USA,
Post­
Harvest
Use
for
Food
Processing
Plants,
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
for
Food
Processing
Plants
DOCUMENT
NUMBER
CUN
2003,
US56N10
DATE
August
12,
2004
CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1.
KEY
PESTS,
AND
SPECIFIC
REASON
FOR
METHYL
BROMIDE
IN
MILLS
AND
FOOD
PROCESSORS
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
Food
and
Drug
Administration
(
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
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.

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
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
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.

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
536,328
505,982
The
U.
S.
imposed
a
reduction
in
use
rate
on
applicants,
and
reduced
the
applicant
requests
to
account
for
their
request
for
growth
in
the
number
of
facilities
treated.
USA,
Post­
Harvest
Use
for
Food
Processing
Plants,
Response
to
June
2004
Questions
Page
2
FIGURE
1.
U.
S.
TOTAL,
REQUESTED,
AND
NOMINATED
MILLS
AND
FOOD
PROCESSORS
0
500
1000
1500
2000
2500
3000
3500
4000
4500
5000
Mills
and
Food
Processors
Number
Total
*

Requested
by
applicant
**

Nominated
by
US
***

Footnotes:
*
The
total
number
of
facilities
(
names
and
addresses
listed
in
Appendix
A)
is
based
on
US
EPA's
Facility
Registry
System
(
FRS)
based
on
Standard
Industrial
Classification
(
SIC)
codes
for
Flour
Millers,
Rice
Millers,
Pet
Foods,
and
Food
Processors.
Only
facilities
with
one
or
more
EPA
permits
are
included
(
4475
Facilities).
**
Total
number
of
facilities
requesting
methyl
bromide
(
275
Facilities).
***
Total
number
of
facilities
included
in
the
US
Nomination
(
275
Facilities).

ECONOMIC
IMPACTS
The
economic
impacts
were
assessed
using
four
economic
parameters:
1.
loss
per
1000
cubic
foot,
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
Question
1
­
USA
CUN
2003/
051,
USc6N4
For
Mills
and
Processors
MBTOC
is
unable
to
assess
this
sector
because
detailed
information
regarding
the
location,
size,
age,
frequency
of
MB
fumigation
and
historical
usage
data
of
each
individual
mill
and
plant
was
not
included
in
the
nomination.

Answer
 
Members
of
this
sector
are
trying
to
comply
with
this
request.
However,
these
consortia
request
more
time
to
compile
these
data
as
they
need
to
ask
for
this
information
from
their
members,
which
in
turn
need
to
gather
the
information
from
the
individual
plants
and
their
pest
control
operators/
fumigation
companies.

To
illustrate
the
magnitude
of
this
task,
the
names
and
addresses
of
facilities
listed
in
Appendix
A
USA,
Post­
Harvest
Use
for
Food
Processing
Plants,
Response
to
June
2004
Questions
Page
3
were
produced
from
the
US
EPA's
Facility
Registry
System
(
FRS)
based
on
Standard
Industrial
Classification
(
SIC)
codes
for
Flour
Millers,
Rice
Millers,
Pet
Foods,
and
Food
Processors.
These
facilities
have
one
or
more
EPA
permits.
Detailed
descriptions
of
the
types
of
establishments
that
are
included
in
each
SIC
codes
are
available
from
the
US
Department
of
Labor,
Occupational
Safety
and
Health
Administration
website
located
at
http://
www.
osha.
gov/
pls/
imis/
sicsearch.
html.
EPA's
Facility
Registry
System
is
publicly
available
and
is
located
at
http://
www.
epa.
gov/
enviro/
html/
fii/
ez.
html
Please
note
that
only
a
small
percentage
of
the
facilities
listed
in
Appendix
A
(
Filename:
CUN2003
Stru
02
Mills
&
Processors
Reply
to
June
2004
Questions.
xls)
use
methyl
bromide
to
control
pests.
There
is
additional
concern
that
release
of
the
exact
locations
has
homeland
security
issues.

MBTOC
Question
2
­
The
Party
may
wish
to
adjust
the
quantity
nominated
in
view
of
recent
registration
of
one
potential
alternative
(
SF)
for
this
usage.

US
Response
­
There
are
two
factors
that
will
delay
the
adoption
of
sulfuryl
fluoride
(
SF)
as
a
methyl
bromide
replacement.
Although
sulfuryl
fluoride
was
registered
by
U.
S.
EPA
in
January
of
2004,
it
was
registered
only
for
the
mills
processing
flour
and
rice
that
do
not
manufacture
any
food
mixes
or
ingredients.
In
addition,
US
pesticide
registration
is
a
multi­
part
process;
registration
at
the
federal
level
must
be
followed
by
a
state
registration.
The
California,
Florida,
and
New
York
state
registrations
are
still
pending.
Because
a
lawsuit
has
been
filed
over
the
SF
registration,
the
registration
process
in
the
remaining
states
is
likely
to
be
slowed.

A
large,
but
currently
unknown,
number
of
mills
that
process
flour
also
produce
partial
recipe
products
that
contain
such
ingredients
as
sugar,
baking
soda,
leavening
agents,
hydrogenated
oils,
etc.
The
registration
of
sulfuryl
fluoride
does
not
include
tolerances
for
these
ingredients
and
therefore
SF
could
not
be
legally
used
in
these
facilities
at
this
time.
It
is
most
likely
that
adoption
of
sulfuryl
fluoride
for
some
of
these
mills
will
be
delayed
until
tolerances
for
these
ingredients
are
sought
by
the
registrant,
reviewed
by
U.
S.
EPA,
and
granted
(
if
they
meet
eligibility
criteria).

As
Figure
1
demonstrates,
only
a
small
proportion
of
the
milling
and
food
processing
facilities
in
the
US
have
applied
to
use
methyl
bromide.
Because
the
US
accelerated
the
registration
of
SF
as
a
methyl
bromide
alternative
the
use
on
food
additives
was
not
included
in
the
registration.
The
US
will
need
to
collect
information
on
the
extent
of
the
number
and
location
of
facilities
where
these
types
of
food
additives
are
used
and
were
included
in
our
original
CUE
request.
At
the
same
time
the
US
will
attempt
to
clarify
if
any
of
these
products
are
sold
to
countries
where
SF
is
not
yet
registered.
As
a
consequence
of
the
factors
listed
above,
we
do
not
believe
it
would
be
prudent
to
adjust
the
quantity
nominated
for
these
uses.
However,
we
are
committed
to
rereviewing
the
status
and
market
penetration
of
SF
as
part
of
the
domestic
allocation
procedure
for
2006,
and
are
committed
to
reducing
the
allocation
to
the
extent
that,
at
that
time,
SF
is
a
viable
alternative
for
the
nominated
uses.

References
2006
Bromide
Usage
Numerical
Index
(
BUNI)
 
Refined
Nomination
Package.
Attached
to
U.
S.
USA,
Post­
Harvest
Use
for
Food
Processing
Plants,
Response
to
June
2004
Questions
Page
4
Response
to
Questions
as
an
Excel
Spreadsheet.
USA,
Post­
Harvest
Use
for
Food
Processing
Plants,
Response
to
June
2004
Questions
Page
5
Appendix
A.
Names
and
Addresses
of
U.
S.
Post­
harvest
Facilities
A­
1.
Flour
Millers
(
SIC
Code
2041)

A­
2.
Rice
Millers
(
SIC
Code
2044)

A­
3.
Pet
Foods
(
SIC
Codes
2047,
2048)

A­
4.
Food
Processors
(
SIC
Codes
2043,
2045,
2051,
2052,
2096,
2099)

NOTE:
Appendices
are
contained
in
the
file:
CUN2003
Stru
02
Mills
&
Processors
Reply
to
June
2004
Questions.
xls
USA,
Post­
Harvest
Use
for
Food
Processing
Plants,
Response
to
June
2004
Questions
Page
6
Table
3.
Number
of
Mills
and
Food
Processing
Facilities
by
Category
Region
State
Flour
Mills
Food
Processing
Pet
Foods
Rice
Eastern
Delaware
1
5
Georgia
10
52
159
Kentucky
13
34
57
Maryland
2
47
33
North
Carolina
19
45
119
New
Jersey
4
64
9
Pennsylvania
29
84
88
South
Carolina
10
31
32
Tennessee
14
42
40
1
Virginia
31
30
38
West
Virginia
3
2
Sub
Total
132
433
582
1
Mountain
Alaska
2
Colorado
5
24
50
Idaho
3
6
15
Montana
4
1
7
Nevada
2
3
Utah
8
17
10
Wyoming
1
Sub
Total
20
52
86
North
East
Connecticut
13
3
Massachusetts
4
39
2
Maine
1
6
2
New
York
12
42
18
Rhode
Island
1
Vermont
2
6
North
East
Sub
Total
17
103
31
Southern
Alabama
7
28
69
Arkansas
2
10
50
18
Arizona
10
1
Florida
5
29
21
Louisiana
5
18
22
17
Mississippi
7
12
33
3
New
Mexico
3
10
9
Oklahoma
2
12
31
Texas
12
65
61
3
Sub
Total
43
194
297
41
Tropical
AS
1
GU
1
Hawaii
1
Puerto
Rico
7
28
29
2
Sub
Total
7
30
30
2
Upper
Midwest
Iowa
43
54
256
Illinois
24
181
121
1
Indiana
23
29
53
Kansas
33
27
147
Michigan
7
35
7
USA,
Post­
Harvest
Use
for
Food
Processing
Plants,
Response
to
June
2004
Questions
Page
7
Minnesota
21
29
96
Missouri
55
54
147
2
North
Dakota
4
4
4
Nebraska
12
29
175
Ohio
23
68
77
South
Dakota
2
15
Wisconsin
7
53
52
Sub
Total
252
565
1150
3
Western
California
22
116
74
31
Oregon
6
18
25
Washington
9
59
42
Sub
Total
37
193
141
31
Grand
Total
508
1570
2317
78
Footnote:
These
facilities
have
one
or
more
EPA
permits.
Descriptions
of
the
establishments
that
are
included
in
each
SIC
codes
are
available
from
the
US
Department
of
Labor,
Occupational
Safety
and
Health
Administration
website
located
at
http://
www.
osha.
gov/
pls/
imis/
sicsearch.
html.
EPA's
Facility
Registry
System
is
publicly
available
and
is
located
at
http://
www.
epa.
gov/
enviro/
html/
fii/
ez.
html
