METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
POST
HARVEST
USE
BY
NPMA
FOR
FACILITIES
AND
COMMODITIES
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
by
NPMA
for
Facilities
and
Commodities
(
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.
Post­
Harvest
NPMA
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.
Post­
Harvest
NPMA
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY...................................................................................................................
6
1.
Nominating
Party..............................................................................................................
6
2.
Descriptive
Title
of
Nomination........................................................................................
6
3.
Situation
of
Nominated
Methyl
Bromide
Use
..................................................................
6
4.
Methyl
Bromide
Nominated
For
Post­
Harvest
Use
(
Commodities
and
Facilities)
Not
Included
in
Other
Chapters..................................................................................................
6
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use.................................
6
6.
Methyl
Bromide
Consumption
for
Past
5
Years
and
Amount
Requested
in
the
Year(
s)
Nominated
For
Post
Harvest
Use
(
commodities
and
facilities)
not
included
in
other
chapters..
8
7.
Location
of
the
Facility
or
Facilities
Where
the
Proposed
Critical
Use
of
Methyl
Bromide
Will
Take
Place.......................................................................................................................
9
PART
B:
SITUATION
CHARACTERISTICS
AND
METHYL
BROMIDE
USE...................
10
8.
Key
Pests
for
which
Methyl
Bromide
is
Requested
...........................................................
10
9
Summary
of
the
Circumstances
in
which
the
Methyl
Bromide
is
Currently
being
Used
.............................................................................................................................................
12
10.
List
Alternative
Techniques
that
are
being
Used
to
Control
Key
Target
Pest
Species
in
this
Sector........................................................................................................................
12
PART
C:
TECHNICAL
VALIDATION...................................................................................
14
11.
Summarize
the
Alternative(
s)
Tested,
Starting
with
the
Most
Promising
Alternative(
s).......................................................................................................................
14
12.
Summarize
Technical
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances:
........................................................................................................
16
PART
D:
EMISSION
CONTROL
...........................................................................................
17
13.
How
has
this
Sector
Reduced
the
Use
and
Emissions
of
Methyl
Bromide
in
the
Situation
of
the
Nomination?..............................................................................................
17
PART
E:
ECONOMIC
ASSESSMENT...................................................................................
18
14.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
.................
18
15.
Summarize
Economic
Reasons,
if
any,
for
each
Alternative
not
being
Feasible
or
Available
for
your
Circumstances
......................................................................................
18
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives.....................................
20
PART
F:
FUTURE
PLANS.....................................................................................................
20
16.
Provide
a
Detailed
Plan
Describing
how
the
Use
and
Emissions
of
Methyl
Bromide
will
be
Minimized
in
the
Future
for
the
Nominated
Use....................................................................
20
17.
Provide
a
Detailed
Plan
Describing
what
Actions
will
be
Undertaken
to
Rapidly
Develop
and
Deploy
Alternatives
for
this
Use....................................................................
20
17.1.
Research......................................................................................................................
20
17.2.
Registration
...............................................................................................................
22
18.
Additional
Comments
...................................................................................................
22
19.
Citations.........................................................................................................................
23
Bibliography........................................................................................................................
24
APPENDIX
A
PUBLISHED
PERFORMANCE
DATA..........................................................
26
U.
S.
Post­
Harvest
NPMA
iv
APPENDIX
B.
2007
METHYL
BROMIDE
USAGE
NUMERICAL
INDEX
(
BUNI)............
28
APPENDIX
C.
2006
METHYL
BROMIDE
RECONSIDERATION
FOR
DRY
COMMODITIES:
COCOA
BEANS.
.......................................................................................
32
APPENDIX
D.
2006
METHYL
BROMIDE
RECONSIDERATION
FOR
DRY
COMMODITIES:
HERBS,
SPICES,
DRIED
MILK,
CHEESE
PROCESSING....................
34
U.
S.
Post­
Harvest
NPMA
v
List
of
Tables
PART
A:
SUMMARY...................................................................................................................
6
Table
4.1:
Methyl
Bromide
Nominated
For
Post­
Harvest
Use
(
Commodities
and
Facilities)
Not
Included
in
Other
Chapters..................................................................................................
6
Table
A.
1:
Executive
Summary...................................................................................................
8
Table
6.1:
Methyl
Bromide
Consumption
for
the
Past
5
Years
and
the
Amount
Requested
in
the
Year(
s)
Nominated
For
Post­
Harvest
Use
(
Commodities
and
Facilities)
Not
Included
In
Other
Chapters
....................................................................................................................
8
PART
B:
SITUATION
CHARACTERISTICS
AND
METHYL
BROMIDE
USE...........................
10
Table
8.1:
Key
Pests
for
Methyl
Bromide
Request:
Facilties
......................................................
10
Table
8.2:
Key
Pests
for
Methyl
Bromide
Request:
Commodities
.............................................
10
Table
B.
1:
Characteristic
of
Sector
­
Facilities
..........................................................................
11
Table
B.
2:
Characteristic
of
Sector:
Commodities
.....................................................................
11
Table
9.1:
(
a)
Food
Processing
Plants........................................................................................
12
Table
9.1:
(
b)
Fixed
Facilities
...................................................................................................
12
PART
C:
TECHNICAL
VALIDATION.......................................................................................
14
Table
11.1:
Summary
of
the
Alternatives
Tested.......................................................................
14
Table
11.2:
Summary
of
Review
or
Position
Papers
concerning
Alternatives
for
Stored
Product
Pests..................................................................................................................................
15
Table
12.1:
Summary
of
Technical
Reason
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................................
16
Table
12.2:
Comparison
of
Alternatives
to
Methyl
Bromide
Fumigation...................................
17
PART
D:
EMISSION
CONTROL
..............................................................................................
17
PART
E:
ECONOMIC
ASSESSMENT.......................................................................................
18
Table
15.1:
Summary
of
Economic
Reasons
for
each
Alternative
not
being
Feasible
or
Available
..........................................................................................................................................
18
PART
F:
FUTURE
PLANS
.......................................................................................................
20
APPENDIX
A
PUBLISHED
PERFORMANCE
DATA...............................................................
26
Appendix
A
­
Table
1:
Effect
of
temperature
on
concentration
and
time
thresholds
for
some
pests
of
stored
products.
(
From:
Bell,
C.
H.
2000)......................................................................
26
Appendix
A
­
Table
2:
Concentration­
Time
Product
recommendations
by
National
Pest
Management
Association
..................................................................................................
27
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
..................................
28
Page
6
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
By
NPMA
For
Facilities
and
Commodities
(
Prepared
in
2005)

3.
SITUATION
OF
NOMINATED
METHYL
BROMIDE
USE
This
sector
includes
commodities
and
food
processing
plants
treated
by
National
Pest
Management
Association
(
NPMA)
members.
Commodities
included
in
this
application
are;
processed
foods
(
such
as
chips,
crackers,
cookies
and
pasta),
spices
and
herbs,
cocoa,
dried
milk,
tea
pellets,
coffee
beans,
tomato
and
bell
peppers,
citrus
and
cassava.
Methyl
bromide
is
typically
utilized
in
processed
food
and
feed
facilities
as
a
space
fumigant
for
treating
the
facility
1
to
3
times
per
year.
As
the
need
arises,
methyl
bromide
is
also
used
for
trailer
fumigations
of
product
or
packaging
material.
These
facilities
are
under
intense
pressure
from
many
insect
pests
as
well
as
rodents.

4.
METHYL
BROMIDE
NOMINATED
FOR
POST­
HARVEST
USE
(
COMMODITIES
AND
FACILITIES)
NOT
INCLUDED
IN
OTHER
CHAPTERS
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
FOR
POST­
HARVEST
USE
(
COMMODITIES
AND
FACILITIES)
NOT
INCLUDED
IN
OTHER
CHAPTERS
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
VOLUME
(
1000
M
3)

2007
147,320
7,358
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
CUE
nomination
in
this
sector
includes
a
request
for
methyl
bromide
use
only
where
use
of
alternatives
is
limited
for
the
reasons
described
below:
1.
pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
2.
technical
difficulties
in
adopting
alternatives,
for
example
heat
may
not
be
suitable
for
wood
frame
buildings
or
commodities
with
high
oil
content
(
development
of
rancidity)
3.
regulatory
concerns,
such
as
the
adoption
of
a
new
fumigant,
such
as
sulfuryl
fluoride,
that
may
not
be
registered
for
all
sites
or
in
all
states
Page
7
COMMODITIES:
Methyl
bromide
fumigation
for
commodities
occurs
to
ensure
pest­
free
food
and
meet
the
strict
requirements
of
the
Food
Sanitation
Regulations.
The
uses
listed
in
this
chapter,
processed
foods
(
chips,
cookies,
crackers,
pasta,
etc.),
spices
and
herbs,
cocoa,
dried
milk,
cheese,
tea
pellets,
coffee
beans,
have
no
technically
feasible
alternative
that
can
be
used
without
incurring
significant
economic
losses.
Phosphine,
alone
or
combined
with
carbon
dioxide,
is
the
only
chemical
alternative
currently
available
for
use
on
these
commodities.
Phosphine
fumigations,
however,
take
much
longer
than
methyl
bromide
fumigations
and
are
not
a
feasible
alternative
when
rapid
fumigations
are
needed.
Harvest
of
commodities
occurs
in
autumn,
when
temperatures
are
falling,
making
temperature­
dependent
phosphine
fumigation
less
likely.
These
sectors
are
already
using
phosphine
alone
or
in
combination
to
the
extent
that
their
processing
systems
and
marketing
needs
allow
it.
Any
additional
shifting
from
methyl
bromide
to
the
slower
phosphine
fumigation
would
result
in
disruption
of
commodity
processing
during
peak
production
times,
lost
market
windows,
and
substantial
economic
losses.
In
addition,
adoption
of
not
in
kind
alternatives,
such
as
controlled
atmospheres,
cold,
and
carbon
dioxide
under
pressure,
would
require
major
investments
for
appropriate
treatment
units
and
/
or
retrofitting
of
existing
warehouses.

FACILITIES:
Food
processing
facilities
in
the
United
States
have
reduced
the
number
of
methyl
bromide
fumigations
by
incorporating
many
of
the
alternatives
identified
by
MBTOC.
Most
important
have
been
implementing
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.

Facilities
in
the
United
States
also
are
using
both
phosphine
and
heat
treatments
to
disinfest
at
least
portions
of
their
plants.
Phosphine,
both
alone
and
in
combination
with
carbon
dioxide,
is
often
used
to
treat
incoming
grains
and
some
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
in
the
plants.
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
maximum
insect
mortality,
with
associated
economic
losses
from
this
downtime.
There
are
also
reports
of
stored
product
insects
becoming
resistant
to
phosphine.

There
are
a
number
of
limitations
associated
with
the
use
of
heat
in
this
industry.
Not
all
areas
of
a
plant
can
be
efficiently
fumigated
with
heat.
Some
food
substances,
for
instance
cheeses,
will
go
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
treatment.
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
some
plants
have
heaters
and
the
power
plants
have
the
capability
to
supply
excess
power
as
needed.
However,
the
southern
zones
and
parts
of
the
western
zones
of
the
United
States
are
geographically
quite
different
from
the
northern
areas.
Winter
temperatures
in
the
south
and
west
seldom
reach
 
1.2
°
C
(
30
°
F)
and
if
temperatures
fall
that
low,
it
is
Page
8
typically
for
only
a
few
hours
one
night.
Frequently
winters
in
these
warmer
areas
of
the
U.
S.
do
not
freeze
at
all.
Subsequently,
these
facilities
do
not
have
heaters,
nor
do
the
power
plants
have
sufficient
power
to
allow
them
to
heat
such
large
areas
and
sustain
the
temperatures
necessary
for
a
kill.
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
in
the
plant
and
its
perimeter.
Still,
many
southern
and
western
facilities
use
heat
treatments
as
a
spot
treatment
whereas
some
northern
facilities
use
heat
treatments
for
all
or
parts
of
their
plants.

By
utilizing
all
these
options,
facilities
in
the
U.
S.
have
been
able
to
reduce
the
number
of
methyl
bromide
fumigations
from
an
average
of
6
times
a
year
to
an
average
of
2
times
in
the
south
and
west
and
once
every
3
to
5
years
in
the
north.
The
U.
S.
CUE
nomination
in
this
sector
only
includes
a
request
for
methyl
bromide
use
where
use
of
alternatives
is
limited
for
the
reasons
described
above.
There
are
many
food
processing
facilities
in
the
U.
S.
for
which
we
are
not
requesting
methyl
bromide
use
because
they
have
been
able
to
successfully
implement
alternatives.
This
U.
S.
CUE
nomination
in
this
sector
includes
a
request
for
methyl
bromide
only
where
use
of
alternatives
is
limited
for
the
reasons
described
above.

TABLE
A.
1:
EXECUTIVE
SUMMARY*
Processed
Foods
(
chips,
cookies,
crackers,
Pasta,
etc)
Spices
and
Herbs
Cocoa
Cheese
processing
Plants
Other
Commodity1
AMOUNT
OF
REQUEST
(
KG)
2007
93,319
10,800
79,950
3,856
1,126
NOMINATED
AMOUNT
(
KG)
2007
74,884
4,891
64,082
2,996
467
*
See
Appendix
B
for
complete
description
of
how
the
nominated
amount
was
calculated.
1Includes
tea
on
pallets,
coffee
beans,
tomatoes,
bell
peppers,
citrus
and
cassava.

6.
METHYL
BROMIDE
CONSUMPTION
FOR
PAST
5
YEARS
AND
AMOUNT
REQUESTED
IN
THE
YEAR(
S)
NOMINATED
FOR
POST
HARVEST
USE
(
COMMODITIES
AND
FACILITIES)
NOT
INCLUDED
IN
OTHER
CHAPTERS
TABLE
6.1:
METHYL
BROMIDE
CONSUMPTION
FOR
THE
PAST
5
YEARS
AND
THE
AMOUNT
REQUESTED
IN
THE
YEAR(
S)
NOMINATED
FOR
POST
HARVEST
USE
(
COMMODITES
AND
FACILITIES)
NOT
INCLUDED
IN
OTHER
CHAPTERS*

HISTORICAL
USE*
REQUESTED
USE
For
each
year
specify:
1998**
1999
2000
2001
2002
2003**
2007
Amount
of
MB
(
kg)
220,300
219,616
193,149
217,636
189,050
Volume
Treated
(
1000
m
³
)
7,020
8,037
6,791
8,293
7,868
Formulation
of
MB
The
applicant
did
not
provide
any
information
on
formulation
Unknown
Dosage
Rate
(
kg/
1000
m
³
)
24.03
24.03
24.03
24.03
24.03
Actual
(
A)
Estimate
(
E)
Unknown
Unknown
*
Based
on
most
current
information.
**
No
data
from
NPMA
for
1998
&
2003.
Page
9
7.
LOCATION
OF
THE
FACILITY
OR
FACILITIES
WHERE
THE
PROPOSED
CRITICAL
USE
OF
METHYL
BROMIDE
WILL
TAKE
PLACE
This
nomination
package
represents
a
wide
variety
of
food
processing
and
commodity
facilities.
The
location
of
each
facility
where
methyl
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.

The
location
of
each
facility
where
methyl
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
10
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:
FACILITIES
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
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
regulations.
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
regulations.
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.
cfsan.
fda.
gov/~
dms/
dalbook.
html
and
http://
www.
fda.
gov/
opacom/
laws/
fdcact/
fdcact4.
htm.

TABLE
8.2:
KEY
PESTS
FOR
METHYL
BROMIDE
REQUEST:
COMMODITIES
GENUS
AND
SPECIES
FOR
WHICH
THE
USE
OF
METHYL
BROMIDE
IS
CRITICAL
COMMON
NAME
SPECIFIC
REASON
WHY
METHYL
BROMIDE
IS
NEEDED
Cydia
pomonella
Codling
moth
Amyelois
transitella
Navel
orangeworm
Plodia
interpunctella
Indianmeal
moth
Tribolium
castaneum
Red
Flour
Beetle
Cadra
figulilella
Raisin
Moth
Carpophilus
sp.
Dried
Fruit
Beetle
Ectomyelois
ceratoniae
Carob
pod
moth
Carpophilus
spp.,
Haptoncus
spp.
Nitidulid
beetles
MB
is
used
mainly
where
rapid
fumigations
are
needed
to
meet
customer
timelines
during
critical
market
windows
and
peak
production
periods.
During
peak
production
months,
phosphine
fumigation
takes
three
times
longer
than
conventional
MB
fumigation
and
17
times
longer
than
vacuum
MB
fumigation.
The
required
duration
of
phosphine
fumigation
increases
as
commodity
temperature
decreases,
making
its
use
impractical
during
the
cold
winter
months.
No
technically
or
economically
feasible
alternatives
exist
at
present
during
these
critical
periods.
Page
11
TABLE
B.
1:
CHARACTERISTIC
OF
SECTOR
­
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
N/
A
*
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.

TABLE
B.
2:
CHARACTERISTIC
OF
SECTOR:
COMMODITIES
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Fumigation
Schedule
(
MB):
All
Commodities
X
X
X
X
X
X
X
X
X
X
X
X
Retail
Target
Market
Window:
All
Commodities
X
X
X
X
Although
fumigations
may
occur
whenever
a
pest
population
explosion
occurs,
ideally
foodprocessing
plants
will
be
fumigated
with
methyl
bromide
on
3­
day
holiday
weekends
just
prior
to
the
summer
and
at
summer's
end.
This
maximizes
efficiency
since
the
facilities
are
usually
closed
and
workers
are
not
present;
and
prior
to
very
warm
temperatures
that
increases
insect
pressure.
Page
12
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/
1000m
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)
National
Pest
Management
Association
Ave.
24­
48
24
hrs
1­
3
60­
100%
F,
M
TABLE
9.1:
(
b)
FIXED
FACILITIES
CUE
TYPE
OF
CONSTRUCTION
AND
APPROXIMATE
AGE
IN
YEARS
VOLUME
(
1,000m
³
)
OR
RANGE
NUMBER
OF
FACILITIES
GASTIGHTNESS
ESTIMATE
National
Pest
Management
Association
5­
10%
1­
15
yrs
old
typically
newer
structures
are
tilt­
up
concrete
construction.

80%
15­
75
yrs
old,
combination
of
metal,
wood,
brick
and
concrete.

5­
10%
75+
years
old,
combination
of
construction
materials
and
methods.
Not
available
Not
available
Tilt­
up
concrete
 
good
to
medium
Metal,
wood,
brick
construction
 
medium
to
poor.

Trailers/
containers
 
good
to
poor,
must
be
inspected
prior
to
treatment.

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
render
a
facility
free
of
pests.
.
The
most
critical
of
these
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.
In
addition
a
major
problem
is
the
infestation
of
equipment
and
bins
where
there
are
no
legal
pesticides
for
those
use
sites
other
than
the
fumigants.
Although
FDA
allows
minimal
contamination
of
food
products,
there
is
a
zero
tolerance
for
insects
imposed
by
market
demands,
therefore,
neither
sanitation
nor
IPM
is
acceptable
as
an
alternative
to
methyl
bromide
fumigation;
but
these
strategies
are
used
to
manage
pest
populations
and
extend
the
time
between
methyl
bromide
fumigations.
Page
13
In
addition
to
sanitation
and
IPM,
most
food
processing
manufacturers
in
the
United
States
currently
use
both
phosphine,
alone
and
in
combination
with
carbon
dioxide,
and
heat
to
fumigate
their
facilities.
Many
of
the
facilities
treat
incoming
grains
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.
Phosphine
is
problematic
in
that
some
stored
product
pests
are
already
becoming
resistant
to
this
chemical
(
Bell
2000).
Some
facilities,
probably
due
to
construction,
are
unable
to
use
phosphine
and/
or
heat.
Facilities
in
the
southern
and
western
parts
of
the
United
States
do
not
have
heat
sources
on
the
premises
thereby
making
heat
fumigations
impractical.
Additionally,
heat
is
a
problem
causing
rancidity
in
butters
and
oils
and
denaturing
proteins
that
may
be
used
in
the
facility.
Yet,
there
are
plants
in
the
U.
S.
that
have
incorporated
both
fumigation
techniques
and
still
need
to
fumigate
with
methyl
bromide
although
they
have
been
able
to
lengthen
times
between
methyl
bromide
applications,
thereby
reducing
the
amount
of
methyl
bromide
used.
Page
14
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
PEST
STUDY
TYPE
RESULTS
CITATION
T.
castaneum
Pilot
feed
and
flour
mills;
Insects
contained
in
plastic
boxes.
Non­
uniform
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
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
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
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
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
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
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
confusum.
Zettler
1991
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
15
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:
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;
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;
modified
atmospheres:
activity
slow,
requires
air­
tight
structures;
sulfuryl
fluoride1:
no
food
tolerances
in
the
U.
S.,
no
registration
for
this
use.
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
(
Table
1,
Appendix
A)
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
1At
the
time
of
this
review,
sulfuryl
fluoride
had
not
been
registered
in
the
United
States
for
any
food
uses.
The
new
registration
does
not
include
the
commodities
within
this
sector.
Page
16
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
and
are
not
subsidized
by
the
federal
government.
Downtime
required
for
CO2
alone
is
much
longer,
at
6­
12
days.
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.
In
addition
some
of
the
equipment
itself
(
for
example:
motors,
mixers,
etc.)
also
have
metal
parts
that
contain
copper.
In
addition
it
requires
longer
application
time
and
is
temperature
sensitive.
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.
Sulfuryl
fluoride
No
United
States
recent
registration
does
not
include
these
uses
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.
Cold
Treatment
No
Contact
Insecticides
No
Cultural
Practices
No
Electrocution
No
Inert
Dust
No
Pest
Exclusion/
Physical
Removal
No
Pesticides
of
Low
Volatility
No
Pheromones
No
Physical
Removal/
Cleaning
/
Sanitation
No
Rodenticide
No
Does
not
completely
disinfest
facility,
however,
all
facilities
are
using
pheromone
traps
for
monitoring,
electrocution
traps
near
entrances,
sanitation
and
cleaning,
contact
and
low
volatility
insecticides
for
spot
treatments
and
to
prevent
pest
outbreaks.
All
facilities
use
rodenticides
in
traps
for
rodents.
Page
17
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
ONE
MB
APPLICATION
Methyl
Bromide
24
24
24
­­
Phosphine,
alone
24
48­
72
24
0­
2
Phosphine
+
CO2
24
48­
72
24
3­
4
Heat
36
48­
52
24
3­
4
PART
D:
EMISSION
CONTROL
13.
HOW
HAS
THIS
SECTOR
REDUCED
THE
USE
AND
EMISSIONS
OF
METHYL
BROMIDE
IN
THE
SITUATION
OF
THE
NOMINATION?

Using
sanitation,
IPM,
i.
e.
the
"
not­
in­
kind"
alternatives
the
industry
has
been
able
to
reduce
methyl
bromide
use
by
extending
the
time
between
fumigations.
Plants
in
the
southern
United
States
used
to
fumigate
with
methyl
bromide
as
much
as
4­
6
times
a
year.
The
use
of
IPM
strategies
and
more
stringent
sanitation
methods
have
allowed
these
facilities
to
reduce
the
number
of
methyl
bromide
fumigations
to
twice
a
year.
These
fumigations
are
typically
at
the
beginning
of
the
summer
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
with
low
volatility
pesticides
(
organophosphates,
pyrethroids,
insect
growth
regulators,
botanicals)
at
the
perimeters
to
kill
pests
within
the
facilities.

The
use
of
methyl
bromide
in
food
processing
plants
in
the
U.
S.
is
minimized
in
several
ways.
In
preparation
for
the
loss
of
methyl
bromide,
the
food
processing
industry
has
been
active
in
finding
ways
to
reduce
pests
in
the
plants
(
these
techniques
were
described
in
Table
12.1).
Page
18
PART
E:
ECONOMIC
ASSESSMENT
14.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
No
data
are
available.

15.
SUMMARIZE
ECONOMIC
REASONS,
IF
ANY,
FOR
EACH
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
FOR
YOUR
CIRCUMSTANCES
TABLE
15.1.
SUMMARY
OF
ECONOMIC
REASONS
FOR
EACH
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
NO.
METHYL
BROMIDE
ALTERNATIVE
ECONOMIC
REASON
(
IF
ANY)
FOR
THE
ALTERNATIVE
NOT
BEING
AVAILABLE
ESTIMATED
MONTH/
YEAR
WHEN
THE
ECONOMIC
CONSTRAINT
COULD
BE
SOLVED
1
Heat
Treatment
Under
laboratory
conditions,
brief
exposure
of
commodities
to
high
temperatures
may
eliminate
insects
without
adversely
affecting
product
quality.
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.
Also,
this
approach
is
not
feasible
for
treating
commercial­
scale
commodity
volumes.
Most
insects
do
not
survive
more
than
12
hours
when
exposed
to
45oC
or
more
than
5
minutes
when
exposed
to
50oC
(
Fields,
1992).
However,
the
effectiveness
of
this
approach
has
not
been
tested
with
large
volumes
of
commodities.
Substitution
of
heat
treatments
where
high
temperatures
are
not
already
used
for
other
applications
would
require
extensive
retrofitting
of
existing
facilities,
as
well
as
heat
delivery
systems
capable
of
rapidly
and
uniformly
heating
large
volumes
of
commodities
in
order
to
achieve
total
insect
control.
Furthermore,
cheese
quality
may
be
adversely
affected
by
exposure
to
heat.
No
indication
was
given
by
the
applicant
as
to
a
timetable
to
solve
identified
problems.

2
Phosphine
alone
or
in
combination
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.
In
addition
some
of
the
equipment
itself
(
for
example:
motors,
mixers,
etc.)
also
have
metal
parts
that
contain
copper.
In
addition
it
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.
Also,
not
suitable
to
replace
methyl
bromide
when
rapid
fumigations
are
needed
to
meet
No
indication
was
given
by
the
applicant
as
to
a
timetable
to
solve
identified
problems.
Page
19
NO.
METHYL
BROMIDE
ALTERNATIVE
ECONOMIC
REASON
(
IF
ANY)
FOR
THE
ALTERNATIVE
NOT
BEING
AVAILABLE
ESTIMATED
MONTH/
YEAR
WHEN
THE
ECONOMIC
CONSTRAINT
COULD
BE
SOLVED
customer
timelines.
Furthermore,
cheese
makers
claim
that
phosphine
causes
damage
to
the
cheese,
"
melting
of
the
cheese"
and
may
cause
acid
residue,
acrid
off­
odors
and
affect
flavor.

Phosphine
fumigation
takes
3­
10
days,
depending
on
temperature,
compared
to
1
day
for
MB
(
Hartsell
et
al.,
1991,
Zettler,
2002,
Soderstrom
et
al.,
1984,
phosphine
labels).
An
additional
2
days
are
needed
for
outgassing
phosphine.
Phosphine
fumigation
is
least
feasible
during
the
colder
winter
months
when,
according
to
label
directions,
the
minimum
exposure
periods
increases
to
8­
10
days
(
plus
two
days
for
aeration)
when
commodity
temperature
decreases
to
5oC
­
12
oC.
Phosphine
is
not
used
when
commodity
temperature
drops
below
5oC
(
Phosphine
and
Eco2fume
®
labels).

3
Irradiation
Although
rapid
and
effective,
irradiation
may
result
in
living
insect
left
in
the
treated
product.
Treated
insects
are
sterilized
and
stop
feeding,
but
are
not
immediately
killed.
The
high
dosages
necessary
to
cause
immediate
mortality
in
target
insects
may
reduce
product
quality.
Irradiation
requires
major
capital
expenditures
and
irradiated
food
are
not
widely
accepted
by
consumers.
No
indication
was
given
by
the
applicant
as
to
a
timetable
to
solve
identified
problems.

4
Carbon
Dioxide
(
high
pressure)
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.
No
indication
was
given
by
the
applicant
as
to
a
timetable
to
solve
identified
problems.

Commodities
and
facilities
listed
in
this
chapter
were
requested
by
the
National
Pest
Management
Association
which
represents
members
that
provide
fumigation
services
to
food
processing
and
storage
facilities.
The
economic
impacts
on
the
facility
from
using
the
next
best
alternative
could
not
be
assessed
since
the
applicant
is
not
the
end­
user.
However,
the
uses
included
in
this
chapter
are
those
with
no
technically
and
economically
feasible
alternative.
In
general,
economic
impacts
to
the
commodity
and
food
processing
sector
can
be
characterized
as
arising
from
three
contributing
factors.
First,
the
direct
pest
control
costs
increased
in
most
cases
because
phosphine
is
more
expensive
due
to
increased
labor
time
required
for
longer
treatment
time
and
increased
number
of
treatments.
Second,
capital
expenditures
may
be
required
to
adopt
phosphine
for
accelerated
replacement
of
plant
and
equipment
due
to
corrosive
nature
of
phosphine.
Finally,
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.

The
industries
that
use
methyl
bromide
for
commodity
and
facility
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
Page
20
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories.
In
addition,
producers'
associations
generally
manage
companies
of
this
type,
and,
therefore,
making
new
capital
investment
is
often
difficult.

MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
No
information
available.

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
(
EPA
or
Agency)
has
made
registering
methyl
bromide
alternatives
a
priority
(
see
Section
17.2).
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.
Page
21
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,
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
US$
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
also
recommend
further
studies
on
sulfuryl
fluoride
tolerances
and
combination
treatments
of
heat/
carbon
dioxide/
phosphine.

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.
Page
22
17.2.
Registration
Since
1997,
the
United
States
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
EPA
currently
has
more
applications
pending
in
its
registration
review
queue
than
the
resources
to
evaluate
them,
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
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
US$
15
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
EPA's
participation
in
the
evaluation
of
research
grant
proposals
each
year
for
USDA's
US$
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
registered
as
a
post­
harvest
fumigant
for
grains
and
flour
mills,
but
not
for
the
commodities
included
in
this
chapter.

18.
ADDITIONAL
COMMENTS
Page
23
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.

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
24
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.

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.

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.
Page
25
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.
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.

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
26
APPENDIX
A
PUBLISHED
PERFORMANCE
DATA
APPENDIX
A
­
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
27
APPENDIX
A
­
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
28
APPENDIX
B.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
Date:
Sector:

Kilograms
(
kgs)
Volume
(
1000m
3
)
Use
Rate
(
kg/
1000m
3
)
Kilograms
(
kgs)
Volume
(
1000m
3
)
Use
Rate
(
kg/
1000m
3
)
2001
&
2002
Average
%
of
Volume
93,319
3,884
24
89,861
3,740
24
0%

10,800
449
24
5,869
244
24
0%

79,950
3,327
24
76,899
3,200
24
0%

3,856
160
24
3,596
150
24
0%

1,126
47
24
560
23
24
0%

189,050
7,868
24
176,784
7,358
24
2007
Request
(­)
Double
Counting
(­)
Growth
(­)
Use
Rate
Adjustment
(­)
QPS
HIGH
LOW
Amount
(
kgs)
Volume
(
1000m
3
)
Use
Rate
(
kg/

1000m
3
)

93,319
­
3,459
14,977
­
74,884
74,884
74,884
3,740
20
10,800
­
4,931
978
­
4,891
4,891
4,891
244
20
79,950
­
3,051
12,816
­
64,082
64,082
64,082
3,200
20
3,856
­
260
599
­
2,996
2,996
2,996
150
20
1,126
­
566
93
­
467
467
467
23
20
189,050
189,050
185,173
171,664
171,664
147,320
147,320
147,320
7,358
20
0%
0%
2%
9%
9%
22%
22%
22%
6%
17%

Low
EPA
High
Low
High
Low
HIGH
LOW
24
20
100%
100%
0%
0%
100%
100%

24
20
100%
100%
0%
0%
100%
100%

24
20
100%
100%
0%
0%
100%
100%

24
20
100%
100%
0%
0%
100%
100%

24
20
100%
100%
0%
0%
100%
100%

Currently
Use
Alternatives?
Research
/

Transition
Plans
Pest­
free
Market
Requirement
Change
from
Prior
CUE
Request
(+/­)
Verified
Historic
MeBr
Use
/

State
Frequency
of
Treatment
of
Product
Loss
per
1000
m
3
(
US$/
1000m)
Loss
per
Kg
of
MeBr
(
US$/
kg)
Loss
as
a
%
of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Yes
Yes
Yes
0
No
1
Yes
Yes
Yes
0
No
1
Yes
Yes
Yes
0
No
1
Yes
Yes
Yes
0
No
1
Yes
Yes
Yes
0
No
1
Conversion
Units:
1
Pound
=
0.453592
Kilograms
1,000
cu
ft
=
0.028316847
1,000
cubic
meters
High
24%
Low
77%

Adopt
new
fumigants
­
Sulfuryl
fluoride
Percent
of
Market
adoption
depends
on
Registration
Date,
Cost,
%
of
Structures
that
are
suitable,

SF
efficacy
still
unknown.
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.
0
Most
Likely
Impact
Value:
Marginal
Strategy
(%)
Combined
Impacts
Time,
Quality,

or
Product
Loss
%
Reduction
from
Initial
Request
Processed
Foods
Cheese
Processing
Plants
FOOD
FACILITY
TYPE
Cocoa
Methyl
Bromide
Critical
Use
Exemption
Process
2007
Bromide
Usage
Numerical
Index
(
BUNI)
POST
HARVEST
USE
(
NPMA)

1/
28/
2005
Quarantine
and
Pre­
Shipment
Regional
Volume
(%)
Key
Pest
Distribution
(%)
Adopt
New
Fumigants
Subtractions
from
Requested
Amounts
(
kgs)

Other
Considerations
Other
Commodity
Spices
and
Herbs
Cocoa
Cheese
Processing
Plants
Economic
Analysis
Not
provided
by
applicant.

Cheese
Processing
Plants
Other
Commodity
Dichotomous
Variables
(
Y/
N)

Cocoa
FOOD
FACILITY
TYPE
Spices
and
Herbs
Other
Issues
Processed
Foods
Heat
&
Phosphine
Other
Commodity
FOOD
FACILITY
TYPE
Processed
Foods
Unknown
Use
Rate
(
kg/
1000m3)
%
of
Average
Volume
Requested:

Average
Volume
in
the
US:

Adjustments
to
Requested
Amounts
2007
Nomination
Options
Spices
and
Herbs
FOOD
FACILITY
TYPE
Processed
Foods
Cheese
Processing
Plants
Other
Commodity
2001
&
2002
Average
Use
not
available
MOST
LIKELY
IMPACT
VALUE
Combined
Impacts
Adjustment
(
kgs)

Nomination
Amount
TOTAL
OR
AVERAGE
Spices
and
Herbs
Cocoa
2007
Amount
of
Request
not
available
Research
Amount
(
kgs)
Page
29
Footnotes
for
Appendix
B:

Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Volume
in
the
U.
S.
 
Average
Volume
in
the
U.
S.
is
the
average
of
2001
and
2002
total
volume
fumigated
with
methyl
bromide
in
the
U.
S.
in
this
sector
(
when
available).
2.
%
of
Average
Volume
Requested
­
Percent
(%)
of
Average
Volume
Requested
is
the
total
volume
in
the
sector's
request
divided
by
the
Average
Volume
in
the
U.
S.
(
when
available).
3.
2007
Amount
of
Request
 
The
2007
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
volume
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
thousand
cubic
feet.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
U.
S.
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
kilograms
active
ingredient
of
methyl
bromide,
total
volume
of
methyl
bromide
use,
and
application
rate
in
kilograms
active
ingredient
of
methyl
bromide
per
thousand
cubic
meters.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
is
the
percentage
(%)
of
the
applicant's
requested
amount
subject
to
QPS
treatments.
6.
Regional
Volume,
2001
&
2002
Average
Volume
 
Regional
Volume,
2001
&
2002
Average
Volume
is
the
2001
and
2002
average
estimate
of
volume
of
methyl
bromide
used
within
the
defined
region
(
when
available).
7.
Regional
Volume,
Requested
Volume
%
­
Regional
Volume,
Requested
Volume
%
is
the
volume
in
the
applicant's
request
divided
by
the
total
volume
fumigated
with
methyl
bromide
in
the
sector
in
the
region
covered
by
the
request.
8.
2007
Nomination
Options
 
2007
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2007
Request
 
Subtractions
from
Requested
Amounts,
2007
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
a
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2007
request
from
an
applicant's
2002
CUE
application
compared
with
the
2007
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2007
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
Page
30
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
Use
Rate
kg/
1000
m3
2007
 
Use
rate
in
pounds
per
thousand
cubic
feet,
2007,
is
the
use
rate
requested
by
the
applicant
as
derived
from
the
total
volume
to
be
fumigated
divided
by
the
total
amount
(
in
pounds)
of
methyl
bromide
requested.
17.
Use
Rate
kg/
1000
m3
low
 
Use
rate
in
pounds
per
thousand
cubic
feet,
low,
is
the
lowest
historic
use
rate
reported
by
the
applicant.
The
use
rate
selected
for
determining
the
amount
to
nominate
is
the
lower
of
this
rate
or
the
2007
use
rate
(
above).
18.
(%)
Key
Pest
Impacts
­
Percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
structures/
food
facilities
and
commodities,
key
pests
are
assumed
to
infest
100%
of
the
volume
for
the
specific
uses
requested
in
that
100%
of
the
problem
must
be
eradicated.
19.
Adopt
New
Fumigants
(%)
 
Adopt
new
fumigants
(%)
is
the
percent
(%)
of
the
requested
volume
where
we
expect
alternatives
could
be
adopted
to
replace
methyl
bromide
during
the
year
of
the
CUE
request.
20.
Combined
Impacts
(%)
­
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
and
new
fumigants.
In
each
case
the
total
area
impacted
is
the
conjoined
area
that
is
impacted
by
any
individual
impact.
The
effects
were
assumed
to
be
independently
distributed
unless
contrary
evidence
was
available
(
e.
g.,
affects
are
known
to
be
mutually
exclusive).
21.
Qualifying
Volume
­
Qualifying
volume
(
1000
cubic
meters)
is
calculated
by
multiplying
the
adjusted
volume
by
the
combined
impacts.
22.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
volume
by
the
use
rate.
23.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
24.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
25.
Total
U.
S.
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
26.
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.
27.
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.
28.
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.
29.
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.
30.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
31.
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.
32.
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.
33.
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.
34.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
35.
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.
36.
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.
Page
31
37.
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.
38.
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.
39.
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.
40.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
Page
32
APPENDIX
C.
2006
Methyl
Bromide
Reconsideration
for
Dry
Commodities:
Cocoa
Beans.

Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
61.519
metric
tons
of
methyl
bromide
for
use
on
cocoa
beans
in
the
U.
S.
for
both
2005
and
2006.
This
is
a
request
at
the
national
level
to
treat
cocoa
beans.

The
U.
S.
nomination
is
only
for
those
food
commodities,
such
as
cocoa,
where
the
use
of
alternatives
is
not
suitable.
In
the
U.
S.
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.
­
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)
or
because
it
changes
the
nature
of
the
final
product
(
e.
g.
cooking
it).
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
use
on
small
grains
(
flour,
rice,
oats,
etc.)
but
not
for
other
foods.
State
registrations
for
small
grains
have
not
yet
been
issued
in
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.
­
Time
to
complete
fumigation:
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.
Capacity
of
fumigation
chambers
can
become
an
issue.
If,
for
example,
fumigation
capacity
for
cocoa
beans
is
fully
utilized,
moving
to
an
alternative
that
requires
a
longer
in­
chamber
time
would
require
construction
of
additional
fumigation
capacity
incurring
large
capital
costs.

MBTOC
recommended
a
25%
cut
to
a
level
of
46.139
metric
tons
for
20061.
The
basis
for
this
suggested
reduction
was
"
for
phasein
of
alternatives".

MBTOC
further
stated
"
Frequent
fumigations
indicate
that
there
are
poor
or
no
measures
to
prevent
re­
infestation,
resulting
in
additional
and
perhaps
unnecessary
use
of
MB."

To
clarify
the
U.
S.
request,
shipments
of
cocoa
beans
are
fumigated
once
each
and
then
distributed
throughout
the
U.
S.
for
further
processing
into
finished
products
such
as
cocoa
powder,
chocolates,
etc,
and
we
therefore
disagree
that
cuts
to
our
request
based
on
the
frequency
of
fumigation
are
appropriate.
Although
phosphine
(
aluminium
phosphide)
is
labeled
1
The
original
recommendation
for
2005
was
for
a
cut
of
10%
to
a
level
of
55.367
metric
tons.
The
cut
was
rejected
by
the
Parties
at
the
November
MOP
and
the
full
request
was
granted.
It
is
now
not
clear
if
the
recommended
amount
for
2006
remains
at
46.139,
a
25%
cut
from
the
requested
amount,
or,
whether
the
amount
will
be
adjusted
to
reflect
a
15%
reduction
for
a
recommended
quantity
of
52.291.
Page
33
for
use
on
cocoa
beans
in
the
US,
the
time
required
to
complete
a
fumigation
is
more
than
96
hours
compared
with
24
hours
for
a
methyl
bromide
fumigation.
This
extra
time
imposes
a
cost
on
the
manufacturers
of
finished
cocoa
products.
According
to
the
International
Cocoa
Organization
(
www.
icco.
org)
"
Some
countries
also
use
plastic
strips
containing
Dichlorovos
for
continuous
chemical
control,
though
these
are
banned
in
some
countries
and
the
U.
S.
is
withdrawing
permission
to
use
it."

Methyl
bromide
is
the
cost­
effective
fumigant
to
use
on
cocoa
beans.
The
short
time
required
allows
rapid
turn­
over
of
existing
fumigation
capacity.

Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
No
technical
assessment
of
the
performance
of
alternatives,
or
economic
assessment
of
the
impact
of
converting
to
alternatives
was
provided
by
MBTOC.
No
economic
data
were
provided
to
support
a
25%
reduction
schedule
as
suggested
by
MBTOC.

To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
longer
treatment
times,
and
the
economic
feasibility
of
a
four
year
transition
time.

U.
S.
2006
nomination
The
U.
S.
has
considered
the
issues
raised
by
MBTOC,
but
continues
to
support
our
request
for
61.519
metric
tons
of
methyl
bromide
for
use
on
cocoa
beans
for
2006
which
is
an
increase
of
15.380
metric
tons
over
the
MBTOC
recommended
amount
of
46.139
metric
tons.
Page
34
APPENDIX
D.
2006
Methyl
Bromide
Reconsideration
for
Dry
Commodities:
Herbs,
Spices,
Dried
Milk,
Cheese
Processing.

Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
83.344
metric
tons
of
methyl
bromide
for
use
on
processed
foods
(
71.889
metric
tons),
herbs
and
spices
(
4.695
metric
tons),
dried
milk
(
0.402
metric
tons),
cheese
processing
facilities
(
2.876
metric
tons),
and
other
commodities
(
3.482
metric
tons)
for
2006.
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
use
on
small
grains
(
flour,
rice,
oats,
etc.)
but
not
for
other
foods.
State
registrations
for
small
grains
have
not
yet
been
issued
in
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
47.925
metric
tons
for
processed
dry
foods2,
3.13
metric
tons
for
herbs
and
spices,
nothing
for
dried
milk,
2.876
metric
tons
for
cheese
processing
facilities
(
the
full
amount
requested)
and
2.321
metric
tons
for
other
commodities.
The
total
recommendation
was
for
56.253
metric
tons
of
methyl
bromide
for
these
uses
in
2006.

2
As
is
the
case
for
cocoa
(
above)
because
the
cut
for
2005
was
rejected
by
the
Parties
at
the
November
MOP,
it
is
not
clear
whether
the
amounts
recommended
by
MBTOC
for
2006
will
remain
as
recommended
(
a
cut
of
approximately
20%
in
addition
to
a
lower
use
rate)
or
will
be
changed
to
a
10%
cut
again,
in
addition
to
the
lower
use
rate)
in
recognition
of
the
higher
2005
amount.
Page
35
USG
agrees
that
in
general,
a
use
rate
of
20g/
m3
should
allow
for
adequate
control
of
pests
in
mills
and
processing
facilities
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.

USG
also
agrees
that
there
are
alternatives
for
controlling
pests
in
dried
milk
and
therefore
withdraws
the
requested
amount
of
0.402
metric
tons
for
this
purpose.

USG
does
not
agree
that
it
is
appropriate
to
cut
10%
(
or
20%)
from
the
requested
use
for
transition
to
alternatives
and
for
improved
sealing.

To
take
the
simpler
issue
first,
there
is
no
evidence
that
facilities
for
which
this
request
for
methyl
bromide
is
being
made
are
failing
to
seal
the
facilities
properly.
As
far
as
the
phase­
in
of
alternatives
is
concerned,
the
Montreal
Protocol
calls
for
a
critical
use
nomination
being
granted
when
there
are
no
alternatives
that
are
both
technically
and
economically
feasible.

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
to
methyl
bromide
use
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
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
Page
36
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.

In
addition,
there
are
economic
costs
incurred
when
alternatives
are
used
that
are
over
and
above
costs
when
using
methyl
bromide
to
control
pests.
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
relative
to
the
costs
incurred
by
methyl
bromide
users.

The
potential
economic
losses
associated
with
the
use
of
heat
treatment
mainly
originate
from
the
cost
of
capital
investment.
Although
economic
costs
were
not
calculated
for
these
specific
types
of
food
processing
facilities,
they
were
calculated
for
milling
facilities.
In
the
milling
facilities
the
estimated
economic
loss
per
1000
m3
ranges
from
$
2,023
to
$
12,439,
depending
on
the
product
being
milled.
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
(
milling)
sector.
We
expect
losses
of
a
similar
scale
in
this
segment
of
the
food
processing
sector
as
well.

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.

Sulfuryl
Fluoride
is
not
registered
for
use
on
herbs
and
spices.
Heat
is
not
an
appropriate
treatment,
as
it
will
degrade
the
quality
of
the
spice/
herb.
Although
phosphine
(
aluminium
phosphide)
is
labeled
for
use
on
spices
and
herbs
in
the
U.
S.,
the
time
required
to
complete
a
fumigation
is
more
than
96
hours
compared
with
24
hours
for
a
methyl
bromide
fumigation.
This
extra
time
imposes
a
cost
on
the
manufacturers
of
these
products.
Because
the
market
is
a
highly
competitive
and
globalized
one,
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories,
phosphine
may
not
be
an
economically
feasible
alternative
for
methyl
bromide
in
this
use.
Page
37
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,
the
economic
assessment
on
the
impact
of
converting
to
alternatives,
and
in
particular
the
economic
data
used
to
support
a
10%
reduction.

To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
longer
treatment
times,
and
the
economic
feasibility
of
a
10%
reduction.

U.
S.
2006
nomination
Therefore
the
U.
S.
is
requesting
that
and
additional
amount
(
over
the
MBTOC
recommended
amount
of
56.253
metric
tons)
of
12.865
metric
tons
by
granted
brining
the
sector
total
to
69.118
metric
tons
of
methyl
bromide.

Citations
Arthur,
F.
H.
2000.
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of
diatomaceous
earth
to
red
flour
beetles
and
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beetles
(
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Tenebrionidae):
Effects
of
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and
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J.
Econ.
Entomol.
93(
2):
526­
532.

Arthur,
F.
H.
1992.
Cyfluthrin
WP
and
EC
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to
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malathion­
resistant
red
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beetles
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beetles
(
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Effects
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on
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4):
436­
444.

Arthur,
F.
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T.
W.
Phillips.
2003.
Stored­
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358.

Bell,
C.
H.
2000.
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the
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Cox,
P.
D.
2004.
Potential
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using
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J
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1­
25.

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

Dunkel,
F.
V.
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L.
J.
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1998.
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stored
grain
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J.
Stored
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307­
321.
Page
38
Fields,
P.
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N.
D.
G.
White.
2002.
Alternatives
to
methyl
bromide
treatments
for
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quarantine
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Review
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Entomology
47:
331­
59.

Hou,
X.,
P.
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W.
Taylor.
2004.
The
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stored­
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J
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47­
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Mahroof,
R.,
Subramanyam,
B.
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Eustace,
D.
2003.
Temperature
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its
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J.
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Mahroof,
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B.
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J.
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Throne,
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2003.
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J.
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Mueller,
D.
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Nielsen,
P.
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Oberlander,
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1997.
Current
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J
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33:
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Skovgard,
H.,
N.
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P.
S.
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1999.
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28(
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