SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
Your
reference:

Our
reference:
OzL./
MBTOC­
CUN/
USA/
MS/
lm
Date:
16
March
2005
Dear
Sir,

Re:
Review
of
Critical­
Use
Nominations
for
Methyl
Bromide
Please
refer
to
the
on­
going
review
process
of
nominations
for
critical­
use
exemptions
for
methyl
bromide.

In
accordance
with
this
process
and
based
upon
the
information
provided
by
your
Government,
the
MBTOC
reviewers
have
some
questions
that
I
am
forwarding
for
your
attention.
The
questions
are
on
technical
issues
and
on
nominations
related
to
structures,
commodities
and
objects.
If
further
questions
on
economic
issues
and
on
nominations
related
to
soil
applications
arise,
they
will
be
communicated
to
you
separately.

I
would
appreciate
it
if
your
response
and
any
questions
you
may
have
are
directly
sent
to
the
Co­
chairs
of
the
Committee
at
the
addresses
provided
below
with
a
copy
to
the
Secretariat.

Dr.
H.
J.
Banks
Dr.
Nahum
M.
Mendoza
10
Beltana
Road
and
Department
of
Agricultural
Parasites
Pialligo,
ACT
2609
Autonomic
University
of
Chapingo
Australia
P.
O.
Box
56230
Chapingo,
Mexico
Tel:
(+
61­
2)
6248­
9228
Tel:
(+
52­
595)
954­
1646
/
1602
Fax:
(+
61­
2)
6248­
9228
Fax;
(+
52­
595)
954­
1646
/
1602
/
40692
E­
Mail:
apples3@
bigpond.
com
E­
Mail:
nahumm@
correo.
chapingo.
mx
Yours
sincerely,

Marco
González
Executive
Secretary
Ozone
Secretariat
Dr.
John
E.
Thompson,
Ph.
D.
International
Affairs
Officer
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington
DC
20520,
U.
S.
A.

Fax:
(+
1­
202)
647­
5947
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
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254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
­
2
­

Copy
to:
Dr.
H.
J.
Banks
Fax:
(+
61­
2)
6248­
9228
Dr.
Nahum
M.
Mendoza
Fax:
(+
52)
5954­
0692
Ms.
Michelle
Marcotte
Tel:
(+
1­
301)
262­
9866
Dr.
Ian
Porter
Fax:
(+
61­
3)
9800­
3521
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
Questions
from
MBTOC
concerning
Post­
harvest
CUNs
General
Issues
The
U.
S.
CUNs
do
not
list
the
structures
to
be
fumigated,
do
not
give
specific
and
individual
volumes,
types
of
structure,
location,
frequency
of
fumigation,
dosage
rate
and
why
each
is
not
suited
to
use
of
alternatives.
Yet,
MBTOC
has
the
job
of
diligently
evaluating
if
the
proposed
use
of
MB
is
critical
for
the
specific
circumstances
of
proposed
use
of
MB.
For
example,
without
this
information
it
is
not
possible
for
MBTOC
to
check
volume
of
structure
to
be
fumigated
against
the
dosage
rate
and
the
requested
amount
of
MB.
Without
this
information
MBTOC
can
not
determine
if
SF
can
be
used
by
a
particular
structure
because
we
do
not
know
if
it
is
located
in
a
state
that
allows
SF
use.
We
can
not
determine
if
heat
can
be
used
successfully
because
we
do
not
know
location
of
the
structure
or
its
volume.

These
questions
were
also
raised
during
consideration
of
last
year's
CUNs
relating
to
fumigation
of
structures.
MBTOC
is
concerned
that
it
will
be
unable
to
assess
the
particular
circumstances
of
the
individual
mills,
food
processing
or
similar
facilities
without
this
information.
MBTOC
cannot
ascertain
whether
such
an
analysis
has
been
carried
out
in
order
to
provide
an
estimate
of
the
critical
need
for
methyl
bromide
in
the
year
of
the
nomination.

MBTOC
can
not
ensure
that
there
is
no
double
counting
of
establishments
and
fumigations
by
fumigators
competing
for
business
from
the
potentially
the
same
customers.
Would
it
be
possible
for
U.
S.
to
explain
to
MBTOC
or
assure
MBTOC
that
there
is
sufficient
oversight
to
ensure
the
same
facility
or
structure
is
not
included
in
more
than
one
CUN
or
by
more
than
one
fumigator
company?

Questions
from
MBTOC
concerning
CUN
Commodities
1.
Section
5
says
that
Eco2Fume
is
the
only
chemical
alternative
available
for
the
treatment
of
dried
fruit
and
nuts.
We
assume
that
other
forms
of
phosphine
supply
are
also
allowable.
However,
MBTOC
is
aware
of
the
registration
of
propylene
oxide
(
PPO)
for
disinfestation
of
nuts
and
some
other
dried
commodities
in
the
US.
Additionally,
the
California
almond
industry
has
built
several
suitable
chambers
and
markedly
increased
its
use
of
PPO
on
almonds
in
the
past
two
years
(
largely
in
response
to
Salmonella
contamination
but
the
process
used
to
control
Salmonella
would
also
be
useful
for
pests).
The
CUN
Table
12.1
page
12
refers
to
the
registration
of
PPO
for
in­
shell
walnuts,
but
does
not
inform
about
the
registration
for
other
commodities
included
in
this
CUN.
Please
inform
MBTOC
of
the
current
registration
status
of
PPO
in
the
US
and
in
California
for
disinfestation
of
the
dried
commodities
included
in
this
CUN
and
reasons
for
not
considering
it
an
available
alternative
for
the
various
commodities.
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
2.
What
percentage
of
walnuts
is
exported
to
Europe
and
is
there
an
EU
tolerance
for
PPO
residues
in
walnuts?

3.
Given
that
registration
status
and
technical
issues
that
might
allow
or
disallow
use
of
a
potential
alternative
shelled
versus
in­
shell
nuts,
can
you
give
MBTOC
the
percentage
of
the
nut
crop
to
be
MB
fumigated
that
is
shelled
or
in­
shell?

4.
Table
6.1
located
on
Page
8
is
incorrect
in
terms
of
amount
of
MB
requested
and/
or
volume
to
be
treated
or
both.
Could
you
please
check
this,
correct
it
and
return
a
corrected
version
to
us?

5.
Please
explain
reasons
for
variation
in
amount
of
MB
used
in
various
years
as
reported
in
Table
6.1.
For
example,
while
we
note
that
the
2007
total
requested
amount
is
less
than
use
in
2003,
it
is
more
than
use
in
2002
and
1998
and
just
slightly
less
than
use
in
year
2000.

6.
Why
is
there
an
increase
in
the
request
for
walnuts
and
pistachios
for
2007
over
2006?
The
CUN
indicates
that
20%
of
walnuts
are
now
treated
with
propylene
oxide
and
other
lines
of
investigation
are
in
progress.
Phosphine
treatment
is
available
and
used
for
nuts
in
store
and
where
handling
facilities,
including
temporary
storage,
allow
the
longer
fumigation
period
to
be
applied.
Yet
increased
MB
use
is
nominated.
Does
this
imply
the
20%
that
is
treated
with
PPO
is
also
treated
with
MB
and
that
there
is
an
increased
requirement
for
methyl
bromide
in
store
for
some
reason?
Note
that
MBTOC
understands
the
need
for
MB
to
be
used
for
research
and
does
not
include
quantities
used
for
research
as
part
of
this
query.

7.
The
dosage
rate
used
for
walnuts
seems
to
be
a
mistake.
Table
1.9a
page
10
indicates
a
walnut
dosage
rate
of
111kg/
1000m3,
yet
MBTOC
believes
the
highest
label
rate
is
48g/
m3.
The
maximum
label
rate
is
higher
than
the
minimum
efficient
dosage
rate
for
walnuts.
Please
supply
MBTOC
with
the
correct,
and
minimum
effective,
intended
MB
dosage
rate
for
walnuts.

8.
Table
12.2
page
14
footnotes
refer
to
vacuum
chamber
fumigation
of
walnuts.
What
percentage
of
walnuts
is
MB
fumigated
in
vacuum
chambers
and
is
this
the
reason
for
the
high
dosage
rate
reported?
If
so,
what
is
the
dosage
rate
used
for
walnuts
that
are
not
fumigated
in
vacuum
chambers?
Vacuum
chamber
fumigation
while
faster,
uses
more
MB.
Please
justify
the
use
of
vacuum
chamber
fumigation
for
MB.
9.
MBTOC
would
like
to
know
more
about
the
marketing
pressures
on
dried
beans.
Although
the
CUN
discusses
marketing
pressures
on
dried
fruit
and
nuts,
including
factors
as
the
need
for
quick
fumigation
before
export
and
domestic
pre­
Christmas
sales,
but
this
information
is
not
included
for
beans.
Since
beans
harvested
earlier
and
used
later
and
with
less
need
for
quick
sales,
might
there
be
less
need
for
quick
fumigation
and
thus
slower
alternatives,
such
as
phosphine,
may
be
suitable?
(
Table
B2,
Page
10)?

10.
Page
20
and
page
22
indicate
there
are
no
technically
feasible
alternatives
for
dried
beans.
Is
phosphine
registered
federally
and
in
California
for
use
on
dried
beans?
If
so,
why
is
it
not
considered
technically
feasible?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
11.
Table
9.1(
a)
Page
10
seems
to
indicate
that
the
reported
dosage
rates
are
used
regardless
of
product
temperature.
Is
this
correct?
Warmer
temperatures,
as
seem
likely
in
California,
can
allow
for
lower
MB
dosage
rates.
Can
you
supply
MBTOC
with
information
on
product
temperature
at
time
of
fumigation?

12.
Table
9.1(
b)
says
no
information
on
gastightness
is
available.
Fumigators
conduct
gastightness
measurements
before
and
during
fumigations.
For
a
critical
use,
Decision
XI/
6
requires
that
MB
emissions
and
use
are
minimized.
MBTOC
seeks
information
on
gastightness
of
fumigations
to
ensure
only
the
minimum
amount
of
MB
technically
required
is
used.
For
this
reason,
and
to
ensure
due
diligence,
we
need
information
on
gastightness.
Failing
that,
can
the
US
confirm
that
MB
fumigations
in
this
sector
will
only
be
conducted
in
conditions
of
at
least
good
gastightness
(
refer
to
Handbook
for
definition
of
`
good
gastightness').
If
good
gastightness
is
not
currently
possible,
how
will
gastightness
of
fumigation
facilities
be
improved
this
year
and
what
effect
is
this
expected
to
have
on
the
potential
critical
quantity
of
methyl;
bromide
in
this
nomination?

13.
Could
the
US
government
inform
MBTOC
if
or
when
SF
becomes
registered
in
California
for
the
uses
included
in
this
CUN,
likely
rate
of
adoption
and
the
effect
SF
adoption
will
have
on
requested
amounts
of
MB?

Questions
from
MBTOC
concerning
CUN
Food
Facilities
1.
The
amount
of
MB
requested
for
2007
represents
an
increase
over
2006
(
401,889
kg
in
2007
versus
394,843
in
2006).
MBTOC
is
aware
of
increased
use
of
heat,
sulfuryl
fluoride
and
increased
successes
with
IPM
that
decrease
frequency
of
fumigation
in
addition
to
much
new
research
that
should
be
helpful
to
the
industry.
MBTOC
thinks
it
is
reasonable
to
expect
some
level
of
continued
adoption
of
alternatives.
Why
then
will
an
increased
amount
of
MB
be
needed
in
2007?

2.
The
CUN
did
not
supply
a
list
of
mill
and
food
processing
facility
locations,
although
the
CUN
says
this
information
will
be
sent
to
MBTOC
when
available
(
page
8).
MBTOC
would
welcome
this
list
as
part
of
understanding
the
needs
for
methyl
bromide
on
a
case­
by­
case
basis
and
ensuring
there
is
no
duplication
between
this
CUN
and
the
one
involving
NPMA­
treated
facilities.
Can
the
US
government
check
this
eventual
list
to
ensure
that
a
food
processing
facility
listed
as
part
of
one
CUN
is
not
also
included
in
another
CUN?
The
list
should
specifically
give
reasons
why
MB
alternatives
are
not
feasible
and/
or
why
the
dosages
and
frequency
of
treatment
cannot
be
(
further)
reduced.

3.
Table
B1
page
9,
footnote
says
that
some
mills
and
food
processing
facilities
in
cooler
locations
are
fumigated
once
every
three
years,
whereas
those
in
Southern
US
locations
are
fumigated
twice
a
year
(
or
2.5
times
per
year
as
reported
in
table
9.1.
a).
In
contrast
Table
B.
2
page
10
footnote
says
rice
mills
are
fumigated
5
x
per
year.
The
CUN
reports
that
rice
mills
are
in
Southern
US,
where
other
mills
such
as
wheat
flour
mills
are
also
located.
Flour
mills
in
SECRETARIAT
FOR
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VIENNA
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AND
ITS
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PROTOCOL
 
THE
OZONE
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O.
Box
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Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
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254
20]
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/
624693
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ozoneinfo@
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org
 
Http://
www.
unep.
org/
ozone
Southern
US
have
been
successful
in
reducing
fumigation
frequency
from
4­
6
times
per
year
to
current
2.5/
yr
(
Part
D13
page
16).
So,
the
5x/
yr
fumigation
frequency
for
rice
mills
is
remarkable.
What
is
the
technical
justification
for
the
higher
frequency
of
fumigation
in
rice
mills?
What
are
the
plans
to
reduce
frequency
of
fumigation?

4.
Table
9.1:
Page
10
notes
variability
in
the
need
for
fumigation
of
pet
food
establishments
between
1/
yr
to
1/
3­
5
years
and
that
only
80%
of
pet
food
establishments
require
fumigation.
What
MB
alternatives
do
the
other
20%
and
the
pet
food
plants
that
do
not
require
frequent
fumigation
use
or
are
there
other
factors?
MBTOC
is
aware
of
the
use
of
spot
heat
treatment
at
a
very
large
commercial
pet
food
company.
Why
is
heat,
either
as
a
whole
site
treatment
or
as
a
component
if
an
IPM
system,
not
considered
technically
and
economically
feasible
for
pet
food
establishments?

5.
Table
9.1:
b
Page
11
reports
gastightness
of
the
establishments
included
in
this
CUN.
Rice
mills
are
reported
to
be
poor
or
very
poor
gastightness.
In
each
other
use
category,
a
significant
percentage
of
establishments
are
reported
as
very
poor,
poor
or
medium
gastightness.
Poor,
very
poor
and
even
medium
gastightness
results
in
increased
methyl
bromide
use
(
and
may
also
create
increased
safety
hazards
from
fumigant
leakage).
For
an
MB
use
to
be
considered
critical
under
Decision
XI/
6,
all
technically
and
ecionomically
feasible
steps
should
have
been
taken
to
minimize
the
critical
use
and
any
associated
emissions
of
MB.
MBTOC
views
gastightness
as
an
important
facet
of
that
aspect
of
assessment.
What
is
the
plan
to
improve
gastightness
of
mills
and
reduce
methyl
bromide
dosage
and
frequency
for
this
year
of
nomination?

6.
The
CUN
implies
that
heat
treatment
is
unsuitable
for
bakeries
because
of
the
presence
of
butter
and
other
heat
sensitive
foods
We
have
assumed
the
paragraphs
on
page
5
and
page
6
pertain
to
bakeries
because
butter
and
other
high
fat
foods
are
more
likely
to
be
present
in
bakeries
than
in
mills,
rice
mills
and
most
food
processing
establishments
but
we
know
that
fats
are
also
present
in
pet
food
establishments.
Butter
and
similar
fats
absorb
methyl
bromide
substantially.
In
commercial
practise
in
the
U.
S.
are
butter
and
similar
fats
actually
present
when
a
bakery
is
fumigated
with
methyl
bromide?
Are
there
food
tolerances
for
methyl
bromide
and
derived
residues
in
butter
and
similar
fats
arising
from
fumigation?
It
is
possible
to
remove
heat
sensitive
foods
outside
of
the
bakery
during
a
heat
treatment,
and
it
seems
quite
likely
that
bakeries
have
the
heat
capability
or
could
withstand
heat
to
56
°
C
as
required.
The
CUN
page
22
notes
that
some
bakeries
have
already
switched
to
heat
and
other
alternatives.
Using
figures
from
the
BUNI,
bakery
MB
requested
amount
for
2007
is
only
11
 
12%
less
than
historical
use
in
2001
 
2002.
Has
the
US
government
calculated
its
bakery
MB
requested
amount
in
consideration
of
the
switch
to
heat
that
has
already
occurred
according
to
page
22,
and
that
is
likely
to
continue
to
occur
between
now
and
2007?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
7.
MBTOC
would
also
like
a
discussion
and
justification
for
the
apparent
growth
in
requested
MB
by
bakeries.
The
2007
requested
amount
of
23,814
kg
is
compared
to
the
2006
amount
of
14,742
kg
in
2006.
Unlike
other
BUNI's
where
growth
in
MB
use
is
identified
(
and
usually
not
allowed),
the
BUNI
associated
with
this
CUN
does
not
identify
or
discuss
this
growth
in
use
of
MB
for
bakeries.
Why
has
the
need
for
MB
increased
from
2006
to
2007,
especially
since
the
CUN
also
says
some
bakeries
are
using
alternatives?
Why
does
the
US,
which
in
BUNI
calculations
for
other
CUNs,
usually
does
not
allow
growth
in
MB
use,
seem
to
allow
growth
in
bakery
MB
use
in
this
instance?

Questions
from
MBTOC
concerning
CUN
Dry
Cure
Pork
Products
1.
This
CUN
is
for
a
critical
use
for
2007,
yet
historical
use
data
is
only
submitted
for
up
to
2002.
When
will
recent
historical
use
data
be
available?

2.
Which
information
on
historical
use
should
MBTOC
use?
Table
6.1
page
7
indicates
very
low
historical
use
between
1998
and
2002
of
about
803
 
1139
kg,
but
the
BUNI
indicates
more
than
40,000
kg.

3.
Industry
sources
indicate
to
MBTOC
that
historical
use
of
MB
for
dry
cure
pork
is
likely
less
than
40,000
lbs
(
not
kg).
The
CUE
adopted
for
this
sector
at
16
MOP
of
67
tonnes
for
2005
appears
to
substantially
exceed
requirements.
What
capacity
is
there
for
use
of
stockpiles
in
place
of
this
particular
nomination?

4.
Table
B1
footnote
Page
8
indicates
that
some
facilities
have
low
gastightness.
This
would
result
in
increased
methyl
bromide
use
(
plus
the
added
pest
pressure
indicated
in
the
CUN).
For
an
MB
use
to
be
considered
critical
under
Decision
XI/
6,
all
technically
and
economically
feasible
steps
should
have
been
taken
to
minimize
the
critical
use
and
any
associated
emissions
of
MB.
MBTOC
views
gastightness
as
an
important
facet
of
that
aspect
of
assessment.
What
is
the
plan
to
improve
gastightness
of
dry
pork
processing
establishments
that
use
MB
and
and
for
reduction
of
methyl
bromide
dosage,
frequency
and
quantity
for
this
year
of
nomination?

5.
Informal
survey
data
available
to
MBTOC
suggests
that
current
MB
usage
in
this
industry
does
not
exceed
10
tonnes
annually.
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
Questions
from
MBTOC
concerning
CUN
NPMA
Foods
and
Food
Processing
Facilities
1.
The
CUN
did
not
supply
a
list
of
food
facilities,
although
the
CUN
says
this
information
will
be
sent
to
MBTOC
when
available
(
page
9).
MBTOC
would
welcome
this
list
as
part
of
understanding
the
needs
for
methyl
bromide
on
a
case­
by­
case
basis
and
ensuring
there
is
no
duplication
between
this
CUN
and
the
one
involving
mills
and
other
processing
facilities.
Table
6.1
page
8
notes
that,
although
not
listed,
the
food
facilities
are
`
not
included
in
other
chapters'.
Can
the
US
government
check
this
eventual
list
to
ensure
that
a
food
processing
facility
listed
as
part
of
one
CUN
is
not
also
included
in
another
CUN?
The
list
should
specifically
give
reasons
why
MB
alternatives
are
not
feasible
and/
or
why
the
dosages
and
frequency
of
treatment
cannot
be
(
further)
reduced.

2.
Page
7
Facilities
section
indicates
that
food
processing
and
commodities
included
in
this
CUN
have
decreased
MB
use
through
improved
IPM,
increased
use
of
phosphine
and
spot
heat.
Fumigations
are
reported
to
have
decreased
from
4­
6
times
per
year
to
an
average
of
2x/
yr
in
the
South
and
1x/
3­
5
yr
in
the
North
(
Page
8).
Yet
from
Table
6.1
Page
8,
reported
volumes
of
MB
treated
space
has
remained
essentially
steady
since
1998
(
Volume
treated
average
1998
 
2002
was
7535
1000m3
and
2007
volume
requested
in
the
CUN
is
7,868
1000m3).
In
terms
of
MB
use,
the
2007
request
(
BUNI
figures)
represents
67%
of
2002
usage
and
76%
of
2001
usage.
The
two
sets
of
information
in
the
CUN
do
not
appear
to
be
in
complete
agreement.
MBTOC
finds
it
difficult
to
conduct
diligent
analysis
when
the
historical
use
data
stops
at
2002.
When
will
recent
historical
use
data
be
available?

3.
If
we
ignore
2006
CUN
amounts
since
the
Parties
have
not
yet
decided
them,
and
look
at
the
amounts
of
MB
granted
by
the
Parties
for
2005,
we
see
that
the
2007
requested
amount
shows
planned
increased
MB
use
for
processed
foods,
cocoa,
herbs
and
spices
and
cheese;
the
`
other
foods'
category
represents
a
decrease.
Increases
in
requested
MB
for
2007
is
not
in
agreement
with
the
CUN
reporting
that
MB
use
has
decreased
through
improved
IPM,
increased
use
of
phosphine
and
spot
heat
treatment
as
reported
in
the
point
above.
Please
comment
on
why
this
industry
needs
increased
critical
MB
in
2007
over
2005
amounts
granted
by
the
Parties.

4.
Table
9.1.
b
page
12
indicates
that
some
facilities
have
low
gastightness.
This
would
result
in
increased
methyl
bromide
use.
For
an
MB
use
to
be
considered
critical
under
Decision
XI/
6,
all
technically
and
economically
feasible
steps
should
have
been
taken
to
minimize
the
critical
use
and
any
associated
emissions
of
MB.
MBTOC
views
gastightness
as
an
important
facet
of
that
aspect
of
assessment.
What
is
the
plan
to
improve
gastightness
of
food
processing
facilities
and
commodity
trailer
fumigations
this
year?

5.
Discussions
about
phosphine
on
page
7
and
page
12
mention
concern
about
phosphine
resistant
pests.
Have
phosphine
resistant
pests
been
reported
in
the
US
and
in
the
facilities
or
commodities
included
in
this
CUN?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
6.
Section
17.1
Research
page
20
and
21
does
not
seem
to
report
research
on
the
food
facilities
and
commodities
included
in
this
CUN,
but
does
report
research
included
in
the
other
CUN
for
food
processing
facilities
also
submitted
by
the
US
(
e.
g.
rice
milling,
bakeries).
Is
it
possible
that
the
appropriate
section
for
this
CUN
was
inadvertently
lost
or
not
included?
The
facilities
and
commodities
included
in
this
CUN
are
likely
to
be
different
than
the
other
CUN
in
terms
of
heat
generating
capacity,
improved
sanitation
and
structures
(
resulting
from
operating
under
HACCP
processing
for
processed
foods)
and
other
factors.
Has
research
been
conducted
on
adopting
and
adapting
MB
alternatives
for
the
types
of
facilities
and
commodities
included
in
this
CUN?

7.
Please
clarify
whether
the
amount
requested
for
herbs
and
spices
is
for
the
herb
and
spice
processing
structure
or
the
commodity.

8.
The
US
FDA
requires
that
a
large
volume
of
the
cocoa
beans
landing
for
import
to
the
US
be
disinfested
because
of
pests
found
on
inspection
or
because
the
exporting
countries
has
been
found
to
consistently
send
infested
cocoa
to
the
US
(
i.
e.
mandatory
detention
by
the
FDA).
Has
the
US
government
made
a
determination
that
the
volume
of
cocoa
beans
treated
with
methyl
bromide
as
a
result
of
its
automatic
detention
by
US
FDA
is
not
a
QPS
treatment?

9.
Is
cheese
sometimes
present
in
the
stores
and
sometimes
not
present?
If
there
are
times
when
cheese
is
not
present
in
the
cheese
stores,
what
avenues
are
being
explored
to
adapt
and
adopt
other
alternatives
when
the
cheese
stores
do
not
contain
cheese?
Are
other
alternatives
registered
to
be
used
when
the
cheese
is
not
in
the
cheese
stores?
Can
improvements
in
IPM
and
use
of
alternative
treatments
such
as
heat
be
used
on
the
cheese
stores
when
cheese
is
not
present
to
result
ensure
the
stores
stay
disinfested
when
the
cheese
is
present?

10.
Foods
in
the
`
other
foods'
category
are
reported
to
include
tea
on
pallets,
coffee
beans,
tomatoes,
bell
peppers,
citrus
and
cassava
(
Table
A1
page
8).
Are
these
items
all
dry
commodities?
If
so,
could
they
be
treated
with
ethylene
oxide
gas
or
irradiated
under
US
regulations?
If
they
are
dry
commodities
is
there
marketing
or
time
pressure
that
prevents
the
use
of
phosphine
and
is
phosphine
registered
for
this
use?
