USA,
Post
Harvest
Use
(
NPMA),
Response
to
June
2004
Questions
Page
1
NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Post
Harvest
Use
by
NPMA
for
Facilities
and
Commodities.

DOCUMENT
NUMBER
CUN
2003/,
US56N10
DATE
August
12,
2004
CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1:
KEY
PESTS
FOR
METHYL
BROMIDE
REQUEST:
FACILITIES
GENUS
AND
SPECIES
OF
MAJOR
PESTS
FOR
WHICH
THE
USE
OF
METHYL
BROMIDE
IS
CRITICAL
COMMON
NAME
SPECIFIC
REASON
WHY
METHYL
BROMIDE
IS
NEEDED
Tribolium
confusum
Confused
flour
beetle
Tribolium
castaneum
Red
flour
beetle
Pest
status
is
due
to
health
hazard:
allergens;
plus
body
parts,
exuviae,
and
excretia
violate
FDA
regulations1.
Methyl
bromide
is
needed
because
these
insects
can
occur
in
areas
with
electronic
equipment
and
materials
that
cannot
tolerate
high
temperatures
(
i.
e.
cooking)
so
phosphine
and
heat
are
not
adequate.

Trogoderma
variable
Warehouse
beetle
Health
hazard:
choking
and
allergens;
plus
body
parts,
exuviae,
and
excretia
violate
FDA
regulations.
Methyl
bromide
is
needed
because
these
insects
can
occur
in
areas
with
electronic
equipment
and
materials
that
cannot
tolerate
high
temperatures
(
i.
e.
cooking)
so
phosphine
and
heat
are
not
adequate.

Lasioderma
serricorne
Cigarette
beetle
Sitophilus
oryzae
Rice
weevil
Plodia
interpunctella
Indianmeal
moth
Oryzaephilus
mercator
Merchant
grain
beetle
Cryptolestes
pusillus
Flat
grain
beetle
Food
contamination
violates
FDA
regulations.
Methyl
bromide
is
needed
because
these
insects
can
occur
in
areas
with
electronic
equipment
and
materials
that
cannot
tolerate
high
temperatures
(
i.
e.
cooking
of
some
products;
oils
and
butter
go
rancid
with
heat)
so
phosphine
and
heat
are
not
adequate.

1
FDA
regulations
can
be
found
at:
http://
www.
fda.
gov/
opacom/
laws/
fdcact/
fdcact4.
htm
and
http://
www.
cfsan.
fda.
gov/~
dms/
dalbook.
html.

TABLE
2:
KEY
PESTS
FOR
METHYL
BROMIDE
REQUEST:
COMMODITIES
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
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
three
times
longer
than
conventional
MB
fumigation
and
17
times
longer
USA,
Post
Harvest
Use
(
NPMA),
Response
to
June
2004
Questions
Page
2
Cadra
figulilella
Raisin
Moth
Carpophilus
sp.
Dried
Fruit
Beetle
Ectomyelois
ceratoniae
Carob
pod
moth
Carpophilus
spp.,
Haptoncus
spp.
Nitidulid
beetles
than
vacuum
MB
fumigation.
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.

AMOUNT
OF
METHYL
BROMIDE
NOMINATED
TABLE
3.
AMOUNT
OF
METHYL
BROMIDE
NOMINATED
BY
THE
U.
S.
IN
2005
AND
2006.
2005
(
KG)
2006
(
KG)
DESCRIPTION
144,863
144,863
No
difference
between
the
years
because
this
is
a
new
CUE.
This
was
added
as
a
supplemental
request
for
2005.

ECONOMIC
IMPACTS
There
was
no
economic
assessment
conducted
for
this
sector
because
the
background
economic
information
was
not
available
from
the
applicant.

RESPONSE
TO
QUESTIONS
MBTOC
Question
1
­
MBTOC
is
unable
to
assess
this
CUN.
The
Party
has
requested
amounts
for
treatment
of
cheese
plants,
and
in
addition
for
a
range
of
commodities
listed
as
spices
and
herbs,
cocoa,
dried
milk,
other
commodities
and
processed
foods.
MBTOC
recognizes
the
need
for
MB
for
cheese
stores
and
for
the
dried
milk.
MBTOC
can
determine
no
reason
why
alternatives
cannot
be
used
for
all
or
most
of
the
spices
and
herbs,
cocoa,
and
processed
foods.
Alternatives
registered
for
some
of
all
these
commodities
in
the
U.
S.
include
irradiation,
ethylene
oxide,
phosphine,
steam,
and
propylene
oxide.
In
addition
most
of
the
use
designated
as
for
other
commodities
may
qualify
as
QPS
treatments.
The
Party
is
requested
to
disaggregate
the
commodity
groups,
specifying
the
target
organism
and
state
any
regulatory
or
technical
reasons
why
each
of
the
possible
alternatives
cannot
be
used
for
each
separate
commodity
group
and
target.

U.
S.
Response
­
The
commodity
and
structures
groups
and
amount
of
methyl
bromide
nominated
are
listed
by
specific
type
of
use
in
Table
4.
In
this
sector,
many
of
the
requesting
facilities
use
methyl
bromide
for
fumigation
of
both
the
structure
and
the
commodity
being
processed
in
that
structure.
A
discussion
of
the
target
pests
and
the
regulatory,
technical
and
economic
feasibility
of
control
using
alternatives
are
provided
below
for
each
type
of
use.
USA,
Post
Harvest
Use
(
NPMA),
Response
to
June
2004
Questions
Page
3
TABLE
4.
TYPE
OF
USE
AND
AMOUNT
OF
METHYL
BROMIDE
NOMINATED
FOR
2006
(
KG)
AND
LOCATION
OF
PEST
LIST
Processed
Foods
(
chips,
cookies,
crackers,
Pasta,
etc)
Cheese
processing
Plants
Spices
and
Herbs
Cocoa
Dried
Milk
Other
Commodity1
Kg
Nominated
89,861
3,596
5,869
76,899
503
4,352
Key
Pests
Table
1
and
listed
below
Table
2
and
listed
below
Commodity:
Processed
Foods
(
chips,
crackers,
cookies,
pasta),
Cheese
Processing
Plants
Key
Pests:
Flour
beetles
 
Tribolium
spp.
Indian
meal
moths
 
Plodia
interpunctella
Cigarette
beetles
 
Lasioderma
serricorne
Dermestid
beetles
 
Trogoderma
spp.
Drug
store
beetles
 
Stegobium
paniceum
Saw­
toothed
grain
beetles
 
Oryzerphilus
surinamenis
Warehouse
beetles
 
Trogoderma
variabile
Shortcomings
of
alternatives:
1.
Irradiation
 
Space
treatments
with
fumigants
are
utilized
to
target
pest
infestations
in
harborage
areas
such
as
equipment,
and
overhead
spaces
where
airborne
food
particles
may
accumulate.
Irradiation
could
not
be
utilized
in
the
same
manner
as
conventional
fumigants
that
are
used
to
treat
an
entire
processing
or
storage
facility.
In
addition,
this
technology
is
not
considered
a
feasible
alternative
due
to
cost
of
purchasing
and
operating
equipment,
logistics
for
treatment,
and
concerns
of
consumer
acceptance
of
irradiated
foods.

2.
Ethylene
oxide
 
This
alternative
is
not
available
for
this
use
because
it
is
not
labeled
for
this
commodity
and
no
food
additive
tolerances
are
in
place.

3.
Propylene
oxide
 
This
alternative
is
not
available
for
this
use
because
it
is
not
labeled
for
this
commodity
and
no
food
additive
tolerances
are
in
place.

4.
Heat
and
Phosphine
 
Heat
treatments
or
phosphine
fumigations
require
longer
treatment
durations
than
that
for
methyl
bromide.
In
the
food
industry,
increased
downtime
equals
lost
productivity.
As
an
example,
estimated
cost/
day
for
downtime
in
an
average
pasta
facility
was
$
125,000.
In
addition,
heat
treatments
are
typically
utilized
several
times
per
year,
which
in
turn
significantly
increases
downtime
(
usually
2
to
4
times/
year
and
at
some
facilities,
heat
treatments
are
performed
monthly).
This
simple
cost
value,
however,
does
not
represent
all
costs
associated
with
heat
or
phosphine
alternatives.
Significant
capital
outlay
would
be
necessary
to
upgrade
equipment
or
systems
(
electrical,
plumbing,

1
Includes
tea
on
pallets,
coffee
beans,
tomatoes,
bell
peppers,
citrus
and
cassava.
USA,
Post
Harvest
Use
(
NPMA),
Response
to
June
2004
Questions
Page
4
etc.)
so
that
they
are
compatible
with
heat
or
phosphine.
Costs
would
need
to
be
budgeted
for
repairs
incurred
from
either
type
of
treatment.
In
addition,
if
in­
place
heat
sources
were
inadequate,
supplemental
heat
costs
would
be
significant.

5.
Steam
 
Not
a
practical
treatment
option
for
dry
finished
food
products
as
this
technique
affects
the
quality
of
the
finished
product
and
can
leave
a
residual
moisture
in
the
processing
equipment.

Commodity:
Spices
and
Herbs,
and
Other
Commodity
2
Key
Pests:
Cigarette
beetles
 
Lasioderma
serricorne
Confused
flour
beetles
 
Tribolium
confusum
Drug
store
beetles
 
Stegobium
paniceum
Indian
meal
moths
 
Plodia
interpunctella
Shortcomings
of
alternatives:
1.
Irradiation
 
A
large
portion
of
spices
and
herbs
and
other
commodities
are
currently
treated
with
irradiation
in
the
U.
S.
Due
to
logistics
and
cost
issues,
this
treatment
method
is
not
always
an
available
method.
See
comments
above
under
processed
foods.

2.
Ethylene
oxide
 
Many
countries
(
Japan,
some
EEC,
the
United
Kingdom)
have
banned
the
use
of
ethylene
oxide
(
ETO)
because
it
reacts
with
organic
spice
components
to
leave
the
harmful
residues
ethylene
chlorohydrin
and
ethylene
bromohydrin
on
spices.
In
Canada,
ETO
can
not
be
used
on
vegetable
seasonings
or
spice
mixtures
containing
salts.
ETO
can
result
in
unacceptable
color
changes
(
darkening)
in
some
vegetable
seasonings
such
as
onion
and
garlic
powder
and
off
flavor
in
mustard
and
mustard
flour.

ETO
is
a
suspected
carcinogen
currently
under
review
by
the
U.
S.
EPA
and
is
scheduled
to
be
completed
in
2006.
The
World
Health
Organization
has
recently
upgraded
ETO
to
a
known
carcinogen.
Due
to
the
instability
and
flammability
of
ETO,
it
must
be
mixed
with
carbon
dioxide
or
nitrogen
(
formerly
was
mixed
with
CFCs).

Source:
M.
Marcotte,
"
Effect
of
Irradiation
on
Spices,
Herbs
and
Seasonings
 
Comparison
with
Ethylene
Oxide
Fumigation."

3.
Propylene
oxide
 
Banned
in
some
countries
for
the
residues
it
leaves
in
spices.
There
is
one
currently
registered
product
in
the
U.
S.
and
application
methods
are
limited
to
fumigation
chambers.
Lack
of
facilities
in
the
U.
S.
to
perform
vacuum
fumigations
2
Includes
tea
on
pallets,
coffee
beans,
tomatoes,
bell
peppers,
citrus
and
cassava.
USA,
Post
Harvest
Use
(
NPMA),
Response
to
June
2004
Questions
Page
5
creates
logistical
problems.
In
addition,
this
technology
is
not
considered
a
feasible
alternative
due
to
cost
of
purchasing
and
operating
fumigation
chambers.

4.
Phosphine
 
See
comments
under
processed
foods
and
cocoa.

5.
Steam
 
Results
in
the
loss
of
volatile
flavor
and
aroma
components
and
color
change.
Steam
can
also
increase
moisture
level
of
the
commodity
being
treated,
possibly
resulting
in
the
high
level
of
mold
contamination
seen
in
spices
and
herbs
and
other
commodities
previously
treated
with
ETO
and
steam.

Commodity:
Cocoa
Key
Pests:
Indian
meal
moth
 
Plodia
interpunctella
Cigarette
beetle
 
Lasioderma
serricome
Foreign
grain
beetle
 
Ahasuerus
advena
Cocoa
moth
species
Warehouse
moths
 
Plodia
spp.
and
Ephestia
spp.
Coffee
bean
weevils
 
Araecerus
fasciculatus
Shortcomings
of
alternatives:
1.
Irradiation
 
See
comments
under
processed
foods.
There
is
currently
no
equipment
present
at
facilities
receiving
cocoa
beans
at
U.
S.
ports,
and
any
such
equipment
would
need
to
be
capable
of
processing
large
volumes
of
product
during
the
seasonal
delivery
period
in
order
to
be
considered
commercially
feasible
in
today's
market.
Equipment
would
also
have
to
be
capable
of
penetrating
bulk
packaged
cocoa.
Due
to
logistics
and
cost
issues,
this
treatment
method
is
not
economically
viable.

2.
Ethylene
oxide
 
This
product
is
not
available
for
cocoa
because
it
is
not
labeled
for
this
commodity
and
no
food
additive
tolerances
in
place.

3.
Propylene
oxide
 
This
product
is
not
available
for
cocoa
because
it
is
not
labeled
for
use
on
cocoa
in
California.
See
above
comments
under
spices
and
herbs.

4.
Phosphine
 
The
major
reason
phosphine
is
not
considered
a
viable
alternative
for
treating
cocoa
beans
is
related
to
the
increased
time
that
it
takes
to
treat
cocoa,
and
the
large
influx
of
shipments
during
peak
periods
of
the
year.
Most
fumigation
work
is
completed
in
large
cocoa
storage
facilities
close
to
waterfronts.
Large
bulk
ships
with
up
to
200,000
burlap
bags
of
cocoa
arrive
at
different
times
of
the
year.
September
through
April
is
the
peak
delivery
months
of
cocoa
into
the
U.
S.,
depending
on
harvest
time.
Ships
are
typically
heavily
infested
with
insects;
sometimes
infestations
are
so
heavy
that
workers
must
wear
full­
face
protection
to
protect
against
insects
interfering
with
their
normal
work
operations
(
30
plus
insects
per
thousand
cubic
feet
counts
are
normal).
USA,
Post
Harvest
Use
(
NPMA),
Response
to
June
2004
Questions
Page
6
During
discharge,
cocoa
beans
are
covered
with
large
tarps
to
prevent
cross­
infestation
with
other
cocoa
stored
at
a
warehouse
site.
Cocoa
at
these
warehouses
is
owned
by
numerous
brokers
and
processors
who
use
these
large
warehouses
as
storage
and
to
complete
on­
time
delivery
of
product
to
processing
plants.
Most
of
these
warehouses
are
not
heated
and
range
in
temperature
from
40­
55
°
F
during
the
busy
delivery
months.
The
recommended
exposure
time
for
phosphine
at
temperatures
of
40­
55
°
F
is
5
to
10
days,
while
methyl
bromide
is
16
to
24
hours
according
to
the
label.

Most
warehouse
employees
(
both
skilled
and
unskilled
laborers)
would
have
to
be
laid
off
whenever
a
shipment
arrives
at
their
location
due
to
the
length
of
fumigation
exposure
time.
Fumigation
costs
would
almost
double
due
to
the
longer
reentry
times
and
much
longer
security
and
monitoring
needs.
For
example,
a
fumigation
with
a
24­
hour
exposure
period
can
be
completed
(
i.
e.,
preparation,
fumigation,
ventilation
and
cleanup)
in
30
to
35
hours,
whereas
a
fumigation
with
a
96
hour
exposure
period
requires
approximately
five
days
to
complete.
Most
of
the
cocoa
is
shipped
to
processors
on
an
on­
time
delivery
system.
If
left
infested,
the
product's
quality
and
quantity
would
be
further
reduced
and
could
cause
cross­
infestation
of
other
product
already
treated.
The
cocoa
would
eventually
become
unusable
according
to
FDA
standards,
if
not
treated.

5.
Steam
 
See
comments
under
spices
and
herbs.
Steam
is
used
to
sterilize
cocoa
beans
during
processing,
but
only
when
the
beans
immediately
go
into
the
next
phrase
of
processing.
Beans
that
are
steamed
will
develop
mold
within
24
hours,
thus
ruining
them.
For
cocoa
beans
to
be
steamed
in
lieu
of
fumigation,
they
would
have
to
be
removed
from
the
bags
in
which
they
are
packed,
steamed,
dried
and
then
re­
packaged.
Cocoa
beans
typically
undergo
extensive
processing,
and
the
additional
cost
of
steam
treatment
in
lieu
of
fumigation
would
increase
processing
costs
beyond
typical
profit
margins
in
the
industry.

REFERENCES
2006
Bromide
Usage
Numerical
Index
(
BUNI)
 
Refined
Nomination
Package.
Attached
to
U.
S.
Response
to
Questions
as
an
Excel
Spreadsheet.

Marcotte,
M.
2000.
Effect
of
Irradiation
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