U.
S.
Pork
i
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
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Post
Harvest
Use
on
Dry
Cured
Pork
Products
(
Prepared
in
2005)

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.


Yes

No
Signature
Name
Date
Title:
U.
S.
Pork
ii
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Steve
Knizner
Title:
Acting
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
Mail
Code
7503C
Washington,
DC
20460
U.
S.
A.
Telephone:
(
703)
305­
6903
Fax:
(
703)
308­
8090
E­
mail:
knizner.
steve@
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
U.
S.
Pork
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.......................................
5
6.
Methyl
Bromide
Consumption
for
Past
5
Years
and
Amount
Required
in
the
Year(
s)
Nominated
..............................................................................................................................
7
7.
Location
of
the
Facility
or
Facilities
Where
the
Proposed
Critical
Use
of
Methyl
Bromide
Will
Take
Place.......................................................................................................................
7
Part
B:
Situation
Characteristics
and
Methyl
Bromide
Use
......................................................................................
8
9.
Summary
of
the
Circumstances
in
which
Methyl
Bromide
is
Currently
Being
Used
............
9
10.
List
Alternative
Techniques
that
are
being
Used
to
Control
Key
Target
Pest
Species
in
this
Sector....................................................................................................................................
10
Part
C:
Technical
Validation.................................................................................................................................
10
11.
Summarize
the
Alternative(
s)
Tested,
Starting
with
the
Most
Promising
Alternative(
s)
..
10
12.
Summarize
Technical
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances
.........................................................................................................
10
Part
D:
Emission
Control......................................................................................................................................
11
13.
How
has
this
Sector
Reduced
the
Use
and
Emissions
of
Methyl
Bromide
in
the
Situation
of
the
Nomination?
...............................................................................................................
11
Part
E:
Economic
Assessment...............................................................................................................................
11
14.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
........................
11
15.
Summarize
Economic
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances
.........................................................................................
11
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
..........................................
11
Part
F:
Future
Plans..............................................................................................................................................
12
16.
Provide
a
Detailed
Plan
Describing
how
the
Use
and
Emissions
of
Methyl
Bromide
will
be
Minimized
in
the
Future
for
the
Nominated
Use....................................................................
12
17.
Provide
a
Detailed
Plan
Describing
what
Actions
will
be
Undertaken
to
Rapidly
Develop
and
Deploy
Alternatives
for
this
Use
.....................................................................................
12
18.
Additional
Comments......................................................................................................
12
19.
Citations..........................................................................................................................
12
APPENDIX
A.
2007
METHYL
BROMIDE
USAGE
NUMERICAL
INDEX
......................................................
13
APPENDIX
B.
Description
of
Dry­
curing
Pork
in
the
US................................................................................
17
APPENDIX
C.
.
2006
Methyl
Bromide
Reconsideration
for
Rice
Mills..........................................................
19
U.
S.
Pork
iv
List
of
Tables
Part
A:
Summary
........................................................................................................................
5
Table
4.1:
Methyl
Bromide
Nominated
.......................................................................................
5
Table
A.
1:
Executive
Summary...................................................................................................
6
Table
6.1:
Methyl
Bromide
Consumption
for
the
Past
5
Years
and
the
Amount
Required
in
the
Year(
s)
Nominated..............................................................................................................
7
Part
B:
Situation
Characteristics
and
Methyl
Bromide
Use.........................................................
8
Table
B.
1:
Characteristic
of
Sector..............................................................................................
8
Table
9.1(
a.):
Dry
Cured
Pork
Products
......................................................................................
9
Table
9.1(
b.):
Fixed
Facilities
.....................................................................................................
9
Part
C:
Technical
Validation
....................................................................................................
10
Table
12.1.
Summary
of
Technical
Reason
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................................
10
Part
E:
Economic
Assessment
...................................................................................................
11
Table
15.1.
Summary
of
Economic
Reasons
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................................
11
APPENDIX
A.
2007
METHYL
BROMIDE
USAGE
NUMERICAL
INDEX..........................
13
U.
S.
Pork
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
on
Dry
Cured
Pork
Products
(
Prepared
in
2005)

3.
SITUATION
OF
NOMINATED
METHYL
BROMIDE
USE
This
sector
is
for
the
production
of
cured
meat
products,
such
as
country
hams.
These
are
produced
primarily
in
the
southern
U.
S.
This
sector
has
no
viable
alternatives
available.
Heat
would
destroy
the
product
and
phosphine
does
not
control
mites
on
the
curing
hams.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
VOLUME
(
1,000
M
3)
2007
40,854
2040
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
Currently
there
are
no
viable
alternatives
to
methyl
bromide
for
the
dried
meat
industry:
phosphine
does
not
control
mites
(
a
major
pest)
and
heat
would
alter
the
product.
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
MB,
making
these
alternatives
technically
and/
or
economically
infeasible.
Phosphine,
alone
or
in
combination
with
carbon
dioxide
does
not
control
mites,
a
major
pest
on
cured
hams.
­
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
because
they
will
only
reinfest
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
U.
S.
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.
U.
S.
Pork
6
­
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.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
certain
commodities
and
structures,
such
as
cereal
mills.
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
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.

TABLE
A.
1:
EXECUTIVE
SUMMARY
National
Country
Ham
Association
American
Association
of
Meat
Processors
Nahunta
Pork
Center
AMOUNT
OF
REQUEST
2007
Kilograms
1,242
168,283
145
AMOUNT
OF
NOMINATION*
2007
Kilograms
709
40,000
145
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
U.
S.
Pork
7
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
Use1
Requested
Use
For
each
year
specify:
1998
1999
2000
2001
2002
20032
2007
Amount
of
MB
(
kg)
1,139
1,112
803
1,020
899
169,670
Volume
Treated
1000
m
³
48
46
35
40
35
7,087
Formulation
of
MB
Information
not
provided
Information
not
provided
Dosage
Rate
(
kg/
1000
m
³
)
24
24
23
25
25
42.4
Actual
(
A)
or
Estimate
(
E)
Information
not
provided
Information
not
provided
1
American
Association
of
Meat
Processors
did
not
provide
historical
data.
2
None
of
Applicants
provided
data
for
2003.

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
other
facilities
smoke
their
products
and
smoking
prevents
insects
from
invading
their
facilities.

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
counties),
Missouri
(
California
county),
North
Carolina
(
Boone,
Goldsboro,
Smithfield,
Wayne
counties),
Virginia
(
Surry
county),
Tennessee
(
various
locations),
and
South
Carolina
(
various
locations).

The
USG
has
sent
out
an
additional
survey
requesting
this
information,
after
receipt,
compilation,
analysis,
and
fact
checking,
this
information
will
be
sent
to
MBTOC.
In
addition,
a
full
list
of
all
processing
plants
that
apply
any
registered
pesticide
in
the
U.
S.
is
available
from
the
U.
S.
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.
This
information
was
previously
submitted
in
August
of
2004.
U.
S.
Pork
8
PART
B:
SITUATION
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
GENUS
AND
SPECIES
FOR
WHICH
THE
USE
OF
METHYL
BROMIDE
IS
CRITICAL
COMMON
NAME
SPECIFIC
REASON
WHY
METHYL
BROMIDE
IS
NEEDED
Necrobia
rufipes
 
common
pest
Red
Legged
Ham
Beetle
("
Ham
Borer")
The
adults
feed
on
the
cured
meat.
The
larvae
burrow
into
the
meat
and/
or
fat.
Insect
infested
meat
is
adulterated
and
cannot
be
sold.
1
Piophila
casei
 
common
pest
Cheese/
Ham
Skipper
The
Skippers
are
larval
stages
of
small
flies
that
burrow
into
the
cured
meat.

Dermestes
spp­
common
pests
Dermested
beetles
Mite
species
­­
common
pest
Ham
Mites
These
mites
feed
and
breed
on
the
surface
of
cured
meats.
Uncontrolled,
mite
populations
can
increase
rapidly,
reaching
enormous
numbers.
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
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
these
products
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
about
three
to
five
times
during
a
typical
year.
During
this
process,
the
curing
house,
typically
a
small
building
(
e.
g.
four
stories),
is
covered
with
tarp
and
fumigated
while
full
of
hams.
U.
S.
Pork
9
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
and,
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.
Curing
facilities
are
located
near
slaughter
houses
and
feed
lots,
thereby
having
high
insect
populations
nearby.

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
with
facility,
but
typically
in
excess
of
27
°
C
(
80
°
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
varies.
Varies
Ranges
from
1
story
to
silo
facilities.
Varies
U.
S.
Pork
10
10.
LIST
ALTERNATIVE
TECHNIQUES
THAT
ARE
BEING
USED
TO
CONTROL
KEY
TARGET
PEST
SPECIES
IN
THIS
SECTOR
Currently,
no
alternative
techniques
are
being
used.

PART
C:
TECHNICAL
VALIDATION
11.
SUMMARIZE
THE
ALTERNATIVE(
S)
TESTED
STARTING
WITH
THE
MOST
PROMISING
ALTERNATIVE(
S):

Phosphine,
alone
and
in
combination
with
carbon
dioxide,
does
not
control
mites,
a
major
pest
in
cured
pork
products.
Additionally,
according
to
the
phosphine
label,
the
state
of
North
Carolina
has
further
restricted
the
use
of
this
alternative.
According
to
state
regulations,
phosphine
may
only
be
used
to
control
rats
and
mice,
but
not
insects.

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
Does
not
control
mites.
North
Carolina
has
more
restrictions.
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
Note
below
5
Sulfuryl
fluoride
Not
registered
for
this
use.
Sulfuryl
fluoride
adsorbs
to
fats,
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:

Note:
Irradiation
does
not
readily
kill
exposed
insects,
but
rather
prevents
further
feeding
and
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.
U.
S.
Pork
11
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
No
alternatives
are
currently
registered
for
use
on
cured
pork
products
in
the
U.
S.
therefore
no
economic
analysis
was
conducted
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
T
here
are
no
legal
or
technically
feasible
alternatives
available
for
this
sector.
U.
S.
Pork
12
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.

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.
U.
S.
Pork
13
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).

Date:
Sector:

Kilograms
(
kgs)
Volume
(
1000m
3)
Use
Rate
(
kg/
1000m
3)
Kilograms
(
kgs)
Volume
(
1000m
3)
Use
Rate
(
kg/
1000m
3)
2001
Volume
%
of
Volume
1,242
15
83
796
31
26
0%

145
7
20
163
7
23
0%

168,283
7,004
24
40,000
1,998
20
0%

169,670
7,026
24
40,960
2,036
20
0%

2007
Request
(­)
Double
Counting
(­)
Growth
(­)
Use
Rate
Adjustment
(­)
QPS
HIGH
LOW
Amount
(
kgs)
Volume
(
1000m
3)
Use
Rate
(
kg/
1000m
3)

1,242
­
446
87
­
709
709
709
35
20
145
­
­
­
­
145
145
145
7
20
168,283
­
128,283
­
­
40,000
40,000
40,000
1,998
20
169,670
169,670
40,941
40,854
40,854
40,854
40,854
40,854
2,040
20
0%
0%
76%
76%
76%
76%
76%
76%
71%
17%

Low
EPA
High
Low
High
Low
HIGH
LOW
26
20
100%
100%
0
0
100%
100%

20
20
100%
100%
0
0
100%
100%

20
20
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
of
Product
Loss
per
1000
m
3
(
US$/
1000m)
Loss
per
Kg
of
MeBr
(
US$/
kg)
Loss
as
a
%
of
Gross
Revenue
Loss
as
a
%
of
Net
Operating
Revenue
No
No
Yes
0
No
1
No
No
Yes
0
No
1
No
No
Yes
0
No
1
Notes
Conversion
Units:
1
Pound
=
0.453592
Kilograms
0.02831685
1,000
cubic
meters
Most
Likely
Impact
Value:
High
24%
Low
77%
Not
Available
%
of
Average
Volume
Requested:
Research
Amount
(
kgs)

0
Average
Volume
in
the
US:

Est.
40,000
kgs
2001
&
2002
Average
Use
Quarantine
and
Pre­
Shipment
Regional
Volume
NATIONAL
COUNTRY
HAM
ASSOCIATION
Use
Rate
(
kg/
1000m
3)

2007
Amount
of
Request
HAM
ASSOCIATION
HAM
ASSOCIATION
TOTAL
OR
AVERAGE
Adjustments
to
Requested
Amounts
NAHUNTA
PORK
CENTER
AMERICAN
ASSOCIATION
OF
MEAT
PROCESSORS
AMERICAN
ASSOCIATION
OF
MEAT
PROCESSORS
2007
Nomination
Options
Nomination
Amount
%
Reduction
from
Initial
Request
NAHUNTA
PORK
CENTER
HAM
ASSOCIATION
NATIONAL
COUNTRY
HAM
ASSOCIATION
NAHUNTA
PORK
CENTER
AMERICAN
ASSOCIATION
OF
MEAT
PROCESSORS
NATIONAL
COUNTRY
HAM
ASSOCIATION
Other
Considerations
NATIONAL
COUNTRY
HAM
ASSOCIATION
NAHUNTA
PORK
CENTER
AMERICAN
ASSOCIATION
OF
MEAT
PROCESSORS
HAM
ASSOCIATION
Subtractions
from
Requested
Amounts
(
kgs)

1,000
cu
ft
=

Other
Issues
(%)
Key
Pest
Distribution
(%)
Adopt
New
Fumigants
Dichotomous
Variables
(
Y/
N)

Methyl
Bromide
Critical
Use
Exemption
Process
1/
28/
2005
2007
Bromide
Usage
Numerical
Index
(
BUNI)
HAM
No
technically
feasible
alternatives
available
(%)
Combined
Impacts
Time,
Quality,
or
Product
Loss
Combined
Impacts
Adjustment
(
kgs)
Marginal
Strategy
Phosphine
not
registered
for
mites
or
in
NC.

MOST
LIKELY
IMPACT
VALUE
Economic
Analysis
U.
S.
Pork
14
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.
2007
Amount
of
Request
 
The
2007
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.
2007
Nomination
Options
 
2007
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,
2007
Request
 
Subtractions
from
Requested
Amounts,
2007
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
2007
request
from
an
applicant's
2002
CUE
application
compared
with
the
2007
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
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2007
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
2007
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
U.
S.
Pork
15
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
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
2007
 
Use
rate
in
pounds
per
thousand
cubic
feet,
2007,
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
2007
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.
Adaptation
/
Transition
­
Estimate
of
the
percentage
of
the
weighted
usage
that
can
be
transitioned
to
a
marginal
strategy.
This
estimate
is
for
areas
of
the
country
where
some
processors
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
22.
Qualifying
Volume
­
Qualifying
volume
(
1000
cubic
meters)
is
calculated
by
multiplying
the
adjusted
volume
by
the
combined
impacts.
23.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
volume
by
the
use
rate.
24.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
25.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
26.
Total
U.
S.
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
27.
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.
28.
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.
29.
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.
30.
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.
31.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
32.
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.
33.
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.
34.
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.
35.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
36.
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.
U.
S.
Pork
16
37.
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.
38.
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.
39.
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.
40.
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.
41.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
U.
S.
Pork
17
APPENDIX
B.
Description
of
Dry­
curing
Pork
in
the
US.

Curing
is
a
method
of
preserving
meat
that
prevents
harmful
microorganisms
from
developing.
Two
curing
methods
have
been
developed
 
wet
(
or
brine)
curing
and
dry
curing.
In
wet
curing,
the
curing
ingredients
are
mixed
with
boiling
water
to
form
"
pickling"
brine.
In
dry
curing,
the
ingredients
are
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
days
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
considerable
pest
pressure
from
insects
such
as
the
ham
skipper,
the
red
legged
ham
beetle,
and
mites.
These
insects
infest
and
feed
on
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
pest
pressure.
In
addition,
most
of
the
curing
facilities
are
located
near
slaughter
houses
and
feed
lots,
which
often
support
residual
populations
of
insects
that
feed
and
breed
on
dry
meats.

Steps
in
the
Curing
Process
U.
S.
Pork
18
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
°
F
(
3.3
°
C)
with
low
humidity.
Sometime
between
days
42
°
F
 
50
°
F
(
4.4
°
C
­
10
°
C),
the
salt
and
sugar
are
scraped
and
rubbed
off
of
the
ham.
In
this
room,
the
low
temperatures
and
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
°
F
 
55
°
F
(
10
°
C
­
12.8
°
C)
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
º
F
­
90
º
F
(
21
°
C
 
32
°
C)
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
insect
and
mite
infestation.
It
is
at
this
stage
that
the
application
of
MB
is
necessary.
U.
S.
Pork
19
APPENDIX
C.
2006
Methyl
Bromide
Reconsideration
for
Rice
Mills
Overview
of
the
US
Nomination
The
U.
S.
has
requested
135.742
metric
tons
of
methyl
bromide
for
use
on
uncooked
(
dry
cured
or
`
country')
hams
for
2006.
MBTOC
was
unable
to
make
a
recommendation
for
this
sector.

Currently
there
are
no
viable
alternatives
to
methyl
bromide
for
the
dried
meat
industry:
phosphine
does
not
control
mites
(
a
major
pest
affecting
this
sector)
and
heat
would
alter
the
product.
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
MB,
making
these
alternatives
technically
and/
or
economically
infeasible.
Phosphine,
alone
or
in
combination
with
carbon
dioxide
does
not
control
mites,
a
major
pest
on
cured
hams.
­
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
because
they
will
only
reinfest
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
U.
S.
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.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
certain
commodities
and
structures,
such
as
cereal
mills.
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
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
U.
S.
Pork
20
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.

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).

In
order
to
address
this
concern,
USG
has
requested
location
information
from
the
post­
harvest
sector
participants.
The
forms
have
begun
to
come
in
from
the
applicants
and
are
currently
under
review.
When
the
analysis
is
complete
it
will
be
forwarded
to
MBTOC.

It
has
been
difficult
to
determine
the
amount
of
methyl
bromide
used
historically
in
this
sector.
Some
data
have
been
supplied
by
applicants1:

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
There
are
currently
no
alternatives
to
methyl
Bromide
in
Ham
fumigation.
Phosphine,
alone
and
in
combination
with
carbon
dioxide,
does
not
control
mites,
a
major
pest
in
cured
pork
products.
Additionally,
according
to
the
phosphine
label,
the
state
of
North
Carolina
has
further
restricted
1
Data
for
only
one
company.
Given
the
small
share
of
the
market
for
dry­
cured
pork
products
represented
by
the
reporting
company,
these
data
cannot
be
taken
as
representative.
U.
S.
Pork
21
the
use
of
this
alternative.
According
to
state
regulations,
phosphine
may
only
be
used
to
control
rats
and
mice,
but
not
insects.

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
and
cannot
be
sold.
The
law
is
part
of
the
Federal
Food,
Drug,
and
Cosmetic
Act
and
available
on
the
World
Wide
Web
at:
http://
www.
cfsan.
fda.
gov/~
dms/
dalbook.
html).
Another
source
for
the
Food,
Drug,
and
Cosmetics
Act
can
be
found
at:
http://
www.
fda.
gov/
opacom/
laws/
fdcact/
fdcact4.
htm
Meat
Inspections
are
through
the
Food
Safety
and
Inspection
Service
(
FSIS)
of
the
United
States
Department
of
Agriculture
(
USDA).
Under
authority
of
the
Federal
Meat,
Poultry
and
Egg
Products
Inspection
Acts,
FSIS
inspects
and
monitors
all
meat,
poultry
and
egg
products
sold
in
interstate
and
foreign
commerce
to
ensure
compliance
with
mandatory
U.
S.
food
safety
standards
and
inspection
legislation.
http://
www.
fsis.
usda.
gov/
regulations_&_
policies/
federal_
inspection_
programs/
index.
asp
Establishments
have
the
option
to
apply
for
Federal
or
State
inspection.
Under
the
agreement,
a
State's
program
must
enforce
requirements
"
at
least
equal
to"
those
imposed
under
the
Federal
Meat
and
Poultry
Products
Inspection
Acts.
However,
product
produced
under
State
inspection
is
limited
to
intrastate
commerce.
FSIS
provides
up
to
50%
of
the
State's
operating
funds,
as
well
as
training
and
other
assistance.

http://
www.
fsis.
usda.
gov/
regulations_&_
policies/
state_
inspection_
programs/
index.
asp
Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
We
have
not
been
provided
by
MBTOC
with
information
on
their
technical
assessment
of
the
performance
of
alternatives,
ortheir
economic
assessment
on
the
impact
of
converting
to
alternatives.
To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
higher
yield
losses,
longer
plant
back
intervals,
the
economic
feasibility
if
key
market
windows
are
missed,
and
the
economic
impact
of
a
20%
transition
to
alternatives
including
estimates
of
management
costs
for
more
intensive
programs
and
how
the
impact
of
less
reliable
alternatives
is
calculated.
The
sources
of
estimates
of
the
extent
of
pest
pressure
should
describe
the
rationale
for
using
other
estimates,
a
description
of
the
questions,
species
being
surveyed
and
quantitative
levels
used.

U.
S.
2006
nomination
In
responding
to
MBTOC
concerns
USG
has
developed
some
information
suggesting
that
less
methyl
bromide
is
needed
in
this
sector
than
previously
thought.
Accordingly,
USG
is
submitting
an
amended
request
for
this
sector
of
40.854
metric
tons
of
methyl
bromide,
a
reduction
to
less
than
1/
3
of
the
previously
requested
amount.
U.
S.
Pork
22
Citations
Bell,
C.
H.
2000.
Fumigation
in
the
21st
Century.
Crop
Protection,
19:
563­
69.
