
of
natural
resource
economics
issues
and
in
recent
years
on
soil
conservation
and
management,
pesticide
use
and
water
quality,
and
small
farm
research
studies.
Mr.
Sandretto
holds
a
Master
of
Arts
degree
(
Economics)
from
Harvard
University
(
Cambridge)
and
a
Master
of
Science
(
Agricultural
Economics)
from
The
University
of
Wisconsin
(
Madison).
Mr
Sandretto
is
a
graduate
of
Michigan
State
University
(
East
Lansing).
Prior
to
serving
in
Washington,
D.
C.
he
was
a
member
of
the
economics
faculty
at
Michigan
State
University
and
at
the
University
of
New
Hampshire
(
Durham).

Judith
St.
John
(
Biologist).
Judy
has
been
with
the
USDA's
Agricultural
Research
Service
since
1967.
She
currently
serves
as
Associate
Deputy
Administrator
and
as
such
she
is
responsible
for
the
Department's
intramural
research
programs
in
the
plant
sciences,
including
those
dealing
with
pre­
and
post­
harvest
alternatives
to
methyl
bromide.
Dr.
St.
John
earned
her
Ph.
D.
(
Plant
Physiology)
from
The
University
of
Florida
(
Gainesville).

James
Throne
(
Biologist).
Jim
is
a
Research
Entomologist
with
the
U.
S.
Department
of
Agriculture's
Agricultural
Research
Service
and
Research
Leader
of
the
Biological
Research
Unit
at
the
Grain
Marketing
and
Production
Research
Center
in
Manhattan,
Kansas.
He
conducts
research
in
insect
ecology
and
development
of
simulation
models
for
improving
integrated
pest
management
systems
for
stored
grain
and
processed
cereal
products.
Other
current
areas
of
research
include
investigating
seed
resistance
to
stored­
grain
insect
pests
and
use
of
near­
infrared
spectroscopy
for
detection
of
insect­
infested
grain.
Jim
has
been
with
ARS
since
1985.
Dr.
Throne
earned
his
Ph.
D.
(
Entomology)
in
1983
from
Cornell
University
(
Ithaca)
and
earned
a
Master
of
Science
Degree
(
Entomology)
in
1978
from
Washington
State
University
(
Pullman).
Dr.
throne
is
a
1976
graduate
(
Biology)
of
Southeastern
Massachusetts
University
(
N.
Dartmouth).

Thomas
J.
Trout
(
Agricultural
Engineer).
Tom
has
been
with
the
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
since
1982.
He
currently
serves
as
research
leader
in
the
Water
Management
Research
Laboratory
in
Fresno,
CA.
His
present
work
includes
studying
factors
that
affect
infiltration
rates
and
water
distribution
uniformity
under
irrigation,
determining
crop
water
requirements,
and
developing
alternatives
to
methyl
bromide
fumigation.
Dr.
Trout
earned
his
Ph.
D.
(
Agricultural
Engineering)
from
Colorado
State
University
(
Fort
Collins)
and
holds
a
Master
of
Science
degree
from
the
same
institution,
also
in
agricultural
engineering.
Dr.
Trout
is
a
1972
graduate
of
Case
Western
Reserve
University
(
Cleveland)
with
a
degree
in
mechanical
engineering.
Prior
to
joining
the
ARS,
Dr.
trout
was
a
member
of
the
engineering
faculty
of
Colorado
State
University
(
Fort
Collins).
He
is
the
author
of
numerous
publications
on
the
subject
of
methyl
bromide
alternatives.

J.
Bryan
Unruh
(
Biologist).
Bryan
is
Associate
Professor
of
Environmental
Horticulture
at
The
University
of
Florida
(
Milton)
and
an
extension
specialist
in
turfgrass.
He
leads
the
statewide
turfgrass
extension
design
team.
Dr.
Unruh
earned
his
Ph.
D.
(
Horticulture)
from
Iowa
State
University
(
Ames)
and
holds
a
Master
of
Science
degree
(
Horticulture)
from
Kansas
State
University
(
Manhattan).
He
is
a
1989
graduate
of
Kansas
State
University.

David
Widawsky
(
Chief,
Economic
Analysis
Branch).
David
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1998.
He
has
also
served
as
an
economist
and
a
team
leader.
As
branch
chief,
David
is
responsible
for
directing
a
staff
of
economists
to
conduct
economic
analyses
in
support
of
pesticide
regulatory
40
decisions.
He
earned
his
Ph.
D.
(
Development
and
Applied
Economics)
from
Stanford
University
(
Palo
Alto),
and
a
Master
of
Science
(
Agricultural
Economics)
from
Colorado
State
University
(
Fort
Collins).
Dr.
Widawsky
is
a
1987
graduate
(
Plant
and
Soil
Biology,
Agricultural
Economics)
of
the
University
of
California
(
Berkeley).
Prior
to
joining
EPA,
Dr.
Widawsky
conducted
research
on
the
economics
of
integrated
pest
management
in
Asian
rice
production,
while
serving
as
an
agricultural
economist
at
the
International
Rice
Research
Institute
(
IRRI)
in
the
Philippines.

TJ
Wyatt
(
Economist).
TJ
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2001.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
and
benefits
of
pesticide
regulation.
His
other
main
area
of
research
is
farmer
decision­
making,
especially
pertaining
to
issues
of
soil
fertility
and
soil
conservation
and
of
pesticide
choice.
Dr.
Wyatt
earned
his
Ph.
D.
(
Agricultural
Economics)
from
The
University
of
California
(
Davis).
Dr.
Wyatt
holds
a
Master
of
Science
(
International
Agricultural
Development)
from
the
same
institution.
He
is
a
1985
graduate
of
The
University
of
Wyoming
(
Laramie).
Prior
to
joining
the
EPA,
he
worked
at
the
International
Crops
Research
Institute
for
the
Semi­
Arid
Tropics
(
ICRISAT)
and
was
based
at
the
Sahelian
Center
in
Niamey,
Niger.

Leonard
Yourman
(
Biologist).
Leonard
is
a
plant
pathologist
with
the
Biological
and
Economic
Analysis
Division
of
the
U.
S.
Environmental
Protection
Agency.
He
currently
conducts
assessments
of
pesticide
use
as
they
relate
to
crop
diseases.
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
Clemson
University
(
Clemson)
and
holds
a
Master
of
Science
(
Horticulture/
Plant
Breeding)
from
Texas
A&
M
University
(
College
Station).
Dr.
Yourman
is
a
graduate
(
English
Literature)
of
The
George
Washington
University
(
Washington,
DC).
.
Prior
to
joining
EPA,
he
conducted
research
on
biological
control
of
invasive
plants
with
USDA
at
the
Foreign
Disease
Weed
Science
Research
Unit
(
Ft.
Detrick,
MD).
He
has
also
conducted
research
on
biological
control
of
post
harvest
diseases
of
apples
and
pears
at
the
USDA
Appalachian
Fruit
Research
Station
(
Kearneysville,
WV).
Research
at
Clemson
University
concerned
the
molecular
characterization
of
fungicide
resistance
in
populations
of
the
fungal
plant
pathogen
Botrytis
cinerea.

Istanbul
Yusuf
(
Economist).
Istanbul
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1998.
She
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
imposed
by
the
regulation
of
pesticides.
She
earned
her
Masters
degree
in
Economics
from
American
University
(
Washington).
Ms
Yusuf
is
a
1987
graduate
of
Westfield
State
College
(
Westfield)
with
a
Bachelor
of
Arts
in
Business
Administration.
Prior
to
joining
EPA
Istanbul
worked
for
an
International
Trading
Company
in
McLean,
Virginia.

Appendix
D:
CHARTS
Charts
1
and
2
attached
as
separate
electronic
file.
