UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Evaluation
of
the
Ability
of
Sulfuryl
Fluoride
(
ProFume
 
)
to
Replace
Methyl
Bromide
in
Post­
Harvest
Uses
FROM:
Colwell
A.
Cook,
Entomologist
Biological
Analysis
Branch
David
Donaldson,
Economist
Economic
Analysis
Branch
THRU:
Richard
Keigwin,
Acting
Director
Biological
and
Economical
Analysis
Division
Office
of
Pesticide
Programs
TO:
Drusilla
Hufford,
Director
Stratospheric
Protection
Division
Office
of
Air
and
Radiation
SUMMARY
This
analysis
was
conducted
in
support
of
the
Office
of
Air
and
Radiation's
(
OAR)
proposed
rulemaking
for
allocation
of
methyl
bromide
for
critical
uses.
In
the
proposed
rule
for
the
2006
allocation
of
methyl
bromide
post­
harvest
critical
use
exemptions,
the
Agency
has
proposed
a
reduction
of
methyl
bromide
in
the
post­
harvest
sector
due
to
the
registration
of
sulfuryl
fluoride
for
some
of
these
uses.
The
facilities
included
in
these
uses
are
rice
mills,
flour
mills,
food
processing
facilities,
and
pet
food
facilities.
Dow
AgroSciences,
the
sulfuryl
fluoride
registrant,
submitted
data
and
comments
in
response
to
the
proposed
rule
which
they
believe
support
a
reduction
in
the
amount
of
new
production
of
methyl
bromide
allocated
in
2006.

The
reduction
of
methyl
bromide
for
the
post­
harvest
uses
proposed
in
the
2006
allocation
rule
is
reasonable
based
on
broader
registration
on
use
sites
and
commodities
for
ProFume
 
,
more
state
registrations,
and
efficacy
and
economic
data
for
sulfuryl
fluoride.
2
BIOLOGICAL
CONSIDERATIONS
In
January
2004,
USEPA
registered
sulfuryl
fluoride
(
ProFume
 
)
as
an
alternative
to
methyl
bromide
for
use
in
structures
and
mills
of
cereal
grains,
dried
fruit
and
tree
nuts.
In
May
of
2005,
the
State
of
California
also
registered
sulfuryl
fluoride
for
these
uses.
In
July
2005,
USEPA
expanded
the
sulfuryl
fluoride
label
by
increasing
sites
to
include
food
processing
facilities
and
more
commodities.
New
York
was
the
last
state
to
register
this
product
in
December
2005.

Sulfuryl
fluoride
is
unique
in
that
it
allows
for
"
precision
fumigation."
The
concentration
of
Profume
 
is
adjusted
by
a
computer
program,
the
Profume
 
Fumiguide.
Major
aspects
determine
the
concentration
of
sulfuryl
fluoride
needed
for
fumigation.
They
are:
1.
Pests
2.
Level
of
control
(
i.
e.
post­
embryonic
or
all
life
stages,
including
eggs)
3.
Temperature
(
requires
higher
gas
concentration
as
temperature
decreases)
4.
Time
of
Exposure
(
if
a
miller
wants
to
decrease
time,
the
concentration
can
be
increased
to
accomplish
this)
5.
Half­
life
of
fumigant
Studies
available
to
the
Agency
(
submitted
by
Dow
AgroSciences
in
addition
to
published
literature)
demonstrate
that
at
warm
temperatures,
sulfuryl
fluoride
is
as
efficacious
on
stored
product
pests
as
methyl
bromide.
These
data
are
from
laboratory
bioassays
and
field
studies
using
containers
and
traps.
Containers
with
a
known
number
of
target
pests
of
different
life
stages
are
often
set
out
during
fumigations
and
mortality
is
recorded
after
fumigation.
Various
traps
are
set
out
in
facilities
to
help
monitor
adult
insect
pest
populations.
One
can
use
trap
catch
data
can
to
infer
kill
of
larvae
and
pupae
based
on
the
number
of
days
or
weeks
no
adults
are
trapped,
given
that
if
the
pupae
or
larvae
had
survived
the
fumigation
they
would
become
adults
within
a
few
days.

Published
literature
reports
that
at
lower
temperatures
a
greater
concentration
of
sulfuryl
fluoride
is
necessary
to
kill
eggs
of
the
stored
product
insect
pests.
This
is
supported
by
the
ProFume
 
Fumiguide.
If
control
of
all
life
stages
is
selected
a
higher
concentration
of
sulfuryl
fluoride
or
increased
time
of
exposure
is
required
than
if
only
post­
embryonic
stages
is
selected.
In
addition,
as
temperature
decreases,
a
higher
concentration
of
sulfuryl
fluoride
is
necessary
to
kill
eggs.

Historically,
the
food
processing
industry's
pest
management
culture
pursues
the
practice
of
targeting
all
life
stages
of
any
pest,
with
their
focus
on
eliminating
the
eggs,
which
is
the
point
source
of
a
new
infestation.
Dow
AgroSciences
is
proposing
to
target
only
the
post­
embryonic
stages
of
these
pests
which
would
in
turn
leave
the
eggs.

Many
of
the
studies
available
to
the
Agency
do
not
always
provide
the
concentration
of
the
fumigant,
the
amount
of
exposure
time,
or
the
temperatures
at
which
the
fumigations
took
place.
Some
studies
do
not
compare
sulfuryl
fluoride
with
methyl
bromide.
This
increases
the
uncertainty
of
this
analysis.
3
USE
CONSTRAINTS
The
facilities
included
in
this
analysis
are
rice
mills,
flour
mills,
food
processing
facilities,
and
pet
food
facilities.
The
Profume
 
label
states
that
all
these
facilities
can
be
fumigated
with
sulfuryl
fluoride.
If
the
product
is
not
listed
on
the
label
as
a
commodity
that
can
be
directly
(
intentionally)
fumigated,
only
incidental
fumigation
is
allowed.
Incidental
fumigation
of
commodities
has
been
defined
by
the
Agency
as
"
fumigation
of
negligible
amounts
of
a
commodity
due
to
their
presence
in
a
different
targeted
use
site."
1
The
intent
is
to
allow
small
amounts,
or
traces,
of
processed
foods
that
remain
on
the
equipment
to
be
fumigated
as
a
result
of
space
fumigation.
It
is
understood
that
food
items
are
removed
from
the
premises
during
fumigation.
"
In
these
instances
the
label
would
require
all
finished
product
and
the
majority
of
the
facility's
bagged
ingredients
to
be
removed
from
the
premises."
1
Many
food
processing
facilities
occupy
one
big
room
and
therefore
do
not
have
the
space
to
separate
products
and
ingredients
from
the
processing
equipment
portions
of
the
plant.

Pet
food
is
considered
a
processed
food,
and
is
not
listed
in
the
commodities
on
the
Profume
 
label.
Cake
mixes
and
other
processed
foods,
such
as
cookies,
pasta,
etc.
will
also
face
these
constraints,
i.
e.
they
can
only
receive
incidental
fumigation.
However,
of
the
facilities
that
process
food,
only
the
Pet
Food
Institute
has
included
the
commodity
in
their
methyl
bromide
CUE
application.
About
30­
40%
of
these
pet
food
facilities
are
not
able
to
separate
ingredients
and
manufactured
products
from
the
equipment
during
space
fumigation.

COST
ANALYSIS
This
section
describes
the
costs
of
sulfuryl
fluoride
use
in
structural
fumigation
in
mills,
pet
food
processing
facilities,
and
food
processing
facilities
based
on
the
biological
considerations,
described
above.

The
cost
of
structural
fumigation
with
sulfuryl
fluoride
is
highly
variable.
Total
fumigation
costs
result
from
the
cost
of
the
fumigant,
labor,
equipment
used
in
the
fumigation
process,
and
facility
downtime.
Costs
vary
by
temperature
and
targeted
control
level,
which
influence
the
amount
of
fumigant
product
used.
The
Agency
lacks
these
data
for
the
submitted
studies.
This
analysis
relies
on
potential
fumigation
practices,
which
increases
the
uncertainty
of
the
estimates.

Limitations
of
the
analysis
include
but
are
not
limited
to:
1)
limited
data
available
to
the
Agency
describing
the
cost
of
fumigant
application
and
the
cost
of
fumigant
product;
2)
costs
of
facility
heating
were
not
available,
which
could
be
used
to
offset
the
high
use
rates
of
sulfuryl
fluoride
where
all
pest
life
stages
are
controlled;
3)
only
limited
efficacy
data
are
available
for
sulfuryl
fluoride.

Given
the
limited
data
submitted
to
the
Agency,
an
analysis
was
conducted
based
on
the
following
assumptions:

1
Hazen,
Susan
B.,
Letter
to
Pet
Food
Institute
dated
November
8,
2005.
4
1.
Fumigation
time
for
both
methyl
bromide
and
sulfuryl
fluoride
is
assumed
to
be
1
day
for
preparation,
1
day
for
fumigation,
and
1day
for
off­
gassing.
2.
Efficacy
of
methyl
bromide
and
sulfuryl
fluoride
are
similar
within
the
range
of
normal
fumigation
temperatures
at
the
post­
embryonic
stage,
but
the
quantity
of
sulfuryl
fluoride
required
is
significantly
higher
when
controlling
all
life
stages,
especially
at
lower
temperatures
3.
The
total
expenditure
for
sulfuryl
fluoride
is
higher
at
lower
temperatures
due
to
higher
application
rates.
These
costs
can
be
offset
by
heating
the
structure.
However,
we
do
not
have
data
covering
heating
costs.
4.
Labor
and
equipment
costs
are
assumed
to
be
the
same
for
structural
fumigation
with
methyl
bromide
and
sulfuryl
fluoride.

RESULTS
OF
THE
COST
ANALYSIS
The
information
available
suggests
that
sulfuryl
fluoride
structural
fumigation
costs
are
comparable
to
methyl
bromide
at
for
the
temperatures
evaluated
(
85,
80,
and
75
degrees
Fahrenheit)
when
targeting
post­
embryonic
pest
life
stages.
Therefore,
use
of
sulfuryl
fluoride
appears
to
be
economically
feasible
in
these
instances
and
temperatures.

When
targeting
pests
in
all
life
stages,
sulfuryl
fluoride
costs
are
greater
than
methyl
bromide
and
vary
by
temperature
level.
At
85
degrees
Fahrenheit
sulfuryl
fluoride
expenditures
are
37%
greater
than
for
methyl
bromide
(
for
fumigant
only),
at
80
degrees
Fahrenheit
sulfuryl
fluoride
expenditures
are
68%
greater,
and
at
75
degrees
Fahrenheit
sulfuryl
fluoride
expenditures
are
94%
greater
(
shown
in
Table
1).
The
Agency
does
not
have
data
representing
sulfuryl
fluoride
application
rates
at
lower
than
75
degrees
Fahrenheit.

Due
to
increased
costs
of
fumigation,
the
adoption
of
sulfuryl
fluoride
may
not
be
feasible
for
certain
facilities
having
low
profit
margins.
The
Agency
estimated
in
2001
that
flour
and
rice
mills,
which
make
up
about
80%
of
fumigated
facilities,
have
net
profit
margins
of
approximately
1.3%
(
flour
mills)
and
approximately
3.1%
(
rice
mills).

Table
1,
Cost
per
1,000
cubic
feet
of
structural
fumigation
Post­
Embryonic
Control
Control
at
all
Life
Stages
Temperature
Methyl
Bromide
Sulfuryl
Fluoride
Percent
Difference
Methyl
Bromide
Sulfuryl
Fluoride
Percent
Difference
85
degrees
Fahrenheit
$
29.42
$
30.54
3%
$
29.42
$
40.23
37%

80
degrees
Fahrenheit
$
29.42
$
30.94
5%
$
29.42
$
49.51
68%

75
degrees
Fahrenheit
$
29.42
$
31.35
7%
$
29.42
$
57.19
94%

Source:
Data
are
from
comments
submitted
to
the
Agency
on
the
proposed
methyl
bromide
allocation
rule.
Notes:
1.
Based
on
a
12
hour
fumigation
with
sulfuryl
floride.
2.
Target
pests
in
structural
fumigation
are
primarily
beetles.
3.
Calculations
were
made
using
fumigant
costs
based
on
wholesale
prices.
5
4.
Calculations
are
based
on
2
fumigations
per
year.
6
CONCLUSIONS
Sulfuryl
fluoride
may
be
a
feasible
alternative
to
methyl
bromide
for
post­
harvest
commodity
fumigation
in
some
cases,
but
in
other
cases
may
not
be
due
to
efficacy,
regulatory,
and
cost
considerations.
Based
on
the
above
analysis,
which
was
conducted
using
information
from
public
comments
for
the
proposed
methyl
bromide
allocation
rule
and
Critical
Use
Exemption
(
CUE)
applications,
the
Agency
can
reasonably
support
the
reduction
of
methyl
bromide
for
the
post­
harvest
uses
proposed
in
the
2006
allocation
rule.

REFERENCE:
2004
CUE
Application;
The
Risk
Management
Association's
Annual
Statement
Studies
2001­
2002.
Public
Comments
on
the
Proposed
Methyl
Bromide
Allocation
Rule.
