METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
POST
HARVEST
USE
FOR
FOOD
PROCESSING
PLANTS
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
for
Food
Processing
Plants
(
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.
Food
Facilities
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.
Food
Facilities
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
for
Food
Processing
Plants.................................................
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
Requested
in
the
Year(
s)
Nominated
for
Food
Processing
Plants
................................................................................
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.....................
9
8.
Key
Pests
for
which
Methyl
Bromide
is
Requested
.........................................................
9
9.
Summary
of
the
Circumstances
in
which
the
Methyl
Bromide
is
Currently
Being
Used
.............................................................................................................................................
10
10.
List
Alternative
Techniques
that
are
being
Used
to
Control
Key
Target
Pest
Species
in
this
Sector........................................................................................................................
11
PART
C:
TECHNICAL
VALIDATION...................................................................................
13
11.
Summarize
the
Alternative(
s)
Tested,
Starting
with
the
Most
Promising
Alternative(
s).......................................................................................................................
13
12.
Summarize
Technical
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances
......................................................................................
15
PART
D:
EMISSION
CONTROL
...........................................................................................
16
13.
How
has
this
Sector
Reduced
the
Use
and
Emissions
of
Methyl
Bromide
in
the
Situation
of
the
Nomination?..............................................................................................
16
PART
E:
ECONOMIC
ASSESSMENT...................................................................................
17
14.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
.................
17
15.
Summarize
Economic
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances
......................................................................................
17
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives.....................................
19
PART
F:
FUTURE
PLANS.....................................................................................................
21
16.
Provide
a
Detailed
Plan
Describing
how
the
Use
and
Emissions
of
Methyl
Bromide
will
be
Minimized
in
the
Future
for
the
Nominated
Use.
..................................................
21
17.
Provide
a
Detailed
Plan
Describing
what
Actions
will
be
Undertaken
to
Rapidly
Develop
and
Deploy
Alternatives
for
this
Use....................................................................
21
17.1.
Research.....................................................................................................................
21
17.2.
Registration
...............................................................................................................
23
17.2.1.
Sulfuryl
Fluoride
....................................................................................................
23
18.
Additional
Comments
...................................................................................................
24
19.
Citations.........................................................................................................................
26
Bibliography........................................................................................................................
27
APPENDIX
A.
Supporting
Data.
............................................................................................
29
U.
S.
Food
Facilities
iv
APPENDIX
B.
Published
Performance
Data.
........................................................................
30
APPENDIX
C.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
.................................
32
APPENDIX
D.
.
2006
Methyl
Bromide
Reconsideration
for
Rice
Mills
................................
36
List
of
Tables
PART
A:
SUMMARY
................................................................................................................
5
Table
4.1:
Methyl
Bromide
Nominated
for
Food
Processing
Plants.......................................
5
Table
A.
1:
Executive
Summary................................................................................................
7
Table
6.1:
Methyl
Bromide
Consumption
for
the
Past
5
Years
and
the
Amount
Requested
in
the
Year(
s)
Nominated
For
Food
Processing
Plants
....................................................
7
PART
B:
SITUATION
CHARACTERISTICS
AND
METHYL
BROMIDE
USE.....................
9
Table
8.1:
Key
Pests
for
Methyl
Bromide
Request..................................................................
9
Table
B.
1:
Characteristic
of
Sector
­
Food
Processing
Plants:
Flour
Mills,
Bakeries,
and
Pet
Food
Facilities....................................................................................................................
9
Table
B.
2:
Characteristics
of
Sector
­
Food
Processing
Plants:
Rice
Mills...........................
10
Table
9.1:
(
a)
Food
Processing
Plants
....................................................................................
10
Table
9.1:
(
b)
Fixed
Facilities
.................................................................................................
11
PART
C:
TECHNICAL
VALIDATION...................................................................................
13
Table
11.1:
Summary
of
the
Alternatives
Tested...................................................................
13
Table
11.2:
Summary
of
Review
or
Position
Papers
concerning
Alternatives
for
Stored
Product
Pests
...................................................................................................................
14
Table
12.1:
Summary
of
Technical
Reason
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................
15
Table
12.2:
Comparison
of
Alternatives
to
Methyl
Bromide
Fumigation
............................
16
PART
D:
EMISSION
CONTROL
...........................................................................................
16
PART
E:
ECONOMIC
ASSESSMENT...................................................................................
17
Table
15.1:
Summary
of
Economic
Reasons
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................
17
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
for
Rice
Miller's
Association
..........................................................................................................................................
19
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
for
Bakeries
......................
19
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
for
Pet
Food
Institute
.......
20
PART
F:
FUTURE
PLANS.....................................................................................................
21
Appendix
A
­
Table
9.1(
a):
Summary
of
the
Circumstances
of
Current
Methyl
Bromide
Use
In
Pet
Food
Processing
Plants..................................................................................
29
Appendix
A
­
Table
9.1(
B):
Summary
of
the
Circumstances
of
Current
Methyl
Bromide
Use
In
Pet
Food
Processing
Plants
­
Fixed
Facilities:
Pet
Food
Institute......................
29
Appendix
B
­
Table
1:
Effect
of
temperature
on
concentration
and
time
thresholds
for
some
pests
of
stored
products.
(
From:
Bell,
C.
H.
2000)
.........................................................
30
Appendix
B
­
Table
2:
Concentration­
Time
Product
recommendations
by
National
Pest
Management
Association
................................................................................................
31
Page
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
in
Food
Processing
Plants
(
Prepared
in
2005)

3.
SITUATION
OF
NOMINATED
METHYL
BROMIDE
USE
This
sector
includes
rice
mills,
flour
mills,
pet
food
manufacturing
facilities,
and
a
few
bakeries.
Primarily
this
sector
is
treating
only
the
portions
of
the
facilities
that
contain
electronic
components
and
have
machinery
with
copper
and
copper
alloy
parts.
These
facilities
are
under
intense
pressure
from
many
insect
pests.
The
flour
millers
and
the
bakeries
in
this
sector
do
not
target
any
of
their
commodities
to
be
fumigated
with
methyl
bromide;
however,
the
rice
millers
and
the
pet
food
manufacturers
may
fumigate
some
products
with
methyl
bromide.

4.
METHYL
BROMIDE
NOMINATED
FOR
FOOD
PROCESSING
PLANTS
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
FOR
FOOD
PROCESSING
PLANTS
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
VOLUME
(
1000
M
3)

2007
401,889
20,689
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
nomination
is
only
for
those
facilities
where
the
use
of
alternatives
is
not
suitable.
In
U.
S.
food
processing
plants
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
methyl
bromide,
making
these
alternatives
technically
and/
or
economically
infeasible.
­
Geographic
distribution
of
the
facilities:
some
facilities
are
situated
in
areas
where
key
pests
usually
occur
at
lower
levels,
such
as
those
located
in
the
northern
part
of
the
U.
S.
In
such
cases,
the
U.
S.
is
only
nominating
a
CUE
for
facilities
where
the
key
pest
pressure
is
moderate
to
high.
­
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.
­
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).
Further,
the
corrosive
nature
of
phosphine
on
certain
metals
Page
6
prevents
its
use
in
mechanical
and
electrical
areas
of
the
facilities.
Additionally,
both
phosphine
and
sulfuryl
fluoride
are
temperature
sensitive.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
portions
of
this
sector.
California,
New
York
and
Alaska
have
not
registered
sulfuryl
fluoride
at
the
time
of
this
analysis.
Further,
it
will
take
some
time
for
applicators
to
be
trained
in
the
use
of
this
chemical
and
for
its
incorporation
into
a
pest
control
program.
A
registration
decision
concerning
the
establishment
of
sulfuryl
fluoride
tolerances
on
other
processed
food
ingredients
in
a
treated
facility
is
still
pending.
­
Delay
in
plant
operations:
e.
g.,
the
use
of
some
methyl
bromide
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.

Over
the
last
decade,
food
processing
facilities
in
the
United
States
have
reduced
the
number
of
methyl
bromide
fumigations
by
incorporating
many
of
the
alternatives
identified
by
MBTOC.
The
most
critical
alternative
implemented
is
IPM
strategies,
especially
sanitation,
in
all
areas
of
a
facility.
Plants
are
now
being
monitored
for
pest
populations,
using
visual
inspections,
pheromone
traps,
light
traps
and
electrocution
traps.
When
insect
pests
are
found,
plants
will
attempt
to
contain
the
infestation
with
treatments
of
low
volatility
pesticides
applied
to
both
surfaces
and
cracks
and
crevices.
These
techniques
do
not
disinfest
a
facility
but
are
critical
in
monitoring
and
managing
pests.
However,
when
all
these
methods
fail
to
control
a
pest
problem,
facilities
will
resort
to
phosphine,
heat,
and
if
all
else
fails,
to
methyl
bromide.

Many
facilities
in
the
United
States
also
are
using
both
phosphine
and
heat
treatments
to
disinfest
at
least
portions
of
their
plants.
Phosphine,
alone
and
in
combination
with
carbon
dioxide,
is
often
used
to
treat
both
incoming
grains
and
finished
products.
Unfortunately,
phosphine
is
corrosive
to
copper,
silver,
gold
and
their
alloys.
These
metals
are
critical
components
of
both
the
computers
that
run
the
machines
as
well
as
some
of
the
machines
themselves.
Therefore,
phosphine
is
not
feasible
in
all
areas
of
food
processing
facilities.
Additionally,
phosphine
requires
more
time
to
kill
insect
pests
than
does
methyl
bromide,
so
plants
need
to
be
shut
down
longer
to
achieve
mortality,
resulting
in
economic
losses.
There
are
also
reports
of
stored
product
pests
becoming
resistant
to
phosphine
(
Taylor,
1989;
Bell,
2000;
Mueller,
2002).

Heat
treatments
have
a
number
of
problems
in
this
industry.
Not
all
areas
of
a
plant
can
be
efficiently
treated
with
heat.
Some
food
substances,
for
instance
oils
and
butters
will
become
rancid
with
heat
treatments.
Not
all
finished
food
products
can
be
heated
for
the
length
of
time
heat
is
required
for
efficient
kill
of
pests.
In
addition,
geography
of
the
United
States
plays
a
crucial
role
in
the
use
of
heat
treatments.
Food
processing
plants
in
the
northern
United
States
will
experience
winters
with
several
weeks
of
sustaining
temperatures
of
­
32
°
to
­
35
°
C
(­
30
°
to
­
25
°
F).
In
these
areas
plants
have
heaters
and
the
power
plants
have
the
capacity
to
supply
excess
power
as
needed.
However,
the
southern
and
parts
of
the
western
zones
of
the
United
States
are
geographically
quite
different.
Winter
temperatures
there
seldom
reach
 
1.2
°
C
(
30
°
F)
and
when
temperatures
should
fall
that
low,
it
is
typically
for
only
a
few
hours
one
night.
For
many
winters,
these
areas
of
the
U.
S.
don't
freeze
at
all.
Subsequently,
these
facilities
do
not
have
heaters,
nor
do
the
power
plants
have
enough
power
to
allow
them
to
heat
such
large
areas
and
sustain
the
temperatures
necessary
for
an
effective
kill
of
pest
populations.
Still,
many
Page
7
southern
and
western
facilities
use
heat
treatments
as
a
spot
treatment
whereas
the
northern
facilities
can
use
heat
treatments
more
extensively.

Sulfuryl
fluoride
was
registered
in
the
U.
S.
in
January
of
2004
for
rice
mills
and
flour
mills.
There
are
some
constraints
with
this
new
fumigant:
it
has
not
been
registered
in
California
or
New
York;
it
is
temperature
dependent;
and
it
requires
extensive
training
of
the
applicators
to
proficiently
use
the
computerized
fumigation
guide.
Several
mills
used
sulfuryl
fluoride
this
summer
to
fumigate
their
facilities.
The
industry
is
trying
to
incorporate
this
new
fumigant
into
their
best
management
practices.

TABLE
A.
1:
EXECUTIVE
SUMMARY*

RICE
MILLER'S
ASSOCIATION
BAKERIES
PET
FOOD
INSTITUTE
NORTH
AMERICAN
MILLER'S
ASSOCIATION
2007
Requested
Amount
(
kg)
200,488
23,814
44,906
317,514
2007
Nominated
Amount
*
(
kg)
64,150
23,814
39,275
274,650
*
See
Appendix
C
for
complete
description
of
how
the
nominated
amount
was
calculated.

6.
METHYL
BROMIDE
CONSUMPTION
FOR
PAST
5
YEARS
AND
AMOUNT
REQUESTED
IN
THE
YEAR(
S)
NOMINATED
FOR
FOOD
PROCESSING
PLANTS
:

TABLE
6.1:
METHYL
BROMIDE
CONSUMPTION
FOR
THE
PAST
5
YEARS
AND
THE
AMOUNT
REQUESTED
IN
THE
YEAR(
S)
NOMINATED
FOR
FOOD
PROCESSING
PLANTS
HISTORICAL
USE
1,2
REQUESTED
USE
For
each
year
specify:
1998
1999
2000
2001
2002
2003
2007
Amount
of
MB
(
kg)
688,441
676,668
634,234
561,276
535,596
565,567
586,721
Volume
Treated
(
1000
m
³
)
25,518
25,788
25,880
25,321
24,553
26,105
26,040
Formulation
of
MB
100%
100%
100%
100%
100%
100%
100%

Dosage
Rate
(
kg/
1000
m
³
)
25.43
25.02
24.32
23.14
22.75
20.98
22.86
1Best
available
estimate
of
United
States
Government
2Based
on
most
current
information.

7.
LOCATION
OF
THE
FACILITY
OR
FACILITIES
WHERE
THE
PROPOSED
CRITICAL
USE
OF
METHYL
BROMIDE
WILL
TAKE
PLACE
This
nomination
package
represents
275
food
processing
facilities
across
the
United
States.
These
facilities
are
distributed
across
the
United
States
from
subtropical
environments
of
Florida
to
the
cold
northern
areas
of
the
Great
Plains.
The
location
of
each
facility
where
methyl
Page
8
bromide
fumigations
may
take
place
was
not
requested
by
the
U.
S.
Government
in
the
forms
filled
out
by
the
applicants.
Therefore,
we
currently
do
not
have
a
complete
listing
of
the
actual
addresses
for
each
facility.
However,
we
have
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.
Page
9
PART
B:
SITUATION
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
8.
KEY
PESTS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
TABLE
8.1:
KEY
PESTS
FOR
METHYL
BROMIDE
REQUEST
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
completely
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
completely
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
completely
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
B.
1:
CHARACTERISTIC
OF
SECTOR
­
FOOD
PROCESSING
PLANTS:
FLOUR
MILLS,
BAKERIES,
AND
PET
FOOD
FACILITIES
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
Harvest
or
Raw
Material
In
X
X
X
X
X
X
X
X
X
X
X
X
Fumigation
Schedule
(
MB)*
X
X
Retail
Target
Market
Window
Not
Applicable
*
Plants
in
the
southern
United
States
may
fumigate
twice
a
year;
plants
in
the
northern
United
States
may
fumigate
once
every
3
years.
However,
fumigations
may
occur
whenever
a
population
explosion
occurs.

Although
fumigations
occur
at
anytime
a
pest
population
explosion
occurs,
usually
foodprocessing
plants
in
the
southern
and
western
areas
of
the
United
States
will
be
fumigated
with
methyl
bromide
on
3­
day
holiday
weekends
just
prior
to
the
summer
and
at
summer's
end.
This
Page
10
maximizes
efficiency
since
the
facilities
are
usually
closed
and
workers
are
not
present;
and
prior
to
and
immediately
after
very
warm
temperatures
that
increases
insect
pressure.

TABLE
B.
2:
CHARACTERISTICS
OF
SECTOR
­
FOOD
PROCESSING
PLANTS:
RICE
MILLS
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
Harvest
or
Raw
Material
In
X
X
X
X
X
X
X
X
X
X
X
X
Fumigation
Schedule
(
MB)*
Retail
Target
Market
Window
Not
Applicable
Rice
Mills
are
fumigated,
on
average,
about
5
times
a
year,
whenever
pests
are
a
problem.

Most
rice
mills
are
located
in
the
southern
areas
of
the
United
States,
which
experience
high
temperatures
year
round.
Subsequently
these
mills
are
under
extreme
insect
pressure
all
year
long.
Therefore,
the
average
number
of
fumigations
exceeds
the
average
of
the
other
members
of
this
sector.

9.
SUMMARY
OF
THE
CIRCUMSTANCES
IN
WHICH
THE
METHYL
BROMIDE
IS
CURRENTLY
BEING
USED
TABLE
9.1:
(
a)
FOOD
PROCESSING
PLANTS
CUE
MB
DOSAGE
(
Kg/
m
³
)
EXPOSURE
TIME
(
hours)
TEMP.
(
º
C)
NUMBER
OF
FUMIGATIONS
PER
YEAR
PROPORTION
OF
FACILITY
TREATED
AT
THIS
DOSE
FIXED
(
F)
MOBILE
(
M)
STACK
(
S)

Rice
Miller's
Association
32
24
variable
5
100%
*
F
Bakeries
North
America
18
24
variable
2.5
100%
F
Pet
Food
Institute
22
24
variable
<
1
Avg.
1application/
1­
2
yrs**
80%
F
North
American
Millers'
Association
19
24
variable
2.5
100
%
F
*
Unspecified
type
of
rice
is
also
fumigated
along
with
the
facilities.
**
Highly
variable.
Some
facilities
need
fumigating
2/
year,
but
other
facilities
fumigate
once
every
3­
5
years.
Page
11
TABLE
9.1:
(
b)
FIXED
FACILITIES
CUE
TYPE
OF
CONSTRUCTION
AND
APPROXIMATE
AGE
IN
YEARS
%
FACILITIES
AT
VOLUMES
(
1,000m
³
)
NUMBER
OF
FACILITIES
GASTIGHTNESS
ESTIMATE*

Rice
Miller's
Association
Combination
of
wood,
stone,
brick,
metal,
and
concrete
5%
1,416­
28,317
90+%
28,317+
22
Poor
to
very
poor
Bakeries
North
America
Combination
of
wood,
stone,
brick,
metal,
and
concrete
28,317+
11
55%
good,
27%
fair,
18%
poor
Pet
Food
Institute1
Combination
of
wood,
stone,
brick,
metal,
and
concrete
25%
1,416­
28,317
75%
28,317+
75
Good
to
poor
areas
North
American
Millers'
Association
Wood,
stone,
brick,
concrete,
metal;
some
about
100
yrs
old,
only
a
few
less
than
10
years
old
50%
<
28
50%
>
28­
142
167
10%
good,
10%
medium,
75%
poor,
5%
very
poor
*
Give
gastightness
estimates
where
possible
according
to
the
following
scale:
good
 
less
than
25%
gas
loss
within
24
hours
or
half
loss
time
of
pressure
difference
(
e.
g.
20
to
10
Pa
(
t1/
2))
greater
than
1
minute;
medium
 
25­
50%
gas
loss
within
24
hours
or
half
loss
time
of
pressure
difference
greater
than
10
seconds;
poor
 
50­
90%
gas
loss
within
24
hours
or
half
loss
time
of
pressure
difference
1­
10
second;
very
poor
 
more
than
90%
gas
loss
within
24
hours
or
a
pressure
half
loss
time
of
less
than
1
second.
1
See
Appendix
A
for
more
information.

10.
LIST
ALTERNATIVE
TECHNIQUES
THAT
ARE
BEING
USED
TO
CONTROL
KEY
TARGET
PEST
SPECIES
IN
THIS
SECTOR
Many
of
the
MBTOC
not
in
kind
alternatives
to
methyl
bromide
are
critical
to
monitoring
pest
populations
and
managing
those
populations,
but
they
do
not
disinfest
food
processing.
The
most
critical
of
these
alternatives
are
sanitation
and
IPM
strategies.
Sanitation
is
important
and
constantly
addressed
in
management
programs
(
Arthur
and
Phillips
2003).
Cleaning
and
hygiene
practices
alone
do
not
reduce
pest
populations,
but
reportedly
improve
the
efficacy
of
insecticides
or
diatomaceous
earth
(
Arthur
and
Phillips
2003).
The
principles
of
IPM
are
to
utilize
all
available
chemical,
cultural,
biological,
and
mechanical
pest
control
practices.
These
include
pheromone
traps,
electrocution
traps,
and
light
traps
to
monitor
pest
populations.
If
pests
are
found
in
traps,
then
contact
insecticides
and
low
volatility
pesticides
are
applied
in
spot
treatments
for
surfaces,
cracks
and
crevices,
or
anywhere
the
pests
may
be
hiding.
These
applications
are
intended
to
restrict
pests
from
spreading
throughout
the
facility
to
try
to
avoid
a
plant
fumigation
(
Arthur
and
Phillips
2003).
However,
IPM
is
not
designed
to
completely
eliminate
pests
from
any
given
facility
or
to
ensure
that
a
facility
remains
free
from
infestation.
Although
FDA
allows
minimal
contamination
of
food
products,
U.
S.
consumers
have
a
zero
tolerance
for
visible
insect
contamination
in
their
food
products.
While
sanitation
and
IPM
strategies
are
used
to
manage
pest
populations
and
extend
the
time
between
methyl
bromide
fumigations,
neither
is
an
acceptable
alternative
to
methyl
bromide
under
high
pest
pressure.

Many
food
processing
facilities
in
the
United
States
also
use
heat
treatments
to
reduce
insect
populations.
However,
some
areas
(
electronics
and
electrical
portions)
of
facilities
are
sensitive
to
heat.
Heat
also
causes
rancidity
in
butters
and
oils
and
denatures
proteins
that
may
be
used
in
the
ingredients,
plus,
not
all
manufactured
products
can
be
heated
to
the
temperature
or
for
the
time
required
in
order
to
get
an
effective
kill
of
insect
pests.
Some
facilities,
due
to
construction,
are
unable
to
use
heat.
There
have
been
reports
of
structural
damage
resulting
from
heat
treatments.
Facilities
in
the
southern
and
western
parts
of
the
United
States
do
not
have
heat
Page
12
sources
on
the
premises
thereby
making
heat
fumigations
impractical
without
costly
investments
that
are
not
economically
feasible.

Phosphine,
alone
and
in
combination
with
carbon
dioxide,
is
used
to
fumigate
portions
of
food
processing
facilities.
Many
facilities
treat
incoming
raw
ingredients
and
their
storage
facilities
with
phosphine,
but
the
corrosive
nature
of
phosphine
limits
its
use
throughout
the
entire
plant,
especially
in
areas
with
electronic
components.
In
the
United
States
it
is
specifically
against
the
label
(
illegal)
to
fumigate
in
areas
with
susceptible
metals
(
at:
http://
oaspub.
epa.
gov/
pestlabl/
ppls).
Phosphine
is
also
problematic
in
that
some
stored
product
pests
are
developing
resistance
to
this
chemical
(
Taylor,
1989,
Bell,
2000,
Mueller,
2002).

Food
processing
facilities
in
the
United
States
have
incorporated
sanitation,
IPM
strategies,
heat
and
phosphine
and
yet,
on
occasion,
insect
pest
populations
will
still
become
too
high
and
a
facility
will
need
to
fumigate
with
methyl
bromide.
However,
by
employing
these
alternatives,
this
sector
has
been
able
to
lengthen
times
between
methyl
bromide
applications,
thereby
reducing
the
total
amount
of
methyl
bromide.
However,
in
some
areas
of
the
country,
information
suggests
that
some
processors
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
The
assessment
of
need
was
adjusted
to
account
for
this.
Page
13
PART
C:
TECHNICAL
VALIDATION
11.
SUMMARIZE
THE
ALTERNATIVE(
S)
TESTED,
STARTING
WITH
THE
MOST
PROMISING
ALTERNATIVE(
S)

TABLE
11.1:
SUMMARY
OF
THE
ALTERNATIVES
TESTED
ALTERNATIVE
PEST
STUDY
TYPE
RESULTS
CITATION
Heat
T.
castaneum
Pilot
feed
and
flour
mills;
Insects
contained
in
plastic
boxes.
Nonuniform
heat.
Number
of
hours
to
reach
50
°
C
varied
between
the
mills
and
within
mills.
100%
mortality
at
most
locations
of
50­
60
°
C
for
52
hrs.
Old
instars
and
pupae
more
heat
tolerant
Mahroof,
et
al.
2003
Heat
T.
castaneum
Lab
Mortality
of
each
life
stage
increased
with
increase
in
temperature
and
exposure
time.
Young
larvae
most
heat­
tolerant
and
required
7.2
hr
at
>
50
°
C.
Mahroof,
et
al.
2003
Heat
and
Diatomaceous
Earth
(
DE)
T.
castaneum
&
T.
confusum
Lab
Mortality
increased
as
temperature
increased
and
decreased
as
humidity
increased.
Mortality
at
one
week
was
greater
than
initial
mortality
probably
due
to
delayed
effects
of
DE.
T.
confusum
mortality
lower
than
T.
castaneum.
Arthur
2000
Heat
and
DE
T.
confusum
2nd
&
3rd
floors
of
a
Pilot
flour
mill
Adult
insects
in
open
rings
placed
in
mill.
100%
mortality
of
beetles
in
25
hr
on
the
north
end
of
the
3rd
floor,
but
south
end
of
2nd
floor
had
only
75%
mortality
with
full
DE
and
50%
mortality
with
partial
DE
after
64
hr.
Dowdy
&
Fields
2002
DE
Ephestia
kuehniella
Lab
Efficacy
was
influenced
by
age
of
the
medium
with
DE
when
investigated
under
driest
conditions
(
58%
rh).
But
this
is
not
a
pest
of
concern
in
the
U.
S.
Nielsen
1998
Low
volatility
insecticides
T.
castaneum
&
T.
confusum
Lab
Field
collected
flour
beetles
demonstrated
varying
degrees
of
resistance
to
several
pesticides:
malathion,
chlorpyrifos,
dichlorvos,
phosphine,
but
not
to
resmethrin.
T.
castaneum
more
resistant
than
T.
confusum.
Zettler
1991
Mountain
Sagebrush
Volatiles
Rhyzopertha
dominica;
P.
interpunctella;
&
T.
castaneum
Lab
Initial
investigation
of
volatiles
from
mountain
sagebrush
demonstrated
some
activity
in
against
these
insects
in
bioassays.
No
indication
of
whether
this
is
really
a
potential
alternative
Dunkel
&
Sears
1998
Low
volatility
insecticides
T.
castaneum
&
T.
confusum
Lab
Malathion­
resistant
flour
beetles
were
susceptible
to
cyfluthrin
treated
steel
panels.
Longer
residuals
on
unpainted
panels
than
on
painted
panels
Arthur
1992
Page
14
ALTERNATIVE
PEST
STUDY
TYPE
RESULTS
CITATION
DEET
(
N,
Ndiethyl
mtoluamide
and
NEEM
(
azadirachthin)
T.
castaneum
and
others
Lab
DEET
repelled
S.
oryzae
by
99%,
T.
castaneum
by
86%,
Cryptolestes
ferrugineus
by
97%
and
O.
surinamensis
by
91%
Neem
was
less
effective
than
DEET
Hou,
et
al.
2004
TABLE
11.2:
SUMMARY
OF
REVIEW
OR
POSITION
PAPERS
CONCERNING
ALTERNATIVES
FOR
STORED
PRODUCT
PESTS
SYNOPSIS
OF
REVIEW
OR
POSITION
PAPERS
CITATION
Review
of
methyl
bromide
alternatives
for
stored
product
insects:
1)
heat:
gradients
in
buildings,
insect
refugia,
rate
can
be
problematic
due
to
structures,
some
equipment
heat
sensitive,
plastics
warp,
dust
explosions,
sugar,
oils,
butter
&
adhesives
removed,
not
all
food
products
can
be
heated;
2)
phosphine:
activity
slow,
flammability
above
concentrations
of
1.8%
by
volume,
corrosion
of
copper,
silver,
and
gold,
no
data
for
in
combination
with
CO2
and
heat;
3)
modified
atmospheres:
activity
slow,
requires
air­
tight
structures;
4)
sulfuryl
fluoride1:
eggs
require
much
higher
concentrations
than
larvae
for
control
Fields
&
White
2002
Cites
studies
on:
the
development
of
resistance
to
phosphine
in
stored
product
pests;
interaction
of
time,
temperature
and
concentration
of
performance
of
phosphine;
sulfuryl
fluoride's
difficulty
in
killing
egg
stage;
Tables
comparing
phosphine
to
methyl
bromide
(
Appendix
B,
Table
1).
Bell
2000
Theoretical
paper
based
on
a
few
lab
studies
and
small
field
crop
trials
indicating
that
traps
currently
used
for
monitoring
pest
populations
could
be
used
to
reduce
those
populations.
No
studies
on
a
commercial
scale
or
food
processing/
storage
facility
were
present.
Cox
2004
Mostly
lab
studies
on
assorted
stored
product
pests
indicate
that
IGRs,
especially
methoprene
and
diflubenzuron,
may
play
a
role
in
controlling
these
insects
Oberlander,
et
al.
1997
A
simulation
model
in
Denmark
suggests
that
increase
temperatures
inside
mills
drives
moth
outbreaks
and
if
mills
were
cooled
to
outdoor
temperatures,
moth
outbreaks
would
be
less
frequent.
Skovgard,
et
al.
1999
Investigations
into
chemical
control
strategies
should
include
a
thorough
examination
of
physical,
biological
and
environmental
factors
that
can
affect
pesticide
toxicity.
These
include:
application
rate,
formulation,
timing,
surface
substrate,
and
target
pest.
WP
formulation
of
cyfluthrin
applied
to
concrete
lasted
longer
than
the
EC
formulation.
T.
confusum
was
more
susceptible
than
T.
castaneum
to
WP.
Zettler
&
Arthur
2000
1Sulfuryl
fluoride
was
not
extensively
reviewed
because
at
the
time
the
review
was
written
there
were
no
tolerances
for
food
established
in
either
the
United
States
or
Canada.
More
information
regarding
this
chemical
can
be
found
in
Section
17.2.1.
Page
15
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
IN
KIND
ALTERNATIVES
TECHNICAL
FEASIBILITY
COMMENTS
Carbon
Dioxide
(
high
pressure)
No
Controlled
&
Modified
Atmospheres
No
Facilities
in
the
United
States
are
not
airtight
enough
for
modified
atmospheres
or
carbon
dioxide
to
be
effective
primarily
because
most
are
more
than
25
years
old.

To
implement
these
alternatives
would
require
new
construction
of
all
facilities.
Ethyl/
Methyl
Formate
No
Not
registered
in
United
States
(
last
product
cancelled
in
Oct.
1989)

Hydrogen
Cyanide
No
Not
registered
in
United
States
(
last
product
cancelled
in
Feb.
1988)
Phosphine,
alone
No
Phosphine,
in
combination
No
Although
does
kill
insects,
it
is
corrosive
to
metals,
especially
copper
and
its
alloys,
bronze
and
brass.
These
metals
are
important
components
of
the
electronics
that
run
the
manufacturing
equipment
and
some
of
the
equipment
itself
(
for
example:
motors,
mixers,
etc.).
In
addition,
phosphine
requires
longer
application
time.
This
alternative
is
already
being
used
in
the
areas
without
electronics
and
where
temperatures
are
not
a
factor.
Resistance
to
this
fumigant
has
also
been
reported
for
several
stored
product
pests.

This
alternative
has
already
been
implemented
in
areas
without
sensitive
metals.

Sulfuryl
fluoride
Unknown
Recently
registered
in
United
States
for
some
uses
in
this
sector
on
January
23,
2004.
The
use
of
this
chemical
will
require
training
of
applicators
by
registrant,
and
each
state
must
register
this
product
as
well.
Efficacy
of
this
chemical
remains
to
be
demonstrated
in
the
field.

May
take
up
to
5
years
before
we
know
if
it
will
replace
methyl
bromide
and
for
industry
conversion.
See
Section
17.2.1.
NOT
IN
KIND
ALTERNATIVE
TECHNICAL
FEASIBILITY
COMMENTS
Heat
Treatment
No
Sufficiently
high
temperature
will
kill
insects
given
enough
time;
but
heat
sources
are
not
readily
available
in
all
areas
of
United
States
(
such
as
those
in
the
south
where
hot
weather
is
the
norm
and
no
heaters
are
available);
and
heat
requires
longer
time
of
exposure.
In
areas
that
can
use
heat,
it
is
being
used.
It
is
not
feasible
in
remaining
plants
or
areas
of
a
plant.

In
order
to
completely
replace
methyl
bromide,
some
facilities
would
need
to
be
relocated
and
others
would
need
major
reconstruction.
Cold
Treatment
No
Contact
Insecticides
No
Cultural
Practices
No
Electrocution
No
Inert
Dust
No
Does
not
disinfest
facilities.
Most
of
these
IPM
strategies
are
currently
practiced
and
widely
implemented
with
the
beneficial
result
of
lengthening
time
between
fumigations.
Facilities
use
sanitation
and
cleaning
to
maintain
their
plants.
They
monitor
populations
with
pheromone
traps.
They
try
to
limit
incoming
pests
with
electrocution
traps
by
entrances/
exits.
When
populations
are
discovered,
they
use
Page
16
Pest
Exclusion/
Physical
Removal
No
Pesticides
of
Low
Volatility
No
Pheromones
No
Physical
Removal/
Cleaning
/
Sanitation
No
Rodenticide
No
physical
removal
and
contact
insecticides
and
low
volatility
pesticides.
Facilities
maintain
rodenticide
bait
stations
around
their
perimeter.

These
IPM
strategies
are
not
a
replacement
for
methyl
bromide,
but
do
lengthen
time
between
fumigations.

TABLE
12.2:
COMPARISON
OF
ALTERNATIVES
TO
METHYL
BROMIDE
FUMIGATION
FUMIGANT
PREPARATION
TIME
(
HR)
FUMIGATION
TIME
(
HRS)
DISSIPATION
TIME
(
HRS)
MINIMUM
NUMBER
OF
APPLICATIONS
TO
REPLACE
ONE
MB
APPLICATION*
Methyl
Bromide
24
24
24
­­
Phosphine,
alone
24
48­
72
24
2
Phosphine
+
CO2
24
48­
72
24
1­
2
Heat
36
48­
52
24
2
*
Additional
treatments
with
the
alternatives
may
be
required
because
they
are
less
effective
on
the
eggs
and
pupae
than
methyl
bromide.

PART
D:
EMISSION
CONTROL
13.
HOW
HAS
THIS
SECTOR
REDUCED
THE
USE
AND
EMISSIONS
OF
METHYL
BROMIDE
IN
THE
SITUATION
OF
THE
NOMINATION?

By
using
sanitation
and
IPM
the
industry
has
been
able
to
reduce
methyl
bromide
use
by
extending
the
time
between
fumigations.
According
to
the
applicants,
10­
12
years
ago,
plants
in
the
southern
United
States
used
to
fumigate
with
methyl
bromide
as
much
as
4­
6
times
a
year.
Currently,
most
southern
facilities
have
reduced
the
number
of
methyl
bromide
fumigations
to
twice
a
year.
These
fumigations
are
typically
at
the
beginning
of
the
summer
when
pest
pressure
is
significantly
increasing
and
at
the
end
of
the
summer.

In
the
northern
regions
of
the
United
States,
IPM
strategies
and
sanitation
methods
have
enabled
some
of
these
facilities
to
fumigate
with
methyl
bromide
once
every
3
years,
and
a
few
facilities
have
gone
without
a
methyl
bromide
fumigation
for
almost
5
years.
The
facilities
in
the
northern
United
States
have
been
able
to
exploit
heat
treatments
more
extensively
than
their
southern
counterparts,
as
well
as
opening
up
facilities
during
extremely
cold
weather
for
extensive
cleaning
coupled
with
low
volatility
pesticides
(
organophosphates,
pyrethroids,
insect
growth
regulators,
botanicals)
at
the
perimeters.
Page
17
PART
E:
ECONOMIC
ASSESSMENT
14.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
TABLE
14.1:
ANNUAL
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
A
3­
YEAR
PERIOD
MB
AND
ALTERNATIVES
COST
RATIO
COST
IN
CURRENT
YEAR
(
US$)
COST
ONE
YEAR
AGO
(
US$)
COST
2
YEARS
AGO
(
US$)
Rice
Miller's
Association
Methyl
Bromide
1
$
2,596
$
2,596
$
2,596
Sulfuryl
Flouride**
1.3
$
3,438
$
3,438
$
3,438
Heat
1.5
$
3,894
$
3,894
$
3,894
Bakeries
Methyl
Bromide
1
$
1,277
$
1,277
$
1,277
Heat
1.5
$
1,916
$
1,916
$
1,916
Pet
Foods
Institute
Methyl
Bromide
1
$
519
$
519
$
519
Heat
1.5
$
779
$
779
$
779
North
American
Miller's
Association
Methyl
Bromide
1
$
1,277
$
1,277
$
1,277
Sulfuryl
Flouride**
1.3
$
1,719
$
1,719
$
1,719
Heat
1.5
$
1,916
$
1,916
$
1,916
*
Costs
in
this
table
only
include
only
the
fumigation
cost
or
heat
treatment.
Losses
such
as
reductions
in
revenue
due
to
lost
days
are
included
in
Tables
E.
1
though
E.
4.

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
METHYL
BROMIDE
ALTERNATIVE
ECONOMIC
REASON
(
IF
ANY)
FOR
THE
ALTERNATIVE
NOT
BEING
AVAILABLE
ESTIMATED
MONTH/
YEAR
WHEN
THE
ECONOMIC
CONSTRAINT
COULD
BE
SOLVED
Heat
Treatment
For
food
processing
facilities
which
are
able
to
convert
to
heat
treatment,
economic
losses
are
from
additional
production
downtimes
due
to
longer
fumigation
time
and
from
capital
expenditures
required
to
adopt
an
alternative.
There
are
other
food
processing
facilities
in
areas
of
United
States
where
heat
treatment
is
not
feasible.
Economic
losses
due
to
downtime
with
heat
treatment
are
persistent.

Potential
economic
losses
were
estimated
for
the
food­
processing
facilities
that
have
not
been
converted
to
heat
treatment.
This
analysis
only
covers
cases
where
heat
treatment
may
potentially
be
technically
feasible,
and
does
not
cover
situations
where
heat
would
degrade
the
commodity
being
processed
(
those
with
fats
and
edible
oils).
Economic
costs
in
the
post­
harvest
uses
of
the
food­
processing
sector
can
be
characterized
as
arising
from
three
contributing
factors.
First,
the
direct
pest
control
costs
are
increased
in
most
cases
because
heat
treatment
is
more
expensive,
and
labor
is
increased
because
of
longer
treatment
time
and
increased
number
of
treatments.
For
food­
processing
facilities
that
are
not
already
using
heat,
capital
expenditure
is
also
required
to
retrofit
them
suitable
for
heat
treatment.
Moreover,
additional
production
downtimes
for
the
use
of
alternatives
are
unavoidable.
Many
facilities
operate
at
or
near
full
production
capacity
and
alternatives
that
take
longer
than
methyl
bromide
or
require
more
Page
18
frequent
application
can
result
in
manufacturing
slowdowns,
shutdowns,
and
shipping
delays.
Slowing
down
production
would
result
in
additional
costs
to
the
methyl
bromide
users.
Economic
cost
per
1000
m3
was
calculated
as
the
additional
costs
of
methyl
bromide
if
methyl
bromide
users
had
to
replace
methyl
bromide
with
heat
treatment.
Implementations
of
heat
treatment
likely
have
substantial
cost
implications
to
the
facilities
that
have
not
been
converted
to
heat
in
the
food­
processing
sector.

The
four
economic
measures
in
Table
E.
1
through
E.
4
were
used
to
quantify
the
economic
impacts
to
post­
harvesting
uses
for
food­
processing.
The
four
economic
measures
are
not
independent
of
each
other
since
they
can
be
calculated
from
the
same
financial
data.
The
measures
do,
however,
complement
each
other
in
evaluating
the
CUE
applicant's
economic
viability.
These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users.

Net
revenue
is
calculated
as
gross
revenue
minus
operating
costs.
This
is
a
good
measure
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
users.
It
should
be
noted
that
net
revenue
does
not
represent
net
income
to
the
users.
Net
income,
which
indicates
profitability
of
an
operation
of
an
enterprise,
is
gross
revenue
minus
the
sum
of
operating
and
fixed
costs.
Net
income
should
be
smaller
than
the
net
revenue
measured
in
this
analysis.
We
did
not
include
fixed
costs
because
it
is
often
difficult
to
measure
and
verify.

Production
downtime
is
estimated
at
almost
two
additional
days
per
heat
treatment.
Potential
economic
losses
associated
with
the
use
of
heat
treatment
also
include
the
cost
of
capital
investment.
The
estimated
economic
losses
are
shown
in
Tables
E.
1
through
E.
4.
The
estimated
economic
loss
as
a
percentage
of
net
revenue
are
over
50%
for
all
the
CUE
applicants
in
the
food­
processing
sector
and
over
100%
for
the
rice
millers
resulting
in
negative
net
revenues.

The
costs
of
using
sulfuryl
fluoride
were
also
estimated
in
Tables
14.1,
E.
1,
and
E.
4
for
rice
and
flour
millers.
For
purposes
of
this
analysis,
current
prices
of
sulfuryl
fluoride
and
equal
efficacy
with
methyl
bromide
were
assumed.
However,
if
methyl
bromide
were
not
available,
the
price
of
sulfuryl
fluoride
could
rise
in
the
future.

The
industries
that
use
methyl
bromide
for
commodity
fumigation
are,
in
general,
subject
to
limited
pricing
power,
changing
market
conditions,
and
government
regulations.
Companies
within
these
industries
operate
in
a
highly
competitive
global
marketplace
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories.
The
results
suggest
that
heat
treatment
is
not
economically
viable
as
an
alternative
for
methyl
bromide
in
existing
facilities
that
still
use
methyl
bromide.
Page
19
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TABLE
E.
1:
ANNUAL
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FOR
RICE
MILLER'S
ASSOCIATION
LOSS
MEASURE
METHYL
BROMIDE
SULFURYL
FLOURIDE
HEAT
TREATMENT
GROSS
REVENUE
(
US$/
1000
M
³
)
$
29,385
$
29,385
$
27,720
­
OPERATING
COSTS
(
A+
B)
PER
1000
M
³
$
27,916
$
28,758
$
29,429
A)
COST
OF
MB
OR
ALTERNATIVE
$
2,596
$
3,438
$
3,894
B)
OTHER
OPERATING
COSTS
$
25,320
$
25,320
$
25,535
NET
REVENUE
(
US$/
1000
M
3)
(
NET
OF
OPERATING
COSTS)
$
1,469
$
627
($
1,709)

LOSS
MEASURES
TIME
LOST
(
DAYS)
0
DAYS
0
days
17
days
LOSS
PER
1000
M
³
(
US$/
1000
M
³
)
$
0
$
843
$
3,178
LOSS
PER
KILOGRAM
MB
(
US$/
KG)
$
0
$
8.43
$
32
LOSS
AS
A
%
OF
GROSS
REVENUE
(%)
0%
3%
11%
LOSS
AS
A
%
OF
NET
REVENUE
(%)
0%
57%
216%

TABLE
E.
2:
ANNUAL
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FOR
BAKERIES
LOSS
MEASURE
METHYL
BROMIDE
HEAT
TREATMENT
GROSS
REVENUE
(
US$/
1000
M
³
)
$
258,334
$
250,584
­
OPERATING
COSTS
(
A+
B)
PER
1000
M
³
$
245,417
$
246,271
A)
COST
OF
MB
OR
ALTERNATIVE
$
1,277
$
1,916
B)
OTHER
OPERATING
COSTS
$
244,140
$
244,355
NET
REVENUE
(
US$/
1000
M
3)
(
NET
OF
OPERATING
COSTS)
$
12,917
$
4,313
LOSS
MEASURES
TIME
LOST
(
DAYS)
0
DAYS
9
days
LOSS
PER
1000
M
³
(
US$/
1000
M
³
)
$
0
$
8,604
LOSS
PER
KILOGRAM
MB
(
US$/
KG)
$
0
$
181
LOSS
AS
A
%
OF
GROSS
REVENUE
(%)
0%
3%
LOSS
AS
A
%
OF
NET
REVENUE
(%)
0%
67%
Page
20
TABLE
E.
3:
ANNUAL
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FOR
PET
FOOD
INSTITUTE
LOSS
MEASURE
METHYL
BROMIDE
HEAT
TREATMENT
GROSS
REVENUE
(
US$/
1000
M
³
)
$
175,452
$
170,773
­
OPERATING
COSTS
(
A+
B)
PER
1000
M
³
$
166,679
$
167,154
A)
COST
OF
MB
OR
ALTERNATIVE
$
519
$
779
B)
OTHER
OPERATING
COSTS
$
166,160
$
166,375
NET
REVENUE
(
US$/
1000
M
3)
(
NET
OF
OPERATING
COSTS)
$
8,773
$
3,619
LOSS
MEASURES
TIME
LOST
(
DAYS)
0
DAYS
8
days
LOSS
PER
1000
M
³
(
US$/
1000
M
³
)
$
0
$
5,153
LOSS
PER
KILOGRAM
MB
(
US$/
KG)
$
0
$
258
LOSS
AS
A
%
OF
GROSS
REVENUE
(%)
0%
3%
LOSS
AS
A
%
OF
NET
REVENUE
(%)
0%
59%

TABLE
E.
4:
ANNUAL
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FOR
NORTH
AMERICAN
MILLER'S
ASSOCIATION
LOSS
MEASURE
METHYL
BROMIDE
SULFURYL
FLOURIDE
HEAT
TREATMENT
GROSS
REVENUE
(
US$/
1000
M
³
)
$
437,472
$
437,472
$
424,348
­
OPERATING
COSTS
(
A+
B)
PER
1000
M
³
$
415,598
$
416,040
$
416,452
A)
COST
OF
MB
OR
ALTERNATIVE
$
1,277
$
1,719
$
1,916
B)
OTHER
OPERATING
COSTS
$
414,321
$
414,321
$
414,536
NET
REVENUE
(
US$/
1000
M
3)
(
NET
OF
OPERATING
COSTS)
$
21,874
$
21,432
$
7,896
LOSS
MEASURES
TIME
LOST
(
DAYS)
0
DAYS
9
days
9
days
LOSS
PER
1000
M
³
(
US$/
1000
M
³
)
$
0
$
442
$
13,978
LOSS
PER
KILOGRAM
MB
(
US$/
KG)
$
0
$
9.30
$
294
LOSS
AS
A
%
OF
GROSS
REVENUE
(%)
0%
0.1%
3%
LOSS
AS
A
%
OF
NET
REVENUE
(%)
0%
2%
64%
Page
21
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.

The
industry
is
committed
to
studying
how
to
improve
insect
control
with
IPM
strategies
and
sanitation
and
to
further
reduce
the
number
of
methyl
bromide
fumigations.
They
are
also
continuing
to
pursue
research
of
heat
treatments
to
maximize
efficiency.
The
United
States
government
is
supporting
research
in
this
sector
(
see
Section
17.1)
and
the
United
States
Environmental
Protection
Agency
(
U.
S.
EPA)
has
made
registering
methyl
bromide
alternatives
a
priority
(
see
Section
17.2).
U.
S.
EPA
registered
sulfuryl
fluoride
for
some
commodities
and
some
mills
on
January
23,
2004
(
see
Section
17.2.1).

17.
PROVIDE
A
DETAILED
PLAN
DESCRIBING
WHAT
ACTIONS
WILL
BE
UNDERTAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
USE:

17.1.
Research
The
number
of
available
insecticides
that
can
be
used
in
and
around
food
plants,
processing
mills,
and
food
warehouses
in
the
U.
S.
has
declined
in
recent
years.
The
research
and
development
of
chemical
alternatives
to
be
used
by
this
sector
is
a
critical
need
in
the
U.
S.
The
post­
harvest
food­
processing
sector
has
invested
substantial
time
and
funding
into
research
and
development
of
technically
and
economically
feasible
alternatives
to
methyl
bromide.
Past
and
current
research
focuses
on
the
biology
and
ecology
of
the
pests,
primarily
insect
pests.
To
implement
non­
chemical
controls
and
reduce
methyl
bromide
use
requires
a
thorough
understanding
of
the
pests
in
order
to
exploit
their
weaknesses.
Some
of
these
investigations
have
studied
the
effects
of
temperature
and
humidity
on
the
fecundity,
development,
and
longevity
of
a
specific
species.
Other
studies
have
been
to
determine
the
structural
preferences
and
microhabitat
requirements
of
a
species.
Studies
of
factors
affecting
population
growth
(
interactions
within
and
among
species)
have
been
conducted.
However,
there
is
still
much
research
that
needs
to
be
done.

IPM
and
sanitation
methods
are
also
under
investigation.
Studies
have
focused
on
food
plant
design,
engineering
modifications
for
pest
exclusion,
and
insect­
resistant
packaging.
New
research
is
demonstrating
a
potential
to
incorporate
chemical
repellents
into
packaging
materials
(
Arthur
and
Phillips
2003).
Further
studies
with
pheromones
and
trapping
strategies
are
helping
to
improve
IPM
in
food
processing
plants.

The
USDA
is
continuing
to
fund
research
projects
for
post­
harvest/
food
processing
plants.
Such
activities
include:

Biology
and
Management
of
Food
Pests
(
Oct
2002­
Sep
2007)
to:
examine
the
reproductive
biology
and
behavior
of
storage
weevils,
Indianmeal
moth,
and
red
and
confused
flour
beetles;
determine
the
influence
of
temperature
on
the
population
growth,
mating
and
development
of
storage
pests,
specifically
storage
weevils,
Indianmeal
moth,
Page
22
and
red
and
confused
flour
beetles;
examine
the
use
of
CO2
concentrations
within
a
grain
mass
to
predict
storage
weevils
and
flour
beetle
population
growth;
and
examine
the
use
of
alternative
fumigants
on
insect
mortality
(
ozone,
sagebrush,
Profume
®
)
.

Chemically
Based
Alternatives
to
Methyl
Bromide
for
Post
harvest
and
Quarantine
Pests
(
Jul
2000
­
Dec
2004)
to:
develop
quarantine/
post
harvest
control
strategies
using
chemicals
to
reduce
arthropod
pests
in
durable
and
perishable
commodities;
develop
new
fumigants
and/
or
strategies
to
reduce
methyl
bromide
use;
develop
technology
and
equipment
to
reduce
methyl
bromide
emissions
to
the
atmosphere;
develop
system
approaches
for
control
using
chemicals
combined
with
nonchemical
methodologies
which
will
yield
integrated
pest
control
management
programs;
and
develop
methods
to
detect
insect
infestations.

The
rice
milling
industry
has
spent
over
U.
S.$
500,000
on
research
to
develop
alternatives
since
1992,
and
plans
to
use
additional
pesticides,
such
as
carbonyl
sulfide,
carbon
dioxide,
phosphine,
magnesium
phosphide
(
magtoxin),
and
dichlorvos
(
vapona)
over
the
next
few
years.
Nonchemical
methods
used
by
this
sub­
sector,
to
reduce
methyl
bromide
use,
include
heat
and
cold
treatments,
and
many
individual
companies
are
involved
in
further
research
and
testing
of
alternatives.
Industry
experts
have
been
trying
to
determine
how
best
to
incorporate
sulfuryl
fluoride
into
their
IPM
programs
since
its
recent
registration.

The
bakery
sector
is
implementing
heat
as
an
alternative
at
those
facilities
where
heat
is
technically
feasible.
Currently,
heat
is
being
implemented
at
several
facilities
nationwide,
but
further
trials
are
needed
to
determine
the
effects
of
heat
on
a
long­
term
basis.
However,
older
facilities
with
hardwood
floors
and
plant
electrical
wiring
systems
are
unsuitable
for
heat
treatments.
Other
methods
being
used
to
reduce
reliance
on
methyl
bromide
are:
exclusion,
cleaning,
early
detection,
improved
design
of
equipment,
trapping,
and
other
integrated
pest
management
(
IPM)
approaches.
Phosphine
continues
to
be
tested.

The
flour
milling
industry
is
committed
to
IPM
techniques
in
order
to
minimize
reliance
on
any
one
tool.
Many
plants
have
reduced
the
amount
of
annual
fumigations
from
4­
5
per
year
to
2­
3
per
year.
Some
of
these
facilities
combine
methyl
bromide
with
carbon
dioxide.
Further,
these
applicants
have
authored
three
manuals
on
fumigation
best
practices,
which
are
widely
utilized
throughout
the
industry.
The
industry
continues
to
test
high
heat,
phosphine,
alone
and
in
combination;
and
the
combination
of
heat,
phosphine,
and
carbon
dioxide.
In
addition,
industry
experts
have
been
trying
to
determine
how
best
to
incorporate
sulfuryl
fluoride
into
their
IPM
programs
since
its
recent
registration.

The
Pet
Food
Institute
has
invested
hundreds
of
thousands
of
dollars
in
research
on
a
variety
of
alternatives
to
methyl
bromide,
including
heat
treatments.
Sulfuryl
fluoride
was
tested
in
an
inactive
pet
food
facility
last
year
as
well.
They
have
made
improvements
in
worker
training,
pest
monitoring,
and
sanitation
to
greatly
reduce
the
necessity
for
fumigations
with
methyl
bromide,
or
any
other
fumigant.
Page
23
17.2.
Registration
Since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
pending
in
its
registration
review
queue
than
the
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
U.
S.
EPA
to
initiate
its
review.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
Agency
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
Agency's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
Agency
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
Agency
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized
The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
Methyl
Bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
This
coordination
has
resulted
in
key
registration
issues
(
such
as
worker
and
bystander
exposure
through
volatilization,
township
caps
and
drinking
water
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
U.
S.$
15
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
U.
S.
EPA's
participation
in
the
evaluation
of
research
grant
proposals
each
year
for
USDA's
U.
S.$
2.5
million
per
year
methyl
bromide
alternatives
research
has
further
ensured
close
coordination
between
the
U.
S.
government
and
the
research
community.

Since
1997,
the
U.
S.
EPA
has
registered
the
following
chemical/
use
combinations
as
part
of
its
commitment
to
expedite
the
review
of
methyl
bromide
alternatives:

 
2000:
Phosphine
in
combination
to
control
stored
product
insect
pests
 
2001:
Indianmeal
Moth
Granulosis
Virus
to
control
Indianmeal
moth
in
stored
grains
 
2004:
Sulfuryl
fluoride
as
a
post­
harvest
fumigant
for
stored
commodities
and
some
mills
(
see
below).

17.2.1.
Sulfuryl
Fluoride
On
January
23,
2004,
U.
S.
EPA
registered
sulfuryl
fluoride
as
a
post­
harvest
fumigant
for
grains
and
flour
mills.
While
registration
for
these
uses
will
provide
opportunities
to
reduce
methyl
bromide
use,
it
must
be
emphasized
that
such
replacement,
if
feasible,
will
only
occur
gradually
over
time.

Alternatives
must
be
tested
by
users
and
found
technically
and
economically
feasible
before
widespread
adoption
will
occur.
As
noted
by
TEAP,
a
specific
alternative,
once
available
may
Page
24
take
up
to
5
fumigation
cycles
of
use
before
efficacy
can
be
determined
in
the
specific
circumstance
of
the
user.
The
registrant
is
requiring
that
applicators
be
trained
by
them
before
using
sulfuryl
fluoride
(
there
is
a
3­
tiered
certification
system).
Several
fumigation
companies
have
teams
trained
by
the
registrant.
Mills
have
begun
testing
sulfuryl
fluoride
in
specific
circumstances.

There
are
additional
pesticide
registration
issues,
however,
that
must
be
resolved
before
sulfuryl
fluoride
can
be
used
in
sectors
for
which
the
U.
S.
is
nominating
methyl
bromide
CUEs.
Sulfuryl
fluoride
is
being
registered
only
for
cereal
and
small
grains
and
mills
that
contain
and/
or
process
these
grains.
Many
mills
also
produce
partial
recipe
products
that
contain
such
ingredients
as
sugar,
leavening
agents,
hydrogenated
oils,
etc.
The
registration
of
sulfuryl
fluoride
does
not
include
tolerances
for
these
ingredients
and
therefore
would
not
be
allowed
in
these
facilities.
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).

States
must
also
register
sulfuryl
fluoride.
All
states
except
California,
New
York,
and
Alaska
have
registered
sulfuryl
fluoride
for
these
post
harvest
uses.

U.
S.
EPA
currently
has
limited
data
on
sulfuryl
fluoride's
performance
relative
to
methyl
bromide.
We
have
little
product
performance
data
(
direct
comparisons
to
methyl
bromide),
no
experience
in
how
well
it
performs
in
different
facilities
and
climates
over
multiple
years,
and
no
information
on
what
costs
might
be
associated
with
adopting
sulfuryl
fluoride.
Based
on
the
limited
data
currently
available,
U.
S.
EPA
believes
that
within
4
years
sulfuryl
fluoride
may
be
able
to
replace
methyl
bromide
in
up
to
75%
of
the
rice
and
flour
mills.
U.
S.
EPA
is
committed
to
monitoring
sulfuryl
fluoride
use
during
the
next
few
years
to
amend
future
CUE
nominations.

18.
ADDITIONAL
COMMENTS
Pheromone
Traps
"
One
misconception
about
pheromone
traps
is
that
a
pest
population
can
be
controlled
by
deploying
these
traps 
that
is
not
true
for
most
situations.
Traps
usually
attract
only
a
small
percentage
of
the
population
that
is
within
the
effective
range
of
the
trap.
Also,
female­
produced
sex
pheromones
attract
only
males;
the
females
that
lay
eggs
and
perpetuate
the
infestation
are
not
affected.
Since
males
of
the
many
insect
species
will
mate
with
multiple
females,
any
males
that
are
not
trapped
can
easily
contribute
to
the
production
of
a
subsequent
generation
of
pests.
New
methods
are
being
researched
for
using
pheromones
in
pest
suppression,
but
current
uses
of
pheromone
traps
are
best
used
only
for
monitoring
purposes."
(
Arthur
and
Phillips
2003)

Sulfuryl
Fluoride
There
are
some
industry
concerns
regarding
sulfuryl
fluoride.
Primarily
that
it
is
temperature
dependent
and
that
large
concentrations
are
necessary
to
kill
eggs.
There
is
concern
regarding
mixing
of
bulk
flour
at
a
10:
1
ratio
to
meet
tolerances.
The
post
harvest
industry
is
aware
that
sulfuryl
fluoride,
as
Vikane
®
,
is
very
expensive
and
they
are
very
concerned
that
the
price
of
Page
25
sulfuryl
fluoride
as
Profume
®
may
be
prohibitive
to
use
at
the
concentrations
required
to
control
pests.

There
have
been
a
few
reported
problems
with
sulfuryl
fluoride
fumigations.
One
facility
(
ca
28,317
m3
or1
million
ft3)
was
treated
at
a
"
less
than
all
life
stages"
level,
which
did
not
control
the
insect
infestation.
Additionally,
that
particular
mill
is
typically
fumigated
with
817
kg
(
1,800
lb)
methyl
bromide,
but
the
May
fumigation
required
1,506
kg
(
3,321
lb)
sulfuryl
fluoride.
This
mill
needed
to
be
fumigated
with
methyl
bromide
about
8
weeks
later.
In
this
same
facility,
the
calculated
amount
of
sulfuryl
fluoride
was
2,371
kg
(
5,226
lb)
for
"
complete
kill",
at
30
º
C
(
86
º
F).
A
facility
of
similar
size
intended
to
fumigate
at
Thanksgiving,
but
the
temperature
would
require
5,897
kg
(
13,000
lb)
sulfuryl
fluoride
for
"
complete
kill."
That
facility
decided
to
go
with
a
methyl
bromide
fumigation
based
on
volumes.

On
page
6
of
the
sulfuryl
fluoride
label:
" 
bulk 
wheat
flour
not
removed
from
the
fumigation
area
must
be
blended
at
a
ratio
of
at
least
10:
1
or
discarded
to
ensure
wheat
flour
offered
to
consumers
does
not
exceed
commodity
tolerances."
Many
of
the
millers
do
not
have
the
capacity
to
mix
the
fumigated
bulk
flour
and
are
therefore
finding
this
requirement
to
be
a
very
difficult
one
to
achieve.
Page
26
19.
CITATIONS
Arthur,
F.
H.
2000.
Toxicity
of
diatomaceous
earth
to
red
flour
beetles
and
confused
flour
beetles
(
Coleoptera:
Tenebrionidae):
Effects
of
temperature
and
relative
humidity.
J.
Econ.
Entomol.
93(
2):
526­
532.

Arthur,
F.
H.
1992.
Cyfluthrin
WP
and
EC
formulations
to
control
malathion­
resistant
red
flour
beetles
and
confused
flour
beetles
(
Coleoptera:
Tenebrionidae):
Effects
of
paint
on
residual
activity.
J.
Entomol.
Sci.
27(
4):
436­
444.

Arthur,
F.
and
T.
W.
Phillips.
2003.
Stored­
product
insect
pest
management
an
d
control,
In:
Food
Plant
Sanitation
eds:
Y.
H.
Hui,
B.
L.
Bruinsma,
J.
R.
Gorham,
W.
Nip,
P.
S.
Tong,
and
P.
Ventresca.
Marcel
Dekker,
Inc.,
New
York,
pp.
341­
358.

Bell,
C.
H.
2000.
Fumigation
in
the
21st
century.
Crop
Protection
19:
563­
569.

Cox,
P.
D.
2004.
Potential
for
using
semiochemicals
to
protect
stored
products
from
insect
infestation.
J
Stored
Prod.
Res.
40:
1­
25.

Dowdy,
A
K.&
P.
G.
Fields.
2002.
Heat
combined
with
diatomaceous
earth
to
control
the
confused
flour
beetle
(
Coleoptera:
Tenebrionidae)
in
a
flour
mill.
J
Stored
Prod.
Res.
38:
11­
22.

Dunkel,
F.
V.
and
L.
J.
Sears.
1998.
Fumigant
properties
of
physical
preparations
from
Mountain
big
sagebrush,
Artemisia
tridentate
Nutt.
ssp.
vaseyana
(
Rydb.)
Beetle
for
stored
grain
insects.
J.
Stored
Prod.
Res.
34(
4):
307­
321.

Fields,
P.
and
N.
D.
G.
White.
2002.
Alternatives
to
methyl
bromide
treatments
for
storedproduct
and
quarantine
insects.
Annual
Review
of
Entomology
47:
331­
59.

Hou,
X.,
P.
Fields,
and
W.
Taylor.
2004.
The
effect
of
repellents
on
penetration
into
packaging
by
stored­
product
insects.
J
Stored
Prod.
Res.
40:
47­
54.

Mahroof,
R.,
Subramanyam,
B.
and
Eustace,
D.
2003.
Temperature
and
relative
humidity
profiles
during
heat
treatment
of
mills
and
its
efficacy
against
Tribolium
castaneum
(
Herbst)
life
stages.
J.
Stored
Prod.
Res.
39:
555­
569.

Mahroof,
R.,
B.
Subramanyam,
J.
E.
Throne,
and
A.
Menon.
2003.
Time­
mortality
relationships
for
Tribolium
castaneum
(
Coleoptera:
Tenebrionidae)
life
stages
exposed
to
elevated
temperatures.
J.
Econ.
Entomol.
96(
4):
1345­
1351.

Mueller,
D.
K.
2002.
Insect
resistance
testing.
Fumigants
and
Pheromones
62:
1­
2.

Nielsen,
P.
S.
1998.
The
effect
of
a
diatomaceous
earth
formulation
on
the
larvae
of
Ephestia
kuehniella
Zeller.
J
Stored
Prod.
Res
34:
113­
121.
Page
27
Oberlander,
H.,
D.
L.
Silhacek,
E.
Shaaya,
and
I.
Ishaaya.
1997.
Current
status
and
future
perspectives
of
the
use
of
insect
growth
regulators
for
the
control
of
stored
product
insects.
J
Stored
Prod.
Res.
33:
1­
6.

Skovgard,
H.,
N.
Holst,
and
P.
S.
Nielsen.
1999.
Simulation
model
of
the
Mediterranean
flour
moth
(
Lepidoptera:
Pyralidae)
in
Danish
flour
mills.
Environ.
Entomol.
28(
6):
1060­
1066.

Taylor,
R.
W.
D.
1989.
Phosphine,
a
major
grain
fumigant
at
risk.
Int.
Pest
Control.
31:
10­
14.

Zettler,
J.
L.
1991.
Pesticide
resistance
in
Tribolium
castaneum
and
T.
confusum
(
Coleoptera:
Tenebrionidae)
form
flour
mills
in
the
United
States.
J.
Econ.
Entomol.
84(
3):
763­
767.

Zettler,
J.
L.
and
F.
H.
Arthur.
2000.
Chemical
control
of
stored
product
insects
with
fumigants
and
residual
treatments.
Crop
Protection
19:
577­
582.

BIBLIOGRAPHY
Arthur,
F.
H.
2000.
Toxicity
of
diatomaceous
earth
to
red
flour
beetles
and
confused
flour
beetles
(
Coleoptera:
Tenebrionidae):
Effects
of
temperature
and
relative
humidity.
J.
Econ.
Entomol.
93(
2):
526­
532.

Arthur,
F.
H.
1992.
Cyfluthrin
WP
and
EC
formulations
to
control
malathion­
resistant
red
flour
beetles
and
confused
flour
beetles
(
Coleoptera:
Tenebrionidae):
Effects
of
paint
on
residual
activity.
J.
Entomol.
Sci.
27(
4):
436­
444.

Bell,
C.
H.
2000.
Fumigation
in
the
21st
century.
Crop
Protection
19:
563­
569.

Cox,
P.
D.
2004.
Potential
for
using
semiochemicals
to
protect
stored
products
from
insect
infestation.
J
Stored
Prod.
Res.
40:
1­
25.

Dowdy,
A
K.&
P.
G.
Fields.
2002.
Heat
combined
with
diatomaceous
earth
to
control
the
confused
flour
beetle
(
Coleoptera:
Tenebrionidae)
in
a
flour
mill.
J
Stored
Prod.
Res.
38:
11­
22.

Dunkel,
F.
V.
and
L.
J.
Sears.
1998.
Fumigant
properties
of
physical
preparations
from
Mountain
big
sagebrush,
Artemisia
tridentate
Nutt.
ssp.
vaseyana
(
Rydb.)
Beetle
for
stored
grain
insects.
J.
Stored
Prod.
Res.
34(
4):
307­
321.

Fields,
P.
and
N.
D.
G.
White.
2002.
Alternatives
to
methyl
bromide
treatments
for
storedproduct
and
quarantine
insects.
Annual
Review
of
Entomology
47:
331­
59.

Hou,
X.,
P.
Fields,
and
W.
Taylor.
2004.
The
effect
of
repellents
on
penetration
into
packaging
by
stored­
product
insects.
J
Stored
Prod.
Res.
40:
47­
54.
Page
28
Mahroof,
R.,
Subramanyam,
B.
and
Eustace,
D.
2003.
Temperature
and
relative
humidity
profiles
during
heat
treatment
of
mills
and
its
efficacy
against
Tribolium
castaneum
(
Herbst)
life
stages.
J.
Stored
Prod.
Res.
39:
555­
569.

Mahroof,
R.,
B.
Subramanyam,
J.
E.
Throne,
and
A.
Menon.
2003.
Time­
mortality
relationships
for
Tribolium
castaneum
(
Coleoptera:
Tenebrionidae)
life
stages
exposed
to
elevated
temperatures.
J.
Econ.
Entomol.
96(
4):
1345­
1351.

Mueller,
D.
K.
2002.
Insect
resistance
testing.
Fumigants
and
Pheromones
62:
1­
2.

Mueller,
D.
K.
1998.
Stored
product
protection 
a
period
of
transition.
Insects
Limited,
Inc.,
Indianapolis,
IN.
337
pp.

Nielsen,
P.
S.
1998.
The
effect
of
a
diatomaceous
earth
formulation
on
the
larvae
of
Ephestia
kuehniella
Zeller.
J
Stored
Prod.
Res
34:
113­
121.

Oberlander,
H.,
D.
L.
Silhacek,
E.
Shaaya,
and
I.
Ishaaya.
1997.
Current
status
and
future
perspectives
of
the
use
of
insect
growth
regulators
for
the
control
of
stored
product
insects.
J
Stored
Prod.
Res.
33:
1­
6.

Skovgard,
H.,
N.
Holst,
and
P.
S.
Nielsen.
1999.
Simulation
model
of
the
Mediterranean
flour
moth
(
Lepidoptera:
Pyralidae)
in
Danish
flour
mills.
Environ.
Entomol.
28(
6):
1060­
1066.

Taylor,
R.
W.
D.
1989.
Phosphine,
a
major
grain
fumigant
at
risk.
Int.
Pest
Control.
31:
10­
14.

UNEP.
1998.
1998
Assessment
of
alternatives
to
methyl
bromide.
United
Nations
Publication.

UNEP.
2001.
Sourcebook
of
Technologies
for
protecting
the
ozone
layer:
alternatives
to
methyl
bromide.
United
Nations
Publication
Zettler,
J.
L.
1991.
Pesticide
resistance
in
Tribolium
castaneum
and
T.
confusum
(
Coleoptera:
Tenebrionidae)
form
flour
mills
in
the
United
States.
J.
Econ.
Entomol.
84(
3):
763­
767.

Zettler,
J.
L.
and
F.
H.
Arthur.
2000.
Chemical
control
of
stored
product
insects
with
fumigants
and
residual
treatments.
Crop
Protection
19:
577­
582.
Page
29
APPENDIX
A.
Supporting
Data.

APPENDIX
A
­
TABLE
9.1(
A):
SUMMARY
OF
THE
CIRCUMSTANCES
OF
CURRENT
METHYL
BROMIDE
USE
IN
PET
FOOD
PROCESSING
PLANTS
FACILITY
NO.
METHYL
BROMIDE
DOSAGE
EXPOSURE
TIME
(
hours)
EXTERIOR
TEMP.
(
º
C)
NUMBER
OF
FUMIGATIONS
PER
YEAR
PROPORTION
OF
PRODUCT
TREATED
AT
THIS
DOSE
FIXED
(
F)
MOBILE
(
M)
STACK
(
S)

1
Midwest
16
g/
m3
24
Day:
35­
38
1
general
2
spot
w/
phos
30%
(
1)
Fixed
(
2)

2
Midwest
16
g/
m3
24
Day:
27
Night:
10
1
general
40%
(
1)
Fixed
(
2)

3
Southeast
16
g/
m3
24
24
1
general
16%
(
1)
Fixed
(
2)

4
Southeast
24
g/
m3
24
21
1
general
15%
(
1)
Fixed
(
2)

5
North
18
g/
m3
24
15
 
25
(
outside)
Approx.
one
<
10%(
1)
Fixed
(
2)

6
Midwest
16
g/
m3
­
24
g/
m3
24
17.8
Approx.
one
40%(
1)
Fixed
(
2)

7
West
16
g/
m3
24
20.6
­
29.4
Approx.
one
40%(
1)
Fixed
(
2)

8
Midwest
16
g/
m3
24
31.7
­
36.7
Approx.
one
50%(
1)
Fixed
(
2)

(
1)
Based
on
%
of
total
volume
treated
(
2)
Fixed
=
Fixed
facility
APPENDIX
A
­
TABLE
9.1(
B):
SUMMARY
OF
THE
CIRCUMSTANCES
OF
CURRENT
METHYL
BROMIDE
USE
IN
PET
FOOD
PROCESSING
PLANTS
­
FIXED
FACILITIES:
PET
FOOD
INSTITUTE
PEST
NO.
TYPE
OF
CONSTRUCTION
AND
APPROXIMATE
AGE
IN
YEARS
VOLUME
(
m
³
)
OR
RANGE
NUMBER
OF
FACILITIES
(
E.
G.
5
SILOS)
GAS
TIGHTNESS
ESTIMATE*

1
Midwest
Tilt­
up
concrete,
some
corrugated
metal
184,800
m3
1
Medium
Areas
&
Poor
Areas
2
Midwest
Tilt­
up
concrete
114,800
m3
1
Good
Areas
&
Medium
Areas
3
Southeast
Corrugated
metal
72,973
m3
1
Poor
4
Southeast
Corrugated
metal
35,954
m3
1
Medium
Areas
&
Poor
Areas
5
North
Corrugated
Metal
on
slab
(
13
years)
7,420
m3
<
1
(
processing
area
only)
Good
6
Midwest
Corrugated
Metal
on
Slab
218,400
m3
1
Medium
7
West
Corrugated
Metal
on
Slab
28,759
m3
1
Medium
to
Poor
8
Midwest
Poured
Concrete
Walls/
Slab
Floor
137,760
m3
1
Very
Good
*
Give
gastightness
estimates
where
possible
according
to
the
following
scale:
good
 
less
than
25%
gas
loss
within
24
hours
or
half
loss
time
of
pressure
difference
(
e.
g.
20
to
10
Pa
(
t1/
2))
greater
than
1
minute;
medium
 
25­
50%
gas
loss
within
24
hours
or
half
loss
time
of
pressure
difference
greater
than
10
seconds;
poor
 
50­
90%
gas
loss
within
24
hours
or
half
loss
time
of
pressure
difference
1­
10
second;
very
poor
 
more
than
90%
gas
loss
within
24
hours
or
a
pressure
half
loss
time
of
less
than
1
second.
Page
30
APPENDIX
B.
Published
Performance
Data.

APPENDIX
B
­
TABLE
1:
EFFECT
OF
TEMPERATURE
ON
CONCENTRATION
AND
TIME
THRESHOLDS
FOR
SOME
PESTS
OF
STORED
PRODUCTS.
(
FROM:
BELL,
C.
H.
2000)
TEMPERATURE
(
º
C)
SPECIES
FUMIGANT
THRESHOLD
(
º
C
OR
TIME)
15
25
Sitophilus
oryzae
Methyl
Bromide
º
C
(
mg/
l)
0.6­
0.9
1.3­
2.0
Tribolium
confusum
Methyl
Bromide
º
C
(
mg/
l)
1.3­
2.0
2.5­
3.0
Tribolium
castaneum
Methyl
Bromide
º
C
(
mg/
l)
1.3­
2.0
3.0­
3.5
Tribolium
castaneum
Phosphine
º
C
(
mg/
l)
0.005­
0.0011
Tribolium
castaneum
Phosphine
Time
(
h)
0.5­
1.5
For
phosphine
relatively
long
exposure
times
are
required
for
kill
of
all
stages
&
time
threshold
is
more
important
than
the
concentration
for
efficient
fumigant
action.
Page
31
APPENDIX
B
­
TABLE
2:
CONCENTRATION­
TIME
PRODUCT
RECOMMENDATIONS
BY
NATIONAL
PEST
MANAGEMENT
ASSOCIATION
OUNCE­
HOURS
MG/
L
SPECIES
STAGE
TEMP
(
°
C)
PHOSPHINE
72
HR
PHOSPHINE
144
HR
METHYL
BROMIDE
SULFURYL
FLUORIDE
eggs
4.4
146.4
eggs
10
8.5
49.5
91.2
eggs
15.6
61.8
37.9
48
eggs
21.1
0.64
0.86
43.2
eggs
26.5
711.7
larvae
4.4
6.9
1.2
379.2
larvae
10
3.7
0.86
206.4
larvae
15.6
0.94
0.72
132
larvae
21.1
0.5
0.43
120
larvae
26.5
55.9
pupae
4.4
5.6
7.4
1046
pupae
10
5.6
4.6
324
pupae
15.6
5.2
1.3
124.8
pupae
21.1
0.58
0.3
108
adult
4.4
2.2
1.9
230.4
adult
10
1.8
1.1
105.6
adult
15.6
1
0.5
64.8
adult
21.1
0.36
0.3
57.6
Lasioderma
serricorne
adult
26.5
34.9
Sitophilus
oryzae
adult
21
0.36
30
eggs
26.7
1124.8
adult
4.4
209.3
178.2
adult
15.6
92.8
97.6
adult
25
0.48
64
55
Tribolium
confusum
adult
26.7
74.2
76.5
Tribolium
castaneum
adult
24
11.5
62
eggs
15
53
eggs
20
29
eggs
25
22
eggs
30
21
larvae
15
34
larvae
20
31
larvae
25
24
larvae
30
25
pupae
15
64
pupae
20
50
pupae
25
43
Plodia
interpunctella
pupae
30
35
Page
32
APPENDIX
C.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)

Date:

Sector:

Kilograms
(
kgs)
Volume
(
1000m3)
Use
Rate
(
kg/
1000m3)
Kilograms
(
kgs)
Volume
(
1000m3)
Use
Rate
(
kg/
1000m3)
2001
&
2002
Average
%
of
Volume
200,488
6,116
33
146,283
4,630
32
20%

23,814
1,206
20
28,354
1,515
19
0%

44,906
2,294
20
39,275
1,803
22
0%

317,514
16,424
19
396,893
19,397
20
0%

586,721
26,040
23
610,805
27,345
22
2007
Request
(­)
Double
Counting
(­)
Growth
(­)
Use
Rate
Adjustment
(­)
QPS
HIGH
LOW
HIGH
LOW
Amount
(
kgs)
Volume
(
1000m
3
)
Use
Rate
(
kg/
1000m3)

200,488
­
54,204
53,581
18,541
74,162
74,162
64,150
64,150
64,150
3,204
20
23,814
­
­
­
­
23,814
23,814
23,814
23,814
23,814
1,272
19
44,906
­
5,630
­
­
39,275
39,275
39,275
39,275
39,275
2,006
20
317,514
­
­
­
­
317,514
317,514
274,650
274,650
274,650
14,207
19
586,721
586,721
526,887
473,306
454,766
454,766
454,766
401,889
401,889
401,889
20,689
19
0%
0%
10%
19%
22%
22%
22%
32%
32%
32%
21%
14%

Low
EPA
High
Low
HIGH
LOW
%
adopt
%
per
year
32
20
100%
100%
100%
100%
54%
14%
0
days
Sulfuryl
Fluoride*

19
19
100%
100%
100%
100%
0%
0%
9
days
heat
20
20
100%
100%
100%
100%
0%
0%
8
days
heat
19
19
100%
100%
100%
100%
54%
14%
9
days
Sulfuryl
Fluoride*

Dichotomous
Variables
(
Y/
N)

Currently
Use
Alternatives?
Research
/

Transition
Plans
Pest­
free
Market
Requirement
Change
from
Prior
CUE
Request
(+/­)
Verified
Historic
MeBr
Use
/
State
Frequency
of
Treatment
/
Yr
Loss
per
1000
m3
(
US$/
1000m)
Loss
per
Kg
of
MeBr
(
US$/
kg)
Loss
as
a
%
of
Gross
Revenue
Loss
as
a
%
of
Net
Revenue
Y
Y
Y
0
N
5x/
1year
843
$
8
$
3%
57%

Y
Y
Y
+
N
2x/
1year
8,604
$
181
$
3%
67%

Y
Y
Y
0
N
1x/
year
5,153
$
258
$
3%
59%

Y
Y
Y
­
N
2.5x/
1year
442
$
9
$
0%
2%

Adopt
new
fumigants
­
Sulfuryl
fluoride
Percent
of
Market
adoption
depends
on
Registration
Date,
Cost,
%
of
Structures
that
are
suitable,
SF
not
registered
in
CA
or
NY
or
AK
SF
might
also
require
registration
on
all
the
additives
typically
found
in
a
mill
or
food
processing
plant
EPA
estimates
are
for
an
eventual
20
to
40%
market
share
after
complete
registration.

Conversion
Units:
1
Pound
=
0.453592
Kilograms
1,000
cu
ft
=
0.028316847
1,000
cu
m
High
24%
Low
76%

MOST
LIKELY
IMPACT
VALUE
Marginal
Strategy
Adoption
/
Transition
Adjustment
(
kgs)
Not
Available
%
of
Average
Volume
Requested:

Not
Available
Average
Volume
in
the
US:

Time,
Quality,
or
Product
Loss
1/
28/
2005
STRUCTURES
­
FOOD
FACILITIES
NORTH
AMERICAN
MILLER'S
ASSOCIATION
FOOD
FACILITY
TYPE
RICE
MILLER'S
ASSOCIATION
BAKERIES
PET
FOOD
INSTITUTE
Other
Issues
RICE
MILLER'S
ASSOCIATION
BAKERIES
Other
Considerations
FOOD
FACILITY
TYPE
RICE
MILLER'S
ASSOCIATION
BAKERIES
PET
FOOD
INSTITUTE
NORTH
AMERICAN
MILLER'S
ASSOCIATION
Regional
Volume
FOOD
FACILITY
TYPE
Nomination
Amount
%
Reduction
from
Initial
Request
PET
FOOD
INSTITUTE
NORTH
AMERICAN
MILLER'S
ASSOCIATION
RICE
MILLER'S
ASSOCIATION
BAKERIES
PET
FOOD
INSTITUTE
NORTH
AMERICAN
MILLER'S
ASSOCIATION
(%)
Combined
Impacts
2007
Amount
of
Request
2001
&
2002
Average
Use
Quarantine
and
Pre­
Shipment
Adjustments
to
Requested
Amounts
Use
Rate
(
kg/
1000m3)

FOOD
FACILITY
TYPE
TOTAL
OR
AVERAGE
2007
Nomination
Options
Economic
Analysis
Methyl
Bromide
Critical
Use
Exemption
Process
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Most
Likely
Impact
Value:
Research
Amount
(
kgs)

0
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

(%)
Key
Pest
Distribution
(%)
Adopt
New
Fumigants
Page
33
Footnotes
for
Appendix
C:

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.
2006
Amount
of
Request
 
The
2006
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.
2006
Nomination
Options
 
2006
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,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
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
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
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
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2006
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
2006
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
Page
34
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
2006
 
Use
rate
in
pounds
per
thousand
cubic
feet,
2006,
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
2006
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.
Page
35
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.
Page
36
APPENDIX
D.
2006
Methyl
Bromide
Reconsideration
for
Rice
Mills
Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
505.982
metric
tons
of
methyl
bromide
for
use
in
mills
and
food
processing
facilities
for
2006.
The
request
was
distributed
as
follows:
114.305
metric
tons
for
rice
mills,
14.742
metric
tons
for
bakeries,
48.081
metric
tons
for
pet
food
facilities,
and
328.854
metric
tons
for
flour
mills.
This
is
a
request
at
the
national
level.

The
U.
S.
nomination
is
only
for
those
facilities
where
the
use
of
alternatives
is
not
suitable.
In
U.
S.
food
processing
plants
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
methyl
bromide,
making
these
alternatives
technically
and/
or
economically
infeasible.
­
Geographic
distribution
of
the
facilities:
some
facilities
are
situated
in
areas
where
key
pests
may
occur
at
low
levels,
such
as
those
located
in
the
northern
part
of
the
U.
S.
In
such
cases,
the
U.
S.
is
only
nominating
a
CUE
for
facilities
where
the
key
pest
pressure
is
moderate
to
high.
­
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.
­
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).
Further,
the
corrosive
nature
of
phosphine
on
certain
metals
prevents
its
use
in
mechanical
and
electrical
areas
of
the
facilities.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
small
grains
such
as
flour,
rice,
oats,
etc.
State
registrations
have
not
yet
been
issued
for
all
states.
Further,
it
will
take
some
time
for
applicators
to
be
trained
in
the
use
of
this
chemical
and
for
its
incorporation
into
a
pest
control
program.
A
registration
decision
concerning
the
establishment
of
sulfuryl
fluoride
tolerances
on
other
processed
food
ingredients
in
a
treated
facility
is
still
pending.
­
Delay
in
plant
operations:
e.
g.,
the
use
of
some
methyl
bromide
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.

MBTOC
recommended
a
total
of
394.843
metric
tons
of
methyl
bromide
for
this
sector
distributed
as
follows:
73.745
metric
tons
for
rice
mills,
14.742
metric
tons
for
bakery
uses,
43.273
for
dry
pet
food
premises,
and
263.083
for
flour
mills.
The
total
recommendation
was
for
394.843
metric
tons
of
methyl
for
these
uses
in
2006.

MBTOC
stated
that
proper
sealing
should
allow
rice
mills
to
reduce
their
use
rate
from
31g/
m
3
to
20
g/
m3.
Although
there
is
no
evidence
that
proper
sealing
procedures
are
not
followed
and
that
is
the
reason
for
the
higher
use
rate
than
is
common
for
the
remainder
of
the
sector,
USG
agrees
that
in
general,
a
use
rate
of
20g/
m3
should
allow
for
adequate
control
of
pests
but
reserves
the
right
to
re­
visit
this
issue
should
we
become
aware
of
data
demonstrating
that
this
level
is
not
adequate
to
control
pests
in
the
specific
circumstances
of
the
nomination
when
Page
37
appropriate
practices
(
eg
careful
sealing
of
the
building/
container
and
other
`
best
practices')
are
followed.
This
reduction
results
in
an
amended
U.
S.
request
of
73.745
metric
tons
of
methyl
bromide
for
this
portion
of
the
sector
as
recommended
by
MBTOC.

MBTOC
appears
to
believe
that
better
sealing
in
rice
facilities
is
necessary
because
they
believe
that
facilities
are
treated
five
times
per
year.
In
this
industry,
the
majority
of
the
milling
facilities
are
old
and
located
in
the
southern
US1
(
close
to
where
rice
is
produced
in
Florida,
Texas,
Louisiana,
Arkansas
and
California)
where
pest
pressures
are
high
and
where
insects
are
able
to
survive
easily
when
driven
outdoors
by
fumigation.
In
addition,
bringing
new
batches
of
rice
into
the
facilities
can
result
in
a
re­
infestation.
USG
does
not
think
that
there
is
further
scope
for
reduction
in
rice
mills.

MBTOC
recommended
that
the
use
rate
for
pet
food
facilities
be
reduced
from
22
to
20
g/
m3.
USG
agrees
that
in
general,
a
use
rate
of
20g/
m3
should
allow
for
adequate
control
of
pests
but
reserves
the
right
to
re­
visit
this
issue
should
we
become
aware
of
data
demonstrating
that
this
level
is
not
adequate
to
control
pests
in
the
specific
circumstances
of
the
nomination
when
appropriate
practices
(
eg
careful
sealing
of
the
building/
container
and
other
`
best
practices')
are
followed.
This
reduction
results
in
an
amended
U.
S.
request
of
44.417
metric
tons
of
methyl
bromide
for
this
portion
of
the
sector,
an
increase
of
1.144
metric
tons
over
the
MBTOC
recommended
amount
of
43.273
metric
tons
MBTOC
further
recommended
that
the
request
for
methyl
bromide
used
in
pet
food
facilities
be
reduced
by
10%
"
to
allow
progressive
adoption
of
fumigant
alternatives
such
as
sulfuryl
fluoride
(
recently
registered
for
flour
mills
(
sic)
2,
continuing
adoption
of
heat
technologies,
improved
sealing
of
buildings,
and
increased
optimization
of
IPM
techniques."

Sulfuryl
fluoride
is
not
registered
for
use
on
dry
pet
food.
There
is
at
present
a
legal
question
as
to
whether
a
registration
is
required
(
authorizing
statute
refers
to
"
foods
for
human
and
other
animals")
or
not
required.
Until
this
issue
is
clarified
sulfuryl
fluoride
cannot
be
used
on
pet
foods.

MBTOC
has
recommended
a
further
reduction
of
10%
in
the
amount
of
methyl
bromide
that
can
be
used
to
fumigate
flour
mills,
citing
increased
adoption
of
sulfuryl
fluoride
in
particular,
and
adoption
of
other
alternatives
more
generally.

Addressing
first
the
issue
of
sulfuryl
fluoride;
as
already
noted,
sulfuryl
fluoride
is
not
registered
in
all
States,
nor
is
it
registered
on
the
additional
components
that
transform
flour
into
bread,
cake,
pancake
and
other
mixes.
It
cannot,
therefore,
be
used
at
all
in
some
jurisdictions
nor
can
it
be
used
in
many
areas
of
`
combined'
processing
facilities.

1
Location
of
the
facilities
is
dictated
by
close
proximity
to
the
raw
ingredients
and
to
major
markets.
For
example,
the
22
rice
mills
are
located
primarily
in
Gulf
Coast
states
and
California.
2
There
is
a
Federal
registration
for
sulfuryl
fluoride
use
in
flour
mills,
rice
mills,
and
other
small
grain
mills,
however,
many
states
have
registration
requirements
in
addition
to
the
Federal
requirements
and
until
a
pesticide
has
obtained
a
state
`
label'
it
cannot
be
used.
At
present
Sulfuryl
Fluoride
is
registered
in
neither
California
nor
New
York
and
so
cannot
be
use
in
those
states.
Page
38
The
Montreal
Protocol
calls
for
a
critical
use
nomination
being
granted
when
there
are
no
alternatives
that
are
both
technically
and
economically
feasible,
There
are
companies
that
have
committed
themselves
to
using
alternatives
to
methyl
bromide
regardless
of
the
cost
differences
as
long
as
they
can
continue
to
meet
necessary
sanitary
standards.
One
such
company
shared
their
experience
with
sulfuryl
fluoride
with
us3
A
nine
story
flour
mill
(
1.2
million
cubic
feet4)
was
fumigated
with
sulfuryl
fluoride.
The
fumigation
took
place
from
October
1st
to
October
3rd.
When
this
facility
has
been
fumigated
with
methyl
bromide
the
typical
amount
used
has
been
between
1200
and
1500
lbs5.
The
fumigation
with
sulfuryl
fluoride
used
5250
lbs.
at
a
temperature
of
826
F
over
a
36
hour
rather
than
a
24
hour
period.
Although
fumigation
with
sulfuryl
fluoride
requires
that
the
material
be
left
in
place
for
a
longer
period
than
is
required
for
methyl
bromide,
this
component
does
not
add
to
the
cost
of
the
alternative
in
this
instance
as
it
is
the
practice
of
this
company
to
conduct
fumigations
over
a
three
day
period
to
allow
adequate
time
for
preparation
and
for
the
gas
to
dissipate
at
the
conclusion
of
the
fumigation.

The
cost
of
a
methyl
bromide
fumigation
is
approximately
$
18,500
of
which
approximately
30­
40%
is
the
cost
of
the
chemical.
The
remaining
costs
are
preparing
and
sealing
the
building,
monitoring,
and
unsealing
at
the
conclusion
of
the
fumigation.
The
cost
of
the
sulfuryl
fluoride
fumigation
was
$
48,000,
nearly
three
times
the
cost
of
the
methyl
bromide
fumigation.
The
ancillary
costs
(
prepping,
sealing,
monitoring,
unsealing,
etc.)
are
the
same
for
both
treatments,
the
cost
difference
is
due
to
the
difference
in
the
price
and
amount
used
of
the
sulfuryl
fluoride.

At
present
the
company
that
produces
sulfuryl
fluoride
is
offering
sulfuryl
fluoride
at
a
price
per
pound
that
is
equal
to
or
below
the
price
of
methyl
bromide.
What
is
not
known
is
whether
this
practice
will
continue
when
methyl
bromide
is
no
longer
available.
There
is
currently
a
sulfuryl
fluoride
product
(
Vikane
®
)
that
is
registered
for
non­
food
uses7.
The
market
price
is
$
10/
lb.
Although
we
expect
that
the
food
use
sulfuryl
fluoride
(
Profume
®
)
to
be
less
expensive,
it
is
currently
impossible
to
determine
the
market
price.
This
compares
to
a
methyl
bromide
cost
of
approximately
$
1.5
to
$
3.0
per
pound.

Over
the
last
decade,
food
processing
facilities
in
the
United
States
have
reduced
the
number
of
methyl
bromide
fumigations
by
incorporating
many
of
the
alternatives
identified
by
MBTOC.
The
most
critical
alternative
implemented
is
IPM
strategies,
especially
sanitation,
in
all
areas
of
a
facility.
Plants
are
now
being
monitored
for
pest
populations,
using
visual
inspections,
pheromone
traps,
light
traps
and
electrocution
traps.
When
insect
pests
are
found,
plants
will
attempt
to
contain
the
infestation
with
treatments
of
low
volatility
pesticides
applied
to
both
surfaces
and
cracks
and
crevices.
These
techniques
do
not
disinfest
a
facility
but
are
critical
in
3
The
company
has
requested
confidentiality.
There
is
great
concern
within
the
industry
that
the
perception
that
food
facilities
are
infested
with
pests
not
become
widespread.
There
was
great
fear
on
the
part
of
company
officials
that
if
the
company
is
identified
with
a
pest
management
issue
the
public
will
boycott
its
products,
feeling
them
(
wrongly)
to
be
unsanitary.
The
discussion
was
arranged
under
the
auspices
of
the
North
American
Millers
Association
and
took
place
in
Arlington
Virginia
in
November
of
2004.
4
1.2
million
cubic
feet
is
approximately
33,980
cubic
meters.
5
1200
to
1500
lbs
is
545
to
680
kg.
The
use
rates
have
thus
varied
between
16
and
20
g/
m3.
6
5250
lbs
is
2380
kg;
82
F
is
28
C.
The
use
rate
is
thus
70g/
m3.
7
Vikane
®
is
primarily
used
as
a
termiticide
for
wood
structures
and
furniture.
Page
39
monitoring
and
managing
pests.
However,
when
all
these
methods
fail
to
control
a
pest
problem,
facilities
will
resort
to
phosphine,
heat,
and
if
all
else
fails,
to
methyl
bromide.

Many
facilities
in
the
United
States
also
are
using
both
phosphine
and
heat
treatments
to
disinfest
at
least
portions
of
their
plants.
Phosphine,
alone
and
in
combination
with
carbon
dioxide,
is
often
used
to
treat
both
incoming
grains
and
finished
products.
Unfortunately,
phosphine
is
corrosive
to
copper,
silver,
gold
and
their
alloys.
These
metals
are
critical
components
of
both
the
computers
that
run
the
machines
as
well
as
some
of
the
machines
themselves.
In
the
United
States
it
is
specifically
against
the
label
(
illegal)
to
fumigate
in
areas
with
susceptible
metals
(
at:
http://
oaspub.
epa.
gov/
pestlabl/
ppls).
Therefore,
phosphine
is
not
feasible
in
all
areas
of
food
processing
facilities.
Additionally,
phosphine
requires
more
time
to
kill
insect
pests
than
does
methyl
bromide,
so
plants
need
to
be
shut
down
longer
to
achieve
mortality,
resulting
in
economic
losses.
There
are
also
reports
of
stored
product
pests
becoming
resist
to
phosphine
(
Taylor,
1989;
Bell,
2000;
Mueller,
2002).

Heat
treatments
have
a
number
of
problems
in
this
industry.
Not
all
areas
of
a
plant
can
be
efficiently
treated
with
heat.
Some
food
substances,
for
instance
oils
and
butters
will
become
rancid
with
heat
treatments.
Not
all
finished
food
products
can
be
heated
for
the
length
of
time
heat
is
required
for
efficient
kill
of
pests.
In
addition,
geography
of
the
United
States
plays
a
crucial
role
in
the
use
of
heat
treatments.
Food
processing
plants
in
the
northern
United
States
will
experience
winters
with
several
weeks
of
sustaining
temperatures
of
­
32
°
to
­
35
°
C
(­
30
°
to
­
25
°
F).
In
these
areas
plants
have
heaters
and
the
power
plants
have
the
capacity
to
supply
excess
power
as
needed.
However,
the
southern
and
parts
of
the
western
zones
of
the
United
States
are
geographically
quite
different.
Winter
temperatures
there
seldom
reach
 
1.2
°
C
(
30
°
F)
and
when
temperatures
should
fall
that
low,
it
is
typically
for
only
a
few
hours
one
night.
For
many
winters,
these
areas
of
the
U.
S.
don't
freeze
at
all.
Subsequently,
these
facilities
do
not
have
heaters,
nor
do
the
power
plants
have
enough
power
to
allow
them
to
heat
such
large
areas
and
sustain
the
temperatures
necessary
for
an
effective
kill
of
pest
populations.
Additionally,
escaping
insects
can
survive
these
outdoor
temperatures
and
re­
enter
the
facility
after
treatment,
even
when
low
volatility
pesticides
are
used
to
treat
the
surfaces
exiting
the
plant.
Still,
many
southern
and
western
facilities
use
heat
treatments
as
a
spot
treatment
whereas
the
northern
facilities
can
use
heat
treatments
more
extensively.

Potential
economic
losses
were
estimated
for
the
food­
processing
facilities
that
have
not
been
converted
to
heat
treatment.
This
analysis
only
covers
cases
where
heat
treatment
may
potentially
be
technically
feasible,
and
does
not
cover
situations
where
heat
would
degrade
the
commodity
being
processed
(
those
with
fats
and
edible
oils).
Economic
costs
in
the
post­
harvest
uses
of
the
food­
processing
sector
can
be
characterized
as
arising
from
three
contributing
factors.
First,
the
direct
pest
control
costs
are
increased
in
most
cases
because
heat
treatment
is
more
expensive,
and
labor
is
increased
because
of
longer
treatment
time
and
increased
number
of
treatments.
For
food­
processing
facilities
that
are
not
already
using
heat,
capital
expenditure
is
also
required
to
retrofit
them
suitable
for
heat
treatment.
Moreover,
additional
production
downtimes
for
the
use
of
alternatives
are
unavoidable.
Many
facilities
operate
at
or
near
full
production
capacity
and
alternatives
that
take
longer
than
methyl
bromide
or
require
more
frequent
application
can
result
in
manufacturing
slowdowns,
shutdowns,
and
shipping
delays.
Slowing
down
production
would
result
in
additional
costs
to
the
methyl
bromide
users.
Page
40
Economic
cost
per
1000
m3
was
calculated
as
the
additional
costs
of
methyl
bromide
if
methyl
bromide
users
had
to
replace
methyl
bromide
with
heat
treatment.
Implementations
of
heat
treatment
likely
have
substantial
cost
implications
to
the
facilities
that
have
not
been
converted
to
heat
in
the
food­
processing
sector.

Production
downtime
was
estimated
at
two
more
days
per
fumigation
with
heat
and
total
capital
expenditures
for
heat
treatment
was
assumed
to
be
$
1,076
per
1000
m3
with
10­
years
lifespan
with
10%
interest
rate
from
the
data
provided
by
the
CUE
applicants
for
post­
harvesting
uses.
The
potential
economic
losses
associated
with
the
use
of
heat
treatment
mainly
originate
from
the
cost
of
capital
investment.
The
estimated
economic
loss
per
1000
m3
ranges
from
$
2,023
for
rice
milling
to
$
12,439
for
flour/
grain
milling.
The
estimated
economic
losses
as
a
percentage
of
gross
revenue
ranges
from
3%
to
18%
and
the
estimated
economic
loss
as
a
percentage
of
net
revenue
are
over
45%
for
all
the
CUE
applicants
in
the
food­
processing
sector.
The
industries
that
use
methyl
bromide
for
commodity
fumigation
are,
in
general,
subject
to
limited
pricing
power,
changing
market
conditions,
and
government
regulations.
Companies
within
these
industries
operate
in
a
highly
competitive
global
marketplace
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories.
The
results
suggest
that
heat
treatment
is
not
economically
viable
as
an
alternative
for
methyl
bromide
in
existing
facilities
that
still
use
methyl
bromide.

For
these
reasons,
both
technical
and
economic,
USG
does
not
believe
it
is
appropriate
to
assume
that
alternatives
that
are
both
technically
and
economically
feasible
will
be
available
to
substitute
for
currently
used
methyl
bromide
in
flour
mills
and
is
requesting
that
the
full
request
of
328.854
metric
tons
of
methyl
bromide,
which
is
an
additional
65.771
metric
tons
of
methyl
bromide
over
the
MBTOC
recommended
amount
of
263.083
metric
tons.

Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.

We
have
not
been
provided
by
MBTOC
with
information
on
the
technical
assessment
of
the
performance
of
alternatives,
or
the
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,
and
the
economic
feasibility
of
sulfuryl
fluoride
if
it
must
be
used
at
a
higher
rate
than
methyl
bromide.

U.
S.
2006
nomination
The
USG
is
requesting
an
additional
66.915
metric
tons
of
methyl
bromide
for
2006
over
the
MBTOC
recommended
amount
of
394.843
metric
tons
for
use
in
flour
mills.
This
represents
an
amended
request
of
461.758
metric
tons
rather
than
the
505.982
metric
tons
of
methyl
bromide
originally
requested.

Citations
Page
41
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F.
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2000.
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1992.
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2002.
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Dunkel,
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1998.
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Mahroof,
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