METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
POST
HARVEST
USE
ON
DRY
CURED
PORK
PRODUCTS
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
(
U.
S.)

BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Post
Harvest
Use
on
Dry
Cured
Pork
Products
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
Mail
Code
7503C
BIOLOGIST:
JULIE
HEFLIN
ECONOMIST:
JIN
KIM
DATE:
FEBRUARY
24,
2004
HOW
TO
NAME
FILE:
SECTOR­
AUTHOR­
DATE
ii
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
................................................................................................
6
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
.......................................
7
6.
Methyl
Bromide
Consumption
for
Past
5
Years
and
Amount
Required
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
........................................................
11
8.
Key
Pests
for
which
Methyl
Bromide
is
Requested............................................................
11
9.
Summary
of
the
Circumstances
in
which
Methyl
Bromide
is
Currently
Being
Used
..........
12
10.
List
Alternative
Techniques
that
are
being
Used
to
Control
Key
Target
Pest
Species
in
this
Sector....................................................................................................................................
12
Part
C:
Technical
Validation
.....................................................................................................
13
11.
Summarize
the
Alternative(
s)
Tested,
Starting
with
the
Most
Promising
Alternative(
s)...
13
12.
Summarize
Technical
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances..........................................................................................................
14
Part
D:
Emission
Control
..........................................................................................................
15
13.
How
has
this
Sector
Reduced
the
Use
and
Emissions
of
Methyl
Bromide
in
the
Situation
of
the
Nomination?................................................................................................................
15
Part
E:
Economic
Assessment
...................................................................................................
15
14.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period.........................
15
15.
Summarize
Economic
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances..........................................................................................
15
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives...........................................
15
Part
F:
Future
Plans...................................................................................................................
15
16.
Provide
a
Detailed
Plan
Describing
how
the
Use
and
Emissions
of
Methyl
Bromide
will
be
Minimized
in
the
Future
for
the
Nominated
Use.
...................................................................
16
17.
Provide
a
Detailed
Plan
Describing
what
Actions
will
be
Undertaken
to
Rapidly
Develop
and
Deploy
Alternatives
for
this
Use
.....................................................................................
16
18.
Additional
Comments......................................................................................................
16
19.
Citations
..........................................................................................................................
16
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
......................
Error!
Bookmark
not
defined.
iv
List
of
Tables
Part
A:
Summary.........................................................................................................................
5
Table
4.1:
Methyl
Bromide
Nominated
.......................................................................................
6
Table
A.
1:
Executive
Summary...................................................................................................
8
Table
6.1:
Methyl
Bromide
Consumption
for
the
Past
5
Years
and
the
Amount
Required
in
the
Year(
s)
Nominated
..............................................................................................................
9
Table
A.
2
2005
Sector
Request
.................................................................................................
10
Table
A.
3
2006
Sector
Nomination
...........................................................................................
10
Part
B:
Situation
Characteristics
and
Methyl
Bromide
Use
.......................................................
11
Table
8.1:
Key
Pests
for
Methyl
Bromide
Request
....................................................................
11
Table
B.
1:
Characteristic
of
Sector
............................................................................................
11
Table
9.1(
a.):
Dry
Cured
Pork
Products.....................................................................................
12
Table
9.1(
b.):
Fixed
Facilities....................................................................................................
12
Part
C:
Technical
Validation
....................................................................................................
13
Table
12.1.
Summary
of
Technical
Reason
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................................
14
Part
E:
Economic
Assessment
...................................................................................................
15
Table
14.1
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
a
3­
Year
Period
..............
15
Table
15.1.
Summary
of
Economic
Reasons
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................................
15
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
..................................
17
5
PART
A:
SUMMARY
1.
NOMINATING
PARTY
The
United
States
of
America
2.
DESCRIPTIVE
TITLE
OF
NOMINATION
Methyl
Bromide
Critical
Use
Nomination
For
Post
Harvest
Use
on
Dry
Cured
Pork
Products
3.
SITUATION
OF
NOMINATED
METHYL
BROMIDE
USE
Curing
is
a
method
of
preserving
meat
that
prevents
harmful
micro­
organisms
from
developing.
Two
curing
methods
have
been
developed
 
wet
(
or
brine)
curing
and
dry
curing.
In
wet
curing,
the
curing
ingredients
were
mixed
with
boiling
water
to
form
"
pickling"
brine.
In
dry
curing,
the
ingredients
were
simply
rubbed
into
the
meat
several
times
over
the
period
of
the
cure.
This
nomination
is
for
dry
cured
pork
products
such
as
dry
cured
ham,
dry
cured
country
ham,
hard
salami,
pepperoni,
and
sausage.
Other
types
of
preserved
pork
products
are
not
included
in
this
request.

Dry
Curing
Pork
in
the
United
States
Dry
cured
country
hams
are
traditional
in
the
southern
part
of
the
United
States.
Historically,
this
process
was
calendar
based
 
beginning
in
the
winter
months
and
ending
the
following
autumn.
Pigs
would
be
slaughtered
and
the
ham
curing
process
always
started
during
the
winter
months.
The
cold
winter
temperatures
would
keep
the
meat
cool
enough
to
slow
the
growth
of
bacteria
that
would
spoil
the
ham.
Each
ham
was
covered
with
a
salt
and
sugar
cure
at
least
twice
and
stacked
for
the
winter.
In
the
spring,
the
ham
was
washed
free
of
the
salt
and
sugar
cure,
placed
in
a
woven
bag,
and
left
to
hang
for
the
summer
and
into
the
fall.
By
late
fall,
the
ham
reached
peak
flavor
and
was
ready
for
consumption.

Modern
commercial
production
now
uses
environmentally
controlled
conditions
that
mimic
the
historical
process
and
allows
the
manufacture
of
a
consistently
high
quality
product
year
round.
Some
processors,
however,
still
chose
to
produce
their
cured
meats
in
the
traditional
manner.
The
time
required
to
cure
hams
vary
from
about
20
to
more
than
120
days.
Key
parameters
in
the
curing
process
are
temperature
and
relative
humidity,
both
of
which
are
controlled
by
air
flow.
In
addition
to
curing,
smoking
may
occur.

Curing
facilities
may
be
up
to
2­
3
stories
in
height
and
typically
have
curing
rooms
that
use
either
wood
or
stainless
steel
racks
to
hang
the
hams.
The
curing
rooms
can
hold
up
to
4000
hams.

Pest
Pressure
It
is
common
for
producers
of
dry
cured
pork
products
to
experience
pest
pressure
from
insects
such
as
the
ham
skipper,
the
red
legged
ham
beetle,
and
mites.
These
insects
infest
and
feed
on
6
meat
as
it
cures
and
ages.
Environmental
conditions
such
as
rain,
temperature,
and
humidity
in
and
around
the
curing
facility
influence
the
level
of
pest
pressure.
In
general,
higher
temperature
and
humidity
levels
result
in
higher
the
pest
pressure.

Steps
in
the
Curing
Process
Step
1
(
Winter
Room)
­­
Ham
is
typically
salted
and
sugared
using
a
dry
rub
method
on
Day
1
and
Day
15.
The
temperature
is
approximately
38
degrees
Fahrenheit
with
low
humidity.
Sometime
between
days
42
­
50,
the
salt
and
sugar
are
scraped
and
rubbed
off
of
the
ham.

In
this
room,
the
high
salt
content
is
sufficient
to
keep
insect
pest
pressure
to
a
minimum.

Step
2
(
Spring
Room)
­­
After
being
removed
from
the
winter
room,
the
hams
are
wrapped
in
cotton
netting
and
placed
in
the
spring
room
for
only
10
­
15
days.
The
temperature
is
approximately
50
­
55
degrees
Fahrenheit
at
50%
humidity.
The
humidity
is
very
important
at
this
stage
and
it
is
monitored
closely.
Most
hams
are
equalized
in
the
spring
room.
Equalization
is
a
process
whereby
the
salt
cure
penetrates
from
the
surface
of
the
ham,
through
the
skin,
and
to
the
inner
portion
of
the
ham.

There
are
no
insect
problems
here
due
to
the
low
temperature
and
the
limited
amount
of
time
that
the
hams
are
in
this
room.

Step
3
(
Summer
or
Aging
Room)
 
Hams
are
next
moved
to
the
summer
(
or
aging
room)
for
up
to
120
days.
The
temperature
is
maintained
between
80
­
90
degrees
Fahrenheit
at
55%
humidity.
These
conditions
are
very
important
to
develop
an
intense,
concentrated
flavor
and
aroma.

As
the
ham
ages,
the
moisture
content
of
the
ham
will
decrease,
the
salt
content
increases,
and
the
chances
of
bacterial
action
become
limited.
If
desired,
smoking
of
the
hams
may
occur
here,
or
in
a
separate
"
smoke
house".

Since
the
temperature
and
humidity
are
higher
in
this
room,
conditions
are
ideal
for
pest
pressure.
It
is
at
this
stage
that
the
application
of
methyl
bromide
is
necessary.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
VOLUME
(
1,000
M
3)
2006
169,246
7043
7
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
nomination
is
only
for
those
facilities
where
the
use
of
alternatives
is
not
suitable.
In
U.
S.
pork
processing
plants
that
produce
dry­
cured
pork
products
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.
­
Geographic
distribution
of
the
facilities:
Facilities
included
in
this
nomination
are
located
in
the
southern
U.
S.
where
mild
temperatures
and
high
relative
humidity
result
in
key
pest
pressures
that
are
moderate
to
severe.
These
ambient
conditions
require
that
pests
be
killed
rather
than
merely
driven
out
of
the
facility
only
to
re­
infest
the
facility
after
fumigation.
­
Age
and
type
of
facility:
older
food
processing
facilities,
especially
those
constructed
of
wood,
experience
more
frequent
and
severe
pest
infestations
that
must
be
controlled
by
fumigation.
In
the
United
States
it
is
usual
for
dry­
cured
processed
pork
to
be
produced
in
traditional
facilities.
These
facilities
are
usually
constructed
of
wood
and
many
are
decades
old,
if
not
older.
Many
newer
facilities
are
constructed
using
the
older
facilities
as
models.
­
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).
All
of
the
pork
products
are
relatively
high
fat
products
so
rancidity
would
be
a
problem.
In
addition,
using
heat
will
alter
the
character
of
the
final
product,
producing,
for
example,
a
cooked
pork
product
rather
than
a
dry­
cured
pork
product
with
the
attendant
flavor
differences.
Further,
the
corrosive
nature
of
phosphine
on
certain
metals
prevents
its
use
in
mechanical
and
electrical
areas
of
the
facilities.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
certain
commodities
and
structures,
such
as
cereal
mills.
State
registrations
have
not
yet
been
issued,
which
limits
the
adoption
of
this
alternative
even
for
labeled
products.
At
present,
pork
and
pork
products
are
not
included
among
the
legal
uses
of
sulfuryl
fluoride
so
this
chemical
is
not
an
option
for
these
facilities.
­
Delay
in
plant
operations:
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
to
the
processors.

It
is
common
for
producers
of
cured
pork
products
to
experience
pest
pressure
from
insects
such
as
the
ham
skipper,
the
red
legged
ham
beetle,
dermestid
beetles,
and
mites.
These
insects
infest
and
feed
on
meat
as
it
cures
and
ages.
Environmental
conditions
(
temperature
and
humidity)
in
and
around
the
facility
strongly
influence
the
level
of
pest
pressure.
Under
favorable
ambient
conditions,
such
as
those
seen
in
silo
curing,
pest
pressure
increases
and
a
regular
fumigation
schedule
is
recommended.
In
the
U.
S.,
the
Food
and
Drug
Administration
(
FDA)
regulates
the
maximum
levels
of
live
or
dead
insects
or
insect
parts
that
may
be
present
in
stored
food
products.
Food
commodities
that
exceed
maximum
limits
allowed
are
considered
adulterated
by
FDA
and
thus
unfit
for
human
consumption.
There
are
currently
no
alternatives
registered
for
use
on
hams
in
the
U.
S.
that
would
provide
the
same
level
of
pest
control.
8
TABLE
A.
1:
EXECUTIVE
SUMMARY
National
Country
Ham
Association
American
Association
of
Meat
Processors
Nahunta
Pork
Center
AMOUNT
OF
NOMINATION
2006
Kilograms
823
168,283
141
Application
Rate
(
kg/
1000
M
3)
25
24
20
Volume
(
1000
M
3)
32
7,004
7
AMOUNT
OF
APPLICANTS
REQUEST
2005
KILOGRAMS
1,922
168,283
145
APPLICATION
RATE
(
KG/
1000
M3)
25
24
20
VOLUME
(
1000
M3)
76
7,004
7
2006
KILOGRAMS
1,922
168,283
145
APPLICATION
RATE
(
KG/
1000
M3)
25
24
20
VOLUME
(
1000
M3)
76
7,004
7
ECONOMICS
Marginal
Strategy
Time
Lost
Loss
per
1000
m
³
Loss
per
kg
MB
(
US$/
kg)
Loss
as
%
of
Gross
Revenue
(%)
Loss
as
%
of
Net
Revenue
(%)
No
information
was
provided.
No
information
was
provided.
No
information
was
provided.
9
6.
METHYL
BROMIDE
CONSUMPTION
FOR
PAST
5
YEARS
AND
AMOUNT
REQUIRED
IN
THE
YEAR(
S)
NOMINATED:

TABLE
6.1:
METHYL
BROMIDE
CONSUMPTION
FOR
THE
PAST
5
YEARS
AND
THE
AMOUNT
REQUIRED
IN
THE
YEAR(
S)
NOMINATED
Historical
Use
Requested
Use
For
each
year
specify:
1997
1998
1999
2000
2001
2002
2005
2006
Amount
of
MB
(
kg)
1,159
1,309
1,291
972
1,659
1,528
170,350
170,350
Volume
Treated
1000
m
³
50
53
52
41
48
43
7,087
7,087
Formulation
of
MB
Information
not
provided
Information
not
provided
Dosage
Rate
(
kg/
1000
m
³
)
31
30
32
29
38
35
25
25
Actual
(
A)
or
Estimate
(
E)
Information
not
provided
Information
not
provided
7.
LOCATION
OF
THE
FACILITIES
WHERE
THE
PROPOSED
CRITICAL
USE
OF
METHYL
BROMIDE
WILL
TAKE
PLACE:

There
more
than
1,650
pork
production
facilities
in
the
United
States.
Of
these,
approximately
850
facilities
require
the
use
of
methyl
bromide
to
fumigate
dry
cured
pork
products.

The
specific
name
and
physical
address
of
each
facility
was
not
requested
in
the
forms
filled
out
by
the
applicants
in
the
United
States.
However,
general
location
information
for
the
following
facilities
is
known:

 
Kentucky
(
Cadiz,
Greenville)
 
Missouri
(
California)
 
North
Carolina
(
Boone,
Goldsboro,
Smithfield,
Wayne
County)
 
Virginia
(
Surry)
 
Tennessee
(
Various
locations)
 
South
Carolina
(
Various
locations).
10
TABLE
A.
2
2005
SECTOR
REQUEST*

2005
(
Sector)
Request
National
Country
Ham
Association
American
Association
of
Meat
Processors
Nahunta
Pork
Center
KILOGRAMS
1,922
168,283
145
APPLICATION
RATE
(
KG/
1000
M3)
25
24
20
Applicant
Request
for
2005
VOLUME
(
1000
M3)
76
7,004
7
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.

TABLE
A.
3
2006
SECTOR
NOMINATION
2006
(
Sector)
Nomination
National
Country
Ham
Association
American
Association
of
Meat
Processors
Nahunta
Pork
Center
KILOGRAMS
1,922
168,283
145
APPLICATION
RATE
(
KG/
1000
M3)
25
24
20
Applicant
Request
for
2006
VOLUME
(
1000
M3)
76
7,004
7
KILOGRAMS
823
168,283
141
APPLICATION
RATE
(
KG/
1000
M3)
25
24
20
CUE
Nominated
for
2006
VOLUME
(
1000
M3)
32
7,004
7
Overall
Reduction
1%
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
169,246
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
11
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
NO.
GENUS
AND
SPECIES
FOR
WHICH
THE
USE
OF
METHYL
BROMIDE
IS
CRITICAL
COMMON
NAME
SPECIFIC
REASON
WHY
METHYL
BROMIDE
IS
NEEDED
1
Necrobia
rufipes
 
common
pest
Red
Legged
Ham
Beetle
The
adults
feed
on
the
cured
meat.
The
larvae
burrow
into
the
meat
and/
or
fat.
The
larvae
are
commonly
referred
to
as
a
"
Ham
Bore.
r"

2
Piophila
casei
 
common
pest
Cheese/
Ham
Skipper
The
Skippers
are
larval
stages
of
small
flies
and
they
burrow
into
the
cured
meat.

3
Dermestes
spp­
common
pests
Dermested
beetles
4
Mite
species
­­
common
pest
Ham
Mites
The
mites
feed
on
the
surface
of
the
cured
meat.

TABLE
B.
1:
CHARACTERISTIC
OF
SECTOR
Jan
Feb
Mar
Apr
May
June
July
Aug
Sept
Oct
Nov
Dec
Raw
Material
In
X
X
X
X
X
X
X
X
X
X
X
X
Fumigation
Schedule
(
MB)
X
X
X
X
X
X
X
X
X
X
X
X
Retail
Target
Market
Window
X
X
X
X
X
X
X
X
X
X
X
X
Raw
pork
product
material
can
come
into
a
curing
facility
in
any
month
of
the
year.

The
Methyl
Bromide
fumigation
schedule
will
vary
depending
on
several
factors
such
as:

1.
Type
of
pork
product
­
Bone­
in
products
have
a
higher
probability
of
pest
infestation
since
the
pests
are
attracted
to
the
bone,
and
they
typically
age
for
longer
periods
of
time.

2.
Type
of
structure/
facility
­
Typically,
older
curing
facilities
have
a
higher
probability
of
pest
infestations,
which
could
be
attributed
to
the
lack
of
air
tightness
of
the
facility.
A
majority
of
the
newer
facilities
have
lower
pest
pressure
due
to
increased
air
tightness.
Additionally,
silo
facilities,
those
that
are
two
to
three
stories
in
height,
have
a
higher
probability
of
insect
infestations
when
compared
to
a
single
story
facility.

A
single
curing
and
ham
storage
operation
can
typically
process
10,307,878
kilograms
(
11,362.5
U.
S.
tons)
of
pork
products
each
year.
The
curing
facilities
are
fumigated
with
methyl
bromide
when
pests
are
detected
in
the
product
or
the
smokehouses.
This
fumigation
typically
occurs
12
about
three
to
five
times
during
a
typical
year.
During
this
process,
the
smokehouse,
typically
small
building
(
e.
g.
four
stories),
is
covered
with
tarp
and
fumigated
while
full
of
hams.

3.
Type
of
curing
­
Curing
can
be
achieved
by
either
temperature
controlled
room
curing,
or
by
ambient
curing.
Ambient
curing,
which
involves
uncontrolled
environmental
conditions,
typically
requires
a
regular
fumigation
schedule
due
to
consistently
high
levels
of
pest
infestations.

4.
Location/
climate
of
structure/
facility
­
These
curing
facilities
are
located
in
southeastern
states,
where
the
temperature
and
humidity
are
higher
for
longer
periods
of
time
throughout
the
year.
Therefore,
there
is
a
greater
opportunity
for
pests
to
be
active
for
longer
periods
of
time.
As
the
pest
pressure
increases,
so
does
the
need
to
fumigate
with
methyl
bromide
The
retail
target
market
window
varies,
but
there
are
higher
demands
for
cured
pork
products
around
holidays
such
as
Thanksgiving,
Christmas,
and
Easter.

9.
SUMMARY
OF
THE
CIRCUMSTANCES
IN
WHICH
METHYL
BROMIDE
IS
CURRENTLY
BEING
USED
TABLE
9.1(
a.):
Dry
Cured
Pork
Products
METHYL
BROMIDE
DOSAGE
(
g/
m
³
)
EXPOSURE
TIME
(
hours)
TEMP.
(
º
C)
NUMBER
OF
FUMIGATIONS
PER
YEAR
PROPORTION
OF
PRODUCT
TREATED
AT
THIS
DOSE
FIXED
(
F),
MOBILE
(
M)
OR
STACK
(
S)
32
Varies
Varies
w/
facility,
but
typically
in
excess
of
27
degrees
C
(
80
degrees
F)
Varies
from
2­
8
fumigations
per
year.
3­
5
times
per
year
common
Up
to
100%
in
some
facilities.
Fixed
TABLE
9.1(
b.):
FIXED
FACILITIES
TYPE
OF
CONSTRUCTION
AND
APPROXIMATE
AGE
IN
YEARS
VOL
(
m
³
)
OR
RANGE
NUMBER
OF
FACILITIES
(
E.
G.
5
SILOS)
GASTIGHTNESS
ESTIMATE*

More
than
850
curing
facilities
use
methyl
bromide.
The
age
of
the
facilities
vary.
Varies
Ranges
from
1
story
to
silo
facilities.
Varies
10.
LIST
ALTERNATIVE
TECHNIQUES
THAT
ARE
BEING
USED
TO
CONTROL
KEY
TARGET
PEST
SPECIES
IN
THIS
SECTOR
Currently,
no
alternative
techniques
are
being
used.
13
PART
C:
TECHNICAL
VALIDATION
11.
SUMMARIZE
THE
ALTERNATIVE(
S)
TESTED
STARTING
WITH
THE
MOST
PROMISING
ALTERNATIVE(
S):

The
applicants
have
not
provided
test
data
on
methyl
bromide
alternatives.
Page
14
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
NO.
METHYL
BROMIDE
ALTERNATIVE
TECHNICAL
REASON
(
IF
ANY)
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
ESTIMATED
MONTH/
YEAR
WHEN
THE
TECHNICAL
CONSTRAINT
COULD
BE
SOLVED
1
Phosphine
alone
&
in
combination
See
**
1
below
2
Propylene
oxide
Not
registered
for
this
use
in
the
U.
S.
3
Contact
insecticides
None
registered
for
this
use
in
the
U.
S.
4
Irradiation
See
**
4
below
5
Sulfuryl
fluoride
Not
registered
for
this
use.
Sulfuryl
fluoride
adsorbs
to
proteins,
so
anticipated
residues
would
likely
be
high.
The
applicants
did
not
provide
any
information
on
this
topic.

Further
details
on
why
an
alternative
was
not
technically
feasible:

**
1
 
Phosphine
alone
and
in
combination
would
disrupt
the
ham
curing
process.
The
process
of
fumigation
and
aeration
with
the
application
of
methyl
bromide
requires
approximately
24
hours.
The
process
of
fumigation
and
aeration
with
phosphine
requires
4
 
5
days.
The
addition
of
3
 
4
days
in
the
fumigation
process
would
delay
all
production
cycles.
The
time
difference
can
become
significant
when
multiple
`
lots'
are
cycling
through
the
stages
of
the
production
process.
A
delay
in
a
lot
cycling
out
of
the
summer/
aging
room
could
lead
to
a
back­
up
in
a
lot
cycling
out
of
the
spring
room
to
the
summer/
aging
room.

Additionally,
adoption
of
phosphine
fumigation
would
require
a
substantial
capital
investment
for
fumigation
chambers
or
gas­
tight
bins.
In
addition,
corrosion
problems
(
e.
g.
corrosion
of
copper
alloys,
electrical
wiring,
equipment,
and
lights)
associated
with
phosphine
fumigation
for
cured
pork
products
would
limit
the
long­
term
usefulness
of
this
fumigant.
The
corrosion
problems
and
development
of
resistance
in
target
pests
could
be
reduced
by
using
low
phosphine­
high
carbon
dioxide­
high
temperature
combination
treatments,
but
adopting
this
method
would
require
a
high
degree
of
technical
skills
which
is
not
widely
available.
This
fumigation
method
requires
that
the
concentrations
of
carbon
dioxide
and
phosphine
and
temperature
be
constantly
monitored
and
adjusted,
that
the
gases
be
uniformly
distributed,
that
unexposed
pockets
do
not
occur,
and
that
the
analytical
equipment
used
for
these
determinations
be
properly
maintained,
calibrated,
and
properly
installed.
Methyl
bromide
appears
to
be
the
only
treatment
that
consistently
provides
the
high
degree
of
insect
and
mite
control
required
in
cured
pork
products
which
depend
on
rapid
fumigation
methods.

Several
stored
grain
insects
have
already
developed
resistance
to
phosphine
(
Bell,
2000),
and
it
is
likely
that
resistance
will
continue
to
develop
in
other
stored
commodity
pests,
making
its
use
a
short­
term
solution.

**
4
­
Irradiation
does
not
readily
kill
exposed
insects,
but
rather
prevents
further
feeding
and
Page
15
reproduction.
Although
unable
to
feed
or
reproduce,
the
surviving
insects
would
still
create
phytosanitary
problems
and
the
high
doses
required
to
kill
exposed
insects
may
affect
product
quality.
Consumer
acceptance
of
irradiated
food
would
hinder
the
adoption
of
this
method.

PART
D:
EMISSION
CONTROL
13.
HOW
HAS
THIS
SECTOR
REDUCED
THE
USE
AND
EMISSIONS
OF
METHYL
BROMIDE
IN
THE
SITUATION
OF
THE
NOMINATION?

No
information
on
how
this
sector
has
reduced
the
use
and
emission
of
methyl
bromide
was
provided
by
the
applicants.

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):

No
alternatives
are
currently
registered
for
use
on
cured
pork
products
in
the
U.
S.
therefore
no
economic
analysis
was
conducted
TABLE
14.1
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
A
3­
YEAR
PERIOD
No
information
was
provided
by
the
applicants.

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
information
was
provided
by
the
applicants.

MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
No
information
was
provided
by
the
applicants.

PART
F:
FUTURE
PLANS
Page
16
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
U.
S.
wants
to
note
that
our
usage
rate
is
among
the
lowest
in
the
world
in
requested
sectors
and
represents
efforts
of
both
the
government
and
the
user
community
over
many
years
to
reduce
use
rates
and
emissions.
We
will
continue
to
work
with
the
user
community
in
each
sector
to
identify
further
opportunities
to
reduce
methyl
bromide
use
and
emissions.

17.
PROVIDE
A
DETAILED
PLAN
DESCRIBING
WHAT
ACTIONS
WILL
BE
UNDERTAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
USE:

No
alternatives
have
been
researched.

18.
ADDITIONAL
COMMENTS
No
additional
comments
were
provided
by
the
applicants.

19.
CITATIONS
Bell,
C.
H.
2000.
Fumigation
in
the
21st
Century.
Crop
Protection,
19:
563­
69.
Page
17
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).

Date:
not
available
Sector:
not
available
Kilograms
(
kgs)
Volume
(
1000m3)
Use
Rate
(
kg/
1000m3)
Kilograms
(
kgs)
Volume
(
1000m3)
Use
Rate
(
kg/
1000m3)
2001
&
2002
Average
%
of
Volume
1,922
76
25
1,430
38
37
0%
not
available
not
available
145
7
20
163
7
23
0%
not
available
not
available
168,283
7,004
24
N/
A
N/
A
N/
A
0%
not
available
not
available
170,350
7,087
23.15
1,593
45
30.36
0%
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
1,922
155
945
­
­
823
823
823
32
25
57%

145
­
4
­
­
141
141
141
7
20
3%

168,283
­
­
­
­
168,283
168,283
168,283
7,004
24
0%

170,350
170,196
169,246
169,246
169,246
169,246
169,246
169,246
7,043
24
1%

0%
0%
1%
1%
1%
1%
1%
1%
1%

2006
Low
High
Low
High
Low
HIGH
LOW
25
25
100
100
0
0
100%
100%

20
20
100
100
0
0
100%
100%

24
24
100
100
0
0
100%
100%

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
m
3
(
US$/
1000m)
Loss
per
Kg
of
MeBr
(
US$/
kg)
Loss
as
a
%
of
Gross
Revenue
?
?
Yes
0
No
4x
/
year
?
?
Yes
0
No
4x
/
year
?
?
Yes
0
No
4x
/
year
Notes
Conversion
Units:
1
Pound
=
0.453592
Kilograms
1,000
cu
ft
=
0.02831685
1,000
cubic
meters
Methyl
Bromide
Critical
Use
Exemption
Process
2/
26/
2004
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
HAM
(%)
Key
Pest
Distribution
(%)
Adopt
New
Fumigants
(%)
Combined
Impacts
2006
Amount
of
Request
2001
&
2002
Average
Use
Quarantine
and
Pre­
Shipment
Regional
Volume
TOTAL
OR
AVERAGE
2006
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)
MOST
LIKELY
IMPACT
VALUE
*
Wayco
Ham
Co.
and
Ozark
Country
Hams
are
both
a
part
of
the
National
Country
Ham
Association,
their
volume
is
a
part
of
double
counting.

HAM
ASSOCIATION
HAM
ASSOCIATION
HAM
ASSOCIATION
HAM
ASSOCIATION
NATIONAL
COUNTRY
HAM
ASSOCIATION
NAHUNTA
PORK
CENTER
AMERICAN
ASSOCIATION
OF
MEAT
PROCESSORS
NATIONAL
COUNTRY
HAM
ASSOCIATION
Use
Rate
(
kg/
1000m3)

NAHUNTA
PORK
CENTER
AMERICAN
ASSOCIATION
OF
MEAT
PROCESSORS
NATIONAL
COUNTRY
HAM
ASSOCIATION
NAHUNTA
PORK
CENTER
Nomination
Amount
%
Reduction
from
Initial
Request
Adjustments
to
Requested
Amounts
Other
Issues
AMERICAN
ASSOCIATION
OF
MEAT
PROCESSORS
Other
Considerations
NATIONAL
COUNTRY
HAM
ASSOCIATION
NAHUNTA
PORK
CENTER
AMERICAN
ASSOCIATION
OF
MEAT
PROCESSORS
Dichotomous
Variables
(
Y/
N)
Average
Volume
in
the
US:

%
of
Average
Volume
Requested:
Loss
as
a
%
of
Net
Operating
Revenue
Economic
Analysis
Marginal
Strategy
None
None
None
Time,
Quality,

or
Product
Loss
Page
18
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
19
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
20
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
21
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
22
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
