METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
POST
HARVEST
USE
FOR
COMMODITIES
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:
YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Post
Harvest
Use
for
Commodities
NOMINATING
PARTY
CONTACT
DETAILS
Contact
Person:
John
E.
Thompson,
Ph.
D.
Title:
International
Affairs
Officer
Address:
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington,
DC
20520
U.
S.
A.
Telephone:
(
202)
647­
9799
Fax:
(
202)
647­
5947
E­
mail:
ThompsonJE2@
state.
gov
Following
the
requirements
of
Decision
IX/
6
paragraph
(
a)(
1),
the
United
States
of
America
has
determined
that
the
specific
use
detailed
in
this
Critical
use
Nomination
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
this
use
would
result
in
a
significant
market
disruption.

X
Yes

No
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Tina
E.
Levine,
Ph.
D.
Title:
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
ii
Mail
Code
7503C
Washington,
DC
20460
U.
S.
A.
Telephone:
(
703)
308­
3099
Fax:
(
703)
308­
8090
E­
mail:
levine.
tina@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
iii
TABLE
OF
CONTENTS
Part
A:
Summary
.......................................................................................................................
5
1.
Nominating
Party................................................................................................................
5
2.
Descriptive
Title
of
Nomination
..........................................................................................
5
3.
Situation
of
Nominated
Methyl
Bromide
Use
......................................................................
5
4.
Methyl
Bromide
Nominated................................................................................................
5
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use.......................................
6
6.
Methyl
Bromide
Consumption
for
Past
5
Years
and
Amount
Requested
in
the
Year(
s)
Nominated
..............................................................................................................................
9
7.
Location
of
the
Facility
or
Facilities
Where
the
Proposed
Critical
Use
of
Methyl
Bromide
Will
Take
Place.......................................................................................................................
9
Part
B:
Situation
Characteristics
and
Methyl
Bromide
Use.....................................................
12
8.
Key
Pests
for
which
Methyl
Bromide
is
Requested
...........................................................
12
9.
Summary
of
the
Circumstances
in
which
Methyl
Bromide
is
Currently
Being
Used
..........
13
10.
List
Alternative
Techniques
that
are
being
Used
to
Control
Key
Target
Pest
Species
in
this
Sector....................................................................................................................................
14
Part
C:
Technical
Validation
...................................................................................................
15
11.
Summarize
the
Alternative(
s)
Tested,
Starting
with
the
Most
Promising
Alternative(
s)
...
15
12.
Summarize
Technical
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances
.........................................................................................................
15
Part
D:
Emission
Control.........................................................................................................
18
13.
How
has
this
Sector
Reduced
the
Use
and
Emissions
of
Methyl
Bromide
in
the
Situation
of
the
Nomination?
...............................................................................................................
18
Part
E:
Economic
Assessment
.................................................................................................
19
14.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
........................
19
15.
Summarize
Economic
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances
.........................................................................................
19
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
..........................................
24
Part
F:
Future
Plans................................................................................................................
27
16.
Provide
a
Detailed
Plan
Describing
How
the
Use
and
Emissions
of
Methyl
Bromide
Will
Be
Minimized
in
the
Future
for
the
Nominated
Use...............................................................
27
17.
Provide
a
Detailed
Plan
Describing
What
Actions
Will
Be
Undertaken
to
Rapidly
Develop
and
Deploy
Alternatives
for
this
Use:
....................................................................................
28
18.
Additional
Comments......................................................................................................
31
19.
Citations..........................................................................................................................
33
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS......................
Error!
Bookmark
not
defined.
iv
LIST
OF
TABLES
Part
A:
Summary
........................................................................................................................
5
Table
4.1:
Methyl
Bromide
Nominated
......................................................................................
5
Table
A.
1:
Executive
Summary...................................................................................................
8
Table
6.1:
Methyl
Bromide
Consumption
for
the
Past
5
Years
and
the
Amount
Requested
in
the
Year(
s)
Nominated..............................................................................................................
9
Table
A.
2:
2006
Nomination
­
Post
Harvest
Use
for
Commodities
...........................................
11
Part
B:
Situation
Characteristics
and
Methyl
Bromide
Use.....................................................
12
Table
8.1:
Key
Pests
for
Methyl
Bromide
Request
...................................................................
12
Table
B.
1:
Key
Pests
by
Commodity........................................................................................
12
Table
B.
2:
Characteristic
of
Sector...........................................................................................
12
Table
9.1(
a.):
Commodities......................................................................................................
13
Table
9.1(
b.):
Fixed
Facilities
..................................................................................................
13
Part
C:
Technical
Validation
...................................................................................................
15
Table
12.1:
Summary
of
Technical
Reason
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................................
15
Table
12.2:
Food
Processing
Plants
 
Comparison
of
Alternatives
to
Methyl
Bromide
Fumigation........................................................................................................................
17
Part
D:
Emission
Control.........................................................................................................
18
Part
E:
Economic
Assessment
.................................................................................................
19
Table
14.1
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
a
3­
Year
Period..............
19
Table
15.1.
Summary
of
Economic
Reasons
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................................
19
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
for
Walnut
...............................
24
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
for
Pistachio.............................
25
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
for
Dried
Fruit..........................
26
Table
E.
4:
Economic
Impacts
of
Methyl
Bromide
Alternatives
for
Date
...................................
27
Part
F:
Future
Plans................................................................................................................
27
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
..................................
35
Page
5
PART
A:
SUMMARY
1.
NOMINATING
PARTY
The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION:

Methyl
Bromide
Critical
Use
Nomination
for
Post
Harvest
Use
for
Commodities
3.
SITUATION
OF
NOMINATED
METHYL
BROMIDE
USE
This
sector
includes
walnuts,
pistachios,
dried
fruit
(
prunes,
raisins,
figs),
and
dates,
which
are
under
intense
pressure
from
numerous
insect
pests.
Methyl
bromide
is
being
used
to
treat
these
commodities
in
a
very
short
period,
during
the
peak
production
season
and
shortly
after
harvest,
before
they
can
be
stored
and/
or
shipped
to
prevent
pests
from
infesting
and
degrading
the
commodity
in
storage.
Most
fumigations
are
made
over
a
few
weeks,
during
the
peak
production
season
when
the
bulk
of
the
harvest
is
moving
into
the
storage
and
shipping
channels.
These
periods
can
be
compressed
when
harvest
occurs
close
to
key
market
windows,
such
as
holiday
markets
for
certain
types
of
dried
fruits
and
nuts.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
VOLUME
TREATED
(
1,000
M
3)
2006
82,916
2,689
The
U.
S.
nomination
is
only
for
those
facilities
where
the
use
of
alternatives
is
not
suitable.
For
U.
S.
commodities
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
Pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide,
making
these
alternatives
technically
and/
or
economically
infeasible.
­
Constraints
of
the
alternatives:
some
types
of
commodities
(
e.
g.,
those
containing
high
levels
of
fats
and
oils)
prevent
the
use
of
heat
as
an
alternative
because
of
its
effect
on
the
final
product
(
e.
g.,
rancidity).
In
other
cases
the
character
of
the
final
product
is
changed,
becoming
cooked
(
toasted)
rather
than
raw
nuts,
for
example.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
dried
fruits
and
nuts;
state
registrations
have
not
yet
been
issued.
All
of
the
dried
fruit
operations
requesting
methyl
bromide
are
located
in
California,
a
state
with
a
lengthy
and
rigorous
registration
process.
Further,
it
will
take
some
time
for
applicators
to
be
trained
in
the
use
of
this
chemical
and
for
its
incorporation
into
a
pest
control
program.
­
Longer
fumigations:
e.
g.,
the
use
of
some
methyl
bromide
alternatives
can
add
a
delay
to
production
by
requiring
additional
time
to
complete
the
fumigation
process.
Production
delays
can
result
in
significant
economic
impacts
if
the
delay
causes
the
producers
to
miss
a
market
window.
Longer
fumigation
periods
may
not
be
feasible
in
situation
where
there
Page
6
is
not
excess
fumigation
capacity
i.
e.
when
facilities
are
in
continuous
use.
In
these
situations
longer
fumigations
for
some
products
mean
that
others
cannot
be
fumigated.

5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
(
Describe
the
particular
aspects
of
the
nominated
use
that
make
methyl
bromide
use
critical,
e.
g.
lack
of
economic
alternatives,
unacceptable
corrosion
risk,
lack
of
efficacy
of
alternatives
under
the
particular
circumstances
of
the
nomination)

Methyl
bromide
is
needed
primarily
to
treat
stored
agricultural
commodities
in
a
very
short
period,
during
the
peak
production
season,
shortly
after
harvest
before
they
can
be
stored
and/
or
shipped.
These
treatments
prevent
field
pests
from
infesting
and
degrading
the
commodity
in
storage.
Fumigations
must
be
made
over
a
very
short
period,
during
the
peak
production
season
when
the
bulk
of
the
harvest
is
moving
into
the
storage
and
shipping
channels.
These
periods
can
be
compressed
when
harvest
occurs
close
to
key
market
windows,
such
as
holiday
markets
for
certain
types
of
nuts.

The
technical
and
economic
feasibility
analyses
indicate
that
phosphine
alone
or
combined
with
carbon
dioxide
(
Eco2fume
®
)
is
the
only
chemical
alternative
currently
available
for
use
on
inshell
walnuts,
pistachios,
dried
fruit,
and
dates.
Phosphine
fumigation,
however,
takes
longer
than
methyl
bromide
and
is
not
a
currently
feasible
alternative
when
rapid
fumigations
are
needed.
Harvest
of
commodities
occurs
in
autumn,
when
temperatures
are
falling,
making
temperature­
dependent
phosphine
fumigation
less
likely.
These
sectors
are
already
using
phosphine
alone
or
in
combination
to
the
extent
that
their
processing
systems
and
marketing
needs
allow
it.
Any
additional
shifting
from
methyl
bromide
to
the
slower
phosphine
fumigation
would
result
in
disruption
of
commodity
processing
during
peak
production
times,
lost
market
windows,
and
substantial
economic
losses.

Adoption
of
not
in
kind
alternatives,
such
as
controlled
atmospheres,
cold,
and
carbon
dioxide
under
pressure
would
require
major
investments
for
appropriate
treatment
units
and
/
or
retrofitting
of
existing
warehouses.
As
with
Eco2fume
®
,
these
alternatives
could
not
be
implemented
in
the
short
term
without
significant
investment
in
new
facilities.
Estimated
costs
for
treatment
facilities
are
at
least
as
great
as
building
costs
for
Eco2fume,
and
do
not
include
costs
of
land
acquisition
and
development.
The
dried
fruit
and
nut
industries
in
the
United
States
have
reduced
the
number
of
methyl
bromide
fumigations
by
incorporating
many
of
the
alternatives
identified
by
MBTOC,
such
as
implementing
IPM
strategies,
especially
sanitation,
in
storage
facilities.
Pest
populations
are
monitored
using
visual
inspections,
pheromone
traps,
light
traps
and
electrocution
traps.
When
insect
pests
are
found,
plants
will
attempt
to
contain
the
infestation
with
treatments
of
low
volatility
pesticides
applied
to
both
surfaces
and
cracks
and
crevices.
These
techniques
do
not
disinfest
a
facility
but
are
critical
in
monitoring
and
managing
pests.

Although,
in
time,
the
commodity
industry
will
be
able
to
gradually
adopt
alternatives
as
these
become
available,
the
sudden
adoption
of
the
next
best
alternative,
phosphine
alone
or
in
combination,
would
adversely
impact
the
industry's
ability
to
rapidly
process
commodities
during
the
peak
harvest
season
and
to
access
key
market
windows.
That
is,
the
industry
would
Page
7
likely
suffer
significant
economic
losses
if
it
were
to
fully
replace
methyl
bromide
with
phosphine,
mainly
because
of
the
cost
of
production
delay.
The
estimated
economic
loss
per
1000
m3
ranges
from
$
18,745
for
dried
fruit
to
$
308,476
for
pistachios.
The
estimated
economic
loss
as
a
percentage
of
net
revenue
is
greater
than
100%
for
the
CUE
applicants
in
the
commodity
sector.
Page
8
TABLE
A.
1:
EXECUTIVE
SUMMARY*
Walnuts
Pistachios
Dried
Fruit
Dates
Amount
of
Request
2006
Kilograms
87,362
4,990
20,412
3,467
Application
Rate
(
kg/
m
³
)
60.87
21.0
24.0
21.0
Volume
(
1000
cubic
meters)
1,435
238
850
167
2006
Nominated
Amount
(
kg)
55,178
4,217
18,218
3,016
Marginal
Strategy
Phosphine
Phosphine
Phosphine
Phosphine
Time
Lost
84
DAYS
PER
YEAR
84
DAYS
PER
YEAR
84
DAYS
PER
YEAR
84
DAYS
PER
YEAR
Loss
per
1000
m
³
$
97,121
$
308,476
$
18,745
$
85,484
Loss
per
kg
MB
(
US$/
kg)
$
978
$
14,620
$
781
$
4,110
Loss
as
%
of
Gross
Revenue
(%)
28.06%
28.02%
28.33%
28.07%

Loss
as
%
of
Net
Revenue
(%)
561.24%
121.72%
130.38%
564.41%

Describe
Economic
Impacts
Economic
losses
are
from
additional
production
downtimes
due
to
longer
fumigation
time
from
and
capital
expenditures
required
to
adopt
an
alternative.

*
See
Appendix
A
for
complete
description
of
how
nominated
amount
was
calculated.
Page
9
6.
METHYL
BROMIDE
CONSUMPTION
FOR
PAST
5
YEARS
AND
AMOUNT
REQUESTED
IN
THE
YEAR(
S)
NOMINATED:

TABLE
6.1:
METHYL
BROMIDE
CONSUMPTION
FOR
THE
PAST
5
YEARS
AND
THE
AMOUNT
REQUESTED
IN
THE
YEAR(
S)
NOMINATED
Historical
Use1
Requested
Use
For
each
year
specify:
1997
1998
1999
2000
2001
2002
2005
2006
Amount
of
MB
(
kg)
88,094
92,006
104,588
91,334
102,616
76,400
125,953
116,230
Volume
Treated
(
1000
m
³
)
2,223
3,285
3,125
2,428
2,718
1,548
2,829
2,690
Formulation
of
MB
Dosage
Rate
(
kg/
1000
m
³
)
28.67
26.38
25.89
28.44
28.58
34.44
31.7
31.7
Actual
(
A)
or
Estimate
(
E)

1
Based
on
most
current
information.

7.
LOCATION
OF
THE
FACILITY
OR
FACILITIES
WHERE
THE
PROPOSED
CRITICAL
USE
OF
METHYL
BROMIDE
WILL
TAKE
PLACE
(
Give
name
and
physical
address.
Continue
on
separate
sheet(
s)
as
annex
to
this
form
if
necessary.
Number
each
address
from
one
onwards)

This
nomination
package
represents
four
commodity
sectors,
all
produced
entirely
in
California:
walnuts,
pistachios,
dried
fruit
(
prunes,
raisins,
and
figs),
and
dates.
Walnuts
are
grown
and
processed
primarily
in
the
Sacramento
and
San
Joaquin
Valleys.
Significant
production
also
occurs
in
the
coastal
valleys
in
the
counties
of
Santa
Barbara,
San
Luis
Obispo,
Monterey,
and
San
Benito.

Pistachios
are
grown
mainly
in
the
San
Joaquin
and
Sacramento
valleys.
Kern
County
leads
California
in
pistachio
production
with
over
40
percent
of
the
total
crop.
Other
top
producing
counties
include
Madera,
Kings,
Fresno
and
Tulare.
Pistachios
are
grown
as
far
north
as
Shasta
County
and
as
far
south
as
Riverside
County.

The
majority
of
California
prunes
are
grown
in
the
Sacramento
Valley.
Other
production
areas
in
the
San
Joaquin
Valley
include
primarily
Tulare
and
Fresno
counties.

About
99%
of
California's
raisin
grape
production
is
in
the
southern
San
Joaquin
Valley
region.
Fresno
County
alone
produces
about
70%
of
California's
raisins.
Merced
County
is
the
only
northern
San
Joaquin
Valley
County
with
any
significant
commercial
production
of
raisins.

The
San
Joaquin
Valley
is
the
predominantly
fig­
producing
area
in
California
with
Madera,
Merced,
and
Fresno
counties
leading
in
production.

Most
U.
S.
dates
are
grown
in
California's
Coachella
Valley,
Riverside
and
Imperial
counties.
Page
10
The
location
of
each
facility
where
methyl
bromide
fumigation
may
take
place
was
not
requested
in
the
forms
filled
out
by
the
applicants
in
the
United
States.
Therefore,
we
currently
do
not
have
a
complete
listing
of
the
addresses
for
each
facility.
Page
11
TABLE
A.
2:
2006
NOMINATION
­
POST
HARVEST
USE
FOR
COMMODITIES*

2006
NOMINATION
­
POST
HARVEST
USE
FOR
COMMODITIES
Walnuts
Pistachios
Dried
Fruit
Dates
Requested
Kilograms
(
kg)
87,362
4,990
20,412
3,467
Requested
Application
Rate
(
kg/
1000
m
³
)
60.9
21.0
24.0
21.0
Applicant
Request
for
2006
Requested
Volume
(
1000
m
³
)
1,435
238
850
167
Nominated
Volume
(
1000
m
³
)
1,148
201
773
145
Nominated
Application
Rate
(
kg/
1000
m
³
)
48
21
24
21
CUE
Nominated
for
2006
Nominated
Kilograms
(
kg)
55,178
4,217
18,218
3,016
2006
NOMINATION
TOTALS
­
POST
HARVEST
USE
FOR
COMMODITIES
OVERALL
REDUCTION
(%)
29
2006
U.
S.
CUE
NOMINATION
(
KG)
82,896
RESEARCH
AMOUNT
(
KG)
20
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
82,916
*
See
Appendix
A
for
complete
description
of
how
nominated
amount
was
calculated.
Page
12
PART
B:
SITUATION
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
8.
KEY
PESTS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
TABLE
8.1:
KEY
PESTS
FOR
METHYL
BROMIDE
REQUEST
GENUS
AND
SPECIES
FOR
WHICH
THE
USE
OF
METHYL
BROMIDE
IS
CRITICAL
COMMON
NAME
SPECIFIC
REASON
WHY
METHYL
BROMIDE
IS
NEEDED
Cydia
pomonella
Codling
moth
Amyelois
transitella
Navel
orangeworm
Plodia
interpunctella
Indianmeal
moth
Tribolium
castaneum
Red
Flour
Beetle
Cadra
figulilella
Raisin
Moth
Carpophilus
sp.
Dried
Fruit
Beetle
Ectomyelois
ceratoniae
Carob
pod
moth
Carpophilus
spp.,
Haptoncus
spp.
Nitidulid
beetles
MB
is
used
mainly
where
rapid
fumigations
are
needed
to
meet
customer
timelines
during
critical
market
windows
and
peak
production
periods.
During
peak
production
months,
phosphine
fumigation
takes
3
times
longer
(
6
days)
than
conventional
MB
fumigation
(
2
days)
and
up
to
20
times
longer
than
vacuum
MB
fumigation
(
7
hours).
The
required
duration
of
phosphine
fumigation
increases
as
commodity
temperature
decreases,
making
its
use
impractical
during
the
cold
winter
months.
No
technically
or
economically
feasible
alternatives
exist
at
present
during
these
critical
periods.

TABLE
B.
1:
KEY
PESTS
BY
COMMODITY
COMMON
NAME
WALNUTS
PISTACHIOS
DRIED
FRUIT
AS
SPECIFIED
DATES
Codling
moth
Common
Navel
orangeworm
Common
Indianmeal
moth
Common
Common
Common
Red
Flour
Beetle
Minor
Common
Warehouse
Beetle
Minor
Raisin
Moth
Common
Minor
Dried
Fruit
Beetle
Common
Carob
pod
moth
Common
Nitidulid
beetles
Common
TABLE
B.
2:
CHARACTERISTIC
OF
SECTOR
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Walnuts,
Pistachios,
Dried
Fruit
X
X
X
X
Harvest
Material
In:
Dates
X
X
X
X
X
Fumigation
Schedule
(
MB):
All
Commodities
x
x
x
x
x
x
x
x
X
X
x
x
Retail
Target
Market
Window:
All
Commodities
X
X
X
X
Critical
methyl
bromide
fumigations
occur
during
the
peak
harvest
of
the
commodities.
Other
fumigations
occur
as
indicated
by
monitoring
throughout
the
year.
Page
13
9.
SUMMARY
OF
THE
CIRCUMSTANCES
IN
WHICH
METHYL
BROMIDE
IS
CURRENTLY
BEING
USED
TABLE
9.1(
a.):
COMMODITIES
COMMODITY
MB
DOSAGE
(
Kg/
1000
m
³
)
EXPOSURE
TIME
(
hours)
TEMP.
(
º
C)
NUMBER
OF
FUMIGATIONS
PER
YEAR
PROPORTION
OF
PRODUCT
TREATED
AT
THIS
DOSE
FIXED
(
F)
MOBILE
(
M)
STACK
(
S)

Dried
Fruit
24
24
Variable
3
100%
F,
M
Pistachios
21
24
Variable
Variable
2­
3
for
some
100%
F,
M
Walnuts
111
24
Variable
2.6
100%
F,
M
Dates
21
24
Variable
1­
2
100%
F,
M
TABLE
9.1(
b.):
FIXED
FACILITIES
(
MB
fumigation
done
mainly
in
vacuum
chambers)

COMMODITY
TYPE
OF
CONSTRUCTION
AND
APPROXIMATE
AGE
IN
YEARS
VOLUME
(
m
³
)
OR
RANGE
NUMBER
OF
FACILITIES
(
E.
G.
5
SILOS)
GAS
TIGHTNESS
ESTIMATE
Dried
Fruit
Pistachios
Walnuts
Dates
No
information
is
available
as
to
the
type
of
construction,
age,
volume,
number
of
facilities,
and
gas
tightness
of
the
diverse
types
of
facilities
in
this
sector.
Page
14
10.
LIST
ALTERNATIVE
TECHNIQUES
THAT
ARE
BEING
USED
TO
CONTROL
KEY
TARGET
PEST
SPECIES
IN
THIS
SECTOR
(
Include
main
alternative
techniques
for
situation
similar
to
the
nomination
such
as
given
in
MBTOC
and
TEAP
reports
(
www.
teap.
org))

Many
of
the
MBTOC
not­
in­
kind
alternatives
to
methyl
bromide
are
critical
to
monitoring
and
managing
pest
populations,
but
they
are
not
designed
to
disinfest
commodities
for
which
there
is
a
zero
tolerance
for
insect
infestations.
The
most
critical
of
these
for
commodities
in
storage
are:
sanitation
and
IPM
strategies.
Sanitation
is
important
and
constantly
addressed
in
management
programs.
Cleaning
and
hygiene
practices
alone
do
not
reduce
pest
populations,
but
reportedly
improve
the
efficacy
of
insecticides
or
diatomaceous
earth
(
Arthur
and
Phillips,
2003).
The
principles
of
IPM
are
to
utilize
all
available
chemical,
cultural,
biological,
and
mechanical
pest
control
practices.
These
include
pheromone
traps,
electrocution
traps,
and
light
traps
to
monitor
pest
populations.
If
pests
are
found
in
traps,
then
contact
insecticides
and
low
volatility
pesticides
are
applied
in
spot
treatments
for
surfaces,
cracks
and
crevices,
or
anywhere
the
pests
may
be
hiding.
These
applications
are
intended
to
restrict
pests
from
spreading
throughout
the
facility
and
thus
avoid
fumigation
(
Arthur
and
Phillips,
2003).
However,
IPM
is
not
designed
to
completely
eliminate
pests
from
any
given
facility
or
to
ensure
that
a
facility
remains
free
from
infestation.
Although
the
U.
S.
Food
and
Drug
Administration
(
FDA)
allows
minimal
contamination
of
food
products,
there
is
a
zero
tolerance
for
insects
imposed
by
market
demands,
therefore,
neither
sanitation
nor
IPM
is
acceptable
as
an
alternative
to
methyl
bromide
fumigation;
but
these
strategies
are
used
to
manage
pest
populations
and
extend
the
time
between
methyl
bromide
fumigations.

In
addition
to
sanitation
and
IPM,
most
commodity
operations
in
the
United
States
currently
use
both
phosphine,
alone
and
in
combination
whenever
feasible.
Phosphine
fumigation
has
proven
to
be
too
slow
for
treating
large
commodity
volumes
that
need
to
be
processed
rapidly.
Although
phosphine
is
more
suitable
for
fumigating
commodities
in
storage,
where
fumigation
time
is
not
a
factor,
its
corrosive
nature
to
certain
metals
limits
its
use
in
some
processing
plants,
especially
those
outfitted
with
electronic
sorting
and
processing
control
equipment.
Page
15
PART
C:
TECHNICAL
VALIDATION
11.
SUMMARIZE
THE
ALTERNATIVE(
S)
TESTED,
STARTING
WITH
THE
MOST
PROMISING
ALTERNATIVE(
S)

TABLE
11.1:
SUMMARY
OF
THE
ALTERNATIVES
TESTED
Please
see
Table
12.1.

12.
SUMMARIZE
TECHNICAL
REASONS,
IF
ANY,
FOR
EACH
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
FOR
YOUR
CIRCUMSTANCES
(
For
economic
constraints,
see
Question
15):

TABLE
12.1:
SUMMARY
OF
TECHNICAL
REASON
FOR
EACH
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
NAME
OF
ALTERNATIVE
TECHNICAL
REASON
FOR
THE
ALTERNATIVE
NOT
BEING
USED
Contact
and
low
volatility
insecticides
Not
registered
in
the
U.
S.
for
use
on
stored
commodities.
The
only
insecticides
registered
for
use
in
storage
facilities
are
for
crack
and
crevice
treatment.
These
fogs,
mists,
and
aerosols
are
effective
only
against
exposed
insects
in
the
facilities
and
are
not
designed
to
penetrate
the
walnut
shell
or
any
kind
of
bulk
commodity
(
Zettler,
2002).
Ethyl
or
methyl
formate
Not
registered
in
the
U.
S.
for
use
on
stored
commodities.
Ethylene
oxide
Not
registered
in
the
U.
S.
for
use
on
stored
commodities.

Phosphine
alone
or
in
combination
In
general,
phosphine
alone
or
in
combination
is
not
suitable
to
replace
methyl
bromide
when
rapid
fumigations
are
needed
to
meet
customer
timelines.
The
delay
would
disrupt
processing
of
dried
fruit
and
nuts,
increasing
production
costs
and
interfering
with
access
to
the
holiday
market.
Furthermore,
phosphine
is
corrosive
to
some
metals
in
electric
and
electronic
equipment
in
processing
plants.

Phosphine
fumigation
takes
3­
10
days,
depending
on
temperature,
compared
to
1
day
for
MB
(
Hartsell
et
al.,
1991,
Zettler,
2002,
Soderstrom
et
al.,
1984,
phosphine
labels).
An
additional
2
days
are
needed
for
outgassing
phosphine.
Phosphine
fumigation
is
least
feasible
during
the
colder
winter
months
when,
according
to
label
directions,
the
minimum
exposure
periods
increases
to
8­
10
days
(
plus
two
days
for
aeration)
when
commodity
temperature
decreases
to
5oC
­
12
oC.
Phosphine
is
not
used
when
commodity
temperature
drops
below
5oC
(
Phosphine
and
Eco2fume
®
labels).

For
walnuts
sold
as
in­
shell
(
approximately
25%
of
the
California
production)
phosphine
fumigation
takes
too
long
during
the
peak
production
period,
when
large
volumes
of
walnuts
are
processed
and
shipped
rapidly.
In
some
cases,
however,
phosphine
has
already
replaced
MB
fumigation
whenever
feasible.
For
walnuts
sold
as
shelled
product,
phosphine
combined
with
carbon
dioxide
(
Eco2fume
®
)
is
being
used
for
in­
storage
fumigation
by
approximately
50%
of
the
industry
since
2001.
The
remaining
50%
lack
large
storage
facilities
that
can
be
sealed
and
left
for
at
least
five
days,
the
time
required
to
fully
disinfest
the
commodity
(
California
Walnut
Commission
&
Walnut
Marketing
Board,
2003).

Propylene
oxide
Propylene
oxide
(
PPO)
was
recently
labeled
for
use
on
in­
shell
nuts
in
California.
Because
PPO
is
a
volatile,
flammable
liquid
that
must
be
used
under
vacuum
conditions
for
safety,
several
years
of
commercial­
scale
testing
will
probably
be
necessary
before
this
technique
is
perfected
for
commercial
use.
Furthermore,
adoption
for
use
on
in­
shell
nuts
will
be
limited
by
the
need
to
use
expensive
vacuum
chambers.
At
present,
PPO
is
already
being
used
by
the
walnut
industry
to
sterilize
approximately
20%
of
bulk
shelled
walnuts
sold
for
dairy
and
bakery
ingredients,
targeting
primarily
mold
and
bacteria,
and
secondarily
insects
(
California
Walnut
Commission
&
Page
16
NAME
OF
ALTERNATIVE
TECHNICAL
REASON
FOR
THE
ALTERNATIVE
NOT
BEING
USED
Walnut
Marketing
Board,
2003).
PPO
is
not
labeled
for
use
on
dried
fruits.

Sulfuryl
fluoride
Sulfuryl
fluoride
was
recently
registered
in
United
States
for
use
on
dried
fruit
and
nuts
on
January
23,
2004.
The
use
of
this
chemical
and
its
accompanying
interactive
computerized
program
will
require
training
and
licensing
of
applicators
by
the
manufacturer.
In
addition,
each
state
must
also
register
this
product.
Research
to
date
has
shown
that
this
sulfuryl
fluoride
is
effective
against
the
adult,
pupal,
and
larval
stages
of
target
insects,
but
less
effective
against
the
egg
stage
(
Fields
and
White,
2002,
Schneider
et
al.
2003).
The
efficacy
of
this
chemical
remains
to
be
demonstrated
in
the
field.
It
may
take
up
to
5
years
to
validate
its
use
as
a
methyl
bromide
replacement
and
for
the
necessary
industry
conversion
(
See
Section
17.2.1.).

Biological
Agents
The
only
biological
agent
available
for
use
in
commodities
is
the
granulosis
virus,
which
acts
specifically
against
Indian
meal
moth
larvae
(
Johnson
et
al.,
1998,
Vail
et
al.,
1991,
Vail
et
al.,
2002).
No
effective
biological
agents
are
available
for
use
against
other
commodity
pests.
The
U.
S.
Food
and
Drug
Administration
does
not
allow
the
use
of
predatory
or
parasitic
insects
in
commodity
storage
areas.

Cold
Treatment
This
technique
is
unfeasible
for
use
on
a
commercial
scale,
especially
during
harvest
when
large
volumes
need
to
be
processed
rapidly.
Longer
treatment
times
would
also
interfere
with
meeting
the
demands
of
critical
European
markets
by
delaying
shipments
by
1­
3
weeks.
For
example,
at
0oC
to
10oC
a
4­
week
exposure
time
is
needed
to
control
the
Indian
meal
moth
in
stored
walnuts
(
Johnson
et
al.,
1997).
Although
it
has
been
demonstrated
that
at
­
10oC
to
­
18oC
several
insect
pests
of
dates
can
be
controlled
in
a
few
hours,
(
Donahaye
et
al.,
1991,
1995),
the
slow
rate
of
cold
penetration
and
daily
introduction
of
fresh
commodities
would
interfere
with
the
ability
to
maintain
a
constant
low
temperature
throughout
storage
areas.
In
California,
the
grower
cooperative
Diamond
Walnuts
(
representing
approximately
50%
of
the
walnuts
grown
in
that
state)
alone
processes
about
3,630
metric
tons
per
day
at
its
Stockton
plant
during
the
peak
harvest
season
in
September
(
California
Walnut
Commission
&
Walnut
Marketing
Board,
2003).
The
longer
treatment
would
also
affect
the
industry's
ability
to
take
advantage
of
national
and
international
market
windows.
Furthermore,
the
cost
of
retrofitting
storage
facilities
and
the
energy
cost
required
to
rapidly
cool
large
volumes
of
walnuts
would
be
prohibitive.

Controlled/
Modified
Atmospheres
Exposure
to
low
oxygen
or
high
carbon
dioxide
has
been
shown
to
effectively
control
pests
of
stored
dried
fruit
and
nuts
in
laboratory
studies.
However,
this
approach
would
require
a
minimum
of
2­
5
days,
depending
on
temperature
(
Calderon
and
Barkai­
Golan,
1990,
Soderstrom
and
Brandl,
1984,
Tarr
et
al.,
1996),
and
would
not
be
feasible
when
commodity
needs
to
be
moved
rapidly
during
peak
production
periods
and
to
meet
international
market
demands.
In
California,
the
grower
cooperative
Diamond
Walnuts
(
representing
approximately
50%
of
the
walnuts
grown
in
that
state)
alone
processes
about
3,630
metric
tons
per
day
at
its
Stockton
plant.
Moreover,
adopting
this
alternative
would
require
considerable
expenditures
for
special
treatment
facilities
and
retrofitting
existing
structures.
Cultural
practices
and
Integrated
Pest
Management
IPM,
which
includes
cultural
practices,
is
designed
to
manage
pests
at
low
population
levels,
not
to
completely
eliminate
them
or
prevent
infestations.

Heat
Treatment
This
approach
is
not
feasible
for
treating
commercial­
scale
commodity
volumes.
Under
laboratory
conditions,
brief
exposure
of
commodities
to
high
temperatures
may
eliminate
insects
without
adversely
affecting
product
quality.
Most
insects
do
not
survive
more
than
12
hours
when
exposed
to
45oC
or
more
than
5
minutes
when
exposed
to
50oC
(
Fields,
1992).
However,
the
effectiveness
of
this
approach
has
not
been
tested
with
large
volumes
of
commodities.
Substitution
of
heat
treatments
where
high
temperatures
are
not
already
used
for
other
applications
would
require
extensive
retrofitting
of
existing
facilities,
as
well
as
heat
delivery
systems
capable
of
rapidly
and
uniformly
heating
large
volumes
of
walnuts
in
order
to
achieve
total
insect
control.
Furthermore,
walnut
quality
may
be
adversely
affected
by
exposure
to
heat,
causing
rancidity
in
walnut
kernel
oils
(
California
Walnut
Commission
&
Walnut
Marketing
Board,
2003).
According
to
the
California
Dried
Plum
Board
(
2003),
an
attempt
to
use
heat
treatment
commercially
with
prunes
in
California
not
only
failed
to
control
target
pests,
but
resulted
in
several
tons
of
prunes
being
damaged
from
heat
exposure.
Page
17
NAME
OF
ALTERNATIVE
TECHNICAL
REASON
FOR
THE
ALTERNATIVE
NOT
BEING
USED
High
pressure
carbon
dioxide
High­
pressure
carbon
dioxide
for
commodity
treatment
requires
the
availability
of
small
fumigation
chambers
designed
to
withstand
the
required
high
pressures.
The
small
size
of
these
units
would
limit
the
amounts
of
walnuts
that
could
be
treated
at
any
one
time,
delaying
the
process
and
causing
critical
market
windows
to
be
missed.
This
technique
is,
therefore,
not
suitable
for
use
on
a
commercial
scale
in
U.
S.
warehouses,
where
large
volumes
of
walnuts
must
be
processed
within
relatively
short
periods.
Furthermore,
these
chambers
are
not
readily
available,
and
the
cost
of
building
a
large
number
of
them
would
be
prohibitive
(
Zettler,
2002).

Irradiation
Although
rapid
and
effective,
irradiation
may
result
in
living
insects
left
in
the
treated
product.
Treated
insects
are
sterilized
and
stop
feeding,
but
are
not
immediately
killed.
The
high
dosages
necessary
to
cause
immediate
mortality
in
target
insects
may
reduce
product
quality.
Irradiation
affects
walnut
oils,
causing
changes
in
flavor,
lowering
kernel
quality,
and
shortening
walnut
shelf
life.
Irradiation
would,
furthermore,
require
major
capital
expenditures.
Moreover,
irradiated
food
is
not
widely
accepted
by
consumers,
adding
another
element
of
uncertainty
to
this
method's
adoption
(
California
Walnut
Commission
&
Walnut
Marketing
Board,
2003).

Pest
Resistant
Packaging
This
measure
only
prevents
reinfestation
of
finished
product,
and
is
not
designed
to
control
infestations
in
bulk
commodity
storage
(
Johnson
and
Marcotte,
1999).

Physical
removal/
Cleaning/
Sanitation
This
technique
is
widely
used
as
an
IPM
component
in
all
dried
fruit
and
nut
operations,
but
by
itself
not
designed
to
disinfest
a
commodity.

TABLE
12.2:
COMMODITY
PROCESSING
PLANTS
 
COMPARISON
OF
ALTERNATIVES
TO
METHYL
BROMIDE
FUMIGATION
Fumigant
Preparation
Time
(
hr)
Fumigation
Time
(
hrs)
Dissipation
Time
(
hrs)
Total
Time
(
hrs)
Number
of
Alternative
Applications
to
One
MB
Application
Methyl
Bromide
24
24
4
52
­­

Methyl
Bromide
(
in
vacuum
chamber)
1
4
2
7
1
­­

Phosphine
alone
or
in
combination
with
CO2
24
72
­
96
48
144
­
168
2.7
­
3.2
(
MB
under
normal
pressure)
20.6
­
24
(
MB
+
low
pressure)
1
During
the
3­
4
week
peak
harvest
season,
many
commodity
processing
plants
operate
24
hours
a
day.
Since
it
takes
approximately
7
hours
to
fumigate
a
given
lot
with
MB
under
vacuum,
these
plants
can
fumigate
3.4
lots
per
day
per
fumigation
chamber,
thus
keeping
up
with
the
incoming
harvested
commodities.
Page
18
PART
D:
EMISSION
CONTROL
13.
HOW
HAS
THIS
SECTOR
REDUCED
THE
USE
AND
EMISSIONS
OF
METHYL
BROMIDE
IN
THE
SITUATION
OF
THE
NOMINATION?
(
Describe
procedures
used
to
determine
optimum
methyl
bromide
dosages
and
exposures,
improved
sealing
processes,
monitoring
systems
and
other
activities
that
are
in
place
to
minimize
dosage
and
emissions)

The
dried
fruit
and
nut
industries
in
the
United
States
have
reduced
the
number
of
methyl
bromide
fumigations
by
incorporating
many
of
the
alternatives
identified
by
MBTOC,
such
as
implementing
IPM
strategies,
especially
sanitation,
in
storage
facilities.
Pest
populations
are
monitored
using
visual
inspections,
pheromone
traps,
light
traps
and
electrocution
traps.
When
insect
pests
are
found,
plants
will
attempt
to
contain
the
infestation
with
treatments
of
low
volatility
pesticides
applied
to
both
surfaces
and
cracks
and
crevices.
These
techniques
do
not
disinfest
a
facility
but
are
critical
in
monitoring
and
managing
pests.
Furthermore,
the
phosphine
+
CO2
(
Eco2fume
®
)
combination
is
already
being
used
to
fumigate
a
substantial
proportion
of
dried
fruit
and
nuts
in
storage.
Page
19
PART
E:
ECONOMIC
ASSESSMENT
14.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
(
Provide
an
analysis
of
how
these
costs
were
estimated
as
a
separate
attachment):

TABLE
14.1
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
A
3­
YEAR
PERIOD
FOR
WALNUTS
MB
AND
ALTERNATIVES
COST
IN
CURRENT
YEAR
(
US$)
COST
ONE
YEAR
AGO
(
US$)
COST
2
YEARS
AGO
(
US$)

WALNUTS
Methyl
Bromide
1
($
1.311
per
1000
m3)
1
($
1.311
per
1000
m3)
1
($
1.311
per
1000
m3)
Phosphine
46
($
61,277
per
1000
m3)
46
($
61,277
per
1000
m3)
46
($
61,277
per
1000
m3)
Pistachios
Methyl
Bromide
1
($
448
per
1000
m3)
1
($
448
per
1000
m3)
1
($
448
per
1000
m3)
Phosphine
496
($
222,385
per
1000
m3)
496
($
222,385
per
1000
m3)
496
($
222,385
per
1000
m3)
Dried
Fruits
Methyl
Bromide
1
($
480
per
1000
m3)
1
($
480
per
1000
m3)
1
($
480
per
1000
m3)
Phosphine
29
($
13,796
per
1000
m3)
29
($
13,796
per
1000
m3)
29
($
13,796
per
1000
m3)
Dates
Methyl
Bromide
1
($
445
per
1000
m3)
1
($
445
per
1000
m3)
1
($
445
per
1000
m3)
Phosphine
139
($
61,832
per
1000
m3)
139
($
61,832
per
1000
m3)
139
($
61,832
per
1000
m3)

15.
SUMMARIZE
ECONOMIC
REASONS,
IF
ANY,
FOR
EACH
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
FOR
YOUR
CIRCUMSTANCES
TABLE
15.1.
SUMMARY
OF
ECONOMIC
REASONS
FOR
EACH
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
NO.
METHYL
BROMIDE
ALTERNATIVE
ECONOMIC
REASON
(
IF
ANY)
FOR
THE
ALTERNATIVE
NOT
BEING
AVAILABLE
ESTIMATED
MONTH/
YEAR
WHEN
THE
ECONOMIC
CONSTRAINT
COULD
BE
SOLVED
1
PHOSPHINE
Economic
losses
from
additional
production
downtimes
due
to
longer
fumigation
time
and
from
capital
expenditures
required
to
adopt
an
alternative.
Economic
losses
due
to
downtime
with
phosphine
are
persistent.
Page
20
Economic
costs
in
the
post­
harvest
uses
of
the
commodity
sector
can
be
characterized
as
arising
from
three
contributing
factors.
First,
direct
pest
control
costs
increase
in
most
cases
because
phosphine
is
more
expensive
due
to
increased
labor
time
required
for
longer
treatment
time
and
increased
number
of
treatments.
Second,
capital
expenditures
may
be
required
to
adopt
phosphine
for
accelerated
replacement
of
plant
and
equipment
due
to
the
corrosive
nature
of
phosphine.
Finally,
additional
production
downtimes
for
the
use
of
alternatives
are
unavoidable.
Many
facilities
operate
at
or
near
full
production
capacity
and
alternatives
that
take
longer
than
methyl
bromide
or
require
more
frequent
application
can
result
in
manufacturing
slowdowns,
shutdowns,
and
shipping
delays.
Slowing
down
production
would
result
in
additional
costs
to
the
methyl
bromide
users.
Economic
cost
per
1000
m3
was
calculated
as
the
additional
costs
of
methyl
bromide
if
methyl
bromide
users
had
to
replace
methyl
bromide
with
phosphine.

The
four
economic
measures
in
Table
E.
1
were
used
to
quantify
the
economic
impacts
to
post­
harvesting
uses
for
commodity.
The
four
economic
measures
are
not
independent
in
such
a
way
that
they
can
be
calculated
from
the
same
financial
data.
The
measures
are,
however,
supplementary
to
each
other
in
evaluating
the
CUE
applicant's
economic
viability.
These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users.

Net
revenue
is
calculated
as
gross
revenue
minus
operating
costs.
This
is
a
good
measure
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
users.
It
should
be
noted
that
net
revenue
does
not
represent
net
income
to
the
users.
Net
income,
which
indicates
profitability
of
an
operation
of
an
enterprise,
is
gross
revenue
minus
the
sum
of
operating
and
fixed
costs.
Net
income
should
be
smaller
than
the
net
revenue
measured
in
this
analysis.
We
did
not
include
fixed
costs
because
it
is
often
difficult
to
measure
and
verify.

A
separate
analysis
was
conducted
for
each
sub­
sector
(
described
below),
and
in
each
case
the
least
cost
alternative
fumigation
system,
based
on
phosphine,
was
found
to
be
no
economically
feasible.
Production
downtime
was
estimated
on
average
at
84
days
per
year
and
total
capital
expenditures
for
accelerated
replacement
of
plant
and
equipment
due
to
corrosive
nature
of
phosphine
was
assumed
to
be
$
1,076
per
1000
m3
with
10­
years
lifespan
with
10%
interest
rate
from
the
data
provided
by
the
CUE
applicants
for
post­
harvesting
uses.
The
potential
economic
losses
associated
with
the
use
of
phosphine
mainly
originate
from
the
cost
of
production
delay.
The
estimated
economic
loss
per
1000
m3
ranges
from
$
13,436
for
dried
fruit
to
$
222,051
for
pistachio.
The
estimated
economic
losses
as
a
percentage
of
gross
revenue
ranges
from
19%
to
22%
and
the
estimated
economic
loss
as
a
percentage
of
net
revenue
are
over
100%
for
all
the
CUE
applicants
in
the
commodity
sector,
which
results
in
negative
profit
margins
with
use
of
phosphine.
The
industries
that
use
methyl
bromide
for
commodity
fumigation
are,
in
general,
subject
to
limited
pricing
power,
changing
market
conditions,
and
government
regulations.
Companies
within
these
industries
operate
in
a
highly
competitive
global
marketplace
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories.
In
addition,
companies
of
this
type
generally
managed
by
producers'
associations
and
therefore,
making
new
capital
investment
is
often
difficult.
The
results
suggest
that
phosphine
is
not
economically
viable
as
an
alternative
for
methyl
bromide.
Page
21
Walnuts
The
United
States
walnut
industry
operates
almost
exclusively
in
California,
where
approximately
5,300
growers
and
51
processors
are
located.
Over
the
past
five
years,
growers
have
produced
an
average
of
265,000
tons
of
walnuts
per
year
on
80,940
hectares
in
California.
The
largest
processor
is
the
Diamond
Cooperative
facility
in
Stockton,
California,
through
which
50
percent
of
all
harvested
walnuts
in
California
pass.
The
other
50
independent
handlers
operate
much
smaller
facilities
that
process
the
remaining
50
percent
of
California
walnuts.
Sales
to
Europe
accounts
for
one­
fifth
of
all
revenue.
Both
production
and
sales
peak
in
the
fall
in
anticipation
of
the
holiday
season
in
December.
Fumigation
of
walnuts
takes
place
during
the
entire
year,
but
fumigation
capacity
is
primarily
a
limiting
factor
immediately
after
harvest.
Approximately
25
percent
of
walnuts
are
sold
in
the
shell,
and
these
are
usually
packed
and
shipped
to
European
market
within
a
couple
of
days
of
the
initial
fumigation
treatment.
The
remaining
75
percent
of
walnuts
are
processed
further
to
create
a
variety
of
packaged
shelled
products.
These
walnuts
must
be
fumigated
before
they
put
in
long­
term
storage
or
continue
in
the
processing
chain
due
to
the
key
pests.
The
U.
S.
walnut
industry
already
has
replaced
methyl
bromide
70
percent
with
Eco2fume
for
in­
storage
fumigation.
Diamond
Cooperative
has
completely
converted
to
using
Eco2fume
for
in­
storage
fumigation.

The
primary
scenario
for
this
analysis
is
based
on
the
Diamond
Cooperative
facility
for
processing
walnuts
in
the
shell
as
the
representative
user
using
the
existing
phosphine
capacity
to
treat
all
walnuts.
Given
the
existing
capacity
of
1500
tons
per
day
of
processing
walnuts
in
the
shell,
having
to
rely
on
phosphine
alone
would
require
an
additional
five
days
to
treat
walnuts
in
the
shell.
At
the
processing
rate
of
one
lot
every
five
days
with
phosphine
compared
with
7­
hour
turn­
around
time
currently
achieved
with
methyl
bromide
under
vacuum,
the
processing
walnuts
in
the
shell
would
be
only
5
percent
or
fumigation
chamber
capacity
would
need
to
be
expanded
to
approximately
20
times
the
existing
capacity.

Alternatively,
all
the
walnuts
could
be
stored
and
processed.
However,
prices
paid
to
growers
would
be
reduced
by
the
increased
supply
that
would
be
forced
onto
the
domestic
market.
Given
that
the
nature
of
the
demand
for
walnuts
is
inelastic,
the
impact
of
this
increase
is
estimated
to
results
in
a
decrease
of
18%
to
the
growers.
In
addition
to
the
price
effect,
there
are
increased
costs
from
using
phosphine.
Additional
expenditures
are
required
to
adopt
phosphine
for
accelerated
replacement
of
plant
and
electronic
equipment
due
to
the
corrosive
nature
of
phosphine
($
215
per
1000
m3).
The
net
effect
of
price
decreases
and
cost
increases
represents
19%
of
gross
revenues
and
346%
of
net
revenues.
This
can
also
be
expressed
as
a
loss
of
$
59,966
per
1000
m3,
and
$
604
per
kilogram
of
methyl
bromide.

Another
scenario
could
represent
the
cost
of
building
additional
fumigation
chambers,
so
that
the
same
amount
of
commodity
could
be
fumigated
during
the
critical
time
period,
and
avoid
commodity
loss
and
price
declines
from
missing
key
market
windows.
In
case
of
the
Diamond
plant,
it
is
estimated
that
a
tank
farm
of
ten
1­
million
pound
capacity
silos
would
be
required
to
support
substitution
of
phosphine
for
on­
receipt
fumigation
of
in­
shell
walnuts
alone.
The
costs
of
these
silos
and
fumigation
chambers
were
not
estimated
due
to
lack
of
information,
but
the
Diamond
Cooperative
indicates
that
there
is
no
space
for
such
a
tank
farm
at
the
Diamond
Cooperative
facility,
so
an
offsite
location
would
have
to
be
found;
hence
there
would
be
the
associated
costs
of
land
acquisition
and
development.
An
environmental
impact
study
would
also
Page
22
be
required.
The
Diamond
Cooperative
estimates
that
at
least
three
to
five
years
would
be
required
for
permitting
and
development
of
an
offsite
fumigation
facility.

Pistachios
The
United
States
pistachio
industry
operates
almost
exclusively
in
California.
In
2001
approximately
730,000
tons
of
pistachios
were
produced
in
California
on
315,588
hectares,
where
there
are
approximately
500
growers
and
21
processors.
Methyl
bromide
is
used
in
the
pistachio
industry
in
post­
harvesting
storage,
among
other
uses.
The
industry
has
already
95%
replaced
methyl
bromide
with
phosphine
in
processing
pistachios.
After
the
pistachios
are
dried,
phosphine
is
used
in
the
storage
facility.
Once
fumigation
with
phosphine
is
complete,
the
pistachios
enter
a
sorting
facility.
The
processors
use
methyl
bromide
during
peak
periods,
when
high
volumes
of
pistachios
are
processed
and
need
to
enter
the
market
quickly,
such
as
holiday
season.
Fumigation
of
pistachios
takes
place
during
the
entire
year,
but
fumigation
capacity
is
primarily
a
limiting
factor
immediately
after
harvest.

The
primary
scenario
for
this
analysis
is
based
on
the
Paramount,
which
is
processing
60%
of
the
total
U.
S.
pistachio
production,
as
the
representative
user
using
the
existing
phosphine
capacity
to
treat
all
pistachios.
Given
the
existing
capacity
of
200
tons
per
day
of
processing
pistachio,
U.
S.
EPA
reviewers
estimated
that
having
to
rely
on
phosphine
alone
would
require
an
additional
84
days
to
treat
pistachios.
In
addition
to
the
production
loss,
there
are
increased
costs
from
using
phosphine.
Additional
expenditures
are
required
to
adopt
phosphine
for
accelerated
replacement
of
plant
and
electronic
equipment
due
to
the
corrosive
nature
of
phosphine
($
215
per
1000
m3).
The
net
effect
of
production
loss
and
cost
increases
represents
20%
of
gross
revenues
and
403%
of
net
revenues.
This
can
also
be
expressed
as
a
loss
of
$
222,051
per
1000
m3,
and
$
10,574
per
kilogram
of
methyl
bromide.

Another
scenario
could
represent
the
cost
of
building
additional
silos
and
fumigation
chambers,
so
that
the
same
amount
of
commodity
could
be
fumigated
with
phosphine
during
the
critical
time
period,
and
avoid
commodity
loss
and
price
declines
from
missing
key
market
windows.
The
costs
of
these
silos
and
fumigation
chambers
were
not
estimated
due
to
lack
of
information.

Dried
Fruit
California
produces
99
percent
of
the
domestic
supply
and
70
percent
of
the
world's
supply
of
dried
plums.
California
also
produces
99
percent
of
the
domestic
raisin
crop,
and
40
percent
of
world
raisin
production.
California
is
responsible
for
nearly
all
of
domestic
fig
production
and
20
percent
of
global
supply.
The
industry
has
already
replaced
50%
methyl
bromide
with
phosphine
in
processing
dried
fruits.
Fumigation
of
pistachios
takes
place
during
the
entire
year.
Phosphine
cannot
replace
methyl
bromide
for
the
5
coldest
months
when
the
temperature
in
the
storage
facilities
is
not
high
enough
to
make
phosphine
effective
for
controlling
target
pests.

The
primary
scenario
for
this
analysis
is
based
on
the
representative
user
using
the
existing
phosphine
capacity
to
treat
all
dried
fruits.
U.
S.
EPA
reviewers
estimated
that
having
to
rely
on
phosphine
alone
would
require
an
additional
84
days
to
treat
all
dried
fruits.
In
addition
to
the
production
loss,
there
are
increased
costs
from
using
phosphine.
Additional
expenditures
Page
23
are
required
to
adopt
phosphine
for
accelerated
replacement
of
plant
and
electronic
equipment
due
to
the
corrosive
nature
of
phosphine
($
215
per
1000
m3).
The
net
effect
of
production
loss
and
cost
increases
represents
22%
of
gross
revenues
and
335%
of
net
revenues.
This
can
also
be
expressed
as
a
loss
of
$
14,660
per
1000
m3,
and
$
610
per
kilogram
of
methyl
bromide.

Dates
California
produces
most
of
domestic
supply
of
dates.
The
industry
has
not
replaced
methyl
bromide
with
phosphine
in
processing
dates.
The
processors
use
methyl
bromide
during
peak
periods,
when
high
volumes
of
dates
are
processed
and
need
to
enter
the
market
quickly,
such
as
holiday
season.
Fumigation
of
dates
takes
place
during
the
entire
year,
but
fumigation
capacity
is
primarily
a
limiting
factor
immediately
after
harvest.

The
primary
scenario
for
this
analysis
is
based
on
the
representative
user
using
the
existing
capacity
to
treat
all
dates.
U.
S.
EPA
reviewers
estimated
that
having
to
rely
on
phosphine
alone
would
require
an
additional
84
days
to
treat
all
dates.
In
addition
to
the
production
loss,
there
are
increased
costs
from
using
phosphine.
Additional
expenditures
are
required
to
adopt
phosphine
for
accelerated
replacement
of
plant
and
electronic
equipment
due
to
the
corrosive
nature
of
phosphine
($
215
per
1000
m3).
The
net
effect
of
production
loss
and
cost
increases
represents
20%
of
gross
revenues
and
404%
of
net
revenues.
This
can
also
be
expressed
as
a
loss
of
$
61,498
per
1000
m3,
and
$
2,957
per
kilogram
of
methyl
bromide.

Another
scenario
could
represent
the
cost
of
building
additional
silos
and
fumigation
chambers,
so
that
the
same
amount
of
commodity
could
be
fumigated
during
the
critical
time
period,
and
avoid
commodity
loss
and
price
declines
from
missing
key
market
windows.
The
costs
of
these
silos
and
fumigation
chambers
were
not
estimated
due
to
lack
of
information.
Page
24
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FOR
WALNUT
Loss
Measure
Methyl
Bromide
Phosphine
Total
Commodity
Treated
(
kg/
1000
m
³
)
320,455
kg
320,455
kg
Average
Market
Price
(
US$/
kg)
$
1.08
$
0.89
Gross
Revenue
(
US$/
1000
m
³
)
$
346,091
$
283,794
Operating
Cost
(
a+
b)
per
1000
m
³
$
328,786
$
328,673
a)
Cost
of
MB
or
Alternative
$
1,311
$
983
b)
Other
Operating
Costs
$
327475
$
327,690
Net
Revenue
(
US$/
ha)
(
net
of
operating
costs)
$
17,305
$(
36,661)

Loss
measures
Time
Lost
(
days)
0
DAYS
84
DAYS
Loss
per
1000
m
³
(
US$/
1000
m
³
)
$
0
$
59,966
Loss
per
Kilogram
MB
(
US$/
kg)
$
0
$
543
Loss
as
a
%
of
Gross
Revenue
(%)
0%
11%

Loss
as
a
%
of
Net
Revenue
(%)
0%
212%
Page
25
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FOR
PISTACHIO
Loss
Measure
Methyl
Bromide
Phosphine
Total
Commodity
Treated
(
kg/
1000
m
³
)
511,628
kg
366,979
kg
Average
Market
Price
(
US$/
kg)
$
2.16
$
2.16
Gross
Revenue
(
US$/
1000
m
³
)
$
1,100,930
$
792,670
Operating
Cost
(
a+
b)
per
1000
m
³
$
1,045,883
$
959,674
a)
Cost
of
MB
or
Alternative
$
448
$
334
b)
Other
Operating
Costs
$
1,045,435
$
959,340
Net
Revenue
(
US$/
ha)
(
net
of
operating
costs)
$
55,047
$(
167,004)

Loss
measures
Time
Lost
(
days)
0
DAYS
84
DAYS
Loss
per
1000
m
³
(
US$/
1000
m
³
)
$
0
$
222,051
Loss
per
Kilogram
MB
(
US$/
kg)
$
0
$
10,524
Loss
as
a
%
of
Gross
Revenue
(%)
0%
28%

Loss
as
a
%
of
Net
Revenue
(%)
0%
133%
Page
26
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FOR
DRIED
FRUIT
Loss
Measure
Methyl
Bromide
Phosphine
Total
Commodity
Treated
(
kg/
1000
m
³
)
88,235
kg
63,529
kg
Average
Market
Price
(
US$/
kg)
$
0.75
$
0.75
Gross
Revenue
(
US$/
1000
m
³
)
$
66,176
$
47,647
Operating
Cost
(
a+
b)
per
1000
m
³
$
61,808
$
57,939
a)
Cost
of
MB
or
Alternative
$
480
$
360
b)
Other
Operating
Costs
$
61,328
$
57,579
Net
Revenue
(
US$/
ha)
(
net
of
operating
costs)
$
4368
$(
10,292)

Loss
measures
Time
Lost
(
days)
0
DAYS
84
DAYS
Loss
per
1000
m
³
(
US$/
1000
m
³
)
$
0
$
13,436
Loss
per
Kilogram
MB
(
US$/
kg)
$
0
$
560
Loss
as
a
%
of
Gross
Revenue
(%)
0%
28%

Loss
as
a
%
of
Net
Revenue
(%)
0%
131%
Page
27
TABLE
E.
4:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FOR
DATE
Loss
Measure
Methyl
Bromide
Phosphine
Total
Commodity
Treated
(
kg/
1000
m
³
)
125,480
kg
90,605
kg
Average
Market
Price
(
US$/
kg)
$
2.42
$
2.42
Gross
Revenue
(
US$/
1000
m
³
)
$
304,533
$
219,263
Operating
Cost
(
a+
b)
per
1000
m
³
$
289,306
$
265,534
a)
Cost
of
MB
or
Alternative
$
445
$
334
b)
Other
Operating
Costs
$
288,861
$
265,200
Net
Revenue
(
US$/
ha)
(
net
of
operating
costs)
$
15,227
$(
46,271)

Loss
measures
Time
Lost
(
days)
0
DAYS
84
DAYS
Loss
per
1000
m
³
(
US$/
1000
m
³
)
$
0
$
61,498
Loss
per
Kilogram
MB
(
US$/
kg)
$
0
$
2,957
Loss
as
a
%
of
Gross
Revenue
(%)
0%
28%

Loss
as
a
%
of
Net
Revenue
(%)
0%
404%

PART
F:
FUTURE
PLANS
16.
PROVIDE
A
DETAILED
PLAN
DESCRIBING
HOW
THE
USE
AND
EMISSIONS
OF
METHYL
BROMIDE
WILL
BE
MINIMIZED
IN
THE
FUTURE
FOR
THE
NOMINATED
USE
The
Industry
is
committed
to
studying
how
to
improve
insect
control
with
IPM
strategies
and
sanitation
and
further
reduce
the
number
of
methyl
bromide
fumigations.
They
are
also
continuing
to
pursue
research
of
heat
treatments
to
maximize
efficiency.
The
United
States
government
is
supporting
research
in
this
sector
(
see
Section
17.1)
and
the
United
States
Environmental
Protection
Agency
(
EPA
or
Agency)
has
made
registering
methyl
bromide
alternatives
a
priority
(
see
Section
17.2).
U.
S.
EPA
registered
sulfuryl
fluoride
for
some
commodities
on
January
23,
2004
(
see
Section
17.2.1).
Page
28
17.
PROVIDE
A
DETAILED
PLAN
DESCRIBING
WHAT
ACTIONS
WILL
BE
UNDERTAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
USE:

17.1
Research
The
amount
of
methyl
bromide
requested
for
research
purposes
is
considered
critical
for
the
development
of
effective
alternatives.
Without
methyl
bromide
for
use
as
a
standard
treatment,
the
research
studies
can
never
address
the
comparative
performance
of
alternatives.
This
would
be
a
serious
impediment
to
the
development
of
alternative
strategies.
The
U.
S.
government
estimates
that
commodities
research
will
require
20
kg
per
year
of
methyl
bromide
for
2005
and
2006.
This
amount
of
methyl
bromide
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
One
example
of
this
type
of
research
is
a
study
testing
the
comparative
performance
of
several
fumigants
for
penetration
through
packing
material
for
control
of
the
Indianmeal
moth
or
confused
flour
beetle.

To
date,
the
U.
S.
government
has
spent
U.
S.$
135.5
million
to
implement
an
aggressive
research
program
to
find
alternatives
to
methyl
bromide
under
the
USDA's
Agricultural
Research
Service
(
ARS)
Methyl
Bromide
Alternatives
program
(
select
Methyl
Bromide
Alternatives
at
this
web
site:
http://
www.
nps.
ars.
usda.
gov).

The
post­
harvest
sector
has
invested
substantial
time
and
funding
into
research
and
development
of
technically
and
economically
feasible
alternatives
to
methyl
bromide.
Past
and
current
research
focuses
on
the
biology
and
ecology
of
the
pests,
primarily
insect
pests.
To
implement
non­
chemical
controls
and
reduce
methyl
bromide
use
requires
a
thorough
understanding
of
the
pests
in
order
to
exploit
their
weaknesses.
Some
of
these
investigations
have
studied
the
effects
of
temperature
and
humidity
on
the
fecundity,
development,
and
longevity
of
a
specific
species.
Other
studies
have
been
to
determine
the
structural
preferences
and
microhabitat
requirements
of
a
species.
Studies
of
factors
affecting
population
growth
(
interactions
within
and
among
species)
have
been
conducted.

The
USDA
is
continuing
to
fund
research
projects
in
post­
harvest
pest
management.
Such
activities
include:

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

Chemically
Based
Alternatives
to
Methyl
Bromide
for
Post
Harvest
and
Quarantine
Pests
(
Jul
2000
­
Dec
2004)
to:
develop
quarantine/
post
harvest
control
strategies
using
chemicals
to
reduce
arthropod
pests
in
durable
and
perishable
commodities;
develop
new
fumigants
and/
or
strategies
to
reduce
methyl
bromide
use;
develop
technology
and
equipment
to
reduce
methyl
bromide
emissions
to
the
atmosphere;
develop
system
approaches
for
control
using
chemicals
combined
with
nonchemical
methodologies
Page
29
which
will
yield
integrated
pest
control
management
programs;
and
develop
methods
to
detect
insect
infestations.

Propylene
Oxide
and
Carbon
Dioxide:
A
non­
flammable
8%
PPO
and
92%
CO2
mixture
is
being
tested
for
use
as
fumigant
on
dried
fruit
and
nuts.
Unlike
100%
PPO,
this
mixture
would
not
require
the
use
of
vacuum
chambers
(
Griffith,
2004).

Overall,
future
research
plans
for
this
industry
encompass
testing
alternatives
that
fumigate
rapidly
and
achieve
high
mortality
rates.
So
far
the
most
promising
of
these
are
sulfuryl
fluoride,
and
tolerances
for
its
use
were
set
on
January
23,
2004
which
will
lead
to
its
official
registration;
heat
treatments;
and
various
combinations
of
heat,
phosphine,
and
carbon
dioxide.
Industry
is
supportive
of
and
closely
follows
USDA
research
on
these
alternatives.

U.
S.
efforts
to
research
alternatives
for
methyl
bromide
have
been
increasing
as
the
phase­
out
has
approached.
The
U.
S.
is
committed
to
sustaining
its
research
efforts
into
the
future
until
technically
and
economically
viable
alternatives
are
found
for
each
and
every
controlled
use
of
methyl
bromide.
We
are
also
committed
to
continuing
to
share
our
research.
Toward
that
end,
for
the
past
several
years,
key
U.
S.
government
agencies
have
collaborated
with
industry
to
host
an
annual
conference
on
alternatives
to
methyl
bromide.
This
conference,
the
Methyl
Bromide
Alternatives
Outreach
(
MBAO),
has
become
the
premier
forum
for
researchers
and
others
to
discuss
scientific
findings
and
progress
in
this
field.

The
following
are
additional
examples
of
research
actions
supported
by
the
dried
fruit
and
nuts
industry
in
California,
with
funding
levels
in
excess
of
U.
S.
$
1,000,000,
and
implemented
by
USDA
(
California
Dried
Plum
Board,
2003):

 
Determination
of
seasonal
prevalence
and
spatial
variation
of
navel
orangeworm.

 
Development
of
pheromone­
mediated
mating
disruption
of
navel
orangeworm
and
attract­
and­
kill
techniques
for
nitidulid
beetles.

 
Determination
of
the
efficacy
of
propylene
oxide:
carbon
dioxide
mixtures
against
a
variety
of
stored
product
insects.

 
Determination
of
the
loading
of
MB
on
activated
carbon
after
repeated
use
and
the
effect
of
high
moisture
on
the
sorption
process.

 
Indianmeal
moth
granulovirus
as
an
alternative
to
methyl
bromide
for
protection
of
dried
fruits
and
nuts.

 
Low
temperature
studies
for
eggs
of
Indianmeal
moth
and
navel
orangeworm
as
a
component
of
integrated
post
harvest
systems.

 
Optimization
of
Indianmeal
moth
trapping.

 
Physical
treatment
for
post
harvest
insects,
aimed
at
determining
heat
tolerance
of
moths
species,
identifying
stage
and
pests
species
most
tolerant
to
vacuum,
and
describing
response
of
cowpea
weevil
eggs
to
commercial
cold
storage
temperatures.

In
addition,
the
following
study
is
being
carried
out
by
the
Dried
Fruit
Association
of
California
and
Dow
Chemical
Company:
Sulfuryl
fluoride
efficacy
and
residue
studies
on
dry
fruit,
designed
to
determine
this
chemical's
effectiveness
against
dried
fruit
pests
and
to
develop
data
for
its
registration
Page
30
17.2
Registration
While
the
U.
S.
government's
role
to
find
alternatives
is
primarily
in
the
research
arena,
we
know
that
research
is
only
one
step
in
the
process.
As
a
consequence,
we
have
also
invested
significantly
in
efforts
to
register
alternatives,
as
well
as
efforts
to
support
technology
transfer
and
education
activities
with
the
private
sector.

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

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

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

Since
1997,
the
U.
S.
EPA
has
registered
the
following
chemical/
use
combinations
as
part
of
its
commitment
to
expedite
the
review
of
methyl
bromide
alternatives:

 
2000:
Phosphine
in
combination
to
control
stored
product
insect
pests
 
2001:
Indianmeal
Moth
Granulosis
Virus
to
control
Indianmeal
moth
in
stored
grains
Sulfuryl
Fluoride
Page
31
On
January
23,
2004,
the
U.
S.
EPA
registered
sulfuryl
fluoride
as
a
post­
harvest
fumigant
for
dried
fruit
and
tree
nuts.
While
registration
for
these
uses
will
provide
opportunities
to
reduce
methyl
bromide
use,
it
must
be
emphasized
that
such
replacement,
if
feasible,
will
only
occur
gradually
over
time.

Alternatives
must
be
tested
by
users
and
found
technically
and
economically
feasible
before
widespread
adoption
will
occur.
As
noted
by
TEAP,
a
specific
alternative,
once
available
may
take
up
to
5
fumigation
cycles
of
use
before
efficacy
can
be
determined
in
the
specific
circumstance
of
the
user.
The
registrant
is
requiring
that
applicators
be
trained
by
them
before
using
sulfuryl
fluoride
(
there
is
a
3­
tiered
certification
system).
It
will
take
some
time
for
potential
applicators
to
be
identified
and
to
take
this
training
before
the
product
can
begin
testing
in
the
specific
circumstances
of
users.

There
are
additional
pesticide
registration
issues,
however,
that
must
be
resolved
before
sulfuryl
fluoride
can
be
used
in
sectors
for
which
the
U.
S.
is
nominating
methyl
bromide
CUEs.
Some
states
must
also
register
sulfuryl
fluoride.
California
needs
to
register
this
product
through
their
regulatory
process,
and
requires
at
least
four
months
after
receiving
an
application,
as
long
as
risk
concerns
do
not
appear
in
their
assessments.
At
the
time
of
this
writing,
however,
California
had
not
received
an
application
from
the
sulfuryl
fluoride
registrant.

There
are
also
data
limitations
preventing
U.
S.
EPA,
at
this
time,
from
estimating
the
degree
to
which
sulfuryl
fluoride
might
replace
some
methyl
bromide
use
in
fumigating
dried
fruits
and
nuts.
We
currently
lack
the
information
to
evaluate
sulfuryl
fluoride's
performance
relative
to
methyl
bromide.
We
have
almost
no
relative
product
performance
data
(
direct
comparisons
to
methyl
bromide),
no
experience
in
how
well
it
performs
in
different
facilities
and
climates
over
multiple
years,
no
price
data,
and
no
information
on
what
other
costs
might
be
associated
with
adopting
sulfuryl
fluoride.
Lacking
such
information,
we
cannot
reach
science­
based
conclusions
on
the
technical
and
economic
feasibility
of
sulfuryl
fluoride
at
this
time.

For
these
reasons,
and
given
the
current
state
of
data,
U.
S.
EPA
is
refraining
from
speculating
on
the
degree
to
which
sulfuryl
fluoride
registrations
might
lead
to
amended
CUE
nominations.
At
the
same
time,
U.
S.
EPA
commits
to
carefully
studying
sulfuryl
fluoride
use
during
the
next
year,
with
the
aim
of
identifying
specific
sectors
where
CUE
requests
can
be
modified,
once
we
have
(
and
have
analyzed)
the
necessary
data.

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

18.
ADDITIONAL
COMMENTS
(
Add
here
any
other
information
that
may
help
clarify
why
a
critical
use
is
needed
for
the
use
being
considered):
Page
32
Page
33
19.
CITATIONS
Arthur,
F.
and
T.
W.
Phillips.
2003.
Stored­
product
insect
pest
management
an
d
control,
In:
Food
Plant
Sanitation
eds:
Y.
H.
Hui,
B.
L.
Bruinsma,
J.
R.
Gorham,
W.
Nip,
P.
S.
Tong,
and
P.
Ventresca.
Marcel
Dekker,
Inc.,
New
York,
pp.
341­
358.

Calderon,
M.
and
R.
Barkai­
Golan.
1990.
Controlled
atmospheres
for
the
preservation
of
tree
nuts
and
dried
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Chapter
6,
Food
Preservation
by
modified
atmospheres,
CRC
Press,
Boca
Raton.

California
Dried
Plum
Board.
2003.
Methyl
bromide
critical
use
exemption
request.
Postharvest
application
California
Walnut
Commission
&
Walnut
Marketing
Board.
2003.
Methyl
bromide
critical
use
exemption
request.
Post
harvest
application.

Donahaye,
E.,
S.
Navarro,
and
M.
Rinder.
1991.
The
influence
of
low
temperatures
on
two
species
of
Carpophilus
(
Coleoptera:
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J.
Appl.
Entomol.
111:
297­
302.

Donahaye,
E.,
S.
Navarro,
and
M.
Rinder.
1995.
Low
temperature
as
an
alternative
to
fumigation
for
disinfesting
dried
fruit
from
three
insect
species.
J.
Stored
Prod.
Res.
31:
63­
70.

Fields,
P.
G.
1992.
The
control
of
stored­
product
insects
and
mites
with
extreme
temperatures.
J.
Stored
Product
Res.
28:
89­
118.

Fields,
P.
and
N.
D.
G.
White.
2002.
Alternatives
to
methyl
bromide
treatments
for
storedproduct
and
quarantine
insects.
Annual
Review
of
Entomology
47:
331­
59.

Griffith,
T.
2004.
VP,
ABERCO,
Inc.
Personal
communication
with
A.
Chiri.,
01­
09­
04.

Johnson,
J.
A.
and
M.
Marcotte.
1999.
Irradiation
control
of
insect
pests
of
dried
fruits
and
walnuts.
Food
Technology
53:
46­
51.

Johnson,
J.
A.,
K.
A.
Valero,
and
M.
M.
Hannel.
1997.
Effect
of
low
temperature
storage
on
survival
and
reproduction
of
Indianmeal
moth
(
Lepidoptera:
Pyralidae).
Crop
Protection:
16:
519­
523.

Johnson,
J.
A.,
P.
V.
Vail,
E.
L.
Soderstrom,
C.
E.
Curtis,
D.
G.
Brandl,
J.
S.
Tebbets,
and
K.
A.
Valero.
1998.
Integration
of
nonchemical,
postharvest
treatments
for
control
of
navel
orangeworm
(
Lepidoptera:
Pyralidae)
and
Indianmeal
moth
(
Lepidoptera:
Pyralidae)
in
walnuts.
J.
Econ.
Entomol.
91:
1437­
1444.

Hartsell,
P.
L.,
J.
C.
Tebbets,
and
P.
V.
Vail.
1991.
Phosphine
fumigation
of
in
shell
almonds
for
insect
control.
Insecticide
&
Acaricide
Tests:
16:
42.
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34
Schneider,
S.
M.,
E.
N.
Rosskopf,
J.
G.
Leesch,
D.
O.
Chellemi,
C.
T.
Bull,
and
M.
Mazzola.
2003.
United
States
Department
of
Agriculture
 
Agricultural
Research
Service
research
on
alternatives
to
methyl
bromide:
pre­
plant
and
post­
harvest.
Pest
Manag.
Sci.
59:
814­
826.

Soderstrom,
E.
L.
and
D.
G.
Brandl.
1984.
Low­
oxygen
atmosphere
for
postharvest
insect
Control
in
bulk­
stored
raisins.
J.
Econ.
Entomol.
77:
440­
445.

Soderstrom,
E.
L.,
P.
D.
Gardner,
J.
L.
Baritelle,
K.
N.
de
Lozano,
and
D.
G.
Brandl.
1984.
Economic
cost
evaluation
of
a
generated
low­
oxygen
atmosphere
as
an
alternative
fumigant
in
bulk
storage
of
raisins.
J.
Econ.
Entomol.
77:
457­
461.

Tarr,
C.,
S.
J.
Hilton,
J.
van
S.
Graver,
and
P.
R.
Clingeleffer.
1996.
Carbon
dioxide
fumigation
of
processed
dried
vine
fruit
(
sultanas)
in
sealed
stacks.
In
E.
Highley,
E.
J.
Wright,
H.
J.
Banks
and
B.
R.
Champ
(
eds.),
Proc.
6th
International
Working
Conference
on
Stored­
Product
Protection,
17­
23
April,
1994,
Canberra,
Australia.
CAB
International
1:
204­
209.

Vail,
P.
V.,
Tebbets,
J.
S.,
Cowan,
D.
C.,
and
Jenner,
K.
E.
1991.
Efficacy
and
persistence
of
a
granulosis
virus
against
infestation
of
Plodia
interpunctella
(
Hübner)
(
Lepidoptera:
Pyralidae)
on
raisins.
J.
Stored
Prod.
Res.
27:
103­
107.

Vail,
P.
V.,
Tebbets,
J.
S.,
and
D.
F.
Hoffmann.
2002.
Efficacy
and
persistence
of
Indiameal
moth
granulovirus
applied
to
nuts.
Proceed.
8th
Intl.
Working
Conf.
on
Stored
Product
Protection.
July
21­
26,
2002,
York,
UK.

Zettler,
J.
L.
2002.
Alternatives
to
post
harvest
uses
of
methyl
bromide
on
dried
fruits
and
nuts
to
be
addressed
by
the
CUE
for
methyl
bromide.
USDA,
ARS.
Unpublished
Report.
Page
35
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).

Date:
not
available
Sector:
not
available
Kilograms
(
kgs)
Volume
(
1000m
3)
Use
Rate
(
kg/
1000m
3)
Kilograms
(
kgs)
Volume
(
1000m
3)
Use
Rate
(
kg/
1000m
3)
2001
Volume
%
of
Volume
20,412
850
24.03
18,218
773
23.57
0%
not
available
not
available
4,990
238
20.98
5,262
201
26.17
0%
not
available
not
available
87,362
1,435
60.87
72,121
1,501
48.06
20%
not
available
not
available
3,467
167
20.82
3,016
145
20.82
0%
not
available
not
available
116,230
2,689
31.67
98,617
2,620
29.65
5%
not
available
not
available
2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
(­)
QPS
HIGH
LOW
Amount
(
kgs)
Volume
(
1000m3)
Use
Rate
(
kg/
1000m
3)
%
Reduction
20,412
­
1,839
355
­
18,218
18,218
18,218
773
24
11%

4,990
­
772
­
­
4,217
4,217
4,217
201
21
15%

87,362
­
­
18,390
13,794
55,178
55,178
55,178
1,148
48
37%

3,467
­
452
­
­
3,016
3,016
3,016
145
21
13%

116,230
116,230
113,168
94,423
80,629
80,629
80,629
82,896
2,267
37
29%

0%
0%
3%
19%
31%
31%
31%
29%
16%

2006
Low
High
Low
High
Low
HIGH
LOW
24
24
100
100
0
0
100%
100%
84
DAYS
21
21
100
100
0
0
100%
100%
84
DAYS
61
48
100
100
0
0
100%
100%
84
DAYS
21
21
100
100
0
0
100%
100%
84
DAYS
Currently
Use
Alternatives?
Research
/

Transition
Plans
Pest­
free
Market
Requirement
Change
from
Prior
CUE
Request
(+/­)
Verified
Historic
MeBr
Use
/
State
Frequency
of
Treatment
/
Yr
Loss
per
1000
m3
(
US$/
1000m)
Loss
per
Kg
of
MeBr
(
US$/
kg)
Loss
as
a
%
of
Gross
Revenue
Y
Y
Y
0
N
2/
year
13,436
$
560
$
28%

Y
Y
Y
+
N
2/
year
222,051
$
10,524
$
28%

Y
Y
Y
0
N
2/
year
96,793
$
975
$
28%

Y
Y
Y
new
N
2/
year
61,498
$
2,957
$
28%

Conversion
Units:
1
Pound
=
0.453592
Kilograms
1,000
cu
ft
=
0.028316847
1,000
cubic
meters
559%
404%

Loss
as
a
%
of
Net
Revenue
Economic
Analysis
131%
133%
Phosphine
Phosphine
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)

Methyl
Bromide
Critical
Use
Exemption
Process
MOST
LIKELY
IMPACT
VALUE
Marginal
Strategy
Phosphine
Phosphine
PISTACHIOS
WALNUTS
DRIED
FRUIT
PISTACHIOS
WALNUTS
DATES
%
Reduction
from
Initial
Request
COMMODITY
TYPE
DRIED
FRUIT
PISTACHIOS
WALNUTS
DATES
DRIED
FRUIT
PISTACHIOS
WALNUTS
Other
Issues
DATES
justments
to
Requested
Amou
Use
Rate
(
kg/
1000m3)
(%)
Key
Pest
Distribution
(%)
Adopt
New
Fumigants
DRIED
FRUIT
Other
Considerations
Dichotomous
Variables
(
Y/
N)
(%)
Combined
Impacts
Time,
Quality,

or
Product
Loss
TOTAL
OR
AVERAGE
2006
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

COMMODITY
TYPE
COMMODITY
TYPE
DATES
Nomination
Amount
2006
Amount
of
Request
2001
&
2002
Average
Use
Quarantine
and
Pre­
Shipment
Regional
Volume
COMMODITY
TYPE
2/
26/
04
Average
Volume
in
the
US:

COMMODITIES
%
of
Average
Volume
Requested:
Page
36
Footnotes
for
Appendix
A:

Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Volume
in
the
U.
S.
 
Average
Volume
in
the
U.
S.
is
the
average
of
2001
and
2002
total
volume
fumigated
with
methyl
bromide
in
the
U.
S.
in
this
sector
(
when
available).
2.
%
of
Average
Volume
Requested
­
Percent
(%)
of
Average
Volume
Requested
is
the
total
volume
in
the
sector's
request
divided
by
the
Average
Volume
in
the
U.
S.
(
when
available).
3.
2006
Amount
of
Request
 
The
2006
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
volume
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
thousand
cubic
feet.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
U.
S.
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
kilograms
active
ingredient
of
methyl
bromide,
total
volume
of
methyl
bromide
use,
and
application
rate
in
kilograms
active
ingredient
of
methyl
bromide
per
thousand
cubic
meters.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
is
the
percentage
(%)
of
the
applicant's
requested
amount
subject
to
QPS
treatments.
6.
Regional
Volume,
2001
&
2002
Average
Volume
 
Regional
Volume,
2001
&
2002
Average
Volume
is
the
2001
and
2002
average
estimate
of
volume
of
methyl
bromide
used
within
the
defined
region
(
when
available).
7.
Regional
Volume,
Requested
Volume
%
­
Regional
Volume,
Requested
Volume
%
is
the
volume
in
the
applicant's
request
divided
by
the
total
volume
fumigated
with
methyl
bromide
in
the
sector
in
the
region
covered
by
the
request.
8.
2006
Nomination
Options
 
2006
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
a
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2006
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
Page
37
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
Use
Rate
kg/
1000
m3
2006
 
Use
rate
in
pounds
per
thousand
cubic
feet,
2006,
is
the
use
rate
requested
by
the
applicant
as
derived
from
the
total
volume
to
be
fumigated
divided
by
the
total
amount
(
in
pounds)
of
methyl
bromide
requested.
17.
Use
Rate
kg/
1000
m3
low
 
Use
rate
in
pounds
per
thousand
cubic
feet,
low,
is
the
lowest
historic
use
rate
reported
by
the
applicant.
The
use
rate
selected
for
determining
the
amount
to
nominate
is
the
lower
of
this
rate
or
the
2006
use
rate
(
above).
18.
(%)
Key
Pest
Impacts
­
Percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
structures/
food
facilities
and
commodities,
key
pests
are
assumed
to
infest
100%
of
the
volume
for
the
specific
uses
requested
in
that
100%
of
the
problem
must
be
eradicated.
19.
Adopt
New
Fumigants
(%)
 
Adopt
new
fumigants
(%)
is
the
percent
(%)
of
the
requested
volume
where
we
expect
alternatives
could
be
adopted
to
replace
methyl
bromide
during
the
year
of
the
CUE
request.
20.
Combined
Impacts
(%)
­
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
and
new
fumigants.
In
each
case
the
total
area
impacted
is
the
conjoined
area
that
is
impacted
by
any
individual
impact.
The
effects
were
assumed
to
be
independently
distributed
unless
contrary
evidence
was
available
(
e.
g.,
affects
are
known
to
be
mutually
exclusive).
21.
Qualifying
Volume
­
Qualifying
volume
(
1000
cubic
meters)
is
calculated
by
multiplying
the
adjusted
volume
by
the
combined
impacts.
22.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
volume
by
the
use
rate.
23.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
24.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
25.
Total
U.
S.
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
26.
Dichotomous
Variables
 
dichotomous
variables
are
those
which
take
one
of
two
values,
for
example,
0
or
1,
yes
or
no.
These
variables
were
used
to
categorize
the
uses
during
the
preparation
of
the
nomination.
27.
Currently
Use
Alternatives
 
Currently
use
alternatives
is
`
yes'
if
the
applicant
uses
alternatives
for
some
portion
of
pesticide
use
on
the
crop
for
which
an
application
to
use
methyl
bromide
is
made.
28.
Research/
Transition
Plans
 
Research/
Transition
Plans
is
`
yes'
when
the
applicant
has
indicated
that
there
is
research
underway
to
test
alternatives
or
if
applicant
has
a
plan
to
transition
to
alternatives.
29.
Pest­
free
Market.
Required
­
This
variable
is
a
`
yes'
when
the
product
must
be
pest­
free
in
order
to
be
sold
either
because
of
U.
S.
sanitary
requirements
or
because
of
consumer
acceptance.
30.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
31.
Change
from
Prior
CUE
Request­
This
variable
takes
a
`+'
if
the
current
request
is
larger
than
the
previous
request,
a
`
0'
if
the
current
request
is
equal
to
the
previous
request,
and
a
`­`
if
the
current
request
is
smaller
that
the
previous
request.
If
the
applicant
has
not
previously
applied
the
word
`
new'
appears
in
this
column.
32.
Verified
Historic
Use/
State­
This
item
indicates
whether
the
amounts
requested
by
administrative
area
have
been
compared
to
records
of
historic
use
in
that
area.
33.
Frequency
of
Treatment
 
This
indicates
how
often
methyl
bromide
is
applied
in
the
sector.
Frequency
varies
from
multiple
times
per
year
to
once
in
several
decades.
34.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
35.
Loss
per
1000
m3
 
This
measures
the
total
loss
per
1000
m3
of
fumigation
when
a
specific
alternative
is
used
in
place
of
methyl
bromide.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative,
such
as
longer
time
spent
in
the
fumigation
chamber.
It
is
measured
in
current
U.
S.
dollars.
36.
Loss
per
Kilogram
of
Methyl
Bromide
 
This
measures
the
total
loss
per
kilogram
of
methyl
bromide
when
it
is
replaced
with
an
alternative.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
U.
S.
dollars.
Page
38
37.
Loss
as
a
%
of
Gross
revenue
 
This
measures
the
loss
as
a
proportion
of
gross
(
total)
revenue.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
U.
S.
dollars.
38.
Loss
as
a
%
of
Net
Operating
Revenue
­
This
measures
loss
as
a
proportion
of
total
revenue
minus
operating
costs.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
U.
S.
dollars.
This
item
is
also
called
net
cash
returns.
39.
Quality/
Time/
Market
Window/
Yield
Loss
(%)
 
When
this
measure
is
available
it
measures
the
sum
of
losses
including
quality
losses,
non­
productive
time,
missed
market
windows
and
other
yield
losses
when
using
the
marginal
strategy.
40.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
Page
39
APPENDIX
C.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

For
the
latter,
there
are
two
large
requests:
cut
flower
and
foliage
production
in
Florida
and
California
(`
Ornamentals')
and
a
group
of
structures
and
process
foods
that
we
have
termed
`
Post­
Harvest
NPMA'
which
includes
processed
(
generally
wheat­
based
foods),
spices
and
herbs,
cocoa,
dried
milk,
cheeses
and
small
amounts
of
other
commodities.
There
was
also
a
small
amount
requested
for
field­
grown
tobacco.

The
details
of
the
case
that
there
are
no
alternatives
which
are
both
technically
and
economically
feasible
are
presented
in
the
appropriate
sector
chapters,
as
are
the
requested
amounts,
suitably
adjusted
to
ensure
that
no
double­
counting,
growth,
etc.
were
included
and
that
the
amount
was
only
sufficient
to
cover
situations
(
key
pests,
regulatory
requirements,
etc.)
where
alternatives
could
not
be
used.

The
amount
requested
by
new
applicants
is
approximately
2.5%
of
the
1991
U.
S.
baseline,
or
about
1,400,000
pounds
of
methyl
bromide,
divided
40%
for
pre­
plant
uses
and
60%
for
postharvest
needs.

The
methodology
for
deriving
the
nominated
amount
used
estimates
that
would
result
in
the
lowest
amount
of
methyl
bromide
requested
from
the
range
produced
by
the
analysis
to
ensure
that
adequate
amounts
of
methyl
bromide
were
available
for
critical
needs.
We
are
requesting
additional
methyl
bromide
in
the
amount
of
about
500,000
Kg,
or
2%
or
the
1991
U.
S.
baseline,
to
provide
for
the
additional
critical
needs
in
the
pre­
plant
and
post­
harvest
sector.

Applicant
Name
2005
U.
S.
CUE
Nomination
(
lbs)

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Michigan
Herbaceous
Perennials
4,200
Page
40
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
