OMB
Control
#
2060­
0482
SECTOR
_________________________

UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
Under
the
Clean
Air
Act
and
the
international
treaty
to
protect
the
ozone
layer
(
the
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer),
the
production
and
import
of
methyl
bromide
will
be
phased
out
in
the
United
States
on
January
1,
2005.
This
application
seeks
information
to
support
a
U.
S.
request
to
produce
and
import
methyl
bromide
for
certain
critical
uses
and
circumstances
beyond
this
2005
phaseout
date.

The
information
in
this
application
will
be
used
to
review
whether
your
use
of
methyl
bromide
is
"
critical"
because
no
technically
and
economically
feasible
alternatives
are
available.
In
order
to
estimate
the
loss
as
a
result
of
not
having
methyl
bromide
available,
EPA
needs
to
compare
data
(
commodity
prices,
revenues,
and
costs)
for
your
use
of
methyl
bromide
with
uses
of
alternative
pest
control
regimens.

If
you
submit
a
well
documented
application
with
sound
reasons
why
alternatives
are
not
technically
and
economically
feasible,
the
U.
S.
government
can
be
a
better
advocate
for
your
exemption
request
internationally.

EPA
Form
#
7620­
18b
Post
Harvest
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
bromide.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.
For
EPA
Use
Only
ID
#
______________

2003
Application
for
Critical
Use
Exemption
of
Methyl
Bromide
for
Post
Harvest
Use
in
2005
and
beyond
in
the
United
States
WHY
IS
THIS
INFORMATION
NEEDED?

Click
on
the
Instructions
tab
located
at
the
bottom
of
the
screen
for
additional
information.

The
information
contained
in
this
application
is
critical
to
process
and
assess
the
need
for
methyl
bromide.
Filling
out
this
application
in
its
entirety
will
bolster
the
U.
S.
government's
ability
to
strengthen
the
nomination
package
for
the
international
review
boards.
WHO
APPLIES?

STATE
CONTACTS
HOW
DO
I
APPLY?

IS
MY
INFORMATION
CONFIDENTIAL?

WHEN
IS
THE
INFORMATION
NEEDED?

Mailing
Address
for
applications
being
submitted
by
mail
directly
to
the
EPA:
Address
for
applications
being
sent
by
courier
or
non­
U.
S.
Postal
overnight
express
delivery
to
the
EPA:

US
Environmental
Protection
Agency
US
Environmental
Protection
Agency
Methyl
Bromide
Critical
Use
Exemption
Methyl
Bromide
Critical
Use
Exemption
Office
of
Pesticide
Programs
Office
of
Pesticide
Programs
Mail
Code
7503C
911
Bay,
BEAD
1200
Pennsylvania
Ave,
NW
1921
Jefferson
Davis
Highway
Washington,
DC
20460
Arlington,
VA
22202
Telephone:
(
703)
308­
8200
OMB
Control
#
2060­
0482
HOW
CAN
I
RECEIVE
ADDITIONAL
INFORMATION?
If
you
have
general
questions
about
this
application
call:

Stratospheric
Ozone
Hotline
1­
800­
296­
1996
The
applicant
may
assert
a
business
confidentiality
claim
covering
part
or
all
of
the
information
in
the
application
by
placing
on
(
or
attaching
to)
the
information,
at
the
time
it
is
submitted
to
EPA,
a
cover
sheet,
stamped
or
typed
legend,
or
other
suitable
form
of
notice
employing
language
such
as
trade
secret,
proprietary,
or
company
confidential.
Allegedly
confidential
portions
of
otherwise
non­
confidential
documents
should
be
clearly
identified
by
the
applicant,
and
may
be
submitted
separately
to
facilitate
identification
and
handling
by
EPA.
If
the
applicant
desires
confidential
treatment
only
until
a
certain
date
or
until
the
occurrence
of
a
certain
event,
the
notice
should
so
state.
Information
covered
by
a
claim
of
confidentiality
will
be
disclosed
by
EPA
only
to
the
extent,
and
by
means
of
the
procedures
set
forth
under
40
CFR
Part
2
Subpart
B;
41
FR
36902,
43
FR
400000.
50
FR
51661.
If
no
claim
of
confidentiality
accompanies
the
information
when
it
is
received
by
EPA,
it
may
be
made
available
to
the
public
by
EPA
without
further
notice
to
the
applicant.

Applicants
submitting
their
application
via
e­
mail
assume
responsibility
for
the
confidentiality
of
the
electronic
message
transmission.

This
application
must
be
postmarked
to
the
EPA
address
below
no
later
than
120
days
after
the
Notice
was
published
in
the
Federal
Register
requesting
critical
use
exemption
applications.

WHERE
DO
I
SUBMIT
THE
APPLICATION?
Electronic
Address
for
applications:
methyl.
bromide@
epa.
gov
When
submitting
an
application
electronically,
you
should
also
print
a
hard
copy,
sign
it,
and
submit
it
by
mail
If
a
consortium
is
applying
for
multiple
methyl
bromide
users,
the
economic
data
should
be
for
a
representative
or
typical
user
within
the
consortium
unless
otherwise
noted.
If
economic
or
technical
factors
(
such
as
types
of
commodities)
affecting
the
ability
of
this
"
representative
user"
to
use
alternatives
are
significantly
different
than
other
users
in
the
consortium,
more
than
one
application
should
be
submitted
to
reflect
these
differences.

Please
contact
your
local,
state,
regional
or
national
commodity
association
and/
or
state
representative
agency
to
find
out
if
they
plan
on
submitting
an
application
on
behalf
of
your
commodity
group.

States
that
have
agreed
to
participate
in
the
exemption
process
are
listed
on
EPA's
website
at
www.
epa.
gov/
ozone/
mbr/
cueqa.
html
You
may
either
complete
an
electronic
(
Microsoft
Excel)
or
a
printed
version
of
the
application.
Please
fill
out
each
form
or
worksheet
in
the
application
as
completely
as
possible.
If
you
are
completing
the
printed
version
and
need
extra
space
you
may
attach
additional
sheets
as
needed.
Additional
information
may
be
available
from
your
local
state
department
of
agriculture
or
at
the
sites
listed
below
or
by
calling
1­
800­
296­
1996.
INSTRUCTIONS
The
information
provided
by
you
in
this
application
will
be
used
to
evaluate
the
requested
methyl
bromide
use.
The
U.
S.
and
other
countries
that
are
parties
to
the
Montreal
Protocol
On
Substances
That
Deplete
The
Ozone
Layer
decided
that:
"
a
use
of
methyl
bromide
should
qualify
as
"
critical"
only
if
the
nominating
Party
determines
that:

(
i)
The
specific
use
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
that
use
would
result
in
a
significant
market
disruption;
and
(
ii)
There
are
no
technically
and
economically
feasible
alternatives
available
to
the
user
that
are
acceptable
from
the
standpoint
of
environment
and
health
and
are
suitable
to
the
crops
and
circumstances
of
the
nomination
 "

If
you
anticipate
that
you
will
need
methyl
bromide
in
2005
because
you
believe
there
are
no
technically
and
economically
feasible
alternatives,
then
you
should
apply
for
the
critical
use
exemption.
This
application
may
be
submitted
either
by
a
consortium
representing
multiple
users
or
by
individual
users.
We
encourage
users
with
similar
circumstances
of
use
to
submit
a
single
application
(
for
example,
any
number
of
post
harvest
users
with
similar
commodity,
pest,
and
structural
conditions
can
submit
a
single
application.)
EPA
Form
#
7620­
18b
Post
Harvest
SECTIONS
OF
WORKBOOK
OMB
Control
#
2060­
0482
The
two
arrows
on
the
bottom
right
of
the
screen
allow
you
to
move
the
worksheet
that
you
are
viewing
to
the
right
or
to
the
left.
This
is
useful
if
the
viewable
area
of
on
the
screen
is
smaller
than
the
entire
page
that
is
in
the
worksheet.

Printing
worksheets
6.
Go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Edit"
then
"
Paste"

7.
Change
the
title
row
of
the
newly
pasted
worksheet
from
the
old
worksheet
number
to
be
consistent
with
the
worksheet
tab.

Note:
This
is
the
only
way
you
can
copy
a
worksheet
and
not
lose
portions
of
the
text
instructions.

Viewing
worksheets
2.
Select
the
top
left
corner
of
the
worksheet
(
this
is
the
space
to
the
left
of
column
A
and
above
row
1.
You
will
know
that
the
entire
worksheet
has
been
selected
because
the
row
and
column
marks
as
well
as
the
worksheet
itself
will
3.
Go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Edit"
then
"
Copy".

Worksheets
are
best
viewed
in
"
Page
Break
Preview."
To
select
the
view
of
the
worksheet,
go
to
the
menu
bar
and
select
"
View"
and
then
"
Page
Break
Preview."
Page
break
preview
shows
only
the
printable
area
of
the
worksheet,
with
the
blue
lines
that
surround
the
screen
indicating
the
edges
of
each
page.

To
increase
or
decrease
the
size
of
the
page
that
is
viewable
on
the
screen,
go
to
the
menu
bar
and
select
"
View"
and
then
"
Zoom".

Navigating
between
worksheets
The
set
of
four
arrows
on
the
bottom
left
of
the
screen
will
help
you
navigate
between
worksheets.
This
is
necessary
to
access
the
remaining
worksheet
tabs
in
the
workbook
that
are
not
viewable.
The
two
arrows
with
vertical
lines
to
either
the
left
or
right
will
take
you
to
the
first
worksheet
and
to
the
last
worksheet
respectively
in
the
workbook.
The
inner
two
arrows
allow
you
move
the
worksheet
tabs
to
the
right
or
to
the
left
incrementally.
4.
Go
to
the
blank
worksheet
where
you
want
the
copied
information
to
be
pasted.

5.
Again,
select
the
top
left
corner
of
the
worksheet
(
left
of
column
A
and
above
row
1)
to
select
the
entire
worksheet.
EXCEL
USER
TIPS
Inserting
a
blank
worksheet:

1.
To
add
additional
blank
worksheets
in
the
Excel
file,
go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Insert"
then
"
worksheet"
2.
A
tab
with
the
name
"
Sheet
1"
will
appear
at
the
bottom
of
the
worksheet
and
will
be
highlighted
in
white.
Take
the
cursor
and
double
click
the
"
new
tab"
3.
By
double
clicking
in
the
tab
you
can
now
rename
the
worksheet
to
the
appropriate
number
letter
designation
(
e.
g.,
3­
A(
1),
3­
A(
1)(
a),
etc.)

4.
To
move
a
newly
inserted
worksheet,
simply
drag
the
worksheet
with
your
mouse
to
the
desired
location.

5.
Once
you
add
a
new
worksheet,
Excel
will
automatically
name
each
subsequently
added
worksheet
as
Sheet
2,
Sheet
3,
etc 
Follow
the
instructions
above
to
rename
the
new
blank
worksheets
as
appropriate.

Copying
and
pasting
an
entire
worksheet's
contents
into
a
blank
worksheet:

1.
Select
the
worksheet
to
be
copied
by
clicking
on
the
worksheet
tab
at
the
bottom
of
the
screen.
The
tab
will
turn
white
in
color
when
it
has
been
selected.
Worksheet
4.
Future
Research
Plans
Worksheet
5.
Application
Summary
Definitions
Climate
Zone
Map
Worksheet
2­
D.
Methyl
Bromide
­
Operating
Costs
for
2002
Worksheet
3.
Alternatives
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Worksheet
3­
B.
Alternatives
­
Changes
in
Operating
Costs
INSTRUCTIONS
Each
worksheet
number
corresponds
to
the
tab
number
in
the
electronic
version
of
the
application.
Instructions
specific
to
each
worksheet
are
provided
at
the
top
of
each
sheet.
A
header
row
is
included
on
each
worksheet
to
include
an
application
ID
number
that
EPA
will
assign.

Instructions
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
Worksheet
2.
Methyl
Bromide
Worksheet
2­
A.
Methyl
Bromide
­
Pest
and
Processing
Information
Worksheet
2­
B.
Methyl
Bromide
­
Historical
Use
for
1997
­
2002
Worksheet
2­
C.
Methyl
Bromide
­
Commodity
Treated
&
Gross
Profit
for
2000
­
2002
If
you
would
like
to
print
all
worksheets
that
are
contained
in
this
workbook,
go
to
the
menu
bar
at
the
top
of
the
screen
and
select
"
File"
and
then
"
Print."
Then
in
the
section
of
the
menu
that
appears
called
"
Print
what,"
select
"
Entire
Workbook."

EPA
Form
#
7620­
18b
Post
Harvest
Is
this
information
Confidential
Business
Information
(
CBI)?
Yes
No
Applicant
Name
Primary
Contact
Contact
Name
Specialty
Address
Agronomic
X
Economic
Daytime
Phone
Cell
Phone
E­
mail
Address
Fax
Alternate
Contact
Contact
Name
Specialty
Address
Agronomic
X
Economic
Daytime
Phone
Cell
Phone
E­
mail
Address
Fax
OMB
Control
#
2060­
0482
Ben
Noble
(
Check
One)
Steve
Hensley
(
Check
One)

4301
North
Fairfax
Dr.,
Ste.
425
Arlington,
VA
22203­
1616
Rice
Millers'
Association
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
The
following
information
will
be
used
to
determine
the
amount
of
methyl
bromide
requested
and
the
contact
person
for
this
request.
It
is
important
that
we
know
whom
to
contact
in
case
we
need
additional
information
during
the
review
of
the
application.

703­
236­
1445
540­
222­
7082
shensley@
usarice.
com
703­
236­
2301
If
yes,
the
applicant
assumes
responsibility
for
the
secure
transmission
of
electronic
submissions.

I
certify
that
all
information
contained
in
this
document
is
factual
to
the
best
of
my
knowledge.
4301
North
Fairfax
Dr.,
Ste.
425
Arlington,
VA
22203­
1616
703­
236­
1471
703­
732­
2336
bnoble@
usarice.
com
703­
236­
2301
Signature
Date
Title
Information
in
this
application
may
be
aggregated
with
information
from
other
applications
and
used
by
the
United
States
government
to
justify
claims
in
the
national
nomination
package
that
a
particular
use
of
methyl
bromide
be
considered
"
critical"
and
authorized
for
an
exemption
beyond
the
2005
phaseout.
Use
of
aggregate
data
will
be
crucial
to
making
compelling
arguments
in
favor
of
critical
use
exemptions.
By
signing
below,
you
agree
now
to
assert
any
claim
of
confidentiality
that
would
affect
the
disclosure
by
EPA
of
aggregate
information
based
in
part
on
information
contained
in
this
application.
Print
Name
Steve
Hensley
Signature
Date
Print
Name
Steve
Hensley
Title
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
bromide.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.

EPA
Form
#
7620­
18b
Post
Harvest
1.

2.

3.

4.
Climate
(
Average
Minimum
Temperature)

Zones:
(
check
all
that
apply)

5.
Yes
Amount
No
6.
Yes
X
CUE
#
02­
0023
No
7.

Year
2005
2006
2007
8.

9.

10.
Yes
Lbs
No
x
11.
Yes
x
Lbs
No
OMB
Control
#
2060­
0482
Total
Volume
(
1,000
cu
ft)
to
be
Treated
lbs.

lbs.
447,000
447,000
Total
Pounds
Active
Ingredient
(
a.
i.)
of
Methyl
Bromide
What
is
the
amount
of
methyl
bromide
being
requested
by
this
application?
(
Do
NOT
include
QPS
amounts)
If
a
consortium
is
submitting
this
application,
the
data
should
be
the
total
for
the
consortium.
Have
you
previously
applied
for
Critical
Use
Exemption
of
Methyl
Bromide?
(
Individual
users
should
enter
their
climate
zone
designation
by
reviewing
the
U.
S.
climate
zone
map
located
at
the
end
of
this
workbook
or
it
can
be
reviewed
online
at
http://
www.
usna.
usda.
gov/
Hardzone/
ushzmap.
html.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
climate
zone.)

1____
2a____
2b____
3a____
3b____
4a____
4b____
5a____
5b____
6a____
6b__
6%__
7a__
25%__
7b__
34%__
8a____
8b____
9a__
16%__
9b____
10a__
19%__
10b____
11____
5%
5,000
to
10,000
(
1,000
cu
ft)
90%
50,000
to
100,000
(
1,000
cu
ft)

lbs.
447,000
(
1,000
cu
ft)
218,000
Is
this
applicant
eligible
for
Quarantine
and
Preshipment
(
QPS)
uses
of
methyl
bromide?

(
1,000
cu
ft)
218,000
(
1,000
cu
ft)
218,000
Please
explain
why
there
may
be
variations
in
the
pounds
or
volume
(
1,000
cu
ft)
treated
from
year
to
year.

N/
A
Please
explain
why
methyl
bromide
is
being
requested.
To
date,
there
is
no
comparable
and
cost
effective
alternative
to
methyl
bromide
for
structural
or
storage
fumigation
of
rice
mills.
Private
industry
is
testing
alternaives
but
has
not
been
successful
in
replacing
methyl
bromide
for
facility
fumigation.

Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
after
January
1,
2005?
2000
(
Enter
the
state,
region,
or
county.
Provide
more
details
about
the
location
if
relevant
to
the
feasibility
of
alternatives
to
methyl
bromide.)
Location
If
yes,
please
specify
amount
(
in
pounds).
Do
you
have
access
to
recycled
methyl
bromide?

If
yes,
please
specify
amount
(
in
pounds).
Range
of
structure/
facility
size
by
processors
included
in
this
application?
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
Arkansas,
California,
Louisiana,
Florida,
Missouri,
and
Mississippi.

(
Include
all
commodities
that
benefit
from
the
application
of
methyl
bromide
in
a
fumigation
cycle.
See
the
Worksheet
entitled
"
Fumigation
Cycle"
for
definitions.)
Commodity
Rice
(
Insert
number
or
percentage
of
users
in
each
category)

0
to
1,000
(
1,000
cu
ft)
1,000
to
5,000
(
1,000
cu
ft)
over
100,000
(
1,000
cu
ft)
10,000
to
50,000
(
1,000
cu
ft)
EPA
Form
#
7620­
18b
Post
Harvest
482
482
Worksheet
Title
2­
A
Methyl
Bromide
­
Pest
and
Commodity
Information
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

The
purpose
of
this
worksheet
is
to
determine
pest
infestation
and
commodity
information
where
methyl
bromide
is
used.
This
forms
the
baseline
for
evaluating
the
impacts
of
using
an
alternative
to
replace
methyl
bromide.

2­
B
Methyl
Bromide
­
Historical
Use
1997
­
2002
If
a
consortium
is
submitting
this
application,
all
data
should
reflect
the
actual
data
for
the
consortium.

This
worksheet
provides
data
in
actual
usage
for
1997­
2002.

2­
C
Methyl
Bromide
­
Commodity
Treated
and
Gross
Profits
for
2000­
2002
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

This
worksheet
provides
commodity
treated
and
gross
profits
for
2000
through
2002.

The
purpose
of
this
worksheet
is
to
determine
past
gross
profits
when
methyl
bromide
is
used.
This
forms
the
baseline
for
evaluating
the
revenue
impacts
of
using
an
alternative
to
replace
methyl
bromide.

2­
D
Baseline
­
Operating
Costs
for
2002
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

This
data
is
needed
to
estimate
a
baseline
for
operating
costs
in
order
to
estimate
changes
in
costs
and
the
impact
on
operating
profit
and
short­
run
economic
viability
as
a
result
of
not
using
methyl
bromide.

The
purpose
of
this
worksheet
is
to
determine
operating
expenses
when
methyl
bromide
is
used.
This
forms
the
baseline
for
evaluating
the
cost
impacts
of
using
an
alternative
to
replace
methyl
bromide.
The
data
requested
are
designed
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable,
which
will
be
shown
in
Worksheet
3­
B.
OMB
Control
#
2060­
0482
Worksheet
2.
Methyl
Bromide
Purpose
of
Data:
To
establish
a
baseline
estimate
of
commodity
treated,
gross
profits,
and
costs
using
methyl
bromide.

Instructions
specific
to
each
worksheet
are
located
at
the
top
of
each
sheet.
EPA
Form
#
7620­
18b
Post
Harvest
1.
Commodity
or
Consortium
2.
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sept
Oct
Nov
Dec
x
3.
Fumigation
Timeline
Beginning
Fumigation
Cycle
(
please
define
time
periods)
Hours
Facility
Preparation
24
Sealing
5
Cleaning
5
Fumigation
Timeline
Reception
of
Raw
Materials
x
x
x
x
x
x
x
x
x
x
x
x
Processing
x
x
x
x
x
x
x
x
x
x
x
x
Storage
x
x
x
x
x
x
x
x
x
x
x
Raw
Materials
x
x
x
x
x
x
x
x
x
x
x
x
Finished
Product
x
x
x
x
x
x
x
x
x
x
x
x
Packing
x
x
x
x
x
x
x
x
x
x
x
x
Shipping
x
x
x
x
x
x
x
x
x
x
x
Retail
Market
Window
x
x
x
x
x
x
x
x
peak
peak
peak
x
Other
Pest
Treatments
x
x
x
x
x
x
x
x
x
x
x
x
Other
4.

4a.
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18b
Post
Harvest
and
clean
up.
Future
market
availability
will
be
negatively
impacted
by
a
reduction/
loss
of
methyl
bromide,
by
impacting
our
containers
under
local
and
state
regulations.
Current
market
availability
is
affected
by
the
time
necessary
to
fumigate,
aerate
fumigating
a
packaged
commodity
is
used
in
a
preventive
manner,
at
the
customer's
request,
and
is
done
in
isolated
ability
to
service
and
retain
a
good
portion
of
our
existing
customers
and
prevent
us
from
acquiring
new
customers.
Rough
rice
and
milled
rice
is
fumigated,
but
not
usually
with
Methyl
Bromide.
Virtually
all
of
the
methyl
bromide
used
for
Provide
a
narrative
of
market
channel
for
each
commodity,
where
it
is
fumigated,
and
how
the
fumigation
effects
market
availability
and
commodity
sale.
Worksheet
2­
A.
Methyl
Bromide
­
Pest
&
Processing
Information
Rice
Millers
Association
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)
What
month
does
your
fumigation
cycle
start?
(
check
only
one)

Time
Interval:
Normally
months
or
weeks
(
e.
g.
WEEKS/
MONTH/
YEAR/
SEASON)

Please
provide
a
simplified
schematic
diagram
which
illustrates
the
basic
steps
of
the
commodity
moving
through
the
process
from
raw
material
to
finished
product.

Receive
raw
material
­­­
Sotrage
­­­
Cleaning­­­
Dehulling
­­­
Whitening
­­­
Polishing
­­­
Grading
­­­
Color
sorting
­­­
Weighing
­­­
Cleaning
­­­
Packing
­­­
Weighing
­­­
Finished
product
­­­
Storing
­­­
Shipping
5.
Target
Pest(
s)
or
Pest
Problem(
s):

Pest
1
Pest
2
Pest
3
6.
Pest
Economic
Threshold
Pest
1
Pest
2
Pest
3
7.
Target
Pest
Infestation
Pest
1
%
Pest
2
%
Pest
3
%

8.

X
X
feet
9.

Structure
/
Facility
x
Commodity
x
Storage
x
All
x
Other
10.

11.
Worksheet
2­
A.
Methyl
Bromide
­
Pest
&
Processing
Information
OMB
Control
#
2060­
0482
Mill
Other
3
3.5
Phosphine
(
Alone)
(
Please
identify
the
top
3
target
pests
or
pest
problems.
Provide
at
least
common
name
and
genus
and
species
if
possible.
Additional
pests
or
pest
problems
can
be
provided
as
an
attachment.)

Common
Name
Genus
Red
and
Confused
Flour
Beetles
Tribolium
Rice
Weevil
Sitophilus
oryzae
Indian
Meal
Moth
Plodia
interpunctella
(
If
available,
please
provide
the
economic
threshold
information
for
each
pest,
units,
and
source
of
information.)
Economic
Threshold
Units
(
e.
g.
pests/
cu
ft)
Source
1
pests/
cu
ft
Facility
Inspection/
Pest
Survey/
IPM
system
1
pests/
cu
ft
Facility
Inspection/
Pest
Survey/
IPM
system
1
pests/
cu
ft
Facility
Inspection/
Pest
Survey/
IPM
system
(
Please
estimate
the
percentage
of
this
user's
total
structural/
facility
volume
with
a
moderate
to
severe
problem
with
these
pests.
Describe
source
of
information
such
as
a
survey
or
expert
estimate.)

Percentage
of
Total
Structure/
Facility
Source
100
75
50
sorting
and
metal
detection.
These
machines
contain
sensitive
electronics
that
cannot
withstand
high
heat
or
phosphine
gas.
Representative
User
:
(
Please
provide
descriptive
factors
appropriate
for
your
operation.)

0.84
900
Volume
of
Facility/
Structure
Treated
with
Methyl
Bromide:
Volume
of
Commodity
Treated
with
Methyl
Bromide:
1,000
cu
ft
Rate
of
Application
per
Fumigation:

Structural
fumigation
includes
all
equipment
­
best
described
as
basic
conveying
and
high
tech
processing
equipment
including
machines
for
milling
In
what
part
and
phase
of
the
operation
does
the
methyl
bromide
fumigation
take
place?
(
check
all
that
apply)
Commodity
Treated
per
Fumigation:

Please
provide
a
brief
description
of
any
equipment
fumigated
in
this
operation.
Details
Alternative
%
Replaced
1,000
cu
ft
pounds
/
_________
Dimension
of
Structure/
Facility:
Total
Commodity
Treated
per
Year:
14,400
Tons
(
short)
21
Tons
(
short)
1
Fumigation
Chamber
Prior
to
Storage
Prior
to
Shipping
What
percentage
of
the
operation
have
alternative(
s)
replaced
methyl
bromide
in
processing
this
commodity
and
if
so,
during
what
phase
of
the
process?

Phosphine
in
Combination
Heat
Treatment
Phase
of
Process
Empty
Bins
EPA
Form
#
7620­
18b
Post
Harvest
482
482
B
C
D
E
Total
Actual
Volume
(
1,000
cu
ft)
Treated
Average
Pounds
ai
Applied
per
Volume
(
1,000
cu
ft)
Total
Weight
of
Commodity
Treated
(
in
Tons
(
short))
Average
Pounds
ai
Applied
per
Ton
(
short)

1997
201,000
0.00204975
1998
160,000
0.00209375
1999
181,000
0.00205525
2000
184,650
0.00205253
2001
162,000
0.00194444
2002
165,000
0.002
OMB
Control
#
2060­
0482
Column
A:

Column
B:

Enter
the
total
actual
volume
(
1,000
cu
ft)
treated.
Note:
This
number
should
be
the
total
actual
volume
(
1,000
cu
ft)
treated
by
the
individual
user
or
total
actual
volume
(
1,000
cu
ft)
treated
for
the
entire
consortium,
for
the
year
indicated.

315,000
330,000
Comments:
412,000
335,000
372,000
379,000
Volume
treated
and
quantity
ai
could
vary
due
to
acquisitions,
fumigation
failures
and/
or
special
pest
problems
that
cannot
be
treated
by
other
alternatives.
Also,
bins
are
fumigated
on
an
as­
needed
basis.
If
there
is
a
variation
(
greater
than
10%)
in
the
quantity
a.
i.,
the
volume
(
1,000
cu
ft)
treated
or
average
application
rate
from
year
to
year,
please
explain
the
reasons
for
the
variation.
Should
your
operation
only
measure
fumigation
in
one
type
of
unit
(
e.
g.
only
the
facility
is
treated
or
only
the
commodity
is
treated),
please
use
appropriate
column
for
volume
or
weight.

Year
A
Total
Actual
Pounds
ai
of
Methyl
Bromide
Applied
The
average
application
rates
in
pounds
ai
of
methyl
bromide
per
volume
(
1,000
cu
ft)
may
be
calculated
by
dividing
Column
A
by
Column
B.

Column
D:

The
average
application
rates
in
pounds
ai
of
methyl
bromide
per
ton
(
short)
may
be
calculated
by
dividing
Column
C
by
Column
D.
Column
E:

_
5________
times
per
_____
year_______
What
is
the
frequency
of
methyl
bromide
applied
per
volume
(
1,000
cu
ft)?
(
1x
/
year,
2x
/
year,
1x
/
3
years,
etc.)
Average
Pounds
ai
Applied
per
Volume
(
1,000
cu
ft)
Worksheet
2­
B.
Methyl
Bromide
­
Historical
Use
1997­
2002
Total
Actual
Pounds
ai
of
Methyl
Bromide
Applied
Enter
the
total
actual
pounds
active
ingredient
(
ai)
of
methyl
bromide
applied.
Note:
This
number
should
be
the
total
pounds
ai
applied
by
the
individual
user
or
the
entire
consortium,
for
the
year
indicated.
Include
only
the
pounds
active
ingredient
of
methyl
bromide.

Total
Weight
of
Commodity
Treated
(
in
Tons
(
short))

Enter
the
total
actual
weight
(
tons
(
short))
treated.
Note:
This
number
should
be
the
total
actual
weight
(
tons
(
short))
treated
by
the
individual
user
or
total
actual
weight
(
tons
(
short))
treated
for
the
entire
consortium,
for
the
year
indicated.
Total
Actual
Volume
(
1,000
cu
ft)
Treated
Column
C:
Average
Pounds
ai
Applied
per
Volume
(
1,000
cu
ft)
EPA
Form
#
7620­
18b
Post
Harvest
A
C
D
E
F
G
H
Year
Market
Category
(
grade,
time,
end
use)
Unit
of
Commodity
(
e.
g.,
pounds,
tons)
Total
Commodity
Treated
(
per
unit
of
commodity)
Price
(
per
unit
of
commodity)
Cost
of
Goods
Sold
(
per
unit
of
commodity)
Gross
Profit
(
per
unit
of
commodity)

$
0.00
OMB
Control
#
2060­
0482
Comments:
Commodity
Gross
profit
may
be
calculated
using
the
data
you
entered
as
the
Total
Commodity
Treated
times
Price
minus
the
Cost
of
Goods
Sold.
If
gross
profit
is
not
equal
to
total
commodity
sold
times
price
subtracted
by
cost
of
goods
sold
((
Column
E
*
Column
F)
­
Column
G),
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
gross
profit
amount
is
different
in
the
comment
section
below.
Gross
Profit
Column
H:

B
Column
F:
Price
Enter
average
prices
received
by
the
users
for
that
commodity
and
category.
For
the
total
line,
you
do
not
have
to
enter
a
price.
Average
price
over
all
categories
can
be
calculated
separately,
if
needed.
If
a
commodity
treated
is
never
owned
by
the
facility,
indicate
the
fees
charged
for
all
services.

Enter
the
total
cost
of
goods
sold
(
raw
materials
purchased)
during
the
period.
If
this
expense
is
not
relevant
to
your
postharvesting
operation,
please
skip
this
column.
Column
G:
Cost
of
Goods
Sold
Enter
marketing
categories
that
determine
prices
received,
for
example,
grade
(
quality,
taste,
color)
or
timeliness
(
holiday
market
season,
early
season,
late
season).
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
if
lack
of
methyl
bromide
would
effect
the
price
in
each
category.
Market
Categories
Column
C:
Enter
all
commodities
that
benefit
from
methyl
bromide
in
the
fumigation
cycle
(
interval
between
fumigations).
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.

If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
commodity
treated
in
the
same
facility/
structure,
please
indicate
so
in
the
comments
section
below.
Column
B:
Commodity
Worksheet
2­
C.
Baseline
­
Methyl
Bromide
­
Commodity
Treated
&
Gross
Profit
for
2000
­
2002
Column
A:

Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
commodities
in
the
fumigation
cycles
from
2000
to
2002.
If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
then
the
year
of
the
fumigation
cycle
is
the
year
methyl
bromide
was
applied.
Year
Enter
the
total
units
of
commodity
treated
with
methyl
bromide
and
processed/
sold
per
area
Enter
the
unit
of
measurement
for
each
commodity
(
lbs,
tons,
cwt).
If
not
by
weight,
specify
in
the
comments
section
the
average
weight
of
the
measure.
For
the
international
review
board,
all
measures
will
be
converted
to
metric.
Column
D:
Unit
of
Commodity
Total
Commodity
Treated
Column
E:
EPA
Form
#
7620­
18b
Post
Harvest
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

2.19
lbs/
cu
ft
4.4
$
9.64
0.73
hours
8
$
5.84
$
15.48
OMB
Control
#
2060­
0482
TOTAL
OPERATING
COSTS
3.
Interest
5.
Other
Operating
Expenses
Operating
Expense
Items
4.
Depreciation
for
Plant
Assets
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Methyl
Bromide
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
Worksheet
2­
D.
Methyl
Bromide
­
Operating
Costs
for
2002
The
purpose
of
this
worksheet
is
to
determine
operating
expenses
when
methyl
bromide
is
used.
This
forms
the
baseline
for
evaluating
the
cost
impacts
of
using
an
alternative
to
replace
methyl
bromide.
The
data
requested
are
designed
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable,
which
will
be
shown
in
Worksheet
3­
B.

A
Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
Other
operating
expenses
include,
but
are
not
limited
to,
wage/
salary,
advertising
and
selling,
utilities,
rent
and
lease,
insurance,
and
supplies.
Be
as
precise
as
necessary
to
explain
how
lack
of
methyl
bromide
would
affect
your
operation,
otherwise
you
may
aggregate
operating
expenses.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

This
field
is
required
only
for
methyl
bromide.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.
Units
(
lbs.
hours,
etc.)

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
methyl
bromide,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.
EPA
Form
#
7620­
18b
Post
Harvest
Worksheet
3­
A
3­
B
OMB
Control
#
2060­
0482
Worksheet
3.
Alternatives
­
Feasibility
of
Alternative
Pest
Control
Regimens
Purpose
of
Data:
To
estimate
the
loss
as
a
result
of
not
having
methyl
bromide
available.
EPA
needs
to
compare
data
(
commodity
prices,
gross
profit,
operating
expenses,
etc.)
on
the
use
of
methyl
bromide
and
alternative
pest
control
regimens.

Complete
worksheet
3­
A
for
each
alternative
pest
control
regimen
listed
in
the
"
U.
S.
Matrix"
for
chemical
controls
(
www.
epa.
gov/
ozone/
mbr/
cueqa.
html)
and
the
"
International
Matrix"
for
nonchemical
pest
controls
(
www.
epa.
gov/
ozone/
mbr/
cue).
Each
worksheet
contains
a
place
holder
in
the
title
for
you
to
insert
the
name
of
the
specific
alternative
pest
control
regimen
addressed.
You
should
add
additional
worksheets
as
required.

Enter
all
alternative
pesticides
and
pest
control
methods
(
and
associated
profit
and
production
practices)
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Definition
worksheet
for
a
comprehensive
definition
on
fumigation
cycles.

Title
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
You
must
complete
one
worksheet
for
each
alternative.
Please
insert
the
name
of
the
alternative
in
the
area
on
top
of
the
page.
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review.
However,
you
must
fill
in
the
information
in
Question
#
1
or
we
will
assume
no
production
or
quality
loss.

The
purpose
of
this
worksheet
is
to
determine
operating
expenses
when
alternatives
are
used
for
evaluating
the
cost
impacts
of
using
an
alternative
to
replace
methyl
bromide.
The
data
requested
are
designed
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

EPA
Form
#
7620­
18b
Post
Harvest
Alternatives
­
Changes
in
Operating
Costs
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

This
data
is
needed
to
estimate
a
baseline
for
operating
costs
in
order
to
estimate
changes
in
costs
and
the
impact
on
operating
profit
and
short­
run
economic
viability
as
a
result
of
not
using
methyl
bromide
and
to
provide
required
information
to
the
international
review
board.

Please
fill
out
this
worksheet
for
each
alternative
specified
in
the
U.
S.
Matrix
and
for
other
alternatives
for
which
the
economic
evaluation
would
bolster
the
case
that
methyl
bromide
is
needed.
1.

Study
#
%
Pest
Control
1
2
2
60
3
unk
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
x
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)
Alternative:
Phosphine
alone
and
in
combination
RC
­
industry
alternative
use
data
FR
­
industry
alternative
use
data
Study
Information
%
of
Structure/
Facility/
Volume
Details
Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

Climate
Restriction
Regulatory
Restriction
­
Label
Restriction
Pest
Resistant
To
Alternative
Structural
Limitations
Too
corrosive
for
use
as
a
structural
fumigant.
Cannot
be
used
in
entire
area.
What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
This
will
not
meet
consumer
quality
standards
because
phosphine
doesn't
kill
weevil
eggs,
which
methyl
bromide
does.

products
fumigated
with
phosphine.
Therefore,
there
is
high
probability
of
another
weevil
outbreak
in
the
product
from
the
eggs.
Also,
some
customers
will
not
Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Longer
exposure
times
required.
Deactivation
and
disposal
of
spent
product
increases
downtime
and
labor
costs.
95
Not
compatible
with
electronics.
Damage
can
be
acute
and
chronic
Other
Restrictions/
Limitations
(
Describe)
Facility
Limitations
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

days/
year
54
Please
specify
the
number
of
days
per
year
of
downtime:

per
fumigaton
per
mill
per
year.
Required
2
fumigations
some
years.
Once
the
facility
is
fumigated
with
phosphine
it
must
be
cosed
for
72
hours
to
get
the
full
effect.
Requires
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.
What
is
the
cost
of
production
delays
or
downtime
per
year?
2,163,000
per
year
longer
shut
down
time
than
MB.
Requires
whole
facility
to
be
shut
down.
Study
#
3
had
over
$
2
Million
cost
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)
Pest
Being
Tested
pilot
stored­
product
insects
Damaged
phones,
computers
and
scales
RF
­
industry
alternative
use
data.
pilot
Unknown
pilot
Rice
Weevil
6
days
downtime
beyond
bromide­
required
downtime
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
Raw
Materials
OMB
Control
#
2060­
048
EPA
Form
#
7620­
18b
Post
Harvest
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Phosphine
alone
and
in
combination
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
Magnesium
Phosphide
Degesch
FUMI­
CEL
and
Magtoxin
1
fumicel
plate
Phosphine
Phostoxin
990
2
550
8­
Jul
Fumigation
Timeline
Fumigation
Timeline
Non­
Chemical
Pest
Control
(
please
describe)

Finished
Product
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)

Reception
of
Raw
Materials
Fumigation
Cycle
Facility
Preparation
Retail
Market
Window
Other
Pest
Treatments
Other
Processing
Storage
Packing
Shipping
Sealing
Cleaning
Time
Interval
­
MONTHS
Fumigations
vary
by
facility
depending
upon
many
factors:
climate,
pest
resurgence,
financial
resources,
harvest
schedules,
etc.
Some
structural
fumigation
occurs
in
May
or
earlier,
pre­
harvest.
Some
fumigation
occurs
monthly
for
product
shipping.

Other
=
IPM,
Pyrethrins,
Electrocuters
Comments:
EPA
Form
#
7620­
18b
Post
Harvest
482
s
482
1.

Study
#
%
Pest
Control
1
3
2
3
unk
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
x
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.

OMB
Control
#
2060­
0482
Reduced
insect
control
and
virtually
no
rodent
control
in
some
structures
compared
to
MB.

EPA
Form
#
7620­
18b
Post
Harvest
Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Cannot
treat
commodity
with
heat.
Destructive
to
structures
of
mixed
construction.
In
southern
states,
heat
treatments
are
costly
since
most
facilities
do
not
have
heating
available,
therefore
heat
and
fuel
must
be
contracted.
Facility
Limitations
Other
Restrictions/
Limitations
(
Describe)
Pest
Resistant
To
Alternative
Structural
Limitations
Can
cause
expansion/
contraction
damage
­
Label
Restriction
Climate
Restriction
Southern
rice
states
have
no
built­
in
heat
sources/
fuels
%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
ineffective
treatment
in
dense
product,
and
damage
to
the
product
from
excessive
heat.
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.

Time
shown
is
days
beyond
what
is
required
for
MB.
Cost
is
one
fumigation
per
mill
per
year.
Two
fumigations
are
required
some
years.
Process
must
be
done
slowly
to
prevent
structural
damage.
What
is
the
cost
of
production
delays
or
downtime
per
year?
700,000
per
year
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
13
days/
year
FR
­
industry
alternative
use
data
Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
RF
­
Industry
alternative
use
data
Unknown
unk
unk
Stored­
product
insects
pilot
Roof
damage,
sprinkler
damage,
flooring
damage,
scale
and
equipment
damage.
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Heat
Treatment
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
x
x
x
x
x
x
EPA
Form
#
7620­
18b
Post
Harvest
Unable
to
use
if
facility
cannot
generate
steam
to
provide
heat
for
treatment
of
buildings.
Heat
Treatment
still
required
fumigation
using
MB
to
for
complete
pest
eradication.
Other
Comments:
Structural
fumigation
in
May
before
harvest.
Cannot
use
heat
for
pre­
shipment
fumigation
of
bagged
product.
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Processing
Storage
Raw
Materials
Finished
Product
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Fumigation
Cycle
Time
Interval
(
e.
g.
­
MONTHS
Facility
Preparation
Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)
Non­
Chemical
Pest
Control
(
please
describe)
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Heat
Treatment
1.

Study
#
%
Pest
Control
1
3
2
3
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
x
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.

EPA
Form
#
7620­
18b
Post
Harvest
Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Fogging
materials
are
contact
insecticides
and
cannot
penetrate
into
crevices
and
equipment.
Cannot
use
in
and
around
finished
product
or
processing
area.
Facility
Limitations
Cannot
be
used
in
processing
area
or
in
finished
product.
Other
Restrictions/
Limitations
(
Describe)
Pest
Resistant
To
Alternative
Structural
Limitations
­
Label
Restriction
Climate
Restriction
%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
would
not
meet
FGIS
quality
standards.
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.

Fogging
prep,
and
24
hour
reentry
prohibition.
What
is
the
cost
of
production
delays
or
downtime
per
year?
$
per
year
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
2.5
days/
year
Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
RF
industry
alternative
use
data
Stored­
product
insects
pilot
Did
not
achieve
complete
insect
control
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Pesticides
of
low
volatility
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
EPA
Form
#
7620­
18b
Post
Harvest
Other
Comments:
Cannot
be
used
for
compelete
structural
fumigation
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Processing
Storage
Raw
Materials
Finished
Product
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Fumigation
Cycle
Time
Interval
(
e.
g.
WEEKS/
MONTH/
YEAR)

Facility
Preparation
Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)
Non­
Chemical
Pest
Control
(
please
describe)
1124
2
Vapona
Vap20­
18.6%
0.02
lbs
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Pesticides
of
low
volatility
1.

Study
#
%
Pest
Control
1
2
3
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.

EPA
Form
#
7620­
18b
Post
Harvest
Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Cannot
be
used
for
structural
fumigation.
Requires
large
quantities
and
longer
times.
Does
not
kill
eggs.
Facility
Limitations
Other
Restrictions/
Limitations
(
Describe)
Pest
Resistant
To
Alternative
Structural
Limitations
Cannot
perform
structural
fumigation.
­
Label
Restriction
Climate
Restriction
%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
Cannot
be
used
for
structural
fumigation
and
not
as
effective
as
MB.
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.
What
is
the
cost
of
production
delays
or
downtime
per
year?
$
per
year
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
days/
year
Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
Adult
rice
weevils
adult
grain
borers
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Carbon
dioxide
(
high
pressure)
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
EPA
Form
#
7620­
18b
Post
Harvest
Other
Comments:
Sometimes
used
for
organic
rice
in
2000
lbs.
lots.
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Processing
Storage
Raw
Materials
Finished
Product
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Fumigation
Cycle
Time
Interval
(
e.
g.
WEEKS/
MONTH/
YEAR)

Facility
Preparation
Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)
Non­
Chemical
Pest
Control
(
please
describe)
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Carbon
dioxide
(
high
pressure)
1.

Study
#
%
Pest
Control
1
2
3
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
x
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Controlled
and
modified
atmospheres
(
carbon
dioxide,
nitrogen,
argon)

Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)

Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
8
days/
year
What
is
the
cost
of
production
delays
or
downtime
per
year?
1,400,000
per
year
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.
Longer
fumigation
time
required
What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
not
as
effective
as
MB.

Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
­
Label
Restriction
Climate
Restriction
Pest
Resistant
To
Alternative
Structural
Limitations
Sealing
and
maintaining
pressure
integrity
Facility
Limitations
Air
circulating
system
required
for
dispersion
Other
Restrictions/
Limitations
(
Describe)

Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Cannot
use
this
method
for
preshipment
fumigation
of
bagged
product.

EPA
Form
#
7620­
18b
Post
Harvest
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Controlled
and
modified
atmospheres
(
carbon
dioxide,
nitrogen,
argon)

Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
Non­
Chemical
Pest
Control
(
please
describe)

Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)

Fumigation
Cycle
Time
Interval
(
e.
g.
WEEKS/
MONTH/
YEAR)

Facility
Preparation
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Processing
Storage
Raw
Materials
Finished
Product
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Other
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
1.

Study
#
%
Pest
Control
1
2
3
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Contact
insecticides
alone
or
with
pest­
free
certification
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)

Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
days/
year
What
is
the
cost
of
production
delays
or
downtime
per
year?
$
per
year
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.
No
additional
downtime
than
from
using
MB,
but
it
is
used
in
conjunction
with
MB.

What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
Not
as
effective,
must
come
into
physical
contact
with
insects,
cannot
penetrate.

Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
­
Label
Restriction
Climate
Restriction
Pest
Resistant
To
Alternative
Structural
Limitations
Cannot
be
used
alone
for
structural
fumigations
Facility
Limitations
Other
Restrictions/
Limitations
(
Describe)

Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Cannot
be
used
for
pre­
shipment
of
bagged
product.
Cannot
be
used
for
structural
fumigation
EPA
Form
#
7620­
18b
Post
Harvest
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Contact
insecticides
alone
or
with
pest­
free
certification
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
Non­
Chemical
Pest
Control
(
please
describe)

Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)

Fumigation
Cycle
Time
Interval
(
e.
g.
WEEKS/
MONTH/
YEAR)

Facility
Preparation
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Processing
Storage
Raw
Materials
Finished
Product
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Other
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
1.

Study
#
%
Pest
Control
1
2
3
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Inert
dust/
diatomaceous
earth
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)

Rice
Weevil
Lesser
and
greater
Borer
All
moths
Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
days/
year
What
is
the
cost
of
production
delays
or
downtime
per
year?
$
per
year
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.

What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
On
appropriate
for
crack
and
crevice
treatment
in
a
processing
area.

Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
­
Label
Restriction
Climate
Restriction
Pest
Resistant
To
Alternative
Structural
Limitations
Cannot
treat
all
areas
of
the
structure
Facility
Limitations
Cannot
use
in
and
around
electical
or
processing
equipment.

Other
Restrictions/
Limitations
(
Describe)

Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Effective
only
on
contact.
Cannot
treat
bagged
commodity
or
in
food
processing
facility
or
for
finished
product.
Requires
too
much
exposure
time
and
requires
aspiration
after
fumigation.

EPA
Form
#
7620­
18b
Post
Harvest
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Inert
dust/
diatomaceous
earth
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
Non­
Chemical
Pest
Control
(
please
describe)

Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)

Fumigation
Cycle
Time
Interval
(
e.
g.
WEEKS/
MONTH/
YEAR)

Facility
Preparation
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Processing
Storage
Raw
Materials
Finished
Product
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Other
Comments:

Sometimes
used
on
rough
rice,
but
most
rough
rice
storage
is
turned
over
very
quickly.

EPA
Form
#
7620­
18b
Post
Harvest
1.

Study
#
%
Pest
Control
1
2
3
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Irradiation
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)

Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
days/
year
What
is
the
cost
of
production
delays
or
downtime
per
year?
$
per
year
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.

What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
Cannot
be
used
for
structural
fumigation.
Some
customers
refuse
irradiated
products.

Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
­
Label
Restriction
Climate
Restriction
Pest
Resistant
To
Alternative
Structural
Limitations
Cannot
be
used.

Facility
Limitations
Other
Restrictions/
Limitations
(
Describe)

Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Can
be
used
on
packaged
products
only
but
is
slow
and
costly,
and
unavailable
in
some
areas.

EPA
Form
#
7620­
18b
Post
Harvest
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Irradiation
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
Non­
Chemical
Pest
Control
(
please
describe)

Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)

Fumigation
Cycle
Time
Interval
(
e.
g.
WEEKS/
MONTH/
YEAR)

Facility
Preparation
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Processing
Storage
Raw
Materials
Finished
Product
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Other
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
1.

Study
#
%
Pest
Control
1
2
3
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Steam
treatments,
alone
or
with
pressure
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)

Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
4
days/
year
What
is
the
cost
of
production
delays
or
downtime
per
year?
700,000
per
year
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.
Longer
fumigation
time
required
and
heat­
up/
cool­
down
periods
must
be
performed
slowly.

What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
Ineffective
in
dense
product
and
product
damage
due
to
heat.

Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
­
Label
Restriction
Climate
Restriction
Pest
Resistant
To
Alternative
Structural
Limitations
Expansion
and
contraction
can
cause
damage.

Facility
Limitations
Other
Restrictions/
Limitations
(
Describe)

Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Cannot
use
on
the
commodity.

EPA
Form
#
7620­
18b
Post
Harvest
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Steam
treatments,
alone
or
with
pressure
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
Non­
Chemical
Pest
Control
(
please
describe)

Heat
entire
structure
and
equipment
with
steam
to
a
pre­
determined
temperature
and
hold
for
a
given
period
of
time
for
kill.

Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)

Fumigation
Cycle
Time
Interval
(
e.
g.
WEEKS/
MONTH/
YEAR)

Facility
Preparation
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Processing
Storage
Raw
Materials
Finished
Product
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Other
Comments:

Cannot
use
on
bagged
product.
Many
facilities
cannot
generate
steam.

EPA
Form
#
7620­
18b
Post
Harvest
1.

Study
#
%
Pest
Control
1
2
3
4
5
2.

Study
#
Copy?
EPA?
1
2
3
4
5
3.
Yes
No
If
yes,
please
continue
with
3a,
3b,
3c.

3a.

3b.

3c.

4.

5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Vacuum
treatment/
hermetic
storage
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
(
Provide
numerical
estimates
where
possible.)

Pest
Being
Tested
Scale
of
Study
(
e.
g.
pilot,
plot)
Resulting
Damages
(
please
specify)

Study
Information
For
the
cited
studies
above,
please
list:
study
name,
authors,
publication,
date,
and
indicate
with
a
checkmark
if
a
copy
is
attached
and
if
it
is
on
the
EPA
website.

Details
Are
there
any
production
delays
(
downtime)
associated
with
this
alternative?

Please
specify
the
number
of
days
per
year
of
downtime:
days/
year
What
is
the
cost
of
production
delays
or
downtime
per
year?
$
per
year
Please
explain
the
details
of
going
into
downtime
and
why
it
is
necessary
with
this
alternative.
Good
only
for
packaged
products.
Downtime
not
a
problem
IF
you
purchase
and
install
several
chambers.

What
is
the
estimated
probability
of
the
commodity
not
meeting
consumer
quality
standards
with
and
without
methyl
bromide
or
alternative
treatments?
(
please
explain.)

High
­
not
as
effective
as
MB.

Restrictions/
Limitations
on
Alternative
Use
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

%
of
Structure/
Facility/
Volume
Details
Regulatory
Restriction
­
Label
Restriction
Climate
Restriction
Pest
Resistant
To
Alternative
Structural
Limitations
Cannot
be
used
for
structural
fumigation.

Facility
Limitations
Other
Restrictions/
Limitations
(
Describe)

Why
is
this
alternative
not
suitable
to
replace
100%
of
methyl
bromide
use
in
processing
this
commodity?
Can
only
be
used
in
specially
constructed
chambers,
with
specific
fumigants,
one
of
them
being
MB.

EPA
Form
#
7620­
18b
Post
Harvest
7.

8.

2.

1
2
3
4
5
6
7
8
9
10
11
12
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Vacuum
treatment/
hermetic
storage
Use
Rate
of
Chemical
Alternative
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Quantity
per
Volume
(
1,000
cu
ft)
Units
(
gals,
lbs.
Etc.)
Volume
(
1,000
cu
ft)
Treated
#
of
Applications
per
Year
Non­
Chemical
Pest
Control
(
please
describe)

Small
quantities
of
product
are
placed
into
a
chamber
and
placed
under
vacuum,
killing
insects
in
the
product.

Fumigation
Timeline
(
Indicate
when
fumigation,
major
commodity
and
pest
management
practices
typically
occur.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.)

Fumigation
Cycle
Time
Interval
(
e.
g.
WEEKS/
MONTH/
YEAR)

Facility
Preparation
Sealing
Cleaning
Fumigation
Timeline
Reception
of
Raw
Materials
Processing
Storage
Raw
Materials
Finished
Product
Packing
Shipping
Retail
Market
Window
Other
Pest
Treatments
Other
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

0.8
hours
27
21.6
21.6
Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)

300,000
25
0
6
125,000
12
0
6
OMB
Control
#
2060­
0482
1.
Pest
Management
Costs
(
a+
b+
c+
d)
If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.
5.
Other
Operating
Expenses
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Comments:
TOTAL
OPERATING
COST
CO2
generation
and
delivery
system
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?

Type
of
Investment
Building
w/
pressure
chambers
a)
Sanitation
4.
Depreciation
for
Plant
Assets
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
Operating
Expense
Items
Units
(
lbs.
hours,
etc.)
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

This
is
not
a
practical
solution
because
it
cannot
be
used
for
structural
fumigation,
which
is
where
the
majority
of
MB
is
used.
Suitable
for
packaged
product
treatment
only.
Operating
cost
is
for
loading
and
unloading
the
pressure
chamber
with
product
prior
to
shipping.
Alternative:
Carbon
dioxide
(
high
pressure)

A
Operating
Expense
Items
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.
EPA
Form
#
7620­
18b
Post
Harvest
prior
to
shipping.
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)
OMB
Control
#
2060­
0482
Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Alternative:
Phosphene
alone
and
in
combination
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

Units
(
lbs.
hours,
etc.)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

A
Operating
Expense
Items
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
4.
Depreciation
for
Plant
Assets
5.
Other
Operating
Expenses
TOTAL
OPERATING
COST
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?

Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.

Type
of
Investment
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
High
corrosion
factor
eliminates
it
as
a
candidate
for
structural
fumigation.
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

77
lbs.
0.58
44.66
0.73
hours
8
5.84
50.5
Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)

300,000
12
0
6
150,000
12
0
6
125,000
12
0
6
OMB
Control
#
2060­
0482
Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Alternative:
Controlled
and
modified
atmospheres
(
CO2,
nitrogen,
argon)

Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

Units
(
lbs.
hours,
etc.)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

A
Operating
Expense
Items
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
4.
Depreciation
for
Plant
Assets
5.
Other
Operating
Expenses
TOTAL
OPERATING
COST
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?
Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.

Type
of
Investment
Gas
generation
and
delivery
system
Air
ciruclation
system
Electrical
modifications
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Custom
Heat
Treatments
Contract
Heat
and
rental
17.9
Fuel
3.2
Labor
3.5
24.6
Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)

1,000,000
12
0
6
150,000
12
0
6
150,000
12
0
6
250,000
12
0
6
3­
B(
3)

Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Alternative:
Heat
Treatment
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

Units
(
lbs.
hours,
etc.)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

A
Operating
Expense
Items
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
4.
Depreciation
for
Plant
Assets
5.
Other
Operating
Expenses
TOTAL
OPERATING
COST
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?

Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.

Type
of
Investment
Steam
heating
system
Air
circulation
system
Electrical
Modification
Equipment
retrofit
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
Investment
costs
are
for
installation
and
maintenance
of
steam
system,
and
unsure
of
application
cost
per
1,000
cu.
ft.
Cannot
treat
product.
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

N/
A
Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)
3
Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Alternative:
Inert
dust/
diatomaceous
earth
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

Units
(
lbs.
hours,
etc.)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

A
Operating
Expense
Items
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
4.
Depreciation
for
Plant
Assets
5.
Other
Operating
Expenses
TOTAL
OPERATING
COST
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?

Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.

Type
of
Investment
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
This
method
of
pest
control
is
used
primarily
for
pre­
processed
bulk
stored
product,
not
for
structural
or
packaged
product
fumigation.
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

N/
A
Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)

4,500,000
12
0
6
OMB
Control
#
2060­
0482
Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Alternative:
Irradiation
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

Units
(
lbs.
hours,
etc.)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

A
Operating
Expense
Items
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
4.
Depreciation
for
Plant
Assets
5.
Other
Operating
Expenses
TOTAL
OPERATING
COST
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?

Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.

Type
of
Investment
Irradiation
equip
for
packaged
product.

Comments:

EPA
Form
#
7620­
18b
Post
Harvest
This
is
not
a
practical
solution
because
it
cannot
be
used
for
structural
fumigation
which
is
where
the
majority
of
MB
is
used.
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

N/
A
Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)
OMB
Control
#
2060­
0482
Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Alternative:
Pesticides
of
low
volitility
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

Units
(
lbs.
hours,
etc.)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

A
Operating
Expense
Items
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
4.
Depreciation
for
Plant
Assets
5.
Other
Operating
Expenses
TOTAL
OPERATING
COST
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?

Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.

Type
of
Investment
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
This
alternative
cannot
be
used
for,
or
around
finished
product.
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)

1,000,000
12
0
6
150,000
12
0
6
150,000
12
0
6
250,000
12
0
6
OMB
Control
#
2060­
0482
Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Alternative:
Steam
treatment,
alone
or
with
pressure
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

Units
(
lbs.
hours,
etc.)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

A
Operating
Expense
Items
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
4.
Depreciation
for
Plant
Assets
5.
Other
Operating
Expenses
TOTAL
OPERATING
COST
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?

Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.

Type
of
Investment
Steam
heating
system
Air
circulation
system
Electrical
modification
Equipment
retrofit
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
Not
sure
of
application
per
1,000
cu.
ft.
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

B
C
D
E
Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
Tons
(
short))
Units
(
lbs,
hours,
etc.)
Unit
Cost
($)
Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

0.8
hours
27
21.6
21.6
Total
Investment
($)
Life
of
Investment
(#
of
years)
Salvage
Value
($)
Interest
Rate
(%)

300,000
25
0
6
50,000
12
0
6
OMB
Control
#
2060­
0482
Worksheet
3­
B.
Alternative
­
Changes
in
Operating
Expenses
Alternative:
Vacuum
treatment/
hermetic
storage
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operating
Expense
Items
Identify
the
operations
to
which
the
costs
apply.
You
may
add
or
delete
lines
as
necessary.
The
operating
expense
items
listed
here
are
not
meant
to
be
exhaustive
or
be
representative
of
your
specific
operating
system.
These
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.

Quantity
Used
per
Volume
(
1,000
cu
ft)
or
Weight
(
tons
(
short))

This
field
is
required
only
for
alternatives.
However
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.

Units
(
lbs.
hours,
etc.)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Unit
Cost
($)

For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
alternatives,
including
any
material
costs
(
e.
g.
tarps).
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.

Cost
($)
per
Volume
(
1,000
cu
ft)
or
Cost
($)
per
Weight
(
tons
(
short))

Enter
all
appropriate
costs
of
operations
per
volume
(
1,000
cu
ft)
or
weight
(
tons
(
short)).
You
may
add
or
delete
lines
as
necessary.

If
operation
is
defined
in
either
cost
per
volume
or
cost
per
weight,
please
keep
the
continuity
of
units.

A
Operating
Expense
Items
1.
Pest
Management
Costs
(
a+
b+
c+
d)

a)
Sanitation
b)
Pest
Control
c)
Fumigation
(
c1+
c2)

c1)
Product
c2)
Application
d)
Other
Pest
Management
Costs
2.
Repairs
/
Maintenance
/
Replacement
3.
Interest
4.
Depreciation
for
Plant
Assets
5.
Other
Operating
Expenses
TOTAL
OPERATING
COST
What
are
the
additional
new
investments
(
structures,
facilities,
equipment,
fumigation
chambers,
etc.)
needed
to
utilize
this
alternative?

Establish
necessary
capital
expenditures
required
for
the
uses
of
alternatives.
For
example,
the
incremental
costs
to
convert
to
heat
treatment
might
include
installing
a
steam
heating
system,
purchasing
generators,
installing
necessary
ductwork,
and
retrofitting
other
components
to
make
them
amenable
to
heat
treatment.

Type
of
Investment
Building
w/
vacuum
chambers
Vacuum
system
Comments:

EPA
Form
#
7620­
18b
Post
Harvest
Not
for
structural
fumigation.
Operating
cost
is
for
loading
and
unloading
the
vacuum
chamber
with
product
prior
to
shipping.
1.
1
4
2
5
3
2.
1
4
2
5
3
3.
1
4
2
5
3
4.

5.

6.

7.

From:
To:

x
x
x
x
x
8.

Year
Amount
($)

9.
$

Cost
10.
OMB
Control
#
2060­
0482
Worksheet
4.
Future
Research
Plans
Please
describe
future
plans
to
test
alternatives
to
methyl
bromide.
You
may
use
this
worksheet
to
describe
all
future
plans.

Identify
the
top
3
to
5
target
pests
for
your
research.
Rusty
Grain
Beetle
Red
Flour
Beetle
Indian
Meal
Moth
Provide
a
list
of
alternative
chemicals
or
cultural
practices
that
have
been
tested.
IPM
Ozone
Insect
Electrocuters
Heat
Prioritize
the
alternative
chemicals
or
cultural
practices
to
be
tested.
Crack/
crevice
treatment
What
would
be
the
best
currently
available
alternative
if
methyl
bromide
were
not
available?

yes
Will
you
collect
data
on
the
probability
of
failure
to
meet
quality
standards?
Please
provide
an
overview/
timeline
of
the
plan
to
transition
away
from
using
methyl
bromide.
10
years
plus
How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?

(
check
all
that
apply)
Formulation
Changes
(
please
specify)
Formulation
Changes
Tarpaulin
(
High
Density
Polyethylene)
_____%
methyl
bromide,
_____%
chloropicrin
Virtually
Impermeable
Film
(
VIF)
_____%
methyl
bromide,
_____%
chloropicrin
Reclamation
Other
Pesticides
(
please
specify)
Sealing
Buildings
Buildings
are
sealed
and
taped
prior
to
application
Cultural
Practices
(
please
specify)
Training
for
employees
is
in
effect
None
known
at
this
time
Grant
requests
made
to
USDA,
EPA,
state,
or
other
funding
group.
(
Describe
each
investment
and
its
associated
costs.
e.
g.
specialized
machinery,
new
facilities,
etc.)

Investment
Investments
are
by
invidual
companies.
Other
total
investments,
if
any,
made
to
reduce
your
reliance
on
methyl
bromide?
Individual
companines
and
researchers
attempting
to
find
what
suits
best
to
particular
geography,
climate,
and
pest
populations.

EPA
Form
#
7620­
18b
Post
Harvest
What
is
the
cumulative
amount
spent
and
the
types
of
contributions
this
consortium
has
made
to
fund
research
to
develop
alternatives
to
methyl
bromide
since
1992?
(
e.
g.
consortium
dues,
direct
research
funding,
etc.)

Name
of
Organization
/
Research
Institution
Integrated
Pest
Management
(
IPM)
In
effect
electrocuters
Non­
Chemical
Methods
(
please
specify)
Other
1.

2.

3.

4.
2005
5.
2005
6.

2006
447,000
lbs.
218,000
2007
447,000
lbs.
218,000
Not
Technically
Feasible
Not
Economically
Feasible
X
X
X
X
X
x
x
x
x
x
x
x
x
x
x
x
For
EPA
Use
Only
ID
#
_______________

SECTOR
___________________________

This
worksheet
will
be
posted
on
the
web
to
notify
the
public
of
requests
for
critical
use
exemptions
beyond
the
2005
phase
out
for
methyl
bromide.
Therefore,
this
worksheet
cannot
be
claimed
as
CBI.

Rice
Millers
Association
4301
N.
Fairfax
Drive,
Ste.
425,
Arlington,
VA
22203
Worksheet
5.
Application
Summary
Consortium
Name:

Location:

447,000
218,000
(
1,000
cu
ft)
of
rice
mills.
Private
industry
is
testing
alternatives
but
has
not
been
successful
in
replacing
methyl
bromide
for
facility
fumigation.

Volume
Treated
Volume
Treated
$
8,000
more
expensive
per
treatment,
damaging
to
equipment
($
2.5
million),
finished
goods/
packaging
areas
cannot
be
heat
treated,
Huge
capital
improvement
costs
to
Has
negative
metallurgical
effects
w/
electrical
systems
and
microprocessors
causing
severe
corrosion
costing
approximately
$
250,000
per
year
in
repairs,
takes
4
to
7
days
(
1,000
cu
ft)

Not
for
food
processing
areas,
crack
and
crevice
treatment
onl
Not
for
commodity,
expensive
to
install
and
maintain
equipmen
CO2
Not
for
structures,
unacceptable
to
customers,
unavailable.
Not
for
structures,
requires
clean
up,
not
for
food
processing
ar
Cannot
be
use
for
structural
fumigation.
Works
best
with
MB.
Controlled
atmospheres
Contact
insecticides
Costly
and
cannot
be
used
in
all
instances.
Cannot
be
use
for
structural
fumigation.
Heat
Treatments
Phosphine
Place
an
"
X"
in
the
column(
s)
labeled
"
Not
Technically
Feasible"
and/
or
"
Not
Economically
Feasible"
where
appropriate.
Use
the
"
Reasons"
column
to
describe
why
the
potential
alternative
is
not
feasible.

Reasons
Potential
Alternatives
Vacuum
treatment
Not
for
structure.
Requires
expensive
equipment
Inert
dust
Irradiation
Pesticides
of
low
volitility
Steam
treatment
OMB
Control
#
2060­
0482
Rice
Millers
Association
lbs.

(
1,000
cu
ft)

To
date
there
is
no
comparable
and
cost
efficient
alternative
to
methyl
bromide
for
structural
or
storage
fumigation
Pounds
of
Methyl
Bromide
Requested
Volume
Treated
with
Methyl
Bromide
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:
Crop:
EPA
Form
#
7620­
18b
Post
Harvest
82
Fumigation
cycle:

Year:

Comparable
data:

2­
year
example:

Other
beneficiary
example
Crop
cycle
change
example:

Crop
Grouping
EPA
Form
#
7620­
18b
The
period
of
time
between
methyl
bromide
fumigations.

If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
"
year"
refers
to
the
calendar
year
when
methyl
bromide
is
applied
(
or
the
beginning
of
the
cycle).

In
order
to
compare
revenues
and
costs
with
and
without
methyl
bromide,
data
on
alternatives
for
pest
control,
yields,
revenues,
and
costs
must
be
for
the
same
time
interval
as
the
methyl
bromide
fumigation
cycle.
If,
however,
quantitative
data,
is
not
available
for
the
entire
fumigation
cycle,
then
to
be
comparable,
the
quantitative
data
for
the
alternatives
should
cover
the
same
portion
of
the
fumigation
cycle
as
the
quantitative
data
for
methyl
bromide,
and
the
rest
of
the
cycle
should
be
discussed
in
the
comments
sections.

If
a
methyl
bromide
fumigation
is
made
every
2
years,
then
the
2001
fumigation
cycle
began
in
2001
and
would
end
in
2003.
The
data
should
cover
the
methyl
bromide
costs
and
usage
for
the
methyl
bromide
fumigation
made
in
2001,
and
all
yields
and
revenues
received
and
other
costs
incurred
during
the
2
year
period.
To
be
comparable,
the
data
on
alternatives
should
cover
a
similar
2
year
period
beginning
in
2005
beginning
at
the
same
time
of
year
when
a
methyl
bromide
fumigation
would
be
made.
The
data
should
cover
all
methyl
bromide
alternatives
used,
and
all
yields
and
revenues
received
during
that
2­
year
interval.
Other
pest
control
and
other
costs
would
only
need
to
be
provided
for
that
interval
if
they
would
change
from
what
they
were
with
methyl
bromide.

If
someone
other
than
the
applicant
benefits
from
a
methyl
bromide
fumigation,
you
should
comment
on
these
benefits
if
you
do
not
have
quantitative
data
for
the
entire
fumigation
cycle.
For
example,
if
a
rotational
crop
in
the
second
year
benefits
from
a
methyl
bromide
fumigation
a
year
earlier,
but
there
is
quantitative
data
only
on
the
first
crop,
then
the
data
on
the
alternatives
should
cover
only
the
first
crop,
and
the
benefits
of
methyl
bromide
and
the
additional
pesticides
that
would
have
to
be
used
on
the
rotational
crop
should
be
discussed
in
the
comments
sections.

If
in
a
one
year
interval,
methyl
bromide
is
applied,
tomatoes
are
grown
and
harvested
followed
by
peppers,
then
the
fumigation
cycle
would
be
one
year
including
the
tomatoes
and
peppers.
If,
however,
without
methyl
bromide,
it
is
not
possible
to
follow
tomatoes
with
peppers
in
the
same
one
year
interval,
then
the
alternative
data
on
pesticides,
costs,
yields,
and
revenues
should
just
cover
tomatoes.
The
loss
of
profit
from
not
being
able
to
grow
peppers
with
the
alternatives
would
be
part
of
the
loss
from
not
having
methyl
bromide.

The
applicant
can
group
simliar
crops
together
if:
(
i)
Crops
would
experience
similar
yield
and
quality
losses
in
the
absence
of
methyl
bromide;
and
(
ii)
Crops
are
grown
on
the
same
fumigation
and
cultivation
cycle
with
similar
operating
costs.
For
example,
nursery
crops
including
various
flower
or
tree
species
can
be
aggregated,
with
average
yields
per
acre
and
prices.
However,
if
crops
are
distinctly
different
in
revenues
and
operating
costs,
or
the
cycles,
the
applicant
may
want
to
present
yield,
price
and
operating
costs
for
each
crop
separately
and
also
indicate
the
proportion
of
land
area
allocated
to
each
crop.
Definitions:
OMB
Control
#
2060­
0482
Post
Harvest
