USA,
Field
Grown
Tomato,
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
Preplant
Soil
Use
for
Tomato
Grown
in
Open
Fields
on
Plastic
Mulch
DOCUMENT
NUMBER
CUN
2003/
050,058,
Usc6N3,
Usc6N9
DATE
August
12,
2004
CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1.
REGION,
KEY
PESTS,
AND
SPECIFIC
REASON
FOR
METHYL
BROMIDE
IN
TOMATO
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Fusarium
wilt,
Verticillium
wilt,
Root
Knot
nematodes,
Pythium
spp.
Registered
alternatives
do
not
provide
consistent,
efficient
and
economical
control
of
listed
pests;
use
of
alternatives
problematic
in
hilly
terrain
included
in
the
nomination.

Michigan
Crown,
root
and
fruit
rot
caused
by
Phytophthora
capsici,
Fusarium
oxysporum
wilt
Methyl
bromide
is
currently
the
only
product
that
can
control
these
soil­
borne
pathogens
and
allow
Michigan
growers
to
deliver
their
produce
during
premium
priced
early
market
windows.
Other
control
measures
have
plant
back
restrictions
that
put
Michigan
tomatoes
outside
the
premium
priced
fresh
market.
Resistant
varieties
have
not
been
identified.

Southeastern
US
Nutsedges
(
Cyperus
rotundus
and
C.
esculentus)

Root­
Knot
nematodes
Phytophthora
Crown
and
Root
Rot
Fusarium
Wilt
(
F.
oxysporum)
None
of
the
listed
MBTOC
alternatives
are
effective
in
controlling
the
key
pests
in
the
Southeastern
US
at
moderate
to
severe
pest
pressure.
Use
of
alternatives
is
restricted
in
areas
with
karst
topography.

AMOUNT
OF
METHYL
BROMIDE
NOMINATED
TABLE
2.
AMOUNT
OF
METHYL
BROMIDE
NOMINATED
BY
THE
U.
S.
IN
2005
AND
2006.
2005
(
KG)
2006
(
KG)
DESCRIPTION
OF
DIFFERENCES
BETWEEN
YEARS
2,865,262
2,844,985
VA
did
not
resubmit
a
CUE.
New
data
on
extent
of
pest
pressure
in
SE
US.
CA
provided
additional
information
on
their
problem.
USA,
Tomato
Response
to
Questions
Page
2
FIGURE
1.
U.
S.
TOTAL,
REQUESTED,
AND
NOMINATED
HECTARES
OF
TOMATOES
0
10000
20000
30000
40000
50000
60000
Tomato
Total
Requested
by
applicants
Nominated
by
U.
S.

Footnote:
Total
hectares,
based
on
United
States
Department
of
Agriculture
Statistics,
are
national
acreage
in
production
for
this
sector.
The
requested
hectares
are
sum
total
of
all
the
hectares
in
the
CUE
applications.
The
nominated
hectares
reflect
reductions
of
the
requested
hectares
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.
Total
pounds
of
methyl
bromide
nominated
by
the
United
States
government
for
this
sector
are
based
on
these
nominated
hectares.
See
the
accompanying
spreadsheet
2006
Bromide
Usage
Numerical
Index
or
"
BUNI"
(
Filename:
USA
2006
BUNI
 
Refined
Nomination
Package.
xls)
for
more
detailed
information
on
how
the
nominated
amount
was
determined.

ECONOMIC
IMPACTS
The
economic
impacts
were
assessed
using
four
economic
parameters:
1.
loss
per
hectare,
2.
loss
per
kilogram
of
methyl
bromide,
3.
loss
as
a
percentage
of
gross
revenue,
and
4.
loss
as
a
percentage
of
net
revenue.
This
assessment
compares
methyl
bromide
to
the
best
available
alternative
to
determine
the
economic
feasibility
of
using
that
alternative.
A
range
of
alternatives
were
examined
to
determine
the
best
available
alternative
scenario
taking
into
account
yield
loss
estimates
and
cost
increase
estimates.
The
result
of
the
economic
impact
analysis
is
presented
in
the
BUNI
analysis.
In
this
sector,
no
alternatives
were
found
to
be
both
technically
and
economically
feasible
for
the
particular
circumstances
nominated
for
the
CUE.

RESPONSE
TO
QUESTIONS
According
to
the
nomination,
no
alternatives
are
available
for
severe
fungal,
nematode
and
nutsedge
pressure
in
certain
areas.
Topography
and
regulatory
issues
prevent
the
use
of
one
possible
alternative
(
1,3­
D).
However
several
fumigant
alternatives
are
providing
effective
control
of
pests
(
e.
g.
1,3­
D/
Pic,
Pic
alone,
metam
sodium
and
Pic
used
in
combination)
and
a
number
of
herbicides
(
e.
g.
halosulfuron
methyl,
trifloxysulfuron)
are
available
to
control
nutsedge.
USA,
Tomato
Response
to
Questions
Page
3
MBTOC
Question
1
­
Information
is
sought
on
scope
for
reduction
of
the
nomination
with
use
of
non­
1,3­
D
alternatives
such
as
metam
sodium/
pic
combinations
in
the
areas
with
karst
geology,
the
proportion
of
the
crop
affected
by
plantback
restrictions
using
nutsedge
herbicides
(
halosulfuron
methyl
and
trifloxysulfuron),
the
restrictions,
if
any,
on
sequential
application
of
alternatives
where
useful,
and
the
scope
for
reduced
MB
dosages
associated
with
use
of
VIF,
strip
treatment
and
herbicide
(
especially
halosulfuron
methyl
and
trifloxysulfuron)
use.

US
Response
 
A.
Metam
sodium/
chloropicrin
combinations
in
areas
with
karst
geology:
In
the
southeastern
United
States,
there
are
two
major
limitations
with
the
use
of
metam
sodium
+
chloropicrin
combinations
at
this
time,
nematode
control
and
worker
safety.
The
most
important
limitation
is
that
nematode
control
would
be
inadequate
in
most,
if
not
all,
of
vegetable
producing
areas
according
to
Dr.
David
Langston
(
plant
pathologist,
University
of
Georgia).
Due
to
this
reason,
University
of
Georgia
researchers
did
not
include
this
combination
in
their
2004
research
trials
on
the
efficacy
of
methyl
bromide
alternatives
in
controlling
soil­
borne
pests.
Other
researchers
in
Florida
and
Georgia
have
indicated
that
metam
sodium
does
not
provide
adequate
weed
control
under
their
growing
conditions.

Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations
with
high
nutsedge
infestation
(
see
Table
3).
Various
treatments
were
tested
on
plots
that
had
multiple
pests.
At
the
Bradenton
site
there
was
moderate
to
heavy
Fusarium
infestation;
heavy
purple
nutsedge
infestation
and
light
root­
knot
nematode
pressure.
At
Gainesville
there
was
heavy
infestation
of
yellow
and
purple
nutsedge
and
moderate
infestation
of
root­
knot
nematode.
In
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metamsodium
treatments
compared
to
MB
at
both
sites.
At
Bradenton,
the
average
yield
from
both
metam­
sodium
treatments
was
33%
of
the
MB
yields,
suggesting
a
67%
yield
loss
from
not
using
MB.
At
Gainesville
the
average
yield
of
the
two
metam­
sodium
treatments
was
56%
of
the
MB
yield,
suggesting
a
44%
yield
loss
from
not
using
MB.
In
considering
metam
sodium
plus
chloropicrin
results,
one
must
keep
in
mind
that
metam
sodium
alone
does
not
provide
adequate
nematode
control
and
that
the
addition
of
chloropicrin
which
controls
plant
pathogens
would
not
be
expected
to
improve
nematicidal
attributes
of
this
fumigant.
USA,
Tomato
Response
to
Questions
Page
4
TABLE
3.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.
1997)

Chemicals
Rate
(/
ha)
Average
Nutsedge
Density
(#/
m2)
Average
Marketable
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

UNTREATED
(
CONTROL)
­
300
ab
20.1
a
59.1
MB
+
Pic
(
67­
33),
chisel­
injected
390
kg
90
c
49.1
b
­­­

1,3
D
+
Pic
(
83­
17),
chisel­
injected
327
l
340
a
34.6
c
29.5
Metam
Na,
Flat
Fumigation
300
l
320
a
22.6
a
54.0
Metam
Na,
drip
irrigated
300
l
220
b
32.3
c
34.2
Footnotes:
(
1)
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability,
using
Duncan's
multiple
range
test.
(
2)
Data
shown
are
from
the
Gainesville/
Horticultural
Unit
site,
1994
season
(
this
was
one
of
three
sites
included
in
this
study).
This
site
had
relatively
high
nutsedge
pressure,
and
data
for
both
pest
pressure
and
marketable
yields
for
all
treatments
shown.

The
second
issue
with
a
metam
sodium
application
is
the
high
worker
exposure
and
worker
safety
concerns
during
the
application
process.
To
obtain
adequate
nutsedge
control
metam
sodium
has
to
be
applied
3
to
4
inches
deep
and
then
followed
immediately
with
the
plastic
laying
operation.
If
the
metam
sodium
is
disked
into
the
soil
or
if
plastic
laying
operation
is
delayed
the
efficacy
of
metam
sodium
in
controlling
the
nutsedge
is
lost.
In
an
effort
to
overcome
the
exposure
concerns
researchers
in
the
southeastern
U.
S.
are
testing
a
new
application
device
in
an
effort
to
address
the
worker
safety
and
exposure
issues.
The
researchers
have
used
the
new
applicator
for
the
first
time
but
now
they
have
to
wait
until
August/
September
2004
to
evaluate
the
efficacy
of
this
method
for
the
first
time
in
controlling
nutsedge.
In
order
to
be
considered
successful
the
new
application
equipment
would
need
to
provide
satisfactory
worker
safety
and
improved
pest
control
efficacy
when
used
with
metam
sodium.

B.
Halosulfuron
and
trifloxysulfuron,
the
proportion
of
the
crop
affected
by
plantback
restrictions
:
Both
of
these
herbicides
are
effective
in
the
control
of
nutsedge.
However
there
are
several
limitations
to
the
use
of
these
products.
These
limitations
are
discussed
below.

Both
herbicides
have
to
be
applied
postemergence
for
adequate
control
of
nutsedge.
This
means
that
nutsedge
has
to
penetrate
the
plastic
tarp
prior
to
application
of
the
herbicide.
Typically
the
grower
tries
to
grow
3
or
more
crops
on
a
single
laying
of
plastic
mulch.
Many
of
the
fields
are
intensely
populated
with
nutsedge
and
the
plastic
would
be
destroyed
very
quickly,
most
likely
after
one
or
two
crops.

Another
problem
with
postemergence
applications
is
that
even
though
both
herbicides
are
effective
in
controlling
nutsedge
they
do
not
contact
the
soil
because
of
the
plastic
tarps
and
thus
provide
no
residual
nutsedge
control.
The
spray
either
contacts
the
crop,
the
weed,
or
the
plastic.
Therefore,
another
flush
of
nutsedge
could
occur,
under
the
plastic,
immediately
after
the
USA,
Tomato
Response
to
Questions
Page
5
herbicide
application.
Nutsedge
continually
emerges
for
at
least
8
to
9
months
out
of
the
year
in
the
southeastern
U.
S.
Both
of
these
herbicides
can
be
applied
as
sequential
applications,
halosulfuron
can
be
applied
twice
per
season
and
trifloxysulfuron
can
be
applied
up
to
3
times
per
season.
However,
with
an
aggressive
weed
such
as
nutsedge
and
a
long
duration
crop
such
as
tomatoes,
6
month
duration,
two
or
three
herbicide
applications
will
not
provide
adequate
control
because
the
majority
of
the
nutsedge
plants
are
protected
under
the
plastic
tarp
where
they
still
compete
with
the
tomato
crop
for
water
and
nutrients.

Herbicide
carryover
is
also
an
issue
for
trifloxysulfuron.
The
research
that
has
been
conducted
indicates
a
high
potential
for
phytotoxicity
to
subsequent
vegetable
crops
and
the
labels
carry
plantback
restrictions
because
of
this.
Rotational
restrictions
on
the
label
vary
from
3
to
18
months
depending
on
crop.
The
transplanted
bell
peppers
,
cucurbits
and
tomatoes
can
be
planted
after
4
months
but
phytotoxicity
restricts
the
planting
of
most
of
the
other
vegetables
for
at
least
12
months.
Therefore,
this
herbicide
is
not
and
will
not
be
used
as
long
as
these
phytotoxicity
issues
restrict
rotational
crops.

An
additional
limitation
with
trifloxysulfuron
is
that
it
is
currently
only
labeled
for
use
in
Florida
and
Georgia.
The
other
southeastern
tomato
growing
states
will
not
be
able
to
use
this
pesticide
until
it
is
registered
for
use
in
their
states.

For
halosulfuron,
the
work
is
being
done
with
the
manufacturer
to
evaluate
the
potential
to
reduce
the
carryover
restrictions
on
the
label.
Presently,
residue
carryover
still
poses
a
serious
restriction
to
crops
following
a
postemergence
application
of
halosulfuron.
The
restricted
crops
include
cabbage
(
15
months
plant
back),
cole
crops
(
18+
months
plant
back),
and
greens
(
36
months
plant
back).
Trifloxysulfuron
plant
back
restrictions
are
very
similar
to
these
restrictions.
The
southeastern
U.
S.
tomato
growers
can
typically
grow
3
crops
in
less
than
12
months.
Therefore,
an
18
month
rotational
restriction
can
limit
their
crop
choices
for
3
to
5
crop
cycles.

Additional
limitations
to
halosulfuron
include
potential
crop
injury
with
excessive
rains
(
greater
than
1
inch),
which
is
not
uncommon
in
areas
of
the
southeastern
U.
S.
The
label
restricts
halosulfuron
use
in
areas
where
soils
are
permeable,
particularly
where
the
ground
water
is
shallow,
because
such
use
may
result
in
ground
water
contamination.

C.
Metam
+
pic
on
karst
topography:
As
mentioned
above
in
Part
A,
this
treatment
will
not
provide
adequate
nematode
or
perennial
weed
control.

D.
Proportion
of
crop
impacted
by
herbicide
carryover:
Based
on
the
label
restrictions,
it
is
estimated
that
more
than
90%
of
Georgia's
production
land
(
Culpepper,
2004)
is
impacted
by
herbicide
carryover
and
the
case
would
be
similar
in
other
southeastern
states.

E.
Strip
treatments:
From
the
information
available
to
us
all
the
tomato
growers
in
the
California,
Michigan,
and
the
southeastern
U.
S.
are
already
using
strip
treatments
with
plastic
tarps
with
their
methyl
bromide
fumigations,
therefore
reductions
in
our
nomination
request
would
not
be
appropriate.
USA,
Tomato
Response
to
Questions
Page
6
F.
VIF:
More
research
remains
to
be
conducted
in
this
arena.
During
2004,
several
trials
are
in
progress
on
the
ability
of
a
methyl
bromide
alternative
fumigant
and
VIF
to
control
nutsedge.
There
are
several
problems
that
remain
to
be
addressed.
 
Plant
back.
This
spring
a
researcher
waited
28
days
after
fumigating
and
laying
VIF
film.
Two­
thirds
of
his
fumigant
alternatives
killed
his
crop.
This
type
of
experience
demonstrates
that
in
the
future
research
will
need
to
be
conducted
on
plant
back
intervals
using
methyl
bromide
with
VIF.
 
VIF
film
is
much
more
expensive
(
2
to
3
times
more).
The
growers
must
remain
economically
competitive
to
survive.
 
VIF
film
is
more
susceptible
to
photodegradation
and
does
not
last
as
long
as
current
films.
Currently
films
are
used
for
multiple
crops
to
reduce
costs
and
avoid
disturbing
the
treated
soil.
 
VIF
film
is
more
difficult
to
lay
compared
to
a
low
density
film
because
it
is
more
prone
to
tearing.
New
equipment
and
techniques
will
need
to
be
developed
and
tested
for
growers
to
use
this
product.

In
conclusion,
the
tomato
growers
need
more
time
to
experiment
with
different
technologies,
alternative
fumigants
and
herbicides
to
determine
how
they
can
integrate
various
technologies
in
tomato
production
to
control
various
pests.

MBTOC
Question
2
­
The
party
is
requested
to
clarify
why
in
Michigan,
the
key
pest,
Phytophthora
capsici,
cannot
be
controlled
by
chloropicrin
and
why
the
use
of
substrate
production
systems
which
are
used
in
similar
climatic
zones
worldwide
cannot
be
used
more
widely.

US
Response
­
In
Michigan,
the
tomato
growers
have
traditionally
used
methyl
bromide
in
combination
with
chloropicrin
to
control
soil­
borne
Phytophthora
capsici.
This
is
the
first
year
(
2004)
researchers
at
Michigan
State
University
have
field
tested
straight
formulations
of
chloropicrin
for
the
control
of
P.
capsici
and
the
results
recorded
in
July
showed
that
all
chloropicrin
treatments
have
plant
losses
caused
by
P.
capsici.
In
the
same
field
study
methyl
bromide
treatments
have
no
plant
mortality
caused
by
P.
capsici.
At
this
stage
it
is
not
clear
whether
or
not
chloropicrin
alone
will
be
a
viable
methyl
bromide
alternative.
The
researchers
plan
to
record
fruit
yields
as
the
fruit
will
mature
in
the
later
part
of
2004
tomato
growing
season.
The
use
of
straight
chloropicrin
is
also
under
scrutiny
by
state
officials
concerned
for
worker
safety
exposed
to
the
high
rate
of
chloropicrin
being
released
during
applications.
The
substrate
production
systems
are
not
a
viable
alternative
in
Michigan
because
of
very
high
cost
of
building
such
systems
(
Estes
and
Peet,
1999).

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

Culpepper,
Stanley.
Personal
communication.
July
2004.
USA,
Tomato
Response
to
Questions
Page
7
Estes,
E.
A.
and
M.
Peet,
1999.
The
Bottom
Line
in
Greenhouse
Tomato
Production.
ARE
Report
No.
18,
September,
1999.
Available
on
line
at
http://
www2.
ncsu.
edu/
unity/
lockers/
users/
e/
eaestes/
are18.
pdf
Locascio,
S.
J.,
J.
P.
Gilreath,
D.
W.
Dickson,
T.
A.
Kucharek,
J.
P.
Jones,
and
J.
W.
Noling.
1997.
Fumigant
alternatives
to
methyl
bromide
for
polyethylene
mulched
tomato.
HortSci.
32:
1208­
1211.
