Methyl Bromide Critical Use Nomination 

for Post-Harvest Use in Structures - Food Processing Plants 

For Administrative Purposes Only:

Date received by Ozone Secretariat:

YEAR:                              CUN:



Nominating Party:	The United States of America

Brief Descriptive Title of Nomination:	Methyl Bromide Critical Use
Nomination for Post-Harvest Use in Structures - Food Processing Plants
(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 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 "_Toc125804152"  Part A: Summary	 
PAGEREF _Toc125804152 \h  7  

  HYPERLINK \l "_Toc125804153"  1. Nominating Party	  PAGEREF
_Toc125804153 \h  7  

  HYPERLINK \l "_Toc125804154"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125804154 \h  7  

  HYPERLINK \l "_Toc125804155"  3. Situation of Nominated Methyl Bromide
Use	  PAGEREF _Toc125804155 \h  7  

  HYPERLINK \l "_Toc125804156"  4. Methyl Bromide Nominated for Food
Processing Plants	  PAGEREF _Toc125804156 \h  7  

  HYPERLINK \l "_Toc125804157"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125804157 \h  7  

  HYPERLINK \l "_Toc125804158"  6. Methyl Bromide Consumption for Past 5
Years and Amount Requested in the Year(s) Nominated for Food Processing
Plants	  PAGEREF _Toc125804158 \h  9  

  HYPERLINK \l "_Toc125804159"  7. Location of the Facility or
Facilities Where the Proposed Critical Use of Methyl Bromide Will Take
Place	  PAGEREF _Toc125804159 \h  11  

  HYPERLINK \l "_Toc125804160"  Part B: Situation Characteristics and
Methyl Bromide Use	  PAGEREF _Toc125804160 \h  12  

  HYPERLINK \l "_Toc125804161"  8. Key Pests for which Methyl Bromide is
Requested	  PAGEREF _Toc125804161 \h  12  

  HYPERLINK \l "_Toc125804162"  9. Summary of the Circumstances in which
the Methyl Bromide is Currently Being Used	  PAGEREF _Toc125804162 \h 
13  

  HYPERLINK \l "_Toc125804163"  10. List Alternative Techniques that are
being Used to Control Key Target Pest Species in this Sector	  PAGEREF
_Toc125804163 \h  14  

  HYPERLINK \l "_Toc125804164"  Part C: Technical Validation	  PAGEREF
_Toc125804164 \h  16  

  HYPERLINK \l "_Toc125804165"  11. Summarize the Alternative(s) Tested,
Starting with the Most Promising Alternative(s)	  PAGEREF _Toc125804165
\h  16  

  HYPERLINK \l "_Toc125804166"  12. Summarize Technical Reasons, if any,
for each Alternative not being Feasible or Available for your
Circumstances	  PAGEREF _Toc125804166 \h  18  

  HYPERLINK \l "_Toc125804167"  Part D: Emission Control	  PAGEREF
_Toc125804167 \h  19  

  HYPERLINK \l "_Toc125804168"  13. How has this Sector Reduced the Use
and Emissions of Methyl Bromide in the Situation of the Nomination?	 
PAGEREF _Toc125804168 \h  19  

  HYPERLINK \l "_Toc125804169"  Part E: Economic Assessment	  PAGEREF
_Toc125804169 \h  19  

  HYPERLINK \l "_Toc125804170"  14. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125804170 \h  19  

  HYPERLINK \l "_Toc125804171"  15. Summarize Economic Reasons, if any,
for each Alternative not being Feasible or Available for your
Circumstances	  PAGEREF _Toc125804171 \h  20  

  HYPERLINK \l "_Toc125804172"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125804172 \h  20  

  HYPERLINK \l "_Toc125804173"  Part F: Future Plans	  PAGEREF
_Toc125804173 \h  23  

  HYPERLINK \l "_Toc125804174"  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 _Toc125804174 \h  23  

  HYPERLINK \l "_Toc125804175"  17. Provide a Detailed Plan Describing
what Actions will be Undertaken to Rapidly Develop and Deploy
Alternatives for this Use	  PAGEREF _Toc125804175 \h  24  

  HYPERLINK \l "_Toc125804176"  17.1.  Research	  PAGEREF _Toc125804176
\h  24  

  HYPERLINK \l "_Toc125804177"  17.2.  Registration	  PAGEREF
_Toc125804177 \h  25  

  HYPERLINK \l "_Toc125804178"  17.2.1.  Sulfuryl Fluoride	  PAGEREF
_Toc125804178 \h  26  

  HYPERLINK \l "_Toc125804179"  18. Additional Comments	  PAGEREF
_Toc125804179 \h  27  

  HYPERLINK \l "_Toc125804180"  19. Citations	  PAGEREF _Toc125804180 \h
 28  

  HYPERLINK \l "_Toc125804181"  Appendix A.  Methyl Bromide Usage Newer
Numerical Index	  PAGEREF _Toc125804181 \h  30  

  HYPERLINK \l "_Toc125804182"  Appendix B.  Supporting Data	  PAGEREF
_Toc125804182 \h  31  

  HYPERLINK \l "_Toc125804183"  Appendix C.  Published Performance Data	
 PAGEREF _Toc125804183 \h  33  

  HYPERLINK \l "_Toc125804184"  Appendix D.  Methyl Bromide Facilities
Data	  PAGEREF _Toc125804184 \h  35  

 

LIST OF TABLES

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125804219"  Part A:
Summary	  PAGEREF _Toc125804219 \h  7  

  HYPERLINK \l "_Toc125804220"  Table 4.1: Methyl Bromide Nominated for
Food Processing Plants	  PAGEREF _Toc125804220 \h  7  

  HYPERLINK \l "_Toc125804221"  Table A.1: Executive Summary	  PAGEREF
_Toc125804221 \h  9  

  HYPERLINK \l "_Toc125804222"  Table 6.1: Methyl Bromide Consumption
for the Past 5 Years and the Amount Requested in the Year(s) Nominated
(Rice Millers)s	  PAGEREF _Toc125804222 \h  9  

  HYPERLINK \l "_Toc125804223"  Table 6.2: Methyl Bromide Consumption
for the Past 5 Years and the Amount Requested in the Year(s) Nominated
(Bakeries)s	  PAGEREF _Toc125804223 \h  10  

  HYPERLINK \l "_Toc125804224"  Table 6.2: Methyl Bromide Consumption
for the Past 5 Years and the Amount Requested in the Year(s) Nominated
(Pet Food Facilities)	  PAGEREF _Toc125804224 \h  10  

  HYPERLINK \l "_Toc125804225"  Table 6.4: Methyl Bromide Consumption
for the Past 5 Years and the Amount Requested in the Year(s) Nominated
(NAMA)	  PAGEREF _Toc125804225 \h  11  

  HYPERLINK \l "_Toc125804226"  Part B: Situation Characteristics and
Methyl Bromide Use	  PAGEREF _Toc125804226 \h  12  

  HYPERLINK \l "_Toc125804227"  Table 8.1: Key Pests for Methyl Bromide
Request	  PAGEREF _Toc125804227 \h  12  

  HYPERLINK \l "_Toc125804228"  Table B.1: Characteristic of Sector -
Food Processing Plants: Flour Mills, Bakeries, and Pet Food Facilities	 
PAGEREF _Toc125804228 \h  13  

  HYPERLINK \l "_Toc125804229"  Table 9.1: (a) Food Processing Plants	 
PAGEREF _Toc125804229 \h  13  

  HYPERLINK \l "_Toc125804230"  Table 9.1: (b) Fixed Facilities	 
PAGEREF _Toc125804230 \h  14  

  HYPERLINK \l "_Toc125804231"  Part C: Technical Validation	  PAGEREF
_Toc125804231 \h  16  

  HYPERLINK \l "_Toc125804232"  Table 11.1: Summary of the Alternatives
Tested	  PAGEREF _Toc125804232 \h  16  

  HYPERLINK \l "_Toc125804233"  Table 11.2: Summary of Review or
Position Papers concerning Alternatives for Stored Product Pests	 
PAGEREF _Toc125804233 \h  17  

  HYPERLINK \l "_Toc125804234"  Table 12.1: Summary of Technical Reason
for each Alternative not being Feasible or Available	  PAGEREF
_Toc125804234 \h  18  

  HYPERLINK \l "_Toc125804235"  Table 12.2: Comparison of Alternatives
to Methyl Bromide Fumigation	  PAGEREF _Toc125804235 \h  19  

  HYPERLINK \l "_Toc125804236"  Part D: Emission Control	  PAGEREF
_Toc125804236 \h  19  

  HYPERLINK \l "_Toc125804237"  Part E: Economic Assessment	  PAGEREF
_Toc125804237 \h  19  

  HYPERLINK \l "_Toc125804238"  Table 14.1: Annual Costs of Alternatives
Compared to Methyl Bromide Over a 3-Year Period	  PAGEREF _Toc125804238
\h  19  

  HYPERLINK \l "_Toc125804239"  Table 15.1: Summary of Economic Reasons
for each Alternative not being Feasible or Available	  PAGEREF
_Toc125804239 \h  20  

  HYPERLINK \l "_Toc125804240"  Table E.1: Economic Impacts of Methyl
Bromide Alternatives for Rice Miller’s Association	  PAGEREF
_Toc125804240 \h  22  

  HYPERLINK \l "_Toc125804241"  Table E.2: Annual Economic Impacts of
Methyl Bromide Alternatives for Bakeries	  PAGEREF _Toc125804241 \h  22 


  HYPERLINK \l "_Toc125804242"  Table E.3: Annual Economic Impacts of
Methyl Bromide Alternatives for Pet Food Institute	  PAGEREF
_Toc125804242 \h  23  

  HYPERLINK \l "_Toc125804243"  Table E.4: Annual Economic Impacts of
Methyl Bromide Alternatives for North American Miller’s Association	 
PAGEREF _Toc125804243 \h  23  

  HYPERLINK \l "_Toc125804244"  Part F: Future Plans	  PAGEREF
_Toc125804244 \h  23  

  HYPERLINK \l "_Toc125804245"  Appendix A.  Methyl Bromide Usage Newer
Numerical Index	  PAGEREF _Toc125804245 \h  30  

  HYPERLINK \l "_Toc125804246"  Appendix B.  Supporting Data	  PAGEREF
_Toc125804246 \h  31  

  HYPERLINK \l "_Toc125804247"  Appendix B - Table 9.1(a): Summary of
the Circumstances of Current Methyl Bromide Use In Pet Food Processing
Plants	  PAGEREF _Toc125804247 \h  31  

  HYPERLINK \l "_Toc125804248"  Appendix B - Table 9.1(B): Summary of
the Circumstances of Current Methyl Bromide Use In Pet Food Processing
Plants - Fixed Facilities: Pet Food Institute	  PAGEREF _Toc125804248 \h
 32  

  HYPERLINK \l "_Toc125804249"  Appendix C.  Published Performance Data	
 PAGEREF _Toc125804249 \h  33  

  HYPERLINK \l "_Toc125804250"  Appendix C - Table 1: Effect of
temperature on concentration and time thresholds for some pests of
stored products. (From: Bell, C. H. 2000)	  PAGEREF _Toc125804250 \h  33
 

  HYPERLINK \l "_Toc125804251"  Appendix C - Table 2: Concentration-Time
Product recommendations by National Pest Management Association	 
PAGEREF _Toc125804251 \h  34  

  HYPERLINK \l "_Toc125804252"  Appendix D.  Methyl Bromide Facilities
Data	  PAGEREF _Toc125804252 \h  35  

 



Part A: Summary  TC "Part A: Summary" \f F \l "1"    TC "Part A:
Summary" \f C \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 in
Structures - Food Processing Plants (Submitted in 2006 for 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 rice mills, flour mills, pet food manufacturing
facilities, and a few bakeries.  Primarily this sector is treating only
the portions of the facilities that contain electronic components and
have machinery with copper and copper alloy parts.  These facilities are
under intense pressure from many insect pests.  The flour millers and
the bakeries in this sector do not target any of their commodities to be
fumigated with methyl bromide, although some may be present during
fumigation.  However, rice millers and pet food manufacturers may target
some of their products during fumigations with methyl bromide.  

4. Methyl Bromide Nominated For Food Processing Plants   TC "4. Methyl
Bromide Nominated for Food Processing Plants" \f C \l "2"  



Table 4.1: Methyl Bromide Nominated For Food Processing Plants   TC
"Table 4.1: Methyl Bromide Nominated for Food Processing Plants" \f F \l
"2"  

Year

	Nomination amount (kg)	Nomination Volume (1000 m3)

2008	362,952	18,950



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"  



The U. S. nomination is only for those facilities where the use of
alternatives is not suitable.  In U. S. food processing plants there are
several factors that make the potential alternatives to methyl bromide
unsuitable.  These include:

Pest control efficacy of alternatives: the efficacy of alternatives may
not be comparable to methyl bromide, making these alternatives
technically and/or economically infeasible.

Geographic distribution of the facilities: some facilities are situated
in areas where key pests usually occur at lower levels, such as those
located in the northern part of the U. S.  In such cases, the U. S. is
only nominating a CUE for facilities where the key pest pressure is
moderate to high.

Age and type of facility: older food processing facilities, especially
those constructed of wood, experience more frequent and severe pest
infestations that must be controlled by fumigation.

Constraints of the alternatives: some types of commodities (e.g., those
containing high levels of fats and oils) prevent the use of heat as an
alternative because of its effect on the final product (e.g.,
rancidity).  Further, the corrosive nature of phosphine on certain
metals prevents its use in mechanical and electrical areas of the
facilities.  Additionally, both phosphine and sulfuryl fluoride are
temperature sensitive.  

Transition to newly available alternatives: Sulfuryl fluoride recently
received a federal registration for portions of this sector.  It will
take some time for sulfuryl fluoride to be incorporated into a pest
management program.  

Delay in plant operations: e.g., the use of some methyl bromide
alternatives can add a delay to production by requiring additional time
to complete the fumigation process. Production delays can result in
significant economic impacts to the processors. 

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

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

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

Sulfuryl fluoride was registered by U.S. EPA in January 2004 for rice
mills and flour mills, and for additional sites and commodities in July
2005.  There are some constraints with this new fumigant:  the initial
uses were registered in California in May 2005; it is temperature
dependent; its efficacy on eggs requires higher concentrations except at
optimal temperatures; and it requires extensive training of the
applicators to proficiently use the computerized fumigation guide.  Many
flour and rice mills have tried sulfuryl fluoride this year to fumigate
their facilities.  Many other facilities are waiting for state
registrations and label clarifications to try this new fumigant.  The
industry is trying to incorporate this newly registered fumigant into
their best management practices.  

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

	Rice Miller’s Association	Bakeries	Pet Food Institute	North American
Miller’s Association

2008 Requested Amount

(kg)	145,603	16,670	47,174	292,113

2008 Nominated Amount *

(kg)	81,258	14,269	26,660	240,765

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

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



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

	Historical Use1,2	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	168,736	171,911	142,881	149,685	149,685	145,603
145,603

Volume Treated (1000 m³)	5,125	5,229	4,587	4,672	4,672	5,975	5,975

Formulation of MB	100%	100%	100%	100%	100%	100%	100%

Dosage Rate (kg/1000 m³)	32.92	32.88	31.15	32.04	32.04	24.37	24.37

1Best available estimate of United States Government

2Based on most current information.

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

	Historical Use1,2	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	34,019	31,570	29,937	26,770	21,707	21,459	16,670

Volume Treated (1000 m³)	1,699	1,586	1,529	1,501	1,614	1,416	833

Formulation of MB	100%	100%	100%	100%	100%	100%	100%

Dosage Rate (kg/1000 m³)	20.02	19.91	19.58	17.84	13.45	15.16	20.02

1Best available estimate of United States Government

2Based on most current information.

Table 6.4: Methyl Bromide Consumption for the Past 5 Years and the
Amount Requested in the Year(s) Nominated (Pet Food Facilities)  TC
"Table 6.2: Methyl Bromide Consumption for the Past 5 Years and the
Amount Requested in the Year(s) Nominated (Pet Food Facilities)" \f F \l
"1"  

	Historical Use1,2	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	43,001	45,200	48,264	30,287	31,301	31,427	47,174

Volume Treated (1000 m³)	1,974	2,075	2,215	1,390	1,695	1,706	2,163

Formulation of MB	100%	100%	100%	100%	100%	100%	100%

Dosage Rate (kg/1000 m³)	21.79	21.79	21.79	21.79	18.46	18.42	21.81

1Best available estimate of United States Government

2Based on most current information.

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

	Historical Use1,2	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	442,252	419,573	408,233	385,553	362,874	340,194
292,113

Volume Treated (1000 m³)	18,406	18,689	19,539	19,255	18,123	16,990
15,093

Formulation of MB	100%	100%	100%	100%	100%	100%	100%

Dosage Rate (kg/1000 m³)	24.03	22.45	20.89	20.02	20.02	20.02	19.35

1Best available estimate of United States Government

2Based on most current information.

7. Location of the Facility or Facilities Where the Proposed Critical
Use of Methyl Bromide Will Take Place  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 275 food processing facilities across
the United States.  These facilities are distributed across the United
States from subtropical environments of Florida to the cold northern
areas of the Great Plains.  The location of each facility where methyl
bromide fumigations may take place was not requested by the U.S.
Government in the forms filled out by the applicants.  However, location
information has previously been submitted to MBTOC, which is included in
this document as Appendix D.  

In addition, a full list of all processing plants that apply any
registered pesticide in the U.S. is available from the U.S. Department
of Labor, Occupational Safety and Health Administration website located
at http://www.osha.gov/pls/imis/sicsearch.html.  EPA’s Facility
Registry System is publicly available and is located at
http://www.epa.gov/enviro/html/fii/ez.html.  

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 of major pests for which the use of Methyl Bromide is
critical	Common Name	Specific Reason why Methyl Bromide is Needed

Tribolium confusum	Confused flour beetle	Pest status is due to health
hazard: allergens; plus body parts, exuviae, and excretia violate Food
and Drug Administration (FDA) regulations1.  Methyl bromide is needed
because these insects can occur in areas with electronic equipment and
materials that cannot tolerate high temperatures (i.e. cooking) so
phosphine and heat are not completely adequate.  Sulfuryl fluoride was
registered for some of these uses, requires high concentration to kill
all life stages, requires higher concentrations as temperature
decreases; experience needed to incorporate into best management plan.  

Tribolium castaneum	Red flour beetle

	Trogoderma variable	Warehouse beetle	Health hazard: choking and
allergens; plus body parts, exuviae, and excretia violate FDA
regulations1.  Methyl bromide is needed because these insects can occur
in areas with electronic equipment and materials that cannot tolerate
high temperatures (i.e. cooking) so phosphine and heat are not
completely adequate.  Sulfuryl fluoride was registered for some of these
uses, requires high concentration to kill all life stages, requires
higher concentrations as temperature decreases; experience needed to
incorporate into best management plan.  

Lasioderma serricorne	Cigarette beetle	Food contamination violates FDA
regulations1.  Methyl bromide is needed because these insects can occur
in areas with electronic equipment and materials that cannot tolerate
high temperatures (i.e. cooking of some products; oils and butter go
rancid with heat) so phosphine and heat are not completely adequate. 
Sulfuryl fluoride was registered for some of these uses, requires high
concentration to kill all life stages, requires higher concentrations as
temperature decreases; experience needed to incorporate into best
management plan.  

Sitophilus oryzae	Rice weevil

	Plodia interpunctella	Indianmeal moth

	Oryzaephilus mercator	Merchant grain beetle

	Cryptolestes pusillus	Flat grain beetle

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

Table B.1: Characteristic of Sector - Food Processing Plants: Flour
Mills, Rice Mills, Bakeries, and Pet Food Facilities  TC "Table B.1:
Characteristic of Sector - Food Processing Plants: Flour Mills,
Bakeries, and Pet Food Facilities" \f F \l "1"  

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

Harvest or Raw Material In	X	X	X	X	X	X	X	X	X	X	X	X

Fumigation Schedule (MB)*



	X



X



	Retail Target Market Window	Not Applicable

* Plants in the southern United States may fumigate twice a year; plants
in the northern United States may fumigate once every 3 years.  However,
fumigations may occur whenever a population explosion occurs.  

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

This year rice millers decreased their request because the number of
fumigations they typically have conducted declined due to two good crop
years, increased use of existing mill and storage space, use of a newly
registered alternative, and some mills made capital investments on
construction for better sealing and sanitation.  However, some mills had
increase in use due to high humidity, high temperatures, and excessive
storms blowing in pests. 

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



Table 9.1: (a) Food Processing Plants  TC "Table 9.1: (a) Food
Processing Plants" \f F \l "1"  

CUE	MB Dosage (kg/m³)	Exposure Time  (hours)	Temp. (ºC)	Number of
Fumigations per Year	Proportion of Facility Treated at this Dose	Fixed
(F) mobile (M) Stack (S)

Rice Miller’s Association	24	24	variable	2	100% *	F

Bakeries North America	20	24	variable	2.5	100%	F

Pet Food Institute	22	24	variable	< 1

Avg. 1application/1-2 yrs**	80%	F

North American Millers’ Association	19	24	variable	2.5	100 %	F

*Unspecified type of rice is also fumigated along with the facilities.

** Highly variable.  Some facilities need fumigating 2/year, but other
facilities fumigate once every 3-5 years.  

Table 9.1: (b) Fixed Facilities  TC "Table 9.1: (b) Fixed Facilities" \f
F \l "1"  

CUE	Type of Construction and Approximate age in Years	% Facilities at
Volumes (1,000m³)

	Number of Facilities	Gastightness Estimate*

Rice Miller’s Association	Combination of wood, stone, brick, metal,
and concrete	5% 1,416-28,317

90+% 28,317+	22	Poor to very poor

Bakeries North America	Combination of wood, stone, brick, metal, and
concrete	28,317+	11	55% good, 27% fair, 18% poor

Pet Food Institute1	Combination of wood, stone, brick, metal, and
concrete	25% 1,416-28,317

75% 28,317+	75	Good to poor areas

North American Millers’ Association	Wood, stone, brick, concrete,
metal; some about 100 yrs old, only a few less than 10 years old	50% <28

50% >28-142	167	10% good, 10% medium, 75% poor, 5% very poor

* Give gastightness estimates where possible according to the following
scale: good – less than 25% gas loss within 24 hours or half loss time
of pressure difference (e.g. 20 to 10 Pa (t1/2)) greater than 1 minute;
medium – 25-50% gas loss within 24 hours or half loss time of pressure
difference greater than 10 seconds; poor – 50-90% gas loss within 24
hours or half loss time of pressure difference 1-10 second; very poor
– more than 90% gas loss within 24 hours or a pressure half loss time
of less than 1 second.

1 See Appendix B for more information.

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

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

Many food processing facilities in the United States use heat treatments
to reduce insect populations.  Heat does kill insects, typically
temperatures of 50-60° C sustained for 8 hours kills the more heat
tolerant life stages of post-harvest pests.  Unfortunately, some areas
(electronics and electrical portions) of facilities are sensitive to
heat.  In addition heat is not a good alternative if ingredients or
products will be a part of a fumigation because it causes rancidity in
butters and oils, denatures proteins that may be used in the
ingredients, and not all manufactured products can be heated to the high
temperature or for the time required in order to get an effective kill
of insect pests.  

Heat stratifies (hot air raises) resulting in hot spots and cold areas
during fumigations.  Also, since various materials have different
expansion coefficients (expand and contract at different rates) some
facilities have reported structural damage resulting from heat
treatments.  Also, some facilities have glass atria and glass is a poor
insulator, creating cold down drafts .  A company that has a patented
process of an air handling system can improve the air distribution to
reduce the effects of heat stratification.  They have reported multiple
successes with their system.  However, facilities in the southern and
western parts of the United States do not have heat sources on the
premises thereby making heat fumigations impractical without costly
investments that are not economically feasible.  

Sulfuryl fluoride was federally registered for flour and rice mills,
tree nuts and dried fruits in January 2004.  California registered this
product for these uses in May 2005.  It has been used in many mills. 
The industry is learning how to incorporate this product into its pest
management strategy.  It integrates temperature (requires less product
as temperature increases) and dosages (choice of only post-embryonic
stages or all life stages) into the mills’ plans.  More sites were
added to the federal label in July 2005, including bakeries and pet food
facilities.  However, some of the manufactured products are not allowed
to be directly fumigated and will need to be removed prior to fumigation
of the facility.  Many facilities will be unable to accomplish this
since they do not have a way to separate ingredients and products within
their facility.  In addition, a fumigation to kill pest eggs within
manufactured products will still require methyl bromide if a sulfuryl
fluoride tolerance for the commodity has not been established.  

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

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  TC "Table 11.1: Summary
of the Alternatives Tested" \f F \l "1"  

Alternative	Pest	Study

Type	Results	Citation

Heat	T. castaneum 	Pilot feed and flour mills;	Insects contained in
plastic boxes.  Non-uniform heat.  Number of hours to reach 50( C varied
between the mills and within mills.  100% mortality at most locations of
50-60(C for 52 hrs.  Old instars and pupae more heat tolerant 	Mahroof,
et al. 2003

Heat	T. castaneum	Lab	Mortality of each life stage increased with
increase in temperature and exposure time.  Young larvae most heat-
tolerant and required 7.2 hr at >50(C. 	Mahroof, et al. 2003

Heat and  Diatomaceous Earth (DE)	T. castaneum & T. confusum	Lab
Mortality increased as temperature increased and decreased as humidity
increased. Mortality at one week was greater than initial mortality
probably due to delayed effects of DE.  T. confusum mortality lower than
T. castaneum.	Arthur 2000

Heat and DE	T. confusum	2nd & 3rd floors of a Pilot flour mill	Adult
insects in open rings placed in mill.  100% mortality of beetles in 25
hr on the north end of the 3rd floor, but south end of 2nd floor had
only 75% mortality with full DE and 50% mortality with partial DE after
64 hr.  	Dowdy & Fields 2002

DE	Ephestia kuehniella	Lab	Efficacy was influenced by age of the medium
with DE when investigated under driest conditions (58% rh).  But this is
not a pest of concern in the U. S. 	Nielsen 1998

Low volatility insecticides	T. castaneum & T. confusum	Lab	Field
collected flour beetles demonstrated varying degrees of resistance to
several pesticides:  malathion, chlorpyrifos, dichlorvos, phosphine, but
not to resmethrin.  T. castaneum more resistant than T. confusum.  
Zettler 1991

Mountain Sagebrush Volatiles	Rhyzopertha dominica; P. interpunctella; &
T. castaneum	Lab	Initial investigation of volatiles from mountain
sagebrush demonstrated some activity in against these insects in
bioassays.   No indication of whether this is really a potential
alternative	Dunkel & Sears 1998

Low volatility insecticides	T. castaneum & T. confusum	Lab
Malathion-resistant flour beetles were susceptible to cyfluthrin treated
steel panels.  Longer residuals on unpainted panels than on painted
panels	Arthur 1992

DEET (N, N-diethyl-m-toluamide) and NEEM (azadirachthin)

	T. castaneum and others	Lab	DEET repelled S. oryzae by 99%, T.
castaneum by 86%, Cryptolestes ferrugineus by 97% and O. surinamensis by
91% Neem was less effective than DEET	Hou, et al. 2004



Table 11.2: Summary of Review or Position Papers concerning Alternatives
for Stored Product Pests  TC "Table 11.2: Summary of Review or Position
Papers concerning Alternatives for Stored Product Pests" \f F \l "1"  

Synopsis of Review or Position Papers	Citation

Review of methyl bromide alternatives for stored product insects: 

1) heat: gradients in buildings, insect refugia, rate can be problematic
due to structures, some equipment heat sensitive, plastics warp, dust
explosions, sugar, oils, butter & adhesives removed, not all food
products can be heated; 

2) phosphine:  activity slow, flammability above concentrations of 1.8%
by volume, corrosion of copper, silver, and gold, no data for in
combination with CO2 and heat; 

3) modified atmospheres: activity slow, requires air-tight structures; 

4) sulfuryl fluoride1: eggs require much higher concentrations than
larvae for control	Fields & White 2002

Cites studies on: the development of resistance to phosphine in stored
product pests; interaction of time, temperature and concentration of
performance of phosphine; sulfuryl fluoride’s difficulty in killing
egg stage; Tables comparing phosphine to methyl bromide (Appendix C,
Table 1).	Bell 2000

Theoretical paper based on a few lab studies and small field crop trials
indicating that traps currently used for monitoring pest populations
could be used to reduce those populations.  No studies on a commercial
scale or food processing/storage facility were present.	Cox 2004

Mostly lab studies on assorted stored product pests indicate that IGRs,
especially methoprene and diflubenzuron, may play a role in controlling
these insects	Oberlander, et al. 1997

A simulation model in Denmark suggests that increase temperatures inside
mills drives moth outbreaks and if mills were cooled to outdoor
temperatures, moth outbreaks would be less frequent.	Skovgard, et al. 
1999

Investigations into chemical control strategies should include a
thorough examination of physical, biological and environmental factors
that can affect pesticide toxicity.  These include: application rate,
formulation, timing, surface substrate, and target pest.  WP formulation
of cyfluthrin applied to concrete lasted longer than the EC formulation.
 T. confusum was more susceptible than T. castaneum to WP.  	Zettler &
Arthur 2000

1Sulfuryl fluoride was not extensively reviewed because at the time the
review was written there were no tolerances for food established in
either the United States or Canada.  More information regarding this
chemical can be found in Section 17.2.1.

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"   (For economic
constraints, see Question 15)



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"  

In Kind Alternatives	Technical Feasibility	Comments

Carbon Dioxide (high pressure)	No	Facilities in the United States are
not airtight enough for modified atmospheres or carbon dioxide to be
effective primarily because most are more than 25 years old. 

To implement these alternatives would require new construction of all
facilities.

Controlled & Modified Atmospheres	No

	Ethyl/Methyl Formate	No	Not registered in United States (last product
cancelled in Oct. 1989)

Hydrogen Cyanide	No	Not registered in United States (last product
cancelled in Feb. 1988)

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

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

Phosphine, in combination	No

	Sulfuryl fluoride	Yes 	Recently registered in United States for some
uses in this sector on January 23, 2004 and July 14, 2005.  The use of
this chemical requires training of applicators by registrant, and each
state must register this product as well.  Efficacy of this chemical
remains to be demonstrated in the field, but appears to be promising. 
May take up to 5 years before we know if it will replace methyl bromide
and for industry conversion. 

Not in Kind Alternative	Technical Feasibility	Comments

Heat Treatment	Yes	Sufficiently high temperature will kill insects given
enough time; but heat sources are not readily available in all areas of
United States (such as those in the south where hot weather is the norm
and no heaters are available); and heat requires longer time of
exposure.  In areas that can use heat, it is being used.  It is not
feasible in remaining plants or areas of a plant.  In order to
completely replace methyl bromide, some facilities would need to be
relocated and others would need major reconstruction.  

Cold Treatment	No	Does not disinfest facilities.  Most of these IPM
strategies are currently practiced and widely implemented with the
beneficial result of lengthening time between fumigations.  Facilities
use sanitation and cleaning to maintain their plants.  They monitor
populations with pheromone traps.  They try to limit incoming pests with
electrocution traps by entrances/exits.  When populations are
discovered, they use physical removal and contact insecticides and low
volatility pesticides.  Facilities maintain rodenticide bait stations
around their perimeter. 

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

 

Contact Insecticides	No

	Cultural Practices	No

	Electrocution	No

	Inert Dust	No

	Pest Exclusion/Physical Removal	No

	Pesticides of Low Volatility	No

	Pheromones	No

	Physical Removal/Cleaning /Sanitation	No

	Rodenticide	No

	

Table 12.2: Comparison of Alternatives to Methyl Bromide Fumigation  TC
"Table 12.2: Comparison of Alternatives to Methyl Bromide Fumigation" \f
F \l "1"   

Fumigant	Preparation Time (hr)	Fumigation Time (hrs)	Dissipation Time
(hrs)	Minimum Number of Applications to Replace One MB Application*

Methyl Bromide	24	24	24	--

Sulfuryl fluoride 	24	24	24	1

Phosphine, alone	24	48-72	24	2

Phosphine + CO2	24	48-72	24	1-2

Heat	36	48-52	24	2

*Additional treatments with the alternatives may be required because
they are less effective on the eggs and pupae than methyl bromide.

Part D: Emission Control  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”   



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

In the northern regions of the United States, IPM strategies and
sanitation methods have enabled some of these facilities to fumigate
with methyl bromide once every 3 years, and a few facilities have gone
without a methyl bromide fumigation for almost 5 years.  The facilities
in the northern United States have been able to exploit heat treatments
more extensively than their southern counterparts, as well as opening up
facilities during extremely cold weather for extensive cleaning coupled
with low volatility pesticides (organophosphates, pyrethroids, insect
growth regulators, botanicals) at the perimeters. 

Part E: Economic Assessment  TC “Part E: Economic Assessment” \f F
\l “1”    TC “Part E: Economic Assessment” \f C \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: Annual Costs of Alternatives Compared
to Methyl Bromide Over a 3-Year Period" \f F \l "1"  

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

Rice Miller’s Association

Methyl Bromide	1	$2,596	$2,596	$2,596

Sulfuryl Fluoride**	1.3	$3,438	$3,438	$3,438

Heat	1.5	$3,894	$3,894	$3,894

Bakeries

Methyl Bromide	1	$1,277	$1,277	$1,277

Sulfuryl Fluoride**	1.3	$1,719	$1,719	$1,719

Heat	1.5	$1,916	$1,916	$1,916

Pet Foods Institute

Methyl Bromide	1	$519 	$519 	$519 

Sulfuryl Fluoride**	1.3	$688	$688	$688

Heat	1.5	$779 	$779 	$779 

North American Miller’s Association

Methyl Bromide	1	$1,277	$1,277	$1,277

Sulfuryl Fluoride**	1.3	$1,719	$1,719	$1,719

Heat	1.5	$1,916	$1,916	$1,916

* Costs in this table only include the cost of fumigation or heat
treatment.  Losses such as reductions in revenue due to lost days are
included in Tables E.1 though E.4.

** Estimates of the cost of sulfuryl fluoride are based on application
at 24 degrees centigrade (75 degrees Fahrenheit) targeting only
embryonic (non-egg) pest life stages.

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”  

Methyl Bromide Alternative	Economic Reason (if any) for the Alternative
not Being Available	Estimated Month/Year when the Economic Constraint
could be Solved

Heat Treatment	For food processing facilities which are able to convert
to heat treatment, economic losses are from additional production
downtimes due to longer fumigation time and from capital expenditures
required to adopt an alternative. There are other food processing
facilities in areas of United States where heat treatment is not
feasible.	Economic losses due to downtime with heat treatment are
persistent.

Sulfuryl Fluoride	A small portion of the food processing facilities can
economically convert to sulfuryl fluoride. Other facilities cannot due
to economic losses that would result from inefficacious control of pests
and higher treatment costs which arise at higher temperatures.  See
“Summary Of Technical Reason For Each Alternative Not Being Feasible
Or Available.”	Limitations of sulfluryl fluoride are persistent



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



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

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

Sulfuryl Fluoride

Results of the assessment of using sulfuryl fluoride as an alternative
to methyl bromide are provided in Tables 14.1, and E.1 through E.4.  For
purposes of this analysis, current prices of sulfuryl fluoride, the
number of applications, and efficacy with methyl bromide were assumed
equal and plant temperatures are assumed to be 24 degrees centigrade (75
degrees Fahrenheit).  This analysis only covers cases where sulfuryl
fluoride is a technically feasible alternative to methyl bromide and can
be used and its use is not restricted.  Fumigation with sulfuryl
fluoride at lower temperatures controlling all pest life stages is
infeasible due to prohibitively high application rates and minimal
efficacy.

Heat Treatment

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

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

Table E.1: Annual Economic Impacts of Methyl Bromide Alternatives for
Rice Miller’s Association  TC "Table E.1: Economic Impacts of Methyl
Bromide Alternatives for Rice Miller’s Association" \f F \l "1"  

Loss Measure	Methyl Bromide	Sulfuryl Fluoride	Heat Treatment

Gross Revenue (US$/1000 m³)	$29,385 	$29,385 	$27,720 

- Operating Costs (a+b) per 1000 m³	$27,916 	$28,758 	$29,429 

	a) Cost of MB or Alternative	$2,596 	$3,438 	$3,894 

	b) Other Operating Costs	$25,320 	$25,320 	$25,535 

Net Revenue (US$/1000 m3)

 (net of operating costs)	$1,469 	$627 	($1,709)

Loss Measures



Time Lost (days)	0 days	0 days	17 days

Loss per 1000 m³ (US$/1000 m³)	$0	$843 	$3,178 

Loss per Kilogram MB (US$/kg)	$0	$8.43 	$32 

Loss as a % of Gross Revenue (%)	0%	3%	11%

Loss as a % of Net Revenue (%)	0%	57%	216%



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

Loss Measure	Methyl Bromide	Sulfuryl Fluoride	Heat Treatment

Gross Revenue (US$/1000 m³)	$258,334 	$258,334 	$250,584 

- Operating Costs (a+b) per 1000 m³	$245,417 	$245,859 	$246,271 

	a) Cost of MB or Alternative	$1,277 	$1,719 	$1,916 

	b) Other Operating Costs	$244,140 	$244,140 	$244,355 

Net Revenue (US$/1000 m3)

 (net of operating costs)	$12,917 	$12,475 	$4,313 

Loss Measures



Time Lost (days)	0 days	0 days	9 days

Loss per 1000 m³ (US$/1000 m³)	$0	$442 	$8,604 

Loss per Kilogram MB (US$/kg)	$0	$9.02 	$181 

Loss as a % of Gross Revenue (%)	0%	<1%	3%

Loss as a % of Net Revenue (%)	0%	4%	67%



Table E.3: Annual Economic Impacts of Methyl Bromide Alternatives for
Pet Food Institute  TC "Table E.3: Annual Economic Impacts of Methyl
Bromide Alternatives for Pet Food Institute" \f F \l "1"  

Loss Measure	Methyl Bromide	Sulfuryl Fluoride	Heat Treatment

Gross Revenue (US$/1000 m³)	$175,452 	$175,452 	$170,773 

- Operating Costs (a+b) per 1000 m³	$166,679 	$166,848	$167,154 

	a) Cost of MB or Alternative	$519 	$688	$779 

	b) Other Operating Costs	$166,160 	$166,160 	$166,375 

Net Revenue (US$/1000 m3)

 (net of operating costs)	$8,773 	$8,604	$3,619 

Loss Measures



Time Lost (days)	0 days	O days	8 days

Loss per 1000 m³ (US$/1000 m³)	$0	$169	$5,153 

Loss per Kilogram MB (US$/kg)	$0	$3.45	$258 

Loss as a % of Gross Revenue (%)	0%	<1%	3%

Loss as a % of Net Revenue (%)	0%	2%	59%



Table E.4: Annual Economic Impacts of Methyl Bromide Alternatives for
North American Miller’s Association  TC "Table E.4: Annual Economic
Impacts of Methyl Bromide Alternatives for North American Miller’s
Association" \f F \l "1"   

Loss Measure	Methyl Bromide	Sulfuryl Fluoride	Heat Treatment

Gross Revenue (US$/1000 m³)	$437,472 	$437,472 	$424,348 

- Operating Costs (a+b) per 1000 m³	$415,598 	$416,040 	$416,452 

	a) Cost of MB or Alternative	$1,277	$1,719	$1,916

	b) Other Operating Costs	$414,321 	$414,321 	$414,536 

Net Revenue (US$/1000 m3)

 (net of operating costs)	$21,874 	$21,432 	$7,896 

Loss Measures



Time Lost (days)	0 days	0 days	9 days

Loss per 1000 m³ (US$/1000 m³)	$0	$442 	$13,978 

Loss per Kilogram MB (US$/kg)	$0	$9.30 	$294 

Loss as a % of Gross Revenue (%)	0%	0.1%	3%

Loss as a % of Net Revenue (%)	0%	2%	64%



Part F: Future Plans  TC "Part F: Future Plans" \f F \l "1"    TC "Part
F: Future Plans" \f C \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 to further reduce the number of methyl
bromide fumigations.  They are also continuing to pursue research of
heat treatments to maximize efficiency.  The United States government is
supporting research in this sector (see Section 17.1) and the United
States Environmental Protection Agency (U.S. EPA) has made registering
methyl bromide alternatives a priority (see Section 17.2). U.S. EPA
registered sulfuryl fluoride for some commodities and some mills on
January 23, 2004 and added more commodities and sites on July 14, 2005.

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

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

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

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

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

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

The bakery sector is implementing heat as an alternative at those
facilities where heat is technically feasible.  Currently, heat is being
implemented at several facilities nationwide, but further trials are
needed to determine the effects of heat on a long-term basis.  However,
older facilities with hardwood floors and plant electrical wiring
systems are unsuitable for heat treatments.  Some buildings are
constructed in such a way that heat treatments have been problematic. 
Other methods being used to reduce reliance on methyl bromide are:
exclusion, cleaning, early detection, improved design of equipment,
trapping, and other integrated pest management (IPM) approaches. 
Phosphine continues to be tested.  Sulfuryl fluoride, newly registered
for this site, is undergoing trials in the states for which it is
registered.  

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

The Pet Food Institute members have invested hundreds of thousands of
dollars in research on a variety of alternatives to methyl bromide,
including heat treatments.  Sulfuryl fluoride has been tested in an
inactive pet food facility last year, and with the recent registration
has been tested at several commercial facilities.  They have made
improvements in worker training, pest monitoring, and sanitation to
greatly reduce the necessity for fumigations with methyl bromide, or any
other fumigant.  Sulfuryl fluoride has been recently registered for this
site (July 2005); however, ingredients and products will need to be
removed from the facility during fumigation, limiting its replacement of
methyl bromide in all pet food facilities.  

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

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

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

The U.S. EPA has also co-chaired the USDA/EPA Methyl Bromide
Alternatives Work Group since 1993 to help coordinate research,
development and the registration of viable alternatives.  This
coordination has resulted in key registration issues (such as worker and
bystander exposure through volatilization, township caps and drinking
water concerns) being directly addressed through USDA’s Agricultural
Research Service’s U. S.$15 million per year research program
conducted at more than 20 field evaluation facilities across the
country.  Also U.S. EPA’s participation in the evaluation of research
grant proposals each year for USDA’s U. S.$2.5 million per year methyl
bromide alternatives research has further ensured close coordination
between the U.S. government and the research community.  

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

2000: Phosphine in combination to control stored product insect pests 

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

2004: Sulfuryl fluoride as a post-harvest fumigant for stored
commodities and some mills 

2005: Sulfuryl fluoride for additional commodities and sites

17.2.1.  Sulfuryl Fluoride  TC "17.2.1.  Sulfuryl Fluoride" \f C \l "2" 


On January 23, 2004, U.S. EPA registered sulfuryl fluoride as a
post-harvest fumigant for grains and flour mills.  While registration
for these uses will provide opportunities to reduce methyl bromide use,
it must be emphasized that such replacement, if feasible, will only
occur gradually over time.  On July 15, 2005, U.S. EPA registered
sulfuryl fluoride added more commodities and sites.  

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).  Several fumigation companies have
teams trained by the registrant.  Mills have begun testing sulfuryl
fluoride in specific circumstances.  

There are additional pesticide registration issues, however, that must
be resolved before sulfuryl fluoride can be used in sectors for which
the U. S. is nominating methyl bromide CUEs.  Some mills manufacture
products that are not listed on the current label, although the label
allows “incidental” fumigation, the mills will need to move the
products so that they are not fumigated.  It is most likely that
adoption of sulfuryl fluoride for some of these mills will be delayed
until tolerances for these ingredients are sought by the registrant,
reviewed by U.S. EPA, and granted (if they meet eligibility criteria).

U.S. EPA currently has limited sulfuryl fluoride product performance
data (direct comparisons to methyl bromide), limited experience in how
well it performs in different facilities and climates over multiple
years, and limited information on what costs might be associated with
adopting sulfuryl fluoride.  Based on the limited data currently
available, U.S. EPA believes that within 5 years sulfuryl fluoride may
be able to replace methyl bromide in up to 75% of the rice and flour
mills.  U.S. EPA is committed to monitoring sulfuryl fluoride use during
the next few years to amend future CUE nominations.  

18. Additional Comments  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. H.  2000.  Toxicity of diatomaceous earth to red flour
beetles and confused flour beetles (Coleoptera: Tenebrionidae):  Effects
of temperature and relative humidity.  J. Econ. Entomol.  93(2):
526-532.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Appendix B.  Supporting Data  TC "Appendix B.  Supporting Data" \f F \l
"1"    TC "Appendix B.  Supporting Data" \f C \l "1"   



Appendix B - Table 9.1(a): Summary of the Circumstances of Current
Methyl Bromide Use In Pet Food Processing Plants  TC "Appendix B - Table
9.1(a): Summary of the Circumstances of Current Methyl Bromide Use In
Pet Food Processing Plants" \f F \l "1"  

Facility No.	Methyl Bromide Dosage	Exposure Time (hours)	Exterior Temp.
(ºC)	Number of Fumigations per Year	Proportion of Product Treated at
this Dose	Fixed (F) mobile (M) Stack (S)



1

Midwest	16 g/m3	24	Day:  35-38	1 general

2 spot w/phos	30% (1)	Fixed (2)

2

Midwest	16 g/m3	24	Day:  27

Night:  10	1 general	40% (1)	Fixed (2)

3

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

4

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

5

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

6

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

7

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

8

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

Based on % of total volume treated

Fixed = Fixed facility



Appendix B - Table 9.1(B): Summary of the Circumstances of Current
Methyl Bromide Use In Pet Food Processing Plants - Fixed Facilities: Pet
Food Institute  TC "Appendix B - Table 9.1(B): Summary of the
Circumstances of Current Methyl Bromide Use In Pet Food Processing
Plants - Fixed Facilities: Pet Food Institute" \f F \l "1"  

Pest No.	Type of Construction and Approximate age in Years	Volume (m³)
or Range	Number of Facilities 

(e.g. 5 silos)	Gas tightness Estimate*

1

Midwest	Tilt-up concrete, some corrugated metal	184,800 m3	1	Medium
Areas & Poor Areas

2

Midwest	Tilt-up concrete	114,800 m3	1	Good Areas & Medium Areas

3

Southeast	Corrugated metal	72,973 m3	1	Poor

4

Southeast	Corrugated metal	35,954 m3	1	Medium Areas & Poor Areas

5

North	Corrugated Metal on slab (13 years)	7,420 m3	< 1 (processing area
only)	Good

6

Midwest	Corrugated Metal on Slab	218,400 m3	1	Medium

7

West	Corrugated Metal on Slab	28,759 m3	1	Medium to Poor

8

Midwest	Poured Concrete Walls/

Slab Floor	137,760 m3	1	Very Good

* Give gastightness estimates where possible according to the following
scale: good – less than 25% gas loss within 24 hours or half loss time
of pressure difference (e.g. 20 to 10 Pa (t1/2)) greater than 1 minute;
medium – 25-50% gas loss within 24 hours or half loss time of pressure
difference greater than 10 seconds; poor – 50-90% gas loss within 24
hours or half loss time of pressure difference 1-10 second; very poor
– more than 90% gas loss within 24 hours or a pressure half loss time
of less than 1 second.



Appendix C.  Published Performance Data  TC "Appendix C.  Published
Performance Data" \f F \l "1"    TC "Appendix C.  Published Performance
Data" \f C \l "1"    



Appendix C - Table 1: Effect of temperature on concentration and time
thresholds for some pests of stored products. (From: Bell, C. H. 2000) 
TC "Appendix C - Table 1: Effect of temperature on concentration and
time thresholds for some pests of stored products. (From: Bell, C. H.
2000)" \f F \l "1"  

Species	Fumigant	Threshold

(ºC or time)	Temperature (ºC)



	15	25

Sitophilus oryzae	Methyl Bromide	ºC (mg/l)	0.6-0.9	1.3-2.0

Tribolium confusum	Methyl Bromide	ºC (mg/l)	1.3-2.0	2.5-3.0

Tribolium castaneum	Methyl Bromide	ºC (mg/l)	1.3-2.0	3.0-3.5

Tribolium castaneum	Phosphine	ºC (mg/l)

0.005-0.0011

Tribolium castaneum	Phosphine	Time (h)

0.5-1.5

For phosphine relatively long exposure times are required for kill of
all stages & time threshold is more important than the concentration for
efficient fumigant action.  

Appendix C - Table 2: Concentration-Time Product recommendations by
National Pest Management Association  TC "Appendix C - Table 2:
Concentration-Time Product recommendations by National Pest Management
Association" \f F \l "1"  

Species	Stage	Temp ((C)	Ounce-Hours	Mg/l



	Phosphine

72 hr	Phosphine

144 hr	Methyl Bromide	Sulfuryl Fluoride

Lasioderma serricorne	eggs	4.4

	146.4



eggs	10	8.5	49.5	91.2



eggs	15.6	61.8	37.9	48



eggs	21.1	0.64	0.86	43.2



eggs	26.5



711.7

	larvae	4.4	6.9	1.2	379.2



larvae	10	3.7	0.86	206.4



larvae	15.6	0.94	0.72	132



larvae	21.1	0.5	0.43	120



larvae	26.5



55.9

	pupae	4.4	5.6	7.4	1046



pupae	10	5.6	4.6	324



pupae	15.6	5.2	1.3	124.8



pupae	21.1	0.58	0.3	108



adult	4.4	2.2	1.9	230.4



adult	10	1.8	1.1	105.6



adult	15.6	1	0.5	64.8



adult	21.1	0.36	0.3	57.6



adult	26.5



34.9

Sitophilus oryzae	adult	21	0.36

30

	Tribolium confusum	eggs	26.7



1124.8

	adult	4.4

	209.3	178.2

	adult	15.6

	92.8	97.6

	adult	25	0.48

64	55

	adult	26.7

	74.2	76.5

Tribolium castaneum	adult	24	11.5

62

	Plodia interpunctella	eggs	15

	53



eggs	20

	29



eggs	25

	22



eggs	30

	21



larvae	15

	34



larvae	20

	31



larvae	25

	24



larvae	30

	25



pupae	15

	64



pupae	20

	50



pupae	25

	43



pupae	30

	35

	Appendix D.  Methyl Bromide Facilities Data  TC "Appendix D.  Methyl
Bromide Facilities Data" \f F \l "1"     TC "Appendix D.  Methyl Bromide
Facilities Data" \f C \l "1"    

CUE Applicant	Facility ID	Size of Facility	Historic Usage



	1999	2000	2001	2002	2003



	Rate (lbs ai/1,000ft3)	Frequency (X/yr)	Rate (lbs ai/1,000ft3)
Frequency (X/yr)	Rate (lbs ai/1,000ft3)	Frequency (X/yr)	Rate (lbs
ai/1,000ft3)	Frequency (X/yr)	Rate (lbs ai/1,000ft3)	Frequency (X/yr)

NCHA	MP18	52,000	3	4	3	4	4	5	3	4	13	14

NCHA	MP19	--	0.5	8	0.5	5	0.5	6	0.5	6	0.5	3

NCHA	MP20	50,000 - 100,000	--	--	--	--	--	--	--	--	--	--

NCHA	MP21	10,000 - 50,000	1.5	4	1.5	4	1.5	3	1.5	3	1.5	3

NCHA	MP22	50,000 - 100,000	3	4	3	4	3	4	3	3	3	3

NCHA	MP23	176,200	8	400lbs	4	200lbs	8	400lbs	8	400lbs	6	300lbs

PFI	PFI1	>500,000	1.5	2	1.5	2	1.5	2	1.5	2	1.5	2

PFI	PFI2	--	--	20	--	20	--	15	--	10	--	5

PFI	PFI3	>500,000	--	--	1.5	1	--	--	1.5	1	--	--

PFI	PFI4	1,000 - 5,000	--	--	--	--	--	--	--	--	--	--

PFI	PFI5	>500,000	1	1	1	1	0	0	1	1	1	1

PFI	PFI6	>500,000	1	2	1	2	1.25	1	1.25	1	1	1

PFI	PFI7	>500,000	1-2	1	0	0	1-2	1	1-2	1	1-2	1

PFI	PFI8	3,000,000	1	1	1.25	1	1.25	1	1	1	1	1

PFI	PFI9	>500,000	1	1	1	1	1	1	1	1	1	1

PFI	PFI10	>500,000	1	1	1	1	1	1	1	1	1	1

PFI	PFI11	700,000	0	0	0	0	0	0	0	0	0	0

PFI	PFI12	>500,000	0	0	0	0	0	0	0	0	0	0

PFI	PFI13	100,000 - 500,000	--	0	--	0	--	0	--	0	--	0

PFI	PFI14	7,000,000+	0	1	0	0	1	1	0	0	1	1

PFI	PFI15	1,750,000cu ft	0	1	0	0	1	1	0	0	1	1

PFI	PFI16	>500,000	1	1	1	1	0	0	1	1	1	1

PFI	PFI17	>500,000	1.5	0	2	1	0	0	2	1	2	1

PFI	PFI18	100,000 - 500,000	--	0	--	0	--	0	--	0	--	0

PFI	PFI19	>500,000	1	1	0	0	1	1	1	1	1	1

PFI	PFI20	3,500,000 cu ft	1	1	0.8	1	0.8	1	0	0	0	0

PFI	PFI21	3,000,000 cu ft	1	1	0	0	0	0	1	1	1-1.5	1

PFI	PFI22	>500,000	1	1	0	0	0	0	0	0	1	1

PFI	PFI23	100,000 - 500,000	--	--	5lb/42 35	1	5lb/42 35	1	5lb/42 35	1
5lb/42 35	1

PFI	PFI24	100,000 - 500,000	0	0	1	1	0	0	0	0	0	0

PFI	PFI25	>500,000	1	1	1	1	1	1	1	1	1	1

PFI	PFI26	2,120,000	1	1	1	1	1	1	1	1	1	1

PFI	PFI27	1,100,000	1	1	1	1	1	1	1	1	1	1

PFI	PFI28	>500,000	1	1	1	1	0	0	1	1	1	1

PFI	PFI29	18.3 million ft^3	--	--	--	--	--	--	--	--	1	1 trailer

PFI	PFI30	2.5 million ft^3	--	0	1	1	1	1	1	1	--	01

PFI	PFI31	18.3 million ft^3	1.5	45 trailers	1.4	45 trailers	1.5	38
trailers	1.5	16 trailers	1.5	25 trailers

PFI	PFI32	1.4 million ft^3	1	1	1	1	1	1	1	1	1	1

PFI	PFI33	23.6 million ft^3 planned	--	--	--	--	--	--	--	--	--	--

PFI	PFI34	23.6 million ft^3 planned	--	--	--	--	--	--	--	--	--	--

PFI	PFI35	11.2 million ft^3	1	1	1	1	1	1	1	1	1	1

PFI	PFI36	8.2 million ft^3	--	--	--	Once, all warehouses	1.5 lbs	Twice
(trailers)	0 lbs	--	1.5 lbs	Twice (trailers)

PFI	PFI37	6.9 million ft^3	--	0	1	1	1	1	1	1	1	1

PFI	PFI38	>500,000	--	0	--	0	1	1	--	0	--	0

PFI	PFI39	>500,000	1.5	1	1.5	1.5	1.5	1	1	1	1	2

PFI	PFI40	>500,000	1	1	1.5	1	1	1	1	1	0	0

PFI	PFI41	>500,000	1.5	1	0	0	0	0	0	0	1	0

PFI	PFI42	240,000ft^2; 4,800,000ft^3	--	--	--	--	--	--	1.0#/t^3	1
1.0#/ft^3	1

PFI	PFI43	7 million ft^3	--	--	--	--	--	--	--	--	--	--

PFI	PFI44	>500,000	1.5	1	1.5	1	1.5	1	1.5	1	1.5	1

PFI	PFI45	100,000 - 500,000	0	0	0	0	0	0	0	0	5	1

PFI	PFI46	5,000 - 10,000	0	0	0	0	0	0	0	0	0	0

PFI	PFI47	10,000 - 50,000	0	0	0	0	0	0	0	0	0	0

PFI	PFI48	>500,000	1	1	0	0	1	1	1	1	1	1

PFI	PFI49	>500,000	0	0	0	0	0	0	0	0	0	0

PFI	PFI50	>500,000	0	0	0	0	0	0	0	0	0	0

PFI	PFI51	100,000 - 500,000	--	--	1.3	1	1	1	1.3	1	--	--

PFI	PFI52	100,000 - 500,000	--	NA	--	NA	--	0	--	0	--	0

Rice Millers	1	>500,000	1	2	1	2	1	2	1	2	1	2

Rice Millers	2	>500,000	1	2	1	2	1	2	1	2	1	2

Rice Millers	3	>500,000	1.5	1	1.5	2	1.5	2	1.5	2	1	2

Rice Millers	4	>500,000	1.5	2	1.5	2	1.5	2	1	2	1	2

Rice Millers	5	>500,000	1	2	1	2	1	2	1	2	1	2

Rice Millers	6	>500,000	0.5	1	0.5	1	0.5	1	0.5	1	0.5	1

Rice Millers	7	10,000-50,000	2	2	2	2	2	2	2	4	2	2

Rice Millers	8	5,000-10,000	1	5	1	5	1	5	1	5	1	5

Rice Millers	9	5,000-10,000	1	4	1	4	1	4	1	4	1	4

Rice Millers	10	--	1	1	1	1	1	1	1	1	1	1

Rice Millers	11	>500,000	3	2	3	2	3	2	3	2	3	2

Rice Millers	12	5,000-10,000	2.15	1	2.2	1	2.2	2	2.19	1	2	2

Rice Millers	13	50,000-100,000	1	9	1	9	1	9	1	9	1	9

Rice Millers	14	--	24,000 lbs.	2	24,000 lbs.	2	12,000 lbs.	1	12,0000
lbs.	1	12,0000lbs	1

Rice Millers	BR549	>500,000	0.5	1	0.5	1	0.5	1	0.5	1	0.5	1

NPMA	1	100,000-500,000	2	52	2	52	2	52	2	52	2	52

NPMA	2	>500,000	2	52	2	52	2	52	2	52	2	52

NPMA	3	>500,000	2	52	2	52	2	52	2	52	2	52

NPMA	4	100,000-500,000	2	52	2	52	2	52	2	52	2	52

NPMA	5	100,000-500,000	2	52	2	52	2	52	2	52	2	52

NPMA	6	50,000-100,000 (H2); 100,000-500,000 (H1)	2	52	2	52	2	52	2	52	2
52

NPMA	7	50,000-100,000 (F1 & F2)	2	52	2	52	2	52	2	52	2	52

NPMA	8	100,000-500,000	2	52	2	52	2	52	2	52	2	52

NPMA	9	50,000-100,000	2	52	2	52	2	52	2	52	2	52

NPMA	10	>500,000	1	1	1	1	1	1	1	1	1	1

NPMA	11	>500,000	2004: Rate – 1-3#/1000 COFT, Frequency - 2	--	--	--
--	--	--

NPMA	12	--	--	--	--	--	3	2	3	2	3	2

NPMA	13	--	--	--	--	--	3	16	3	17	3	3

NPMA	14	>500,000	1	2	1	3	1	2	1	2	1	1

NPMA	15	50,000-100,000	6oz/1000cu ft	2	6oz/1000cu ft	2	6oz/1000cu ft	1
6oz/1000cu ft	2	6oz/1000cu ft	3

NPMA	16	>500,000	1.5	1	--	--

	--	--	1.5	1

NPMA	17	100,000-500,000	3	2	3	2	3	1	3	2	3	3

NPMA	18	100,000-500,000	3	1	--	--	3	1	3	1	--	--

NPMA	19	--	25.5	2	25.5	2	25.5	2	25.5	2	25.5	2

NPMA	20	>500,000	--	--	1	1	--	--	--	--	--	--

LifeLine Foods

>500,000	--	--	--	--	--	--	1,800	1	--	--

NAMA	1	>500,000	1.5	3-4	1.5	3-4	1.5	3-4	2	3-4	1.5	3-4

NAMA	2	>500,000	1	3	1	3	1	3	1	3	1	3

NAMA	3	>500,000	1.5oz	2	1.5oz	1	1.5oz	2	1.5oz	2	1.5oz	2

NAMA	4	>500,000	1	2	1	2	1	2	1	3	1	2

NAMA	5	1,000-5,000	--	--	--	--	--	--	--	--	--	--

NAMA	6	1,000-5,000	1.25	1	1.25	1	1.25	1	1	1	1.25	1

NAMA	7	1,000-5,000	--	--	--	--	--	--	--	--	1	1

NAMA	8	1,000-5,000	1.12	2	1.12	2	1.12	1	1	1	1.12	1

NAMA	9	>500,000	1.65	1	1.57	1	1.57	1	2	1	1.55	1

NAMA	10	>500,000	--	--	--	--	--	--	--	--	0.81	1

NAMA	11	0-1,000	1.25	2	1.25	2	1.25	1	1	1	1.25	1

NAMA	12	>500,000	0.75	1	0.75	1	0.75	1	1	1	0.75	1

NAMA	13	>500,000	0.5	1	0.75	1	1	1	0	0	0	0

NAMA	14	1,000-5,000	1.5-3	2	1.5-3	2	1.5-3	2	1.5-3	2	1.5-3	2

NAMA	15	885000	0.75	2	0.75	2	0.75	2	1	2	0.75	2

NAMA	16	>500,000	1.5	2	1.5	2	1.5	2	2	2	1.5	2

NAMA	17	>500,000	925	2	1050	2	1050	2	1,100	1	1100	1

NAMA	18	>500,000	3325	1	2800	1	3400	1	3,700	1	3500	1

NAMA	19	>500,000	1.25	3	1.25	3	1.25	2	1	2	1.25	2

NAMA	20	>500,000	1.25	3	1.25	3	1.25	2	1	2	1.25	3

NAMA	21	>500,000	1.8	2	1.8	2	1.8	2	2	2	1.8	2

NAMA	22	>500,000	1	4	1	3	1	4	1	3	1.3	2

NAMA	23	>500,000	1.5	2	1.5	2	1.5	2	2	2	1.5	2

NAMA	24	>500,000	1.5	2	1.5	2	1.5	2	2	2	1.5	2

NAMA	25	>500,000	1.5	2	1.5	2	1.5	2	2	2	1.5	2

NAMA	26	>500,000	1.8	3	1.8	3	1.8	3	2	3	1.8	3

NAMA	27	>500,000	1	3	1	3	1	3	1	3	1	3

NAMA	28	100,000-500,000	1	3	1.2	3	1.5	4	1	3	1.4	3

NAMA	29	>500,000	?	?	?	?	?	?	?	?	?	?

NAMA	30	>500,000	1	4	1	4	1	3	1	3	1	3

NAMA	31	>500,000	N/A

N/A

N/A

1-1.5	3	1-1.5	3

NAMA	32	>500,000	1.5	3-4	1.5	3-4	1.5	3-4	2	3-4	1.5	3-4

NAMA	33	>500,000	--	--	--	--	--	--	1-1.5	3-4	1-1.5	3-4

NAMA	34	565	1.85	3	1.94	3	1.77	3	2	3	2.12	3

NAMA	35	50,000-100,000	1	2	1	2	1	3	1	3	1	2

NAMA	37	>500,000	.5-.75	3	.5-.75	2	.5-.75	3	.5-.75	3	.5-.75	3

NAMA	38	10,000-50,000	1.25	3	1.25	3	1.25	3	1	3	1.25	3

NAMA	39	945591	0.75	2	0.75	2	0.75	2	1	2	0.75	2

NAMA	40	>500,000	0.5	3	0.5	3	0.5	3	1	3	0.5	3

NAMA	41	50,000-100,000	1.5	3	1.5	3	1.5	2	2	2	1.5	2

NAMA	42	>500,000	1	2	1	2	1	2	1	2	1	2

NAMA	43	100,000-500,000	1.25	2	1.25	2	1.25	2	1	2	1.25	2

NAMA	44	50,000-100,000	0.5	2	0.5	2	0.5	2	1	2	0.5	2

NAMA	45	1,000-5,000	1	2	1	2	1	2	1	2	1	2

NAMA	46	0-1,000	--	--	--	--	--	--	--	--	--	--

NAMA	47	1,000-5,000	.5-1	4	.5-1	4	.5-1	4	.5-1	4	.5-1	4

NAMA	48	5,000-10,000	1	3	1	2	1	2	1	2	1	2

NAMA	49	--	1.5	3	1.5	3	1.5	3	2	3	1.5	3

NAMA	50	1,000-5,000	--	--	--	--	1.5	2	1.5, 3	2	1.5	1

NAMA	51	0-1,000	1.5	3	1.5	2	1.5	3	2	2	1.3	3

NAMA	52	>500,000	1.8	2	1.8	2	1.8	1	2	2	1.8	2

NAMA	53	100,000-500,000	1.5	3	1.5	3	1.5	3	2	3	1.5	1

NAMA	54	>500,000	1	1	1	2	1	2	1	1	--	0

NAMA	55	>500,000	--	--	--	--	--	--	1,800lbs	1	--	--

NAMA	56	100,000-500,000	3	23	3	34	3	18	3	17	3	15

NAMA	57	>500,000	1	2	1	2	1	2	1	2	1	2

NAMA	58	10,000-50,000	1.25	4	1.25	4	1.25	4	1	3	1.25	3

NAMA	59	50,000-100,000











NAMA	60	1,000-5,000	16	1	16	2	16	2	16	2	16	2

NAMA	61	>500,000	1.5	2	1.5	2	1.5	2	2	2	N/A	N/A

NAMA	62	>500,000

3

3

3

3

3

NAMA	63	1,000-5,000	1.5	2	1.5	2	1.5	2	2	2	1	2

NAMA	64

0.25	3	0.25	3	0.25	3	0	3	0.25	3

NAMA	65	>500,000	1.5	2	1.5	2	1.5	2	2	2	N/A	N/A

NAMA	66	1,000-5,000	1.5	2	1.5	2	1.5	2	2	2	1.5	2

NAMA	67	>500,000

3

4

3

3

3

NAMA	68	1,000-5,000	per label	3	per label	3	per label	3	per label	3	per
label	3

NAMA	69	1,000-5,000	per label	3	per label	3	per label	3	per label	3	per
label	3

NAMA	70	100,000-500,000	--	--	--	--	--	--	--	--	--	--

NAMA	71	>500,000	2	2	1.8	2	1.6	2	2	2	1.6	2

NAMA	72	100,000-500,000

N/A

N/A

N/A

N/A

N/A

NAMA	73	>500,000	1.5	2	1.5	2	1.5	2	2	2	1.5	2

NAMA	74	>500,000	1	4	1	3	1	3	1	3	1	3

NAMA	75	>500,000	1.5	3	1.5	3	1.5	3	2	2	1.5	2

NAMA	76	100,000-500,000	--	--	--	--	--	--	--	--	--	--

NAMA	77	>500,000	3	2	3	2	3	2	3	2	3	1

NAMA	78	100,000-500,000	1.25	1	1.25	1	1.25	1	1	1	1.25	1

NAMA	79	100,000-500,000	1.5	2	1.5	2	1.5	3	2	2	1.5	1

NAMA	80	100,000-500,000	1.5	2	1.5	2	1.5	1	2	2	1.5	1

NAMA	81	100,000-500,000	1.5	1	1.5	1	1.5	1	2	1	1.5	1

NAMA	82	100,000-500,000	1.5	2	1.5	2	1.5	2	2	2	1.5	2

NAMA	83	1,000-5,000	1.5	3	1.5	3	1.5	2	2	2	1.5	2

NAMA	84	10,000-50,000	0	0	1.5	3	1.5	4	2	6	1.5	4

NAMA	85	100,000-500,000	1	2	1	2	1	2	1	2	1	2

NAMA	86	100,000-500,000	1	2	1	2	1	2	1	2	1	2

NAMA	87	>500,000	0.75	2	0.75	2	0.75	2	1	2	0.75	2

NAMA	88	>500,000	1	2	1	2	1	2	1	2	1	2

NAMA	89	>500,000	0.75	2	0.75	2	0.75	2	1	2	0.75	2

NAMA	90	>500,000	0.6	2	0.6	2	0.6	2	1	2	0.6	2

NAMA	91	>500,000	1	1	1	1	1	1	1	1	1	1

NAMA	92	>500,000	1	2	1	2	1	2	1	2	1	2

NAMA	93	>500,000	1	1	1	1	1	1	1	1	1	1

NAMA	94	>500,000	1	2	1	2	1	2	1	2	1	2



U. S. Structures -Food Facilities	  PAGE  9 

U. S. Structures -Food Facilities	  PAGE  39 

