2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
POST­
HARVEST/
FOOD
PROCESSING
PLANTS
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
post­
harvest/
food
processing
plants,
like
the
other
nominations
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
food
processing
plants
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
ozonedepleting
chemicals
previously
given
scrutiny
under
the
Protocol's
distinct
and
separate
Essential
Use
exemption
process.
The
United
States
believes
that
it
is
vitally
important
for
the
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
post­
harvest/
food
processing
plants,
following
detailed
technical
and
economic
review,
the
U.
S.
has
determined
that
some
use
of
methyl
bromide
in
food
processing
plants
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
food
processing
plants
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
Processing
Food
Plants
Work
on
the
U.
S.
critical
use
exemption
process
began
in
early
2001.
At
that
time,
the
U.
S.
Environmental
Protection
Agency
(
U.
S.
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
food
processing
industry
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
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
Food
Processing
5a.
Food
Processing
Plants
in
the
U.
S.

Food
processing
is
a
US$
500
billion
global
industry
that
involves
the
processing
and
packaging
of
meat,
fish,
fruits,
vegetables,
and
specialty
food
and
beverage
products
using
technologies
including
canning,
dehydration,
freezing,
and
refrigeration.
The
U.
S.
portion
of
this
global
food
processing
industry
is
approximately
US$
130
billion
(
or
26
percent).
In
the
U.
S.,
there
are
approximately
17,000
food
processing
facilities.
Food
processing
is
a
value­
added
activity
that
involves
capital­
intensive
specialty
equipment
and
facilities.
For
example,
dog
and
cat
food
manufacturing
requires
machinery
that
renders
grains,
oilseed
mill
products,
and
meat
byproducts.
Rendered
raw
ingredients
are
later
finished
by
extrusion
(
reconstituted
and
pressed
into
meat­
like
pieces),
dried,
and
packed.

The
four
U.
S.
food
processing
sub­
sectors
in
this
first/
initial
U.
S.
nomination,
rice
milling,
flour
milling,
pet
food
manufacturing,
and
bakeries,
generate
US$
12.1
billion
in
annual
sales
revenue
from
255
facilities.
The
four
sub­
sectors
of
this
first
U.
S.
critical
use
nomination
for
methyl
bromide
are
only
2
percent
of
the
U.
S.
food
processing
industry,
by
facility,
or
9
percent,
by
sales
revenue.

5b.
U.
S.
Food
Processing
Practices
Food
processing
plants
are
highly
variable
depending
upon
the
product
manufactured
(
for
example:
flour,
baked
goods,
cat
food,
dog
treats).
However,
they
all
have
three
major
components:
the
raw
material
receiving
area,
the
production
area
and
the
warehouse
(
St.
Car
2003).
The
receiving
area
contains
the
ingredients
arriving
from
outside
the
plant
and
is
generally
a
storage
bin.
For
example,
in
flour
mills
this
area
will
receive
wheat;
for
pet
food
plants
it
will
receive
meat,
meat
by­
products,
as
well
as
cereal
grains.
The
receiving
area
has
electronic
equipment
to
monitor
capacity
and
rate
of
use.
The
primary
area
where
manufacturers
still
need
methyl
bromide
fumigations
is
the
production
area.
This
is
the
site
where
the
ingredients
are
combined
and
manufactured
into
a
final
product.
The
production
area
is
congested
with
equipment,
such
as
sifters,
strainers,
filters,
magnets,
metal
detectors,
mixers,
ovens
and
extruders,
all
of
which
are
highly
technical
and
run
by
computers.
The
warehouse
includes
the
packaging
and
storage
areas
of
the
finished
product.
Some
warehouses
also
include
trailers
for
transporting
the
final
goods,
which
need
to
be
pest
free.
Often,
the
warehouses
are
a
corner
of
the
production
area
and
not
an
actual
separate
building.
In
addition
to
the
processing
facility
there
are
concerns
about
pest
infestation
of
packaged
products.
Processed
foods
are
packaged
in
many
types
of
materials
including
oxygen
barrier
bags;
non­
barrier
packaging;
shrink
wrap;
plastics,
multi­
layer
thermal
seal
pouches
and
cans.
Each
of
these
packaging
materials
has
different
sensitivities
with
pest
management
treatments,
including
methyl
bromide,
and
presents
a
different
challenge
for
penetrating
into
the
packaged
food
to
kill
the
insects.

Food
processing
facilities
are
distributed
throughout
the
U.
S.
and
are
thus
subjected
to
very
different
weather
conditions
and
pest
pressures.
In
the
southern
portion
of
the
U.
S.,
there
is
often
no
heat
source
for
the
facilities
as
temperatures
rarely
will
dip
to
freezing.
Insect
and
other
pest
populations
are
very
high
in
this
geographical
area
as
well.
In
the
northern
sections
of
the
U.
S.,
plants
have
heat
sources,
as
the
temperatures
may
be
­
23E
C
(­
10E
F)
for
several
weeks.
In
addition,
their
pest
pressures
are
lower
as
the
severe
temperatures
help
to
keep
populations
low.

Almost
all
food
processing
plants
in
the
U.
S.
operate
24
hours
a
day,
7
days
a
week,
year
round.
Ten
years
ago
nearly
all
plants
fumigated
with
methyl
bromide
up
to
4
times
a
year.
In
preparation
for
the
loss
of
methyl
bromide,
the
industry
has
been
active
in
finding
ways
to
reduce
pests
in
the
plants
(
these
techniques
will
be
described
later).
Currently,
the
southern
plants
fumigate
with
methyl
bromide
twice
a
year.
Whereas,
the
northern
plants
have
been
able
to
extend
their
methyl
bromide
fumigations
as
far
apart
as
once
every
3
years.

5c.
Other
Issues
Related
to
the
U.
S.
Food
Processing
Industry
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).
This
law,
the
Federal
Food,
Drug
and
Cosmetic
Act
(
FFDCA
402),
ensures
human
and
animal
foods
are
safe
and
properly
labeled
(
Zimmerman,
et
al.
2003).
The
U.
S.
FDA
defines
when
hazards
and
filth
are
unacceptable
in
human
and
animal
foods
(
http://
www.
fda.
gov/
opacom/
laws/
fdcact/
fdcact4.
htm).
U.
S.
FDA
also
establishes
Defect
Action
Levels
(
DALs)
which
define
how
much
filth
is
allowed
in
a
food
(
Gecan
2003;
http://
www.
cfsan.
fda.
gov/~
dms/
dalbook.
html).
Filth
may
include
health
hazards
(
for
example
setae,
or
barbed
hairs,
from
dermestid
beetle
immatures
are
a
choking
hazard
for
children
and
pets)
or
contaminants
that
may
render
the
food
adulterated,
but
not
actually
hazardous.
These
contaminants
include
the
body
parts
of
pests
(
legs,
wings,
scales),
as
well
as
their
excreta
(
feces,
urine).

Consumers
in
the
U.
S.
have
very
high
expectations
for
their
food
products,
including
food
for
their
pets.
U.
S.
citizens
tend
to
file
lawsuits
against
manufacturers
as
a
normal
reaction
to
a
perceived
wrong.
There
are
few
barriers
in
the
U.
S.
to
filing
these
lawsuits
and
virtually
no
consequences
to
filing
lawsuits
under
questionable
grounds.
There
are
also
cases
where
people
have
"
sabotaged"
their
own
foods
with
maggots,
roaches,
even
rats,
in
order
to
attempt
to
obtain
monetary
compensation.
Manufacturers
are
very
concerned
about
the
negative
publicity
these
lawsuits
cause.
In
order
to
protect
the
reputation
of
their
company
as
well
as
the
future
sales
of
their
products,
manufacturers
strive
to
produce
high
quality
foodstuffs.
The
food
processing
industry
makes
it
a
high
priority
to
safeguard
the
healthfulness
and
cleanliness
of
their
products.

6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
Food
Processing
Plants
6a.
Target
Pests
Controlled
with
Methyl
Bromide
Humans
have
much
competition
for
their
food.
It
has
been
estimated
that
arthropod
pests
account
for
8
to
25
percent
postharvest
and
structural
losses
in
developed
countries
and
as
much
as
75
percent
in
developing
countries
(
Mason
2003).

Food
processing
plants
are
under
pressure
by
insects,
rodents
and
birds
(
applicants
reported
about
74
different
arthropod
pests,
5
rodent
pests,
and
3
bird
pests).
The
primary
reason
for
methyl
bromide
fumigations
is
insect
pressure,
not
only
insects
in
the
ingredients
and
finished
products,
but
also
in
the
structure
itself.
The
list
of
insects
is
too
long
for
this
summary,
but
a
few
of
the
main
insects
are:
warehouse
beetle
(
Trogoderma
variabile);
grain
beetles,
mainly
sawtoothed
(
Oryzaephilius
surinamensis)
and
merchant
(
O.
mercator);
and
flour
beetles
(
Tribolium
spp.).
Some
insects
feed
within
the
grains
(
ex.
weevils,
lesser
grain
borers),
meat
products
and
by­
products
(
ex.
redlegged
ham
beetle,
larder
beetles),
or
are
external
feeders
(
ex.
Indian
meal
moth,
mealworms).
In
nature,
these
pests
are
scavengers,
in
other
words,
they
eat
dead
animal
and
plant
matter.
Their
ecological
job
is
to
help
break
down
organic
matter
to
release
inorganic
products
for
recycling
in
the
environment.
The
food
processing
plant
is
analogous
to
a
feast
for
these
animals.

Food
processing
plants
are
also
a
changing,
transient
ecosystem.
Therefore,
for
these
animals
to
exploit
this
resource,
they
must
have
a
high
growth
rate,
a
high
reproduction
rate,
and
must
be
generalist
feeders
(
Sinha
1991).
These
characteristics
allow
for
the
pests
to
leave
many
offspring
to
take
advantage
of
the
varieties
of
materials
in
a
food
processing
plant.
It
is
these
same
characteristics
that
make
managing
them
so
challenging.

Not
only
do
these
insects
eat
the
foodstuffs
themselves,
but
they
also
leave
cast
skins,
excreta,
scales,
webbing,
body
parts,
etc.
which
adulterates
the
food.
Moreover,
some
of
these
insects
are
health
hazards.
Warehouse
beetles,
the
major
pest
for
this
sector,
are
dermestid
beetles
whose
immatures
have
setae
(
barbed
hairs)
that
are
a
choking
hazard
to
small
children
and
pets.
Flour
beetles
secrete
quinones
which
have
been
implicated
as
carcinogens.
There
is
also
the
possibility
of
allergic
reactions
to
arthropod
fragments,
excreta,
pheromones.
Cockroaches,
ants
and
flies
have
been
known
to
transport
disease­
causing
bacteria,
such
as
salmonella
(
Mason
2003).

6b.
Technical
and
Economic
Assessment
of
Alternatives
For
the
U.
S.
food
processing
industry,
the
MBTOC
not
in­
kind
alternatives
to
methyl
bromide
are
critical
for
monitoring
pest
populations
and
managing
those
populations,
but
they
do
not
disinfect
food
processing
plants
that
have
pests.
In
the
U.
S.,
phosphine
is
the
only
fumigant,
other
than
methyl
bromide,
registered
for
disinfecting
food
processing
plants.
Both
heat
and
phosphine
can
be
used
to
disinfect
infested
food
processing
plants
in
some
cases.
Some
facilities,
probably
due
to
construction,
are
unable
to
use
heat
or
phosphine.
Moreover,
phosphine
is
a
major
concern
because
of
its
corrosive
nature.
Currently,
there
are
plants
in
the
U.
S.
that
use
both
techniques
and
still
need
to
fumigate
with
methyl
bromide;
even
though
they
have
been
able
to
lengthen
times
between
methyl
bromide
applications.
The
potential
economic
losses
associated
with
the
use
of
phosphine
and
heat
treatment
are
large
enough
to
substantively
affect
the
profitability
and
competitiveness
of
entities
within
the
food
processing
sector.

We
begin
our
technical
and
economic
assessment
by
presenting
the
not­
in­
kind
(
non­
chemical)
alternatives,
and
then
describe
the
attributes
of
the
in­
kind
(
chemical)
alternatives.
The
results
of
the
U.
S.
interdisciplinary
team
review
of
the
MBTOC
listed
alternatives
are
summarized
in
Table
1.
However,
this
summary
does
not
address
fumigants
which
are
not
registered
for
disinfecting
food
processing
plants
in
the
U.
S.,
such
as:
hydrogen
cyanide,
ethyl
formate,
sulfuryl
fluoride,
and
controlled/
modified
atmospheres.
Terms
in
bold
are
alternatives
identified
by
the
MBTOC
for
structures
and
flour
mills.
The
only
alternatives
that
are
capable
of
disinfecting
plants
are
heat
and
phosphine.
Table
1.
Methyl
Bromide
Alternatives
Identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
for
Food
Processing
Plants
Methyl
Bromide
Alternatives
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
Biological
Agents
No
No
Cold
Treatments
No
No
Integrated
Pest
Management
(
IPM)
No
No
Electrocution
No
No
Contact
Insecticides
No
No
Low
Volatility
Pesticides
No
No
Sanitation
No
No
Pest
Exclusion
No
No
Physical
Removal
No
No
Diatomaceous
Earth
No
No
Heat
Treatment
Yes*
No
Phosphine,
alone
Yes*
No
Phosphine,
in
combination
Yes*
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.

6c.
Technical
Feasibility
of
the
"
Not
In
Kind"
Alternatives
Biological
Agents,
such
as
insects
or
pathogens.
This
is
not
an
option
for
the
food
processing
industry
since
the
introduction
of
more
insects,
or
pathogens,
would
contribute
to
contamination
of
the
food.
The
FFDCA
does
not
distinguish
between
body
parts
(
legs,
wings,
etc)
of
beneficials
from
those
of
pests.

Cold
Treatment.
Insects
can
dramatically
reduce
their
metabolism
and
acclimate
to
cold
temperature.
The
U.
S.
does
not
have
any
food
manufacturing
plants
that
are
air­
tight
enough
to
allow
this
to
be
feasible.

Integrated
Pest
Management
(
IPM).
IPM
is
currently
practiced
in
all
the
food
processing
facilities
that
submitted
an
application
for
critical
use
exemption.
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.
The
principles
of
IPM
include
other
portions
of
the
Not
In
Kind
Alternatives,
such
as
pheromone
traps,
electrocution
traps,
and
light
traps
to
monitor
pest
populations.
When
pests
are
found
in
traps,
then
contact
insecticides
and
low
volatility
pesticides
are
applied
in
spot
treatments
for
surfaces,
cracks
and
crevices,
or
anywhere
the
pests
may
be
hiding.
These
applications
are
intended
to
restrict
pests
from
spreading
throughout
the
facility
to
try
to
avoid
a
plant
fumigation
(
Arthur
and
Phillips
2003).
However,
while
IPM
practices
are
used
in
the
U.
S.
whenever
feasible
to
reduce
reliance
on
MBR,
IPM
is
not
designed
to
completely
eliminate
pests
from
any
given
facility
nor
to
ensure
that
a
facility
remains
free
from
infestation.
Because
of
the
zero
tolerance
for
insects
imposed
by
market
demands
and
regulatory
requirements,
IPM
is
not
an
acceptable
alternative
to
methyl
bromide
fumigation.

Sanitation,
Pest
Exclusion,
Physical
Removal,
Diatomaceous
Earth.
Sanitation
is
important
and
constantly
addressed
in
management
programs
(
Arthur
and
Phillips
2003).
Cleaning
and
hygiene
practices
alone
do
not
reduce
pest
populations,
but
reportedly
improve
the
efficacy
of
insecticides
or
diatomaceous
earth
(
Arthur
and
Phillips
2003).
Part
of
sanitation
involves
quickly
removing
damaged
and
contaminated
foods
and
packaging.
Sanitation,
pest
exclusion,
physical
removal
and
diatomaceous
earth
cannot
control
pest
populations
below
FDA's
DALs.

Heat
Treatment.
If
done
correctly,
heat
of
60Eto
65E
C
(
140Eto
150E
F)
for
12
hours
will
kill
all
stages
of
insects.
Consequently,
this
is
an
option
for
a
disinfectant
in
food
processing
plants.
However,
in
the
U.
S.,
it
takes
4
to
5
heat
fumigations
to
equal
one
methyl
bromide
fumigation.
Heat
treatments
in
the
northern
areas
of
the
U.
S.
take
2
to
3
days
longer
than
a
methyl
bromide
fumigation.
It
is
critical
to
raise
the
temperature
so
as
not
to
damage
the
building,
as
different
components
of
these
facilities
(
concrete,
metals,
wood,
stone)
all
expand
at
different
rates.
All
of
these
components
contract
at
different
rates,
so
the
process
of
cooling
the
building
is
also
critical.

Currently,
many
plants
in
the
U.
S.,
in
preparing
for
the
loss
of
methyl
bromide,
have
made
the
conversion
to
utilize
heat
treatments.
There
are
costs
in
retrofitting
a
plant
for
heat
treatments.
For
instance
sprinklers
have
to
be
replaced
since
they
are
set
to
go
off
at
55E
C
(
130E
F).
Heat
will
also
damage
electrical
insulation
as
well
as
computer
components.
So
these
items
must
be
modified
or
replaced.
Heat
treatments
in
the
southern
U.
S.
is
more
of
a
problem
since
they
do
not
have
heaters
at
their
plants
to
supply
the
energy
needed
for
a
treatment
and
consequently
these
plants
must
purchase
their
heat
source
elsewhere.
However,
by
employing
sanitation,
IPM,
and
heat
treatments,
plants
in
the
southern
U.
S.
have
been
able
to
go
from
4
methyl
bromide
fumigations
per
year
to
2
fumigations
per
year
and
northern
U.
S.
facilities
have
been
able
to
reduce
their
methyl
bromide
fumigations
to
1
fumigation
per
3
years.

While
heat
may
be
useful
in
some
plants,
other
food
processing
plants
are
unable
to
heat
their
building
uniformly
or
maintain
the
proper
temperature
long
enough
for
heat
to
be
efficacious.
In
several
cases,
for
instance
a
building
5
stories
high,
the
upper
level
is
too
hot
and
the
floor
still
has
not
reached
proper
temperature
for
control.
Additionally,
any
fats,
such
as
butter
and
oils,
will
become
rancid
from
heat;
and
heat
will
also
cook
many
substances
(
meats,
some
grains).
Therefore,
heat
treatment
is
not
a
replacement
for
methyl
bromide
for
all
plants.

6d.
Technical
Feasibility
of
the
"
In
Kind"
Alternatives
Phosphine,
alone.
In
the
U.
S.,
phosphine
is
the
only
fumigant
other
than
methyl
bromide
registered
for
food
manufacturing
plants.
It
is
the
fumigant
of
choice
to
disinfect
the
commodities
coming
into
most
pet
food
processing
plants.

While
technically
feasible,
phosphine
does
require
more
time
to
kill
insects
than
does
methyl
bromide.
Further,
some
insect
pests,
such
as
lesser
grain
borers,
flour
beetles,
flat
grain
beetles
and
sawtoothed
grain
beetles,
have
been
found
to
be
resistant
to
phosphine.
Phosphine
is
also
very
corrosive
to
metals,
especially
copper
and
its
alloys,
bronze
and
brass.
These
metals
are
critical
components
of
the
electronics
that
run
all
the
manufacturing
equipment.
In
addition
some
of
the
equipment
itself
(
for
example:
motors,
mixers,
etc.)
also
have
metal
parts
that
contain
copper.

Phosphine,
in
combination.
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,
additional
research
is
needed
on
the
effectiveness
of
this
combination
and
its
effects
on
the
rate
of
metal
corrosion.
Additionally
the
same
problems
concerning
heat
treatments
will
also
be
a
concern
in
combination
with
phosphine
and
carbon
dioxide.
Carbon
dioxide
will
have
little
effect
in
most
of
the
food
processing
plants
since
the
facilities
in
the
U.
S.
are
not
airtight.
Also,
using
lower
concentrations
of
phosphine
with
resistance
in
the
pest
populations
will
select
for
the
resistant
insects
much
quicker,
and
therefore,
is
not
recommended.

6e.
Economic
Feasibility
The
economic
assessment
of
feasibility
for
post­
harvest/
food
processing
plant
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
an
aggregate
of
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
the
increased
labor
time
required
for
longer,
or
an
increased
number
of,
treatments.

(
1b)
capital
expenditures,
which
are
often
large
amounts
required
to
adopt
an
alternative,
such
as
investments
to
retrofit
a
facility
to
make
it
suitable
for
heat
treatment.

(
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
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
in
food
processing
facilities.
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.
Following
the
U.
S.
technical
and
economic
review,
discussions
were
held
with
senior
risk
management
personal
in
the
U.
S.
government
to
decide
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
the
nomination
being
submitted
with
this
overview
is
the
work
of
well
over
60
experts
both
in
and
outside
of
government.

Technically
feasible
alternatives
to
methyl
bromide
in
food
processing
are
heat
treatment,
phosphine
alone,
and
phosphine
in
combination.
Implementation
of
these
alternatives
has
substantial
implications
for
this
sector
of
applicants.
Significant
financial
impacts
likely
will
result
from
increased
operating
costs
for
materials
and
labor,
capital
expenditures,
and
increased
production
downtime.
In
rice
milling
and
flour
milling
in
part,
the
plants
operate
on
small
profit
margins.
For
example
the
last
new
flour
mill
built
in
the
U.
S.
went
bankrupt
in
part
because
it
could
not
pass
along
the
start
up
costs
to
consumers.
Therefore,
any
additional
costs
associated
with
construction
or
retrofitting
of
the
facility
cannot
be
passed
along
to
the
customer.

Heat
Heat
is
already
being
used
in
plants
that
can
be
heated
efficiently.
Some
plants
in
food
processing
sector
have
already
modified
their
plants
for
heat
fumigation.
These
plants
make
constant
spot
heat
treatments,
which
can
be
accomplished
often
in
different
parts
of
the
plant
during
working
hours.
However,
there
are
also
old
plants
that
need
to
make
their
facilities
amenable
to
heat
treatment
and
require
additional
production
downtime
for
the
use
of
alternatives.
The
food
processing
sector
comprises
a
wide
range
of
products
and
production
processes.
Heat
treatment
cannot
be
economically
feasible
for
some
plants
while
it
has
been
used
by
other
plants.
Therefore,
methyl
bromide
requests
are
only
for
those
plants
where
alternatives
are
not
technically
feasible
and/
or
not
economically
feasible.

The
potential
economic
losses
associated
with
the
use
of
heat
treatment
mostly
arise
from
the
cost
of
production
delay
and
capital
expenditures
to
make
the
facility
amenable
to
heat
treatment.
Table
2
provides
a
summary
of
the
estimated
economic
losses
associated
with
heat
treatment.
The
estimated
economic
loss
as
a
percentage
of
net
revenue
ranges
from
10
percent
to
41
percent.
The
industries
that
currently
use
methyl
bromide
for
structural
fumigation
are,
in
general,
subject
to
limited
pricing
power
because
companies
within
these
industries
operate
in
a
highly
competitive
global
marketplace
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories.
In
addition,
companies
of
this
type
generally
carry
large
debt
loads,
potentially
making
new
capital
investment
difficult.
Rice
millers,
flour
millers,
and
bakers
in
part
operate
with
low
profit
margins.
The
potential
magnitude
of
economic
losses
associated
with
not
having
methyl
bromide
could
cause
bankruptcies
and
therefore
market
disruption.
Table
2.
Summary
of
Financial
and
Economic
Impacts
for
Food
Processing
Sector
for
Heat
Treatment.
Economic
Loss
Measure1
Rice
Milling
(
representative
size
:
10
million
cf2)
Bakery
(
representative
size
:
5
million
cf)
Dog
and
Cat
Food
(
representative
size
:
1
million
cf)
Flour
milling
(
representative
size
:
1.2
million
cf)
Absolute
loss
per
representative
facility
(
Total
=
a+
b+
c)
$
665,000
$
1,229,000
$
360,000
$
341,000
a)
Direct
pest
control
costs
$
20,000
$
68,000
$
25,000
$
45,000
b)
Capital
expenditures
$
250,000
$
1,120,000
$
145,000
$
175,000
c)
Production
delays
$
413,000
$
41,000
$
142,000
166,000
Economic
loss
as
a
percentage
of
net
revenue
41%
27%
10%
25%

Economic
loss
as
per
pound
of
Methyl
bromide
requested
$
32
$
197
$
264
$
273
1
Heat
treatment
is
assumed
to
provide
the
same
level
of
product
protection
as
methyl
bromide
and
thus,
economic
impacts
are
computed
as
the
cost
change
of
switching
to
the
alternatives.
2
cubic
feet
Phosphine
alone.
Phosphine,
alone
is
more
costly
than
heat
treatment
due
to
capital
expenditure
for
accelerated
replacement
of
plant
and
equipment
due
to
corrosive
nature
of
phosphine.
A
dog
and
cat
food
manufacturing
facility
showed
that
the
required
capital
expenditure
for
phosphine,
alone
was
over
US$
700,000
per
year
(
while
implementation
of
heat
treatment
would
require
a
capital
investment
of
US$
100,000
per
year.)

Phosphine
in
combination.
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.

7.
Critical
Use
Exemption
Nomination
for
Food
Processing
Plants
As
noted
above,
this
nomination
is
for
a
critical
use
exemption
for
methyl
bromide
for
rice
millers,
flour
millers,
pet
foods,
and
bakeries
in
the
U.
S.
The
total
nomination
is
for
612,576
kg
(
1,335,000
lbs)
of
methyl
bromide,
which
could
be
used
to
treat
26.5
million
cu
m
(
936,000
1,000
cu
ft),
representing
an
average
application
rate
of
0.022
kg/
cu
m
(
1.5
lbs/
1,000
cu
ft)
The
average
application
rates
for
all
of
these
facilities
conform
to
standard
practices.

The
U.
S.
interdisciplinary
review
team
found
a
critical
need
for
methyl
bromide
for
rice
millers,
flour
millers,
pet
foods,
and
bakeries
in
the
U.
S.
The
alternatives
identified
by
MBTOC
were,
as
reviewed
above,
regarded
by
reviewers
in
most
cases
as
technically
infeasible
and
in
all
others
economically
infeasible
for
acceptable
management
of
the
pest
complex
in
these
types
of
food
processing
plants
throughout
the
U.
S.

Tables
3,
4,
5,
and
6
summarize
the
critical
use
exemption
actual
amount
requested
from
the
food
processing
sectors.
Table
3.
Summary
of
Methyl
Bromide
Use
&
Requests
by
the
Rice
Milling
Sector.
1997
1998
1999
2000
2001
2005
2006
2007
kgs
186,880
151,953
168,746
171,911
142,881
202,756
202,756
202,756
1,000
cubic
meters
5,692
4,531
5,125
5,229
4,587
6,173
6,173
6,173
rate
(
kg/
cu
m)
0.0328
0.0335
0.0329
0.0329
0.0311
0.0328
0.0328
0.0328
Historic
methyl
bromide
use
in
the
rice
milling
sector
has
slowly
declined
since
1997,
with
the
exception
of
an
increase
between
1998­
1999.
However,
the
industry
is
expecting
to
grow
in
the
coming
years,
and
food
safety
standards
are
increasingly
high
in
the
United
States
and
worldwide.
A
representative
user
of
the
U.
S.
rice
milling
industry
processes
rice
for
both
domestic
and
export
markets.
Facilities
are
very
large,
and
many
U.
S.
rice
mills
are
located
in
warm
climates
that
are
conducive
to
insect
production;
pest
pressure
is
very
high.
In
addition,
many
domestic
and
export
customers
require
rice
to
be
fumigated
with
methyl
bromide
prior
to
shipment.

Table
4.
Summary
of
Methyl
Bromide
Use
&
Requests
by
the
Bakeries
Sector.
1997
1998
1999
2000
2001
2005
2006
2007
kgs
39,236
39,009
34,019
31,570
34,019
14,742
14,742
14,742
1,000
cubic
meters
1,982
1,982
1,699
1,586
1,699
736
736
736
rate
(
kg/
cu
m)
0.0198
0.0197
0.0200
0.0199
0.0200
0.0200
0.0200
0.0200
The
bakery
sector
in
the
United
States
works
with
insect
sensitive
ingredients
which
are
typically
stored
on
site
in
silos
/
bins
in
large
expansive
rooms.
Due
to
the
dusting
nature
of
flour
and
other
dry
ingredients,
it
is
extremely
difficult
to
maintain
control
of
all
life
forms
of
insects
in
environment.
This
is
a
requirement
for
compliance
with
government
food
regulations.
In
these
situations,
methyl
bromide
is
now
the
only
suitable
tool
for
structural
fumigations
which
provides
control
against
infestation
risks.
However,
this
sector
has
attempted
to
reduce
reliance
on
methyl
bromide
by
switching
to
heat
treatments
in
those
plants
where
heat
has
proven
to
be
a
viable
option.
This
U.
S.
critical
use
exemption
nomination
is
for
continued
methyl
bromide
use
in
the
bakery
facilities
where
heat
cannot
be
implemented
because
of
the
building
structures.

Table
5.
Summary
of
Methyl
Bromide
Use
&
Requests
by
the
Pet
Food
Sector.
1997
1998
1999
2000
2001
2005
2006
2007
kgs
43,386
43,887
43,001
45,200
48,264
48,081
48,081
48,081
1,000
cubic
meters
1,992
2,015
1,974
2,075
2,216
2,209
2,209
2,209
rate
(
kg/
cu
m)
0.0218
0.0218
0.0218
0.0218
0.0218
0.0218
0.0218
0.0218
The
United
States
pet
food
industry
has
slightly
increased
methyl
bromide
use
since
1997;
however,
as
many
facilities
are
represented
with
this
application,
there
is
considerable
variability
in
the
number
of
plants
fumigated
during
a
particular
year,
and
the
frequency
of
fumigation
of
any
one
plant.
The
amount
of
methyl
bromide
used
from
one
year
to
the
next
varies
with
the
ability
to
schedule
"
downtime"
in
the
production
schedule
for
fumigation,
pest
introductions
through
contaminated
ingredients,
plant
closures,
partial
fumigations
when
possible,
and
costcutting
measures.

A
representative
plant
has
an
average
production
capacity
is
381,024
kilograms
per
day,
and
plant
age
ranges
from
3
to
30
years;
the
average
facility
age
is
18.5
years.
Typically,
plants
run
three
shifts,
5.5
days
per
week,
although
some
are
operative
24
hours
per
day,
7
days
per
week.
The
average
warehouse
inventory
is
1,360,800
kgs
of
finished
product
on
the
floor,
and
the
average
value
of
the
finished
product
is
US$
600,000.
Larger
plants
have
a
larger
value,
as
they
tend
to
produce
high­
value
treats
and
biscuits.
The
average
raw
material
and
ingredient
value
of
inventory
available
is
907,200
kgs;
this
figure
includes
bulk
grains,
animal
protein,
liquid
and
dry
flavorings,
vitamins,
minerals,
and
other
micro
ingredients.
The
value
of
daily
production
averages
US$
100,000
and
is
closer
to
$
290,000
for
larger
facilities.

Table
6.
Summary
of
Methyl
Bromide
Use
&
Requests
by
the
Flour
Milling
Sector.
1997
1998
1999
2000
2001
2005
2006
2007
kgs
 
453,592
430,912
385,553
340,194
340,194
328,854
317,514
1,000
cubic
meters
­­­
16,991
16,991
16,991
16,991
16,991
16,991
16,991
rate
(
kg/
cu
m)
­­­
0.0267
0.0254
0.0227
0.0200
0.0200
0.0194
0.0187
A
representative
flour
mill
produces
approximately
362,880
kgs
of
processed
grain
products
every
day.
The
industry
has
reduced
its
application
rate
consistently,
as
shown
in
the
above
table,
and
has
decreased
from
the
traditional
4­
5
treatments
per
year
down
to
2­
3
treatments
per
year.
In
addition,
the
industry
optimizes
fumigation
with
improved
techniques,
which
has
helped
to
reduce
the
both
the
application
rate
and
the
total
amount
of
methyl
bromide
used.
Augmenting
the
methyl
bromide
fumigation
with
carbon
dioxide
has
also
improved
the
effectiveness
of
fewer
methyl
bromide
fumigations.

The
U.
S.
nomination
has
been
determined
based
first
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
7.
Methyl
Bromide
CUE
Nomination
for
Post­
Harvest/
Food
Processing
Plants
Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)
2005
612,576
536,328
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
food
processing
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.
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.
The
use
of
methyl
bromide
in
food
processing
plants
in
the
U.
S.
is
minimized
in
several
ways.
In
preparation
for
the
loss
of
methyl
bromide,
the
food
processing
industry
has
been
active
in
finding
ways
to
reduce
pests
in
the
plants
(
these
techniques
were
described
above)
so
the
use
of
methyl
bromide
could
be
reduced.
Ten
years
ago
the
plants
were
fumigated
with
methyl
bromide
up
to
4
times
a
year.
Currently,
the
southern
plants
fumigate
with
methyl
bromide
twice
a
year
(
typically
on
3­
day
weekends).
Whereas,
the
northern
plants
have
been
able
to
extend
their
methyl
bromide
fumigations
as
far
apart
as
once
every
3
to
5
years.

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
2003
and
2004
70%
reduction.
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
food
processing
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
insect
pests.
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
investigations
have
studied
the
effects
of
temperature
and
humidity
on
the
fecundity,
development,
and
longevity
of
a
specific
species.
Other
studies
have
been
to
determine
the
structural
preferences
and
micro
habitat
requirements
of
a
species.
Studies
of
factors
affecting
population
growth
(
interactions
within
and
among
species)
have
been
conducted.
However,
with
74
different
arthropod
pests,
5
rodent
pests,
and
3
bird
pests
there
is
still
much
research
that
needs
to
be
done.

IPM
and
sanitation
methods
are
also
under
investigation.
This
includes
food
plant
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
food
processing
plants.

The
number
of
available
insecticides
that
can
be
used
in
and
around
food
plants,
processing
mills,
and
food
warehouses
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
USDA
is
continuing
to
fund
research
projects
for
post­
harvest/
food
processing
plants.
Such
activities
include:

Biology
and
Management
of
Food
Pests
(
Oct
2002­
Sep
2007)
to:
examine
the
reproductive
biology
and
behavior
of
storage
weevils,
Indian
meal
moth,
and
red
and
confused
flour
beetles;
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;
examine
the
use
of
CO2
concentrations
within
a
grain
mass
to
predict
storage
weevils
and
flour
beetle
population
growth;
and
examine
the
use
of
alternative
fumigants
on
insect
mortality
(
ozone,
sagebrush,
Profume).

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

The
rice
milling
industry
has
spent
over
US$
500,000
on
research
to
develop
alternatives
since
1992,
and
plans
to
use
additional
pesticides,
such
as
carbonyl
sulfide,
carbon
dioxide,
phosphine,
magtoxin,
and
vapona
over
the
next
few
years.
Non­
chemical
methods
used
by
this
sub­
sector,
to
reduce
methyl
bromide
use,
include
heat
and
cold
treatments,
and
many
individual
companies
are
involved
in
further
research
and
testing
of
alternatives.
Industry
experts
also
recommend
further
studies
on
sulfuryl
fluoride
tolerances
and
combination
treatments
of
heat/
carbon
dioxide/
phosphine.

The
bakery
sector
is
implementing
heat
as
an
alternative
at
those
facilities
where
heat
is
technically
feasible.
Currently,
heat
is
being
implemented
at
several
facilities
nationwide.
Other
methods
being
used
to
reduce
reliance
on
methyl
bromide
are:
exclusion,
cleaning,
early
detection,
improved
design
of
equipment,
trapping,
and
other
integrated
pest
management
(
IPM)
approaches,
and
plans
to
continue
these
efforts
in
the
coming
years.
Heat
treatment
continues
to
be
tested,
but
further
trials
are
needed
to
determine
the
effects
of
heat
on
a
long­
term
basis.
Other
conditions
such
as
older
buildings
with
hardwood
floors,
plant
electrical
wiring
systems
are
not
especially
conducive
to
heat
treatments.
In
addition
to
the
possibility
of
heat,
this
sector
is
also
extremely
supportive
of
third­
party
research
conducted
by
the
USDA
on
sulfuryl
fluoride.

The
flour
milling
industry
is
committed
to
IPM
techniques
in
order
to
minimize
reliance
on
any
one
tool.
Many
plants
have
reduced
the
amount
of
annual
fumigations
from
4­
5
to
2­
3
and
combine
methyl
bromide
with
carbon
dioxide.
Further,
these
applicants
have
authored
three
manuals
on
the
subject,
which
are
widely
utilized
throughout
the
industry,
and
continue
testing
high
heat,
phosphine
alone
and
in
combination;
and
the
combination
of
heat,
phosphine,
and
carbon
dioxide.

Overall,
future
research
plans
for
this
industry
encompass
testing
alternatives
that
fumigate
rapidly
and
achieve
high
mortality
rates.
So
far
the
most
promising
of
these
are
sulfuryl
fluoride,
which
is
pending
registration
in
the
United
States;
heat
treatments;
and
various
combinations
of
heat,
phosphine,
and
carbon
dioxide.
Industry
is
supportive
of
and
closely
follows
USDA
research
on
these
alternatives.

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.
Environmental
Protection
Agency
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
groundwater
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
$
13.5
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
submitted
to
the
USDA's
Cooperative
State
Research,
Education,
and
Extension
Service
methyl
bromide
alternatives
research
program
of
US$
2.5
million
per
year
has
further
ensured
that
critical
registration
issues
are
being
addressed
by
the
research
community.

Since
1997,
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
Again,
while
these
activities
appear
promising,
it
must
be
noted
that
issues
related
to
toxicity,
ground
water
contamination,
and
the
release
of
air
pollutants
may
pose
significant
problems
with
respect
to
some
alternatives
that
may
lead
to
use
restrictions
since
many
of
the
growing
regions
are
in
sensitive
areas
such
as
those
in
close
proximity
to
schools
and
homes.
Ongoing
research
on
alternate
fumigants
is
evaluating
ways
to
reduce
emission
under
various
application
regimes
and
examining
whether
commonly
used
agrochemicals,
such
as
fertilizers
and
nitrification
inhibitors,
could
be
used
to
rapidly
degrade
soil
fumigants.
For
example,
if
registration
of
iodomethane
or
another
alternative
occurs
in
the
near
future,
commercial
availability
and
costs
will
be
factors
that
must
be
taken
into
consideration.

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
experts,
we
have
determined
that
the
MBTOC
listed
potential
alternatives
for
the
post­
harvest/
food
processing
sector
are
not
currently
technically
or
economically
feasible
from
the
standpoint
of
U.
S.
food
processing
manufacturers
covered
by
this
exemption
nomination.
Even
the
most
promising
of
these
alternatives
is
economically
infeasible
due
to
potential
decreases
in
revenue
and
increases
in
production
costs
associated
with
adopting
the
alternatives.

In
addition,
we
have
demonstrated
that
we
have
and
will
continue
to
expend
significant
efforts
to
identify
and
commercialize
alternatives
to
the
use
of
methyl
bromide
in
post­
harvest/
food
processing
plants.
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
food
processing
plants
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
Biology
References
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.

Gecan,
J.
S.
2003.
Food
Defect
Action
Levels.
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.
77­
86.

Mason,
Linda.
2003.
Insects
and
Mites.
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.
293­
315.
Sinha,
R.
N.
1991.
Storage
Ecosystems.
In:
Gorham,
R.
ed.
Ecology
and
Management
of
Food­
Industry
Pests.
Arlington,
VA:
Association
of
Official
Analytical
Chemists.
pp.
17­
30.

St.
Cyr,
Alfred
J.
2003.
Food
Plant
Inspections.
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
51­
60.

Zimmerman,
M.
L.,
A.
R.
Olsen,
and
S.
L.
Freidman.
2003.
Filth
and
Extraneous
Material
in
Food.
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.
69­
75.

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

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

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.

North
America
Millers'
Association.
The
Use
of
Methyl
Bromide
in
the
Wheat,
Corn,
Oat
and
Rye
Milling
Industry.
2002.

The
Food
Institute.
Food
Price
Inflation
Expected
to
Remain
Moderate
in
2003.
The
Food
Institute
Report,
Sep.
30.
2002.

United
States
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
requests
for
the
Food
Processing
Sector
in
the
U.
S.

CUE­
02­
0023,
Rice
Millers'
Association
CUE­
02­
0026,
Kraft
Food
North
America,
Inc.

CUE­
02­
0027,
Pet
Food
Institute
CUE­
02­
0031,
North
American
Millers
Association
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
subdivided
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.
Food
Plant/
Structural
(
F/
S)
Part
A
Sector
Summary
of
Economic
Estimates
Absolute
Loss
Per
Representative
Facility
CUE
#

02­
00
Sector
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
MeBr
Requested
($
USD)

23
F/
S
Rice
Millers'
Assn
methyl
bromide
10
million
cubic
feet
23
F/
S
Rice
Millers'
Assn
Heat
treatment
Y
10
million
cubic
feet
$
20,000
$
250,000
$
413,000
$
665,000
41%
$
71
26
F/
S
Kraft
Foods
methyl
bromide
5
million
cubic
feet
26
F/
S
Kraft
Foods
Heat
treatment
Y
5
million
cubic
feet
$
68,000
$
1,120,000
$
41,000
$
1,229,000
27%
$
433
27
F/
S
Pet
Food
Institute
methyl
bromide
1
million
cubic
feet
27
F/
S
Pet
Food
Institute
Heat
treatment
Y
1
million
cubic
feet
$
25,000
$
145,000
$
142,000
$
360,000
10%
$
582
31
F/
S
Flour
Millers'
Assn
methyl
bromide
1.2
million
cubic
feet
31
F/
S
Flour
Millers'
Assn
Heat
treatment
Y
1.2
million
cubic
feet
$
45,000
$
175,000
$
166,000
$
342,000
25%
$
602
Food
Plant/
Structural
(
F/
S)
Part
B
Sector
Summary
of
Economic
Estimates
MeBr
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
MeBr
cost
per
facility
($
USD)
MeBr
cost
per
kgs
($
USD
)
Application
&

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)

23
F/
S
Rice
Millers'
Assn
methyl
bromide
$
27,300,000
9,320
9,320
kg
ai
$
27,961.36
$
6.60
$
347,039
$
375,000
$
25,304,370
$
1,620,630
0%
$
0
23
F/
S
Rice
Millers'
Assn
Heat
treatment
$
27,300,000
$
395,000
$
25,304,370
$
955,630
41%
$
71
26
F/
S
Kraft
Foods
methyl
bromide
$
120,000,000
2,841
2,841
kg
ai
$
8,522.73
$
6.60
$
41,750
$
68,000
$
115,320,000
$
4,612,000
0%
$
0
26
F/
S
Kraft
Foods
Heat
treatment
$
120,000,000
$
136,000
$
115,320,000
$
3,383,000
27%
$
433
27
F/
S
Pet
Food
Institute
methyl
bromide
$
16,300,000
618
618
kg
ai
$
1,854.55
$
6.60
$
18,145
$
20,000
$
12,714,000
$
3,566,000
0%
$
0
27
F/
S
Pet
Food
Institute
Heat
treatment
$
16,300,000
$
45,000
$
12,714,000
$
3,206,000
10%
$
582
31
F/
S
Flour
Millers'
Assn
methyl
bromide
$
48,800,000
568
568
kg
ai
$
1,704.55
$
6.60
$
43,295
$
45,000
$
38,064,000
$
10,691,000
0%
$
0
31
F/
S
Flour
Millers'
Assn
Heat
treatment
$
48,800,000
$
90,000
$
38,064,000
$
10,349,000
25%
$
602
2
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).

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.

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.
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)
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
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
gricultural
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
insectinfested
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
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.
