Methyl Bromide Critical Use Nomination

for Post Harvest Use for 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 for Commodities (Submitted in 2006 for 2008 Use
Season)



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:	  HYPERLINK "mailto:ThompsonJE2@state.gov" 
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:







Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwin

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) 308-8200

Fax:	(703) 308-8090

E-mail:	Keigwin.Richard@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

Paper Documents:

Title of Paper Documents and Appendices	Number of Pages	Date Sent to
Ozone Secretariat



















electronic copies of all paper documents: 

Title of Electronic Files	Size of File (kb)	Date Sent to Ozone
Secretariat



















TABLE OF CONTENTS

  TOC \f \h \z    HYPERLINK \l "_Toc125863917"  Part A: Summary	 
PAGEREF _Toc125863917 \h  5  

  HYPERLINK \l "_Toc125863918"  1. Nominating Party	  PAGEREF
_Toc125863918 \h  5  

  HYPERLINK \l "_Toc125863919"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125863919 \h  5  

  HYPERLINK \l "_Toc125863920"  3. Situation of Nominated Methyl Bromide
Use	  PAGEREF _Toc125863920 \h  5  

  HYPERLINK \l "_Toc125863921"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125863921 \h  5  

  HYPERLINK \l "_Toc125863922"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125863922 \h  6  

  HYPERLINK \l "_Toc125863923"  6. Methyl Bromide Consumption for Past 5
Years and Amount Requested in the Year(s) Nominated	  PAGEREF
_Toc125863923 \h  7  

  HYPERLINK \l "_Toc125863924"  7. Location of the Facility or
Facilities Where the Proposed Critical Use of Methyl Bromide Will Take
Place	  PAGEREF _Toc125863924 \h  8  

  HYPERLINK \l "_Toc125863925"  Part B: Situation Characteristics and
Methyl Bromide Use	  PAGEREF _Toc125863925 \h  9  

  HYPERLINK \l "_Toc125863926"  8. Key Pests for which Methyl Bromide is
Requested	  PAGEREF _Toc125863926 \h  9  

  HYPERLINK \l "_Toc125863927"  9. Summary of the Circumstances in which
Methyl Bromide is Currently Being Used	  PAGEREF _Toc125863927 \h  10  

  HYPERLINK \l "_Toc125863928"  10. List Alternative Techniques that are
being Used to Control Key Target Pest Species in this Sector	  PAGEREF
_Toc125863928 \h  12  

  HYPERLINK \l "_Toc125863929"  Part C: Technical Validation	  PAGEREF
_Toc125863929 \h  12  

  HYPERLINK \l "_Toc125863930"  11. Summarize the Alternative(s) Tested,
Starting with the Most Promising Alternative(s)	  PAGEREF _Toc125863930
\h  12  

  HYPERLINK \l "_Toc125863931"  12. Summarize Technical Reasons, if any,
for each Alternative not being Feasible or Available for your
Circumstances	  PAGEREF _Toc125863931 \h  14  

  HYPERLINK \l "_Toc125863932"  Part D: Emission Control	  PAGEREF
_Toc125863932 \h  16  

  HYPERLINK \l "_Toc125863933"  13. How has this Sector Reduced the Use
and Emissions of Methyl Bromide in the Situation of the Nomination?	 
PAGEREF _Toc125863933 \h  16  

  HYPERLINK \l "_Toc125863934"  Part E: Economic Assessment	  PAGEREF
_Toc125863934 \h  16  

  HYPERLINK \l "_Toc125863935"  14. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125863935 \h  17  

  HYPERLINK \l "_Toc125863936"  15. Summarize Economic Reasons, if any,
for each Alternative not being Feasible or Available for your
Circumstances	  PAGEREF _Toc125863936 \h  17  

  HYPERLINK \l "_Toc125863937"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125863937 \h  20  

  HYPERLINK \l "_Toc125863938"  Part F: Future Plans	  PAGEREF
_Toc125863938 \h  21  

  HYPERLINK \l "_Toc125863939"  16. Provide a Detailed Plan Describing
How the Use and Emissions of Methyl Bromide Will Be Minimized in the
Future for the Nominated Use	  PAGEREF _Toc125863939 \h  21  

  HYPERLINK \l "_Toc125863940"  17. Provide a Detailed Plan Describing
What Actions Will Be Undertaken to Rapidly Develop and Deploy
Alternatives for this Use	  PAGEREF _Toc125863940 \h  21  

  HYPERLINK \l "_Toc125863941"  17.1 Research	  PAGEREF _Toc125863941 \h
 21  

  HYPERLINK \l "_Toc125863942"  17.2 Registration	  PAGEREF
_Toc125863942 \h  23  

  HYPERLINK \l "_Toc125863943"  18. Additional Comments	  PAGEREF
_Toc125863943 \h  25  

  HYPERLINK \l "_Toc125863944"  19. Citations	  PAGEREF _Toc125863944 \h
 26  

  HYPERLINK \l "_Toc125863945"  Appendix A.  20008 Methyl Bromide Usage
Newer Numerical Index	  PAGEREF _Toc125863945 \h  28  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125863946"  Part A:
Summary	  PAGEREF _Toc125863946 \h  5  

  HYPERLINK \l "_Toc125863947"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc125863947 \h  5  

  HYPERLINK \l "_Toc125863948"  Table A.1: Executive Summary	  PAGEREF
_Toc125863948 \h  7  

  HYPERLINK \l "_Toc125863949"  Table 6.1: Methyl Bromide Consumption
for the Past 5 Years and the Amount Requested in the Year(s) Nominated	 
PAGEREF _Toc125863949 \h  7  

  HYPERLINK \l "_Toc125863950"  Table 6.1: Methyl Bromide Consumption
for the Past 5 Years and the Amount Requested in the Year(s) Nominated	 
PAGEREF _Toc125863950 \h  8  

  HYPERLINK \l "_Toc125863951"  Table 6.1: Methyl Bromide Consumption
for the Past 5 Years and the Amount Requested in the Year(s) Nominated	 
PAGEREF _Toc125863951 \h  8  

  HYPERLINK \l "_Toc125863952"  Table 6.1: Methyl Bromide Consumption
for the Past 5 Years and the Amount Requested in the Year(s) Nominated	 
PAGEREF _Toc125863952 \h  8  

  HYPERLINK \l "_Toc125863953"  Part B: Situation Characteristics and
Methyl Bromide Use	  PAGEREF _Toc125863953 \h  9  

  HYPERLINK \l "_Toc125863954"  Table 8.1: Key Pests for Methyl Bromide
Request	  PAGEREF _Toc125863954 \h  9  

  HYPERLINK \l "_Toc125863955"  Table B.1: Key Pests by Commodity	 
PAGEREF _Toc125863955 \h  9  

  HYPERLINK \l "_Toc125863956"  Table B.2: Characteristic of Sector	 
PAGEREF _Toc125863956 \h  10  

  HYPERLINK \l "_Toc125863957"  Table 9.1(a.): Commodities	  PAGEREF
_Toc125863957 \h  10  

  HYPERLINK \l "_Toc125863958"  Table 9.1(b.): Fixed Facilities	 
PAGEREF _Toc125863958 \h  11  

  HYPERLINK \l "_Toc125863959"  Part C: Technical Validation	  PAGEREF
_Toc125863959 \h  12  

  HYPERLINK \l "_Toc125863960"  Table 12.1: Summary of Technical Reason
for each Alternative not being Feasible or Available	  PAGEREF
_Toc125863960 \h  14  

  HYPERLINK \l "_Toc125863961"  Table 12.2: Food Processing Plants –
Comparison of Alternatives to Methyl Bromide Fumigation	  PAGEREF
_Toc125863961 \h  16  

  HYPERLINK \l "_Toc125863962"  Part D: Emission Control	  PAGEREF
_Toc125863962 \h  16  

  HYPERLINK \l "_Toc125863963"  Part E: Economic Assessment	  PAGEREF
_Toc125863963 \h  16  

  HYPERLINK \l "_Toc125863964"  Table 14.1 Costs of Alternatives
Compared to Methyl Bromide Over a 3-Year Period	  PAGEREF _Toc125863964
\h  17  

  HYPERLINK \l "_Toc125863965"  Table 15.1.  Summary of Economic Reasons
for each Alternative not being Feasible or Available	  PAGEREF
_Toc125863965 \h  17  

  HYPERLINK \l "_Toc125863966"  Table E.1: Economic Impacts of Methyl
Bromide Alternatives for Walnut	  PAGEREF _Toc125863966 \h  20  

  HYPERLINK \l "_Toc125863967"  Table E.3: Economic Impacts of Methyl
Bromide Alternatives for Dried Fruit	  PAGEREF _Toc125863967 \h  20  

  HYPERLINK \l "_Toc125863968"  Table E.4: Economic Impacts of Methyl
Bromide Alternatives for Dates	  PAGEREF _Toc125863968 \h  20  

  HYPERLINK \l "_Toc125863969"  Table E.4: Economic Impacts of Methyl
Bromide Alternatives for Dried Beans	  PAGEREF _Toc125863969 \h  20  

  HYPERLINK \l "_Toc125863970"  Part F: Future Plans	  PAGEREF
_Toc125863970 \h  21  

  HYPERLINK \l "_Toc125863971"  Appendix A.  2008 Methyl Bromide Usage
Newer Numerical Index	  PAGEREF _Toc125863971 \h  28  

 

Part A: Summary  TC "Part A: Summary" \f C \l "1"     TC "Part A:
Summary" \f F \l "1"  



1. Nominating Party  TC "1. Nominating Party" \f C \l "2"  



The United States of America (U. S.)



2. Descriptive Title of Nomination  TC "2. Descriptive Title of
Nomination" \f C \l "2"  :



Methyl Bromide Critical Use Nomination for Post Harvest Use for
Commodities (Submitted in 2006 for the 2008 use season)



3. Situation of Nominated Methyl Bromide Use  TC "3. Situation of
Nominated Methyl Bromide Use" \f C \l "2"   



This sector includes walnuts, dried fruit (prunes, raisins, figs),
dates, and dried beans garbanzo and blackeye) produced in California,
which are under intense pressure from numerous insect pests.  Methyl
bromide is being used to treat these commodities in a very short time
period, during the peak production season and shortly after harvest,
before they can be stored and/or shipped to prevent pests from infesting
and degrading the commodity in storage.  Most fumigations are made over
a few weeks, during the peak production season when the bulk of the
harvest is moving into the storage and shipping channels.  These periods
can be compressed when harvest occurs close to key market windows, such
as holiday markets for certain types of dried fruits, nuts, and beans.  





4. Methyl Bromide Nominated  TC "4. Methyl Bromide Nominated" \f C \l
"2"  



Table 4.1: Methyl Bromide Nominated  TC "Table 4.1: Methyl Bromide
Nominated" \f F \l "2"  

Year	Nomination amount (kg)	Volume Treated (1,000 m3)

2008	67,699	1,749



The U. S. nomination is only for those facilities where the use of
alternatives is not suitable.  For U. S. commodities 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).  In other cases the character of the final product is
changed, becoming cooked (toasted) rather than raw nuts, for example.

Transition to newly available alternatives:  Sulfuryl fluoride recently
received a Federal registration for dried fruits and nuts.  California
state registration for dried fruits and tree nuts, but not for use on
dates or dry beans, was issued in early 2005.  Many of the countries to
which the U. S. exports have not yet registered sulfuryl fluoride,
severely restricting its use in this sector.  All of the dried fruit and
nut operations requesting methyl bromide are located in California.  

Longer fumigations: 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 if the delay causes the producers to miss a market
window.  Longer fumigation periods may not be feasible in situations
where there is not excess fumigation capacity i.e. when facilities are
in continuous use.  In these situations longer fumigations for some
products mean that others cannot be fumigated.

5. Brief Summary of the Need for Methyl Bromide as a Critical Use  TC
"5. Brief Summary of the Need for Methyl Bromide as a Critical Use" \f C
\l "2"   



Methyl bromide is needed primarily to treat stored agricultural
commodities in a very short period, during the peak production season,
shortly after harvest before they can be stored and/or shipped.  These
treatments prevent field pests from infesting and degrading the
commodity in storage.  Fumigations must be made over a very short
period, during the peak production season when the bulk of the harvest
is moving into the storage and shipping channels.  These periods can be
compressed when harvest occurs close to key market windows, such as
holiday markets for certain types of nuts.

Sulfuryl fluoride was registered in California for use in tree nuts and
dried fruits (but not for dried beans or dates) in May of 2005.  Many of
the trade partners for these commodities have not yet registered
sulfuryl fluoride for these uses.  There is no way to determine at
harvest which products will be exported.  All the walnuts and dried
fruits are fumigated directly out of the field before storage or
processing, thus limiting the use of sulfuryl fluoride for these
commodities at this time.  

The technical and economic feasibility analyses indicate that phosphine
alone or combined with carbon dioxide (Eco2fume®) is the only chemical
alternative currently available for use on in-shell walnuts, dried
fruit, dates, and dried beans.  Phosphine fumigation, however, takes
longer than methyl bromide and is not a currently 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.  

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.  As with Eco2fume®, these alternatives could not be
implemented in the short term without significant investment in new
facilities.  Estimated costs for treatment facilities are at least as
great as building costs for Eco2fume, and do not include costs of land
acquisition and development.  The dried fruit and nut industries in the
United States have reduced the number of methyl bromide fumigations by
incorporating many of the alternatives identified by MBTOC, such as
implementing IPM strategies, especially sanitation, in storage
facilities.  Pest populations are monitored 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.

Although, in time, the commodity industry will be able to gradually
adopt alternatives as these become available, the sudden adoption of the
next best alternative, phosphine alone or in combination, would
adversely impact the industry’s ability to rapidly process commodities
during the peak harvest season and to access key market windows.  That
is, the industry would likely suffer significant economic losses if it
were to fully replace methyl bromide with phosphine, mainly because of
the cost of production delay.  The estimated economic loss as a
percentage of net revenue is greater than 100% for the CUE applicants in
the commodity sector.  

Table A.1: Executive Summary*  TC "Table A.1: Executive Summary" \f F \l
"2"  

		Walnuts	Beans	Dried Plum	Dates

Amount of Request

2008

(kg)	108,046	7,342	20,412	3,464

Amount of Nomination

2008

(kg)	43,888	4,371	17,410	2,009

* See Appendix A for complete description of how nominated amount was
calculated.  

6. Methyl Bromide Consumption for Past 5 Years and Amount Requested
in the Year(s) Nominated  TC "6. Methyl Bromide Consumption for Past 5
Years and Amount Requested in the Year(s) Nominated" \f C \l "2"  :



Table 6.1: Methyl Bromide Consumption for the Past 5 Years and the
Amount Requested in the Year(s) Nominated (Walnuts)  TC "Table 6.1:
Methyl Bromide Consumption for the Past 5 Years and the Amount Requested
in the Year(s) Nominated" \f F \l "1"  

For each year specify: 	Historical Use1	Requested Use

	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	81,025	68,305	77,111	67,132	93,159	83,007	137,983

Volume Treated (1000 m³)	1,686	1,421	1,605	1,397	1,936	1,727	2,871

Dosage Rate (kg/1000 m³)	48.06	48.06	48.06	48.06	48.13	48.06	48.06

Actual (A) or Estimate (E)	E	E	E	E	E	E	E

	1 Based on most current information.

Table 6.2: Methyl Bromide Consumption for the Past 5 Years and the
Amount Requested in the Year(s) Nominated (Beans)  TC "Table 6.1: Methyl
Bromide Consumption for the Past 5 Years and the Amount Requested in the
Year(s) Nominated" \f F \l "1"  

For each year specify: 	Historical Use1	Requested Use

	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	14,734	10,620	6,577	7,564	5,409	3,334	7,342

Volume Treated (1000 m³)	334	241	149	172	123	76	157

Dosage Rate (kg/1000 m³)	44.05	44.05	44.05	44.05	44.05	44.06	46.64

Actual (A) or Estimate (E)	E	E	E	E	E	E	E

	1 Based on most current information.

Table 6.3: Methyl Bromide Consumption for the Past 5 Years and the
Amount Requested in the Year(s) Nominated (Dried Plums)  TC "Table 6.1:
Methyl Bromide Consumption for the Past 5 Years and the Amount Requested
in the Year(s) Nominated" \f F \l "1"  

For each year specify: 	Historical Use1	Requested Use

	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	17,001	16,251	18,218	18,250	16,571

20,412

Volume Treated (1000 m³)	1109	684	773	734	804

850

Dosage Rate (kg/1000 m³)	15.33	23.76	23,57	24.85	20.62

24.03

Actual (A) or Estimate (E)	E	E	E	E	E	E	E

	1 Based on most current information.

Table 6.4: Methyl Bromide Consumption for the Past 5 Years and the
Amount Requested in the Year(s) Nominated (Dates)  TC "Table 6.1: Methyl
Bromide Consumption for the Past 5 Years and the Amount Requested in the
Year(s) Nominated" \f F \l "1"  

For each year specify: 	Historical Use1	Requested Use

	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	2,616	2,468	2,887	3,145	1,999	2,019	3,464

Volume Treated (1000 m³)	109	103	120	131	83	84	167

Dosage Rate (kg/1000 m³)	24.03	20.03	24.03	24.03	24.03	24.03	24.03

Actual (A) or Estimate (E)	E	E	E	E	E	E	E

	1 Based on most current information

7. Location of the Facility or Facilities Where the Proposed Critical
Use of Methyl Bromide Will Take Place  TC "7. Location of the Facility
or Facilities Where the Proposed Critical Use of Methyl Bromide Will
Take Place" \f C \l "2"   



This nomination package represents four commodity sectors, all produced
entirely in California: walnuts, dried fruit (prunes, raisins, and
figs), and dates.  Walnuts are grown and processed primarily in the
Sacramento and San Joaquin Valleys.  Significant production also occurs
in the coastal valleys in the counties of Santa Barbara, San Luis
Obispo, Monterey, and San Benito. 

The majority of California prunes are grown in the Sacramento Valley. 
Other production areas in the San Joaquin Valley include primarily
Tulare and Fresno counties. 

About 99% of California's raisin grape production is in the southern San
Joaquin Valley region. Fresno County alone produces about 70% of
California's raisins. Merced County is the only northern San Joaquin
Valley County with any significant commercial production of raisins.

The San Joaquin Valley is the predominantly fig-producing area in
California with Madera, Merced, and Fresno counties leading in
production.  

Most U.S. dates are grown in California’s Coachella Valley, Riverside
and Imperial counties.  

Part B: Situation Characteristics and Methyl Bromide Use  TC "Part B:
Situation Characteristics and Methyl Bromide Use" \f C \l "1"    TC
"Part B: Situation Characteristics and Methyl Bromide Use" \f F \l "1"  



8. Key Pests for which Methyl Bromide is Requested  TC "8. Key Pests for
which Methyl Bromide is Requested" \f C \l "2"  



Table 8.1: Key Pests for Methyl Bromide Request  TC "Table 8.1: Key
Pests for Methyl Bromide Request" \f F \l "1"  

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	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 3 times longer (6 days) than conventional MB fumigation
(2 days) and up to 20 times longer than vacuum MB fumigation (7 hours). 
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.  Pest status is due to health
hazard: allergens; plus body parts, exuviae, and excretia violate FDA
regulations1.  

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

	Callosobruchus maculates	Cowpea Weevil

	1 FDA regulations can be found at:    HYPERLINK
"http://www.cfsan.fda.gov/~dms/dalbook.html" 
http://www.cfsan.fda.gov/~dms/dalbook.html  and   HYPERLINK
"http://www.fda.gov/opacom/laws/fdcact/fdcact4.htm" 
http://www.fda.gov/opacom/laws/fdcact/fdcact4.htm . 

Table B.1: Key Pests by Commodity  TC “Table B.1: Key Pests by
Commodity” \f F \l “1”  

Common Name	Walnuts	Dried Fruit as specified	Dates	Beans

Codling moth	Common



	Navel orangeworm	Common



	Indianmeal moth	Common	Common



Red Flour Beetle	Minor



	Raisin Moth

Common	Minor

	Dried Fruit Beetle

Common



Carob pod moth

	Common

	Nitidulid beetles

	Common

	Cowpea weevil



Common



Table B.2: Characteristic of Sector  TC "Table B.2: Characteristic of
Sector" \f F \l "1"  

	Jan	Feb	Mar	Apr	May	Jun	Jul	Aug	Sep	Oct	Nov	Dec

Harvest Material In:	Walnuts, Dried Fruit







x	x	x	x



Dates	x







x	x	x	x

	Beans





X	X

X	X	X

	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

Critical methyl bromide fumigations occur during the peak harvest of the
commodities.  Other fumigations occur as indicated by monitoring
throughout the year.

9. Summary of the Circumstances in which Methyl Bromide is Currently
Being Used  TC "9. Summary of the Circumstances in which Methyl Bromide
is Currently Being Used" \f C \l "2"  



Table 9.1(a.): Commodities  TC "Table 9.1(a.): Commodities" \f F \l "1" 
 

Commodity	MB Dosage 

(Kg/1000 m³)	Exposure Time (hours)	Temp. (ºC)	Number of Fumigations
Per Product	Proportion of Product Treated at this Dose	Fixed (F) mobile
(M) Stack (S)

Dried Fruit	24	24	Variable	1	100%	F, M

Walnuts	56	24	Variable	1	100%	F, M

Dates	21	24	Variable	1	100%	F, M

Beans	47	24 	Variable	1	100%	F, M



Table 9.1(b.): Fixed Facilities  TC "Table 9.1(b.): Fixed Facilities" \f
F \l "1"   (MB fumigation done mainly in vacuum chambers)

Commodity	Type of Construction and Approximate age in Years	Volume (m³)
or Range	Number of Facilities 

(e.g. 5 silos)	Gas tightness Estimate

Dried Fruit	No information is available as to the type of construction,
age, volume, number of facilities, and gas tightness of the diverse
types of facilities in this sector.

Walnuts

	Dates

	Beans

	

10. List Alternative Techniques that are being Used to Control Key
Target Pest Species in this Sector  TC "10. List Alternative Techniques
that are being Used to Control Key Target Pest Species in this Sector"
\f C \l "2"   



Many of the MBTOC not-in-kind alternatives to methyl bromide are
critical to monitoring and managing pest populations, but they are not
designed to disinfest commodities for which there is a zero tolerance
for insect infestations.  The most critical of these for commodities in
storage are: sanitation and IPM strategies.  Sanitation is important and
constantly addressed in management programs.  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 and thus avoid fumigation (Arthur and
Phillips, 2003).  However, IPM is not designed to completely eliminate
pests from any given facility or to ensure that a facility remains free
from infestation.  Although the U. S. Food and Drug Administration (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.  

In addition to sanitation and IPM, most commodity operations in the
United States currently use both phosphine, alone and in combination
whenever feasible.  Phosphine fumigation has proven to be too slow for
treating large commodity volumes that need to be processed rapidly. 
Although phosphine is more suitable for fumigating commodities in
storage, where fumigation time is not a factor, its corrosive nature to
certain metals limits its use in some processing plants, especially
those outfitted with electronic sorting and processing control
equipment.

Part C: Technical Validation  TC "Part C: Technical Validation" \f F \l
"1"    TC "Part C: Technical Validation" \f C \l "1"  



11. Summarize the Alternative(s) Tested, Starting with the Most
Promising Alternative(s)  TC "11. Summarize the Alternative(s) Tested,
Starting with the Most Promising Alternative(s)" \f C \l "2"  



Table 11.1: Summary of the Alternatives Tested

Please see Table 12.1.

12. Summarize Technical Reasons, if any, for each Alternative not being
Feasible or Available for your Circumstances  TC "12. Summarize
Technical Reasons, if any, for each Alternative not being Feasible or
Available for your Circumstances" \f C \l "2"   



Table 12.1: Summary of Technical Reason for each Alternative not being
Feasible or Available   TC "Table 12.1: Summary of Technical Reason for
each Alternative not being Feasible or Available" \f F \l "1"  

Name of Alternative	Technical Reason for the Alternative Not Being Used

Contact and low volatility insecticides	Not registered in the U.S. for
use on stored commodities.  The only insecticides registered for use in
storage facilities are for crack and crevice treatment.  These fogs,
mists, and aerosols are effective only against exposed insects in the
facilities and are not designed to penetrate the walnut shell or any
kind of bulk commodity (Zettler, 2002).   

Ethyl or methyl formate	Not registered in the U.S. for use on stored
commodities. 

Ethylene oxide	Not registered in the U.S. for use on stored commodities.

Phosphine alone or in combination	In general, phosphine alone or in
combination is not suitable to replace methyl bromide when rapid
fumigations are needed to meet customer timelines.  The delay would
disrupt processing of dried fruit and nuts, increasing production costs
and interfering with access to the holiday market.  Furthermore,
phosphine is corrosive to some metals in electric and electronic
equipment in processing plants.   

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). 

For walnuts sold as in-shell (approximately 25% of the California
production) phosphine fumigation takes too long during the peak
production period, when large volumes of walnuts are processed and
shipped rapidly.  In some cases, however, phosphine has already replaced
MB fumigation whenever feasible.  For walnuts sold as shelled product,
phosphine combined with carbon dioxide (Eco2fume®) is being used for
in-storage fumigation by approximately 50% of the industry since 2001. 
The remaining 50% lack large storage facilities that can be sealed and
left for at least five days, the time required to fully disinfest the
commodity (California Walnut Commission & Walnut Marketing Board, 2003).




Propylene oxide

	Propylene oxide (PPO) was recently labeled for use on in-shell nuts in
California.  Because PPO is a volatile, flammable liquid that must be
used under vacuum conditions for safety, several years of
commercial-scale testing will probably be necessary before this
technique is perfected for commercial use.  Furthermore, adoption for
use on in-shell nuts will be limited by the need to use expensive vacuum
chambers.  At present, PPO is already being used by the walnut industry
to sterilize approximately 20% of bulk shelled walnuts sold for dairy
and bakery ingredients, targeting primarily mold and bacteria, and
secondarily insects (California Walnut Commission & Walnut Marketing
Board, 2003).  PPO is not labeled for use on dried fruits.  

Sulfuryl fluoride	Sulfuryl fluoride was registered in United States for
use on dried fruit and nuts on January 23, 2004.  A California
registration for use on tree nuts and dried fruit was issued in May,
2005.  The use of this chemical and its accompanying interactive
computerized program will require training and licensing of applicators
by the manufacturer.  Research to date has shown that sulfuryl fluoride
is effective against the adult, pupal, and larval stages of target
insects, but less effective against the egg stage (Fields and White,
2002, Schneider et al. 2003).  The efficacy of this chemical remains to
be demonstrated in the field.  It may take up to 5 years to validate its
use as a methyl bromide replacement and for the necessary industry
conversion ( See Section 17.2.1.).  Sulfuryl Fluoride is not registered
in the major markets where walnuts are exported.  Because walnuts are
fumigated as they leave the field, and before they are segregated into
export and domestic use, the use of sulfuryl fluoride will continue to
be restricted until there is an EU registration for sulfuryl fluoride on
walnuts.

Biological Agents	The only biological agent available for use in
commodities is the granulosis virus, which acts specifically against
Indian meal moth larvae (Johnson et al., 1998, Vail et al., 1991, Vail
et al., 2002).  No effective biological agents are available for use
against other commodity pests.  The U.S. Food and Drug Administration
does not allow the use of predatory or parasitic insects in commodity
storage areas.   

Cold Treatment	This technique is unfeasible for use on a commercial
scale, especially during harvest when large volumes need to be processed
rapidly.  Longer treatment times would also interfere with meeting the
demands of critical European markets by delaying shipments by 1-3 weeks.
 For example, at 0oC to 10oC a 4-week exposure time is needed to control
the Indian meal moth in stored walnuts (Johnson et al., 1997).  Although
it has been demonstrated that at -10oC to -18oC several insect pests of
dates can be controlled in a few hours, (Donahaye et al., 1991, 1995),
the slow rate of cold penetration and daily introduction of fresh
commodities would interfere with the ability to maintain a constant low
temperature throughout storage areas.  In California, the grower
cooperative Diamond Walnuts (representing approximately 50% of the
walnuts grown in that state) alone processes about 3,630 metric tons per
day at its Stockton plant during the peak harvest season in September
(California Walnut Commission & Walnut Marketing Board, 2003).  The
longer treatment would also affect the industry’s ability to take
advantage of national and international market windows.  Furthermore,
the cost of retrofitting storage facilities and the energy cost required
to rapidly cool large volumes of walnuts would be prohibitive.        

Controlled/Modified Atmospheres	Exposure to low oxygen or high carbon
dioxide has been shown to effectively control pests of stored dried
fruit and nuts in laboratory studies.  However, this approach would
require a minimum of 2-5 days, depending on temperature (Calderon and
Barkai-Golan, 1990, Soderstrom and Brandl, 1984, Tarr et al., 1996), and
would not be feasible when commodity needs to be moved rapidly during
peak production periods and to meet international market demands.  In
California, the grower cooperative Diamond Walnuts (representing
approximately 50% of the walnuts grown in that state) alone processes
about 3,630 metric tons per day at its Stockton plant.  Moreover,
adopting this alternative would require considerable expenditures for
special treatment facilities and retrofitting existing structures.      


Cultural practices and Integrated Pest Management	IPM, which includes
cultural practices, is designed to manage pests at low population
levels, not to completely eliminate them or prevent infestations.   

Heat Treatment	This approach is not feasible for treating
commercial-scale commodity volumes.  Under laboratory conditions, brief
exposure of commodities to high temperatures may eliminate insects
without adversely affecting product quality.  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 walnuts in order to achieve total
insect control.  Furthermore, walnut quality may be adversely affected
by exposure to heat, causing rancidity in walnut kernel oils (California
Walnut Commission & Walnut Marketing Board, 2003).  According to the 
California Dried Plum Board (2003), an attempt to use heat treatment
commercially with prunes in California  not only failed to control
target pests, but resulted in several tons of prunes being damaged from
heat exposure.  

High pressure carbon dioxide	High-pressure carbon dioxide for commodity
treatment requires the availability of small fumigation chambers
designed to withstand the required high pressures.  The small size of
these units would limit the amounts of walnuts that could be treated at
any one time, delaying the process and causing critical market windows
to be missed.   This technique is, therefore, not suitable for use on a
commercial scale in U.S. warehouses, where large volumes of walnuts must
be processed within relatively short periods.  Furthermore, these
chambers are not readily available, and the cost of building a large
number of them would be prohibitive (Zettler, 2002).

Irradiation	Although rapid and effective, irradiation may result in
living insects 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 affects walnut oils, causing
changes in flavor, lowering kernel quality, and shortening walnut shelf
life.  Irradiation would, furthermore, require major capital
expenditures.  Moreover, irradiated food is not widely accepted by
consumers, adding another element of uncertainty to this method’s
adoption (California Walnut Commission & Walnut Marketing Board, 2003). 

Pest Resistant Packaging	This measure only prevents reinfestation of
finished product, and is not designed to control infestations in bulk
commodity storage (Johnson and Marcotte, 1999).  

Physical removal/ Cleaning/Sanitation	This technique is widely used as
an IPM component in all dried fruit and nut operations, but by itself
not designed to disinfest a commodity.



Table 12.2: Commodity Processing Plants – Comparison of Alternatives
to Methyl Bromide Fumigation  TC "Table 12.2: Food Processing Plants –
Comparison of Alternatives to Methyl Bromide Fumigation" \f F \l "1"   

Fumigant	Preparation Time (hr)	Fumigation Time (hrs)	Dissipation Time
(hrs)	Total Time (hrs)	Number of Alternative Applications to One MB
Application

Methyl Bromide	24	24	4	52	--

Methyl Bromide (in vacuum chamber)	1	4	2	7 1	--

Phosphine alone or in combination with CO2	24	72 - 96	48	144 - 168	2.7 -
3.2 (MB under normal pressure)

20.6 - 24 (MB + low pressure)

1 During the 3-4 week peak harvest season, many commodity processing
plants operate 24 hours a day.  Since it takes approximately 7 hours to
fumigate a given lot with MB under vacuum, these plants can fumigate 3.4
lots per day per fumigation chamber, thus keeping up with the incoming
harvested commodities. 

Part D: Emission Control  TC "Part D: Emission Control" \f C \l "1"   
TC "Part D: Emission Control" \f F \l "1"  



13. How has this Sector Reduced the Use and Emissions of Methyl Bromide
in the Situation of the Nomination?  TC "13. How has this Sector Reduced
the Use and Emissions of Methyl Bromide in the Situation of the
Nomination?" \f C \l "2"   



The dried fruit, bean, and nut industries in the United States have
reduced the number of methyl bromide fumigations by incorporating many
of the alternatives identified by MBTOC, such as implementing IPM
strategies, especially sanitation, in storage facilities.  Pest
populations are monitored 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.  Furthermore, the phosphine + CO2
(Eco2fume®) combination is already being used to fumigate a substantial
proportion of dried fruit and nuts in storage.  

Part E: Economic Assessment  TC "Part E: Economic Assessment" \f C \l
"1"    TC "Part E: Economic Assessment" \f F \l "1"  



14. Costs of Alternatives Compared to Methyl Bromide Over 3-Year Period 
TC "14. Costs of Alternatives Compared to Methyl Bromide Over 3-Year
Period" \f C \l "2"  :



Table 14.1 Annual Costs of Alternatives Compared to Methyl Bromide Over
a 3-Year Period  TC "Table 14.1 Costs of Alternatives Compared to Methyl
Bromide Over a 3-Year Period" \f F \l "2"  

MB and Alternatives	Cost Ratio	Cost in Current Year (US$)	Cost One Year
Ago (US$)	Cost 2 Years Ago (US$)

Walnuts

           Methyl Bromide	1	 $              612 	 $              612 	 $
             612 

            Phosphine	1.10	 $              674 	 $              674 	 $ 
            674 

Dried Fruits

           Methyl Bromide	1	 $             413 	 $             413 	 $  
          413 

           Phosphine	1.27	 $             525 	 $             525 	 $    
        525 

Dates                     (Not estimated since there are no technically
feasible alternatives.)

Dried Beans          (Not estimated since there are no technically
feasible alternatives.)

* Costs in this table only include fumigation cost plus electrical
corrosive cost due to phosphine.  Losses such as reductions in revenue
due to lost days are included in Tables E.1 though E.3.

These costs assume one treatment per year with methyl bromide or
phosphine.

15. Summarize Economic Reasons, if any, for each Alternative not being
Feasible or Available for your Circumstances  TC "15. Summarize Economic
Reasons, if any, for each Alternative not being Feasible or Available
for your Circumstances" \f C \l "2"  



Table 15.1.  Summary of Economic Reasons for each Alternative not being
Feasible or Available  TC "Table 15.1.  Summary of Economic Reasons for
each Alternative not being Feasible or Available" \f F \l "2"  

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	Phosphine	Economic losses from additional production downtimes due to
longer fumigation time and from capital expenditures required to adopt
an alternative.	Economic losses due to downtime with phosphine are
persistent.



Economic costs in the post-harvest uses of the commodity sector can be
characterized as arising from three contributing factors.  First, direct
pest control costs increase 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 the 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 additional economic cost per
1000 m3 was calculated if methyl bromide users had to replace methyl
bromide with phosphine.  

The four economic measures in Tables E.1 through E.3 were used to
quantify the economic impacts to post-harvesting uses for commodities. 
The four economic measures are not independent of each other since they
can be calculated from the same financial data. The measures are,
however, supplementary to each other in evaluating the CUE applicant’s
economic viability.  These measures represent different ways to assess
the economic feasibility of methyl bromide alternatives for methyl
bromide users.

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

A separate analysis was conducted for each sub-sector (described below),
and in each case the least cost alternative fumigation system, based on
phosphine, was found to be not economically feasible.  Production
downtime was estimated on average at 84 days per year and total capital
expenditures for accelerated replacement of plant and equipment due to
corrosive nature of phosphine was assumed to be $1,076 per 1000 m3 with
10-years lifespan with 10% interest rate from the data provided by the
CUE applicants for post-harvesting uses. The potential economic losses
associated with the use of phosphine mainly originate from the cost of
production delay.  The estimated economic losses are shown in Tables E.1
through E.3.  The estimated economic losses as a percentage of net
revenue are over 100% for all the CUE applicants in the commodity
sector, which results in negative net revenues with use of phosphine. 
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.  In
addition, companies of this type generally managed by producers’
associations and therefore, making new capital investment is often
difficult. The results suggest that phosphine is not economically viable
as an alternative for methyl bromide.

Walnuts

The United States walnut industry operates almost exclusively in
California, where approximately 5,300 growers and 51 processors are
located.  Over the past five years, growers have produced an average of
265,000 tons of walnuts per year on 80,940 hectares in California.  The
largest processor is the Diamond Cooperative facility in Stockton,
California, through which 50 percent of all harvested walnuts in
California pass. The other 50 independent handlers operate much smaller
facilities that process the remaining 50 percent of California walnuts. 
Sales of walnuts to Europe accounts for one-fifth of all revenue.  Both
production and sales peak in the fall in anticipation of the holiday
season in December.  Fumigation of walnuts takes place during the entire
year, but fumigation capacity is primarily a limiting factor immediately
after harvest.  Approximately 25 percent of walnuts are sold in the
shell, and these are usually packed and shipped to European market
within a couple of days of the initial fumigation treatment. The
remaining 75 percent of walnuts are processed further to create a
variety of packaged shelled products. These walnuts must be fumigated
before they are put in long-term storage or continue in the processing
chain due to the key pests. The U.S. walnut industry already has
replaced methyl bromide 70 percent with Eco2fume for in-storage
fumigation.  Diamond Cooperative has completely converted to using
Eco2fume for in-storage fumigation.

The primary scenario for this analysis is based on the Diamond
Cooperative facility for processing walnuts in the shell as the
representative user using the existing phosphine capacity to treat all
walnuts.  Given the existing capacity of 1500 tons per day of processing
walnuts in the shell, having to rely on phosphine alone would require an
additional five days to treat walnuts in the shell. At the processing
rate of one lot every five days with phosphine compared with 7-hour
turn-around time currently achieved with methyl bromide under vacuum,
the processing walnuts in the shell would be only 5 percent or
fumigation chamber capacity would need to be expanded to approximately
20 times the existing capacity.  

Alternatively, all the walnuts could be stored and processed.  However,
prices paid to growers would be reduced by the increased supply that
would be forced onto the domestic market.  Given that the nature of the
demand for walnuts is inelastic, the impact of this supply increase is
expected to result in a decrease in price to the growers.  In addition
to the price effect, there are increased costs from using phosphine.
Additional expenditures are required to adopt phosphine for accelerated
replacement of plant and electronic equipment due to the corrosive
nature of phosphine.  The net effect of price decreases and cost
increases is shown in Table E.1.

Another scenario could represent the cost of building additional
fumigation chambers, so that the same amount of commodity could be
fumigated during the critical time period, and avoid commodity loss and
price declines from missing key market windows. In case of the Diamond
plant, it is estimated that a tank farm of ten 1-million pound capacity
silos would be required to support substitution of phosphine for
on-receipt fumigation of in-shell walnuts alone.  The costs of these
silos and fumigation chambers were not estimated due to lack of
information, but the Diamond Cooperative indicates that there is no
space for such a tank farm at the Diamond Cooperative facility, so an
offsite location would have to be found; hence there would be the
associated costs of land acquisition and development. An environmental
impact study would also be required.  The Diamond Cooperative estimates
that at least three to five years would be required for permitting and
development of an offsite fumigation facility.

Dried Fruit

California produces 99 percent of the domestic supply and 70 percent of
the world’s supply of dried plums. California also produces 99 percent
of the domestic raisin crop, and 40 percent of world raisin production.
California is responsible for nearly all of domestic fig production and
20 percent of global supply. The industry has already replaced 50%
methyl bromide with phosphine in processing dried fruits.  

The primary scenario for this analysis is based on the representative
user using the existing phosphine capacity to treat all dried fruits. 
U.S. EPA reviewers estimated that having to rely on phosphine alone
would require an additional 84 days to treat all dried fruits. In
addition to the production loss, there are increased costs from using
phosphine.  Additional expenditures are required to adopt phosphine for
accelerated replacement of plant and electronic equipment due to the
corrosive nature of phosphine.  The net effect of production losses and
cost increases is shown in Table E.3.

Dates

An economic analysis was not done for dates because there are no
technically feasible alternatives for dates.

Dried Beans

An economic analysis was not done for dried beans because there are no
technically feasible alternatives for dried beans.

Measures of Economic Impacts of Methyl Bromide Alternatives  TC
"Measures of Economic Impacts of Methyl Bromide Alternatives" \f C \l
"2"  



These analyses assume one treatment per year for methyl bromide and
phosphine

Table E.1: Annual Economic Impacts of Methyl Bromide Alternatives  TC
"Table E.1: Economic Impacts of Methyl Bromide Alternatives for Walnut"
\f F \l "2"   for Walnut

Loss Measure	Methyl Bromide	Phosphine

Total Commodity Treated (kg/1000 m³)	320,455	320,455

Average Market Price (US$/kg)	$           1.08	$         0.886

Gross Revenue (US$/1000 m³)	$     346,091	$     283,795

Operating Cost (a+b) per 1000 m³	$     328,087	$     328,149

a) Cost of MB or Alternative	$            612	$            459

b) Other Operating Costs	$     327,475	$     327,690

Net Revenue (US$/ha) (net of operating costs)	$       18,005	$     
(44,354)

Loss measures



Time Lost (days)	0	84

Loss per 1000 m³ (US$/1000 m³)	$                 -	$       62,358

Loss per Kilogram MB (US$/kg)	$                 -	$         1,299

Loss as a % of Gross Revenue (%)	0%	18%

Loss as a % of Net Revenue (%)	0%	346%

Time lost with phosphine is assumed to result in a lower average market
price for walnuts because less would be treated during peak prices, and
increased supply at other times would depress off-peak prices.

Table E.3: Annual Economic Impacts of Methyl Bromide Alternatives  TC
"Table E.3: Economic Impacts of Methyl Bromide Alternatives for Dried
Fruit" \f F \l "2"   for Dried Fruit

Loss Measure	Methyl Bromide	Phosphine

Total Commodity Treated (kg/1000 m³)	88,235	63,529

Average Market Price (US$/kg)	$           0.75	$           0.75

Gross Revenue (US$/1000 m³)	$       66,176	$       47,647

Operating Cost (a+b) per 1000 m³	$       61,741	$       57,889

	a) Cost of MB or Alternative	$            413	$            310

	b) Other Operating Costs	$       61,328	$       57,579

Net Revenue (US$/ha) (net of operating costs)	$         4,435	 $     
(10,242)

Loss measures



Time Lost (days)	0	84

Loss per 1000 m³ (US$/1000 m³)	$                 -	$       14,677

Loss per Kilogram MB (US$/kg)	$                 -	$            612

Loss as a % of Gross Revenue (%)	0%	22%

Loss as a % of Net Revenue (%)	0%	331%

Time lost with phosphine is assumed to reduce the total commodity that
could be treated.

Table E.4: Economic Impacts of Methyl Bromide Alternatives  TC "Table
E.4: Economic Impacts of Methyl Bromide Alternatives for Dates" \f F \l
"2"   for Date

An economic analysis was not done for dates because there are no
technically feasible alternatives for dates.

Table E.5: Economic Impacts of Methyl Bromide Alternatives  TC "Table
E.4: Economic Impacts of Methyl Bromide Alternatives for Dried Beans" \f
F \l "2"   for Dried Beans

An economic analysis was not done for dried beans because there are no
technically feasible alternatives for dried beans.

Part F: Future Plans  TC "Part F: Future Plans" \f C \l "1"    TC "Part
F: Future Plans" \f F \l "1"  



16. Provide a Detailed Plan Describing How the Use and Emissions of
Methyl Bromide Will Be Minimized in the Future for the Nominated Use  TC
"16. Provide a Detailed Plan Describing How the Use and Emissions of
Methyl Bromide Will Be Minimized in the Future for the Nominated Use" \f
C \l "2"  

The Industry is committed to studying how to improve insect control with
IPM strategies and sanitation and further reduce the number of methyl
bromide fumigations.  They are also continuing to pursue research of
phosphine 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). 
U.S. EPA registered sulfuryl fluoride for some commodities on January
23, 2004 (see Section 17.2.1) and further expanded the use sites on this
label on July 15, 2005.  Sulfuryl fluoride was registered for use on
dried fruit and tree nuts, but not on dry beans or dates, in the state
of California in May, 2005.  Many of the applicants are waiting for the
foreign countries to which they export to register this product to fully
utilize the potential of this compound.  

For further details regarding the transition plans for this sector
please consult the national management strategy.-+

17. Provide a Detailed Plan Describing What Actions Will Be Undertaken
to Rapidly Develop and Deploy Alternatives for this Use:  TC "17.
Provide a Detailed Plan Describing What Actions Will Be Undertaken to
Rapidly Develop and Deploy Alternatives for this Use" \f C \l "2"  



17.1 Research  TC "17.1 Research" \f C \l "2"   

The amount of methyl bromide requested for research purposes is
considered critical for the development of effective alternatives. 
Without methyl bromide for use as a standard treatment, the research
studies can never address the comparative performance of alternatives. 
This would be a serious impediment to the development of alternative
strategies.  The U.S. government estimates that commodities research
will require 20 kg per year of methyl bromide for 2005 and 2006.  This
amount of methyl bromide is necessary to conduct research on
alternatives and is in addition to the amounts requested in the
submitted CUE applications.  One example of this type of research is a
study testing the comparative performance of several fumigants for
penetration through packing material for control of the Indianmeal moth
or confused flour beetle. 

To date, the U.S. government has spent U. S.$135.5 million to implement
an aggressive research program to find alternatives to methyl bromide
under the USDA’s Agricultural Research Service (ARS) Methyl Bromide
Alternatives program (select Methyl Bromide Alternatives at this web
site:   HYPERLINK "http://www.nps.ars.usda.gov" 
http://www.nps.ars.usda.gov ).

The post-harvest 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.  

The USDA is continuing to fund research projects in post-harvest pest
management.  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, Indian meal 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.

	Propylene Oxide and Carbon Dioxide: A non-flammable 8% PPO and 92% CO2
mixture 	is being tested for use as fumigant on dried fruit and nuts. 
Unlike 100% PPO, this 	mixture would not require the use of vacuum
chambers (Griffith, 2004). 

Overall, future research plans for this industry encompass testing
alternatives that fumigate rapidly and achieve high mortality rates.  So
far the most promising of these are sulfuryl fluoride, heat treatments;
and various combinations of heat, phosphine, and carbon dioxide. 
Industry is supportive of and closely follows USDA research on these
alternatives.  

U. S. efforts to research alternatives for methyl bromide have been
increasing as the phase-out has approached.  The U. S. is committed to
sustaining its research efforts into the future until technically and
economically viable alternatives are found for each and every controlled
use of methyl bromide.   We are also committed to continuing to share
our research.  Toward that end, for the past several years, key U. S.
government agencies have collaborated with industry to host an annual
conference on alternatives to methyl bromide.  This conference, the
Methyl Bromide Alternatives Outreach (MBAO), has become the premier
forum for researchers and others to discuss scientific findings and
progress in this field.

The following are additional examples of research actions supported by
the dried fruit and nuts industry in California, with funding levels in
excess of U.S. $1,000,000, and implemented by USDA (California Dried
Plum Board, 2003):

Determination of seasonal prevalence and spatial variation of navel
orangeworm.

Development of pheromone-mediated mating disruption of navel orangeworm
and attract-and-kill techniques for nitidulid beetles.

Determination of the efficacy of propylene oxide: carbon dioxide
mixtures against a variety of stored product insects.

Determination of the loading of MB on activated carbon after repeated
use and the effect of high moisture on the sorption process.  

Indianmeal moth granulovirus as an alternative to methyl bromide for
protection of dried fruits and nuts.

Low temperature studies for eggs of Indianmeal moth and navel orangeworm
as a component of integrated post harvest systems.

Optimization of Indianmeal moth trapping.

Physical treatment for post harvest insects, aimed at determining heat
tolerance of moths species, identifying stage and pests species most
tolerant to vacuum, and describing response of cowpea weevil eggs to
commercial cold storage temperatures.

In addition, the following study is being carried out by the Dried Fruit
Association of California and Dow Chemical Company: Sulfuryl fluoride
efficacy and residue studies on dry fruit, designed to determine this
chemical’s effectiveness against dried fruit pests and to develop data
for its registration 

17.2 Registration  TC "17.2 Registration" \f C \l "2"   

While the U.S. government’s role to find alternatives is primarily in
the research arena, we know that research is only one step in the
process.  As a consequence, we have also invested significantly in
efforts to register alternatives, as well as efforts to support
technology transfer and education activities with the private sector.  

Since 1997, the Agency has made the registration of alternatives to
methyl bromide a high registration priority.  Because the Agency
currently has more applications pending in its review than the resources
to evaluate them, U.S. EPA prioritizes the applications in its
registration queue.  By virtue of being a top registration priority,
methyl bromide alternatives enter the science review process as soon as
U.S. EPA receives the application and supporting data rather than
waiting in turn for the U.S. EPA to initiate its review.  

As one incentive for the pesticide industry to develop alternatives to
methyl bromide, the Agency has worked to reduce the burdens on data
generation, to the extent feasible while still ensuring that the
Agency’s registration decisions meet the Federal statutory safety
standards.  Where appropriate from a scientific standpoint, the Agency
has refined the data requirements for a given pesticide application,
allowing a shortening of the research and development process for the
methyl bromide alternative.  Furthermore, Agency scientists routinely
meet with prospective methyl bromide alternative applicants, counseling
them through the preregistration process to increase the probability
that the data is done right the first time and rework delays are
minimized

The U.S. EPA has also co-chaired the USDA/U.S. EPA Methyl Bromide
Alternatives Work Group since 1993 to help coordinate research,
development and the registration of viable alternatives.  The work group
conducted six workshops in Florida and California (states with the
highest use of methyl bromide) with growers and researchers to identify
potential alternatives, critical issues, and grower needs covering the
major methyl bromide dependent crops and post harvest uses.

This coordination has resulted in key registration issues (such as
worker and bystander exposure through volatilization, township caps and
drinking water concerns) being directly addressed through USDA’s
Agricultural Research Service’s U. S.$15 million per year research
program conducted at more than 20 field evaluation facilities across the
country.  Also U.S. EPA’s participation in the evaluation of research
grant proposals each year for USDA’s U. S.$2.5 million per year methyl
bromide alternatives research has further ensured close coordination
between the U.S. government and the research community.  

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

2000: Phosphine in combination to control stored product insect pests 

2001: Indianmeal Moth Granulosis Virus to control Indianmeal moth in
stored grains

Sulfuryl Fluoride

On January 23, 2004, the U. S. EPA registered sulfuryl fluoride as a
post-harvest fumigant for dried fruit and tree nuts.  Sulfuryl fluoride
was registered for these uses in California in May, 2005.  While
registration for these uses will provide opportunities to reduce methyl
bromide use, it must be emphasized that such replacement, if feasible,
will only occur gradually over time.  The primary hurdle to overcome is
that many of these commodities are exported.  Unfortunately, our trade
partners have not all registered sulfuryl fluoride for these specific
uses.  

Alternatives must be tested by users and found technically and
economically feasible before widespread adoption will occur.  As noted
by TEAP, a specific alternative, once available may take up to 5
fumigation cycles of use before efficacy can be determined in the
specific circumstance of the user.  The registrant is requiring that
applicators be trained by them before using sulfuryl fluoride (there is
a 3-tiered certification system).  However, the registrant has been
training applicators in California.  It may take some time for other
potential applicators to be identified and to take this training before
the product can be applied in all the specific circumstances of users.  

There are also data limitations preventing U.S. EPA, at this time, from
estimating the degree to which sulfuryl fluoride might replace methyl
bromide use in fumigating dried fruits and nuts.  We currently lack the
information to evaluate sulfuryl fluoride’s performance relative to
methyl bromide.  We have limited relative product performance data
(direct comparisons to methyl bromide), little experience in how well it
performs in different facilities and climates over multiple years,
limited price data, and limited information on what other costs might be
associated with adopting sulfuryl fluoride.  Lacking such information,
we cannot reach science-based conclusions on the technical and economic
feasibility of sulfuryl fluoride at this time.

For these reasons, and given the current state of data, U.S. EPA is
refraining from speculating on the degree to which sulfuryl fluoride
registrations might lead to amended CUE nominations.  At the same time,
U.S. EPA commits to carefully studying sulfuryl fluoride use during the
next year, with the aim of identifying specific sectors where CUE
requests can be modified, once we have (and have analyzed) the necessary
data.

Registering potential alternatives is not the end of the process. 
Potential alternatives must be tested by users and found technically and
economically feasible before widespread adoption will occur.  Also,
countries to which we export must also have registered the alternatives
for the same uses.  As noted by TEAP, a specific alternative, once
available may take two or three cropping seasons of use before efficacy
can be determined in the specific circumstance of the user.  In an
effort to speed adoption of alternatives, the U.S. government has also
been involved by promoting technology transfer, experience transfer, and
private sector training. 

18. Additional Comments  TC "18. Additional Comments" \f C \l "2"   



Pheromone Traps

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

Sulfuryl Fluoride

There are some industry concerns regarding sulfuryl fluoride.  Primarily
that it is temperature dependent and that higher concentrations are
necessary to kill eggs of insect pests.  The post harvest industry is
very concerned about the price of sulfuryl fluoride at these
concentrations required to control all life stages of pests, especially
when temperatures are low.  



19. Citations  TC "19. Citations" \f C \l "2"   



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.  

Calderon, M. and R. Barkai-Golan.  1990.  Controlled atmospheres for the
preservation of tree nuts and dried fruits.  Chapter 6, Food
Preservation by modified atmospheres, CRC Press, Boca Raton.

 

California Dried Plum Board.  2003.  Methyl bromide critical use
exemption request.  Postharvest application

California Walnut Commission & Walnut Marketing Board.  2003.  Methyl
bromide critical use exemption request.  Post harvest application.   

Donahaye, E., S. Navarro, and M. Rinder.  1991.  The influence of low
temperatures on two species of Carpophilus (Coleoptera: Nitidulidae). 
J. Appl. Entomol.  111:297-302.

Donahaye, E., S. Navarro, and M. Rinder.  1995.  Low temperature as an
alternative to fumigation for disinfesting dried fruit from three insect
species.  J. Stored Prod. Res. 31:63-70.

  

Fields, P.G.  1992.  The control of stored-product insects and mites
with extreme temperatures.  J. Stored Product Res.  28:89-118.

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

Griffith, T.  2004.  VP, ABERCO, Inc.  Personal communication with A.
Chiri.,  01-09-04. 

Johnson, J.A. and M. Marcotte.  1999.  Irradiation control of insect
pests of dried fruits and walnuts.  Food Technology 53:46-51.  

Johnson, J.A., K.A. Valero, and M.M. Hannel.  1997.  Effect of low
temperature storage on survival and reproduction of Indianmeal moth
(Lepidoptera: Pyralidae).  Crop Protection: 16:519-523.  

Johnson, J.A., P.V. Vail, E.L. Soderstrom, C.E. Curtis, D.G. Brandl,
J.S. Tebbets, and K.A. Valero.  1998.  Integration of  nonchemical,
postharvest treatments for control of navel orangeworm (Lepidoptera: 
Pyralidae) and Indianmeal moth (Lepidoptera:Pyralidae) in walnuts.  J.
Econ. Entomol.  91: 1437-1444.        

Hartsell, P.L., J.C. Tebbets, and P.V. Vail.  1991.  Phosphine
fumigation of in shell almonds for

insect control.  Insecticide & Acaricide Tests: 16:42.

Schneider, S.M., E.N. Rosskopf, J.G. Leesch, D.O. Chellemi, C.T. Bull,
and M.Mazzola.  2003.  United 	States Department of Agriculture –
Agricultural Research Service research on alternatives to 	methyl
bromide: pre-plant and post-harvest.  Pest Manag. Sci. 59:814-826.     

Soderstrom, E.L. and D.G. Brandl.  1984.  Low-oxygen atmosphere for
postharvest insect Control in bulk-stored raisins.  J. Econ. Entomol. 
77:440-445.

Soderstrom, E.L., P.D. Gardner, J.L. Baritelle, K.N. de Lozano, and D.G.
Brandl.  1984.  Economic cost evaluation of a generated low-oxygen
atmosphere as an alternative fumigant in bulk storage of raisins.  J.
Econ. Entomol.  77:457-461.

Tarr, C., S.J. Hilton, J. van S. Graver, and P.R. Clingeleffer.  1996. 
Carbon dioxide fumigation of processed dried vine fruit (sultanas) in
sealed stacks.  In E.Highley, E.J. Wright, H.J.  Banks and B.R. Champ
(eds.), Proc.6th International Working Conference on Stored-Product
Protection, 17-23 April, 1994, Canberra, Australia.  CAB International
1:204-209.

   

Vail, P.V., Tebbets, J.S., Cowan, D.C., and Jenner, K.E.  1991. 
Efficacy and persistence of a granulosis virus against infestation of
Plodia interpunctella (Hübner) (Lepidoptera: Pyralidae) on raisins.  J.
Stored Prod. Res. 27:103-107. 

Vail, P.V., Tebbets, J.S., and D.F. Hoffmann.  2002.  Efficacy and
persistence of Indiameal moth granulovirus applied to nuts.  Proceed.
8th Intl. Working Conf. on Stored Product Protection.  July 21-26, 2002,
York, UK.   

Zettler, J.L.  2002.  Alternatives to post harvest uses of methyl
bromide on dried fruits and nuts to be addressed by the CUE for methyl
bromide.  USDA, ARS.  Unpublished Report.   

Appendix A.  2008 METHYL Bromide Usage Newer Numerical Index  TC
"Appendix A.  2008 Methyl Bromide Usage Newer Numerical Index" \f F \l
"1"    TC "Appendix A.  20008 Methyl Bromide Usage Newer Numerical
Index" \f C \l "1"   

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.  

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.

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.

Pest-free Requirements - 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.

Other Issues.- Other issues is a short reminder of other elements of an
application that were checked

Frequency of Treatment of Product – This indicates how often methyl
bromide is applied in the sector.  Frequency varies from multiple times
per year to once in several decades.

Quarantine and Pre-Shipment Removed? – This indicates whether the
Quarantine and pre-shipment (QPS) hectares subject to QPS treatments
were removed from the nomination.

Most Likely Combined Impacts (%) – 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 to make the adjustment to the
requested amounts in the most appropriate category when the adjustment
could fall into more than one category. 

Regulatory Issues (%) - Regulatory issues (%) is the percent (%) of the
requested area where alternatives cannot be legally used (e.g., township
caps) pursuant to state and local limits on their use.  

Key Pest Distribution (%) - 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.

Total 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).   

Most Likely Baseline Transition – Most Likely Baseline Transition
amount was determined by the DELPHI process and was calculated by
determining the maximum share of industry that can transition to
existing alternatives.

(%) Able to Transition – Maximum share of industry that can transition

Minimum # of Years Required – The minimum number of years required to
achieve maximum transition.

(%) Able to Transition per Year – The Percent Able to Transition per
Year is the percent able to transition divided by the number of years to
achieve maximum transition.

EPA Adjusted Use Rate - Use rate is the lower of requested use rate for
2008 or the historic average use rate or is determined by MBTOC
recommended use rate reductions.

2008 Amount of Request – The 2008 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 1,000 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 US
nomination. 

EPA Preliminary Value – The EPA Preliminary Value is the lowest of the
requested amount from 2005 through 2008 with MBTOC accepted adjustments
(where necessary) included in the preliminary value.

EPA Baseline Adjusted Value – The EPA Baseline Adjusted Value has been
adjusted for MBTOC adjustments, QPS, Double Counting, Growth, Use Rate/
Strip Treatment, Miscellaneous adjustments, and Combined Impacts.

EPA Transition Amount – The EPA Transition Amount is calculated by
removing previous transition amounts since transition was introduced in
2007 and removing the amount of the percent (%) Able to Transition per
Year multiplied by the EPA Baseline Adjusted Value. 

Most Likely Impact Value – The qualified amount of the initial request
after all adjustments have been made given in total kilograms of
nomination, total volume of nomination, and final use rate of
nomination.

Sector Research Amount – The total U.S. amount of methyl bromide
needed for research purposes in each sector.

Total US Sector Nomination - Total U.S. sector nomination is the most
likely estimate of the amount needed in that sector.

 MBTOC has asserted that 48g/m3 is adequate for the fumigation of
in-shell walnuts.  The USG disputes this assertion and offers the
following:

SUBJECT:  Reducing the dosage used on walnuts for export

TO:  Christine Augustyniak

        USEPA

FROM:  Jim Leesch /s/

        Research Entomologist

        Commodity Protection & Quality Research Unit

The requested dose of 61g/m3 of methyl bromide is not excessive
considering the insect pest of concern.  When walnuts are harvested and
exported, the most tolerant stage to methyl bromide and the insects of
interest are the diapausing larvae of the codling moth, Cydia pomonella
hidden inside sound walnuts.  Original testing established the treatment
schedule at 56g/m3 for 24 hours at atmospheric pressure, which is too
long for the walnut industry to hold walnuts being processed for the
holiday (Thanksgiving , Christmas and New Years) season.  Because a 24
hour exposure was too long, the schedule was changed to conduct the
fumigation under vacuum using the same dose but reducing the time to 4
hours.  If the time is cut any shorter, then 61 g/m3 is not out of line
to assure that all diapausing codling moth larvae are killed.  If there
is a recommendation that the dosage be reduced below the original 56
g/m3, that would jeopardize the effectiveness of the treatment.  Again,
if the time were reduced to 3 hours ins

tead of 4 hours, then the dose would have to be adjusted upward to
compensate for the reduced contact with the fumigant, so 61 g/m3 is
certainly in line and in fact, it may be too low for total kill.

I hope this explanation helps you with your assessment of the
recommendations for walnuts.  Hope to see you at eh MBAO meetings in San
Diego.

United States Department of Agriculture Research, Education and
Economics Agricultural Research Service

Commodity Protection & Quality Research Unit San Joaquin Valley
Agricultural Sciences Center 9611 S Riverbend Ave, Parlier, CA 93648
KLM[nrs

Jim Leesch:  Voice: 559-596-2739  Fax: 559-596-2721

 E-mail: jleesch@fresno.ars.usda.gov Pacific West Area

.

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