Methyl Bromide Critical Use Nomination for

Post Harvest Use on Dry Cured Pork Products

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 on Dry Cured Pork Products (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 "_Toc125776021"  Part A: Summary	 
PAGEREF _Toc125776021 \h  5  

  HYPERLINK \l "_Toc125776022"  1. Nominating Party	  PAGEREF
_Toc125776022 \h  5  

  HYPERLINK \l "_Toc125776023"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125776023 \h  5  

  HYPERLINK \l "_Toc125776024"  3. Situation of Nominated Methyl Bromide
Use	  PAGEREF _Toc125776024 \h  5  

  HYPERLINK \l "_Toc125776025"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125776025 \h  5  

  HYPERLINK \l "_Toc125776026"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125776026 \h  5  

  HYPERLINK \l "_Toc125776027"  6. Methyl Bromide Consumption for Past 5
Years and Amount Required in the Year(s) Nominated	  PAGEREF
_Toc125776027 \h  7  

  HYPERLINK \l "_Toc125776028"  7. Location of the Facilities Where the
Proposed Critical Use of Methyl Bromide Will Take Place	  PAGEREF
_Toc125776028 \h  9  

  HYPERLINK \l "_Toc125776029"  Part B: Situation Characteristics and
Methyl Bromide Use	  PAGEREF _Toc125776029 \h  10  

  HYPERLINK \l "_Toc125776030"  9. Summary of the Circumstances in which
Methyl Bromide is Currently Being Used	  PAGEREF _Toc125776030 \h  11  

  HYPERLINK \l "_Toc125776031"  10.  List Alternative Techniques that
are being Used to Control Key Target Pest Species in this Sector	 
PAGEREF _Toc125776031 \h  11  

  HYPERLINK \l "_Toc125776032"  Part C: Technical Validation	  PAGEREF
_Toc125776032 \h  12  

  HYPERLINK \l "_Toc125776033"  11.  Summarize the Alternative(s) Tested
Starting with the Most Promising Alternative(s)	  PAGEREF _Toc125776033
\h  12  

  HYPERLINK \l "_Toc125776034"  12.Summarize Technical Reasons, if any,
for each Alternative not being Feasible or Available for your
Circumstances	  PAGEREF _Toc125776034 \h  12  

  HYPERLINK \l "_Toc125776035"  Part D: Emission Control	  PAGEREF
_Toc125776035 \h  13  

  HYPERLINK \l "_Toc125776036"  13. How has this Sector Reduced the Use
and Emissions of Methyl Bromide in the Situation of the Nomination?	 
PAGEREF _Toc125776036 \h  13  

  HYPERLINK \l "_Toc125776037"  Part E: Economic Assessment	  PAGEREF
_Toc125776037 \h  13  

  HYPERLINK \l "_Toc125776038"  Costs of Alternatives Compared to Methyl
Bromide Over 3-Year Period	  PAGEREF _Toc125776038 \h  13  

  HYPERLINK \l "_Toc125776039"  15. Summarize Economic Reasons, if any,
for each Alternative not being Feasible or Available for your
Circumstances	  PAGEREF _Toc125776039 \h  13  

  HYPERLINK \l "_Toc125776040"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125776040 \h  13  

  HYPERLINK \l "_Toc125776041"  Part F: Future Plans	  PAGEREF
_Toc125776041 \h  13  

  HYPERLINK \l "_Toc125776042"  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 _Toc125776042 \h  13  

  HYPERLINK \l "_Toc125776043"  17. Provide a Detailed Plan Describing
what Actions will be Undertaken to Rapidly Develop and Deploy
Alternatives for this Use	  PAGEREF _Toc125776043 \h  14  

  HYPERLINK \l "_Toc125776044"  18. Additional Comments	  PAGEREF
_Toc125776044 \h  14  

  HYPERLINK \l "_Toc125776045"  19. Citations	  PAGEREF _Toc125776045 \h
 16  

  HYPERLINK \l "_Toc125776046"  Appendix A.  Methyl Bromide Usage Newer
Numerical Index	  PAGEREF _Toc125776046 \h  17  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125776124"  Part A:
Summary	  PAGEREF _Toc125776124 \h  5  

  HYPERLINK \l "_Toc125776125"  Table 4.1: Methyl Bromide Nominated For
Dry Cured Pork Products	  PAGEREF _Toc125776125 \h  5  

  HYPERLINK \l "_Toc125776126"  Table A.1: Executive Summary	  PAGEREF
_Toc125776126 \h  7  

  HYPERLINK \l "_Toc125776127"  Table 6.1: Methyl Bromide Consumption
for the Past 5 Years and the Amount Required in the Year(s) Nominated
(American Association of Meat Processors)	  PAGEREF _Toc125776127 \h  7 


  HYPERLINK \l "_Toc125776128"  Table 6.2: Methyl Bromide Consumption
for the Past 5 Years and the Amount Required in the Year(s) Nominated
(National Country Ham Association)	  PAGEREF _Toc125776128 \h  8  

  HYPERLINK \l "_Toc125776129"  Table 6.3: Methyl Bromide Consumption
for the Past 5 Years and the Amount Required in the Year(s) Nominated
(Nahunta Pork Center)	  PAGEREF _Toc125776129 \h  8  

  HYPERLINK \l "_Toc125776130"  Table 6.4: Methyl Bromide Consumption
for the Past 5 Years and the Amount Required in the Year(s) Nominated
(Gwaltney of Smithfield)	  PAGEREF _Toc125776130 \h  9  

  HYPERLINK \l "_Toc125776131"  Table 8.1: Key Pests for Methyl Bromide
Request	  PAGEREF _Toc125776131 \h  10  

  HYPERLINK \l "_Toc125776132"  Table B.1: Characteristic of Sector	 
PAGEREF _Toc125776132 \h  10  

  HYPERLINK \l "_Toc125776133"  Table 9.1(a.): Dry Cured Pork Products	 
PAGEREF _Toc125776133 \h  11  

  HYPERLINK \l "_Toc125776134"  Table 9.1(b.): Fixed Facilities	 
PAGEREF _Toc125776134 \h  11  

  HYPERLINK \l "_Toc125776135"  Part C: Technical Validation	  PAGEREF
_Toc125776135 \h  12  

  HYPERLINK \l "_Toc125776136"  Table 12.1.  Summary of Technical Reason
for each Alternative not being Feasible or Available	  PAGEREF
_Toc125776136 \h  12  

  HYPERLINK \l "_Toc125776137"  Part D: Emission Control	  PAGEREF
_Toc125776137 \h  13  

  HYPERLINK \l "_Toc125776138"  Part E: Economic Assessment	  PAGEREF
_Toc125776138 \h  13  

  HYPERLINK \l "_Toc125776139"  Part F: Future Plans	  PAGEREF
_Toc125776139 \h  13  

  HYPERLINK \l "_Toc125776140"  Appendix A.  Methyl Bromide Usage Newer
Numerical Index	  PAGEREF _Toc125776140 \h  17  

 

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 on Dry Cured
Pork Products (Prepared in 2006 for use in 2008)

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



This sector is for the production of cured meat products, such as
country hams.  These are produced primarily in the southern U.S.  This
sector has no viable alternatives available.  Heat would destroy the
product and phosphine does not control mites on the curing hams. 
Sulfuryl fluoride was registered in mid-July 2005 for use on this
commodity and is currently being tested to determine its efficacy on the
primary pests, especially mites. 

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



Table 4.1: Methyl Bromide Nominated For Dry Cured Pork Products  TC
"Table 4.1: Methyl Bromide Nominated For Dry Cured Pork Products" \f F
\l "1"  

Year

	Nomination amount (kg)	Nomination Volume (1000 m3)

2008	19,669	1,022



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"  



Currently there are no viable alternatives to methyl bromide for the
dried meat industry:  phosphine does not control mites (a major pest)
and heat would alter the product.  Sulfuryl fluoride received a recent
federal registration and is now being tested for efficacy against the
mites and other pests of cured meat products.  

In U.S. pork processing plants that produce dry-cured pork products
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 MB, making these alternatives technically and/or
economically infeasible.  Phosphine, alone or in combination with carbon
dioxide does not control mites, a major pest on cured hams.  Mites are
not listed on the sulfuryl fluoride label, and there are no efficacy
data available concerning mites.  

Geographic distribution of the facilities:  Facilities included in this
nomination are located in the southern U.S. where mild temperatures and
high relative humidity result in key pest pressures that are moderate to
severe.  These ambient conditions require that pests be killed because
they will only reinfest the facility after fumigation.  

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.  In the U.S. it is
usual for dry-cured processed pork to be produced in traditional
facilities.  These facilities are usually constructed of wood and many
are decades old, if not older.  Many newer facilities are constructed
using the older facilities as models.

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).  All of the pork products are relatively high fat products
so rancidity would be a problem.  In addition, using heat will alter the
character of the final product, producing, for example, a cooked pork
product rather than a dry-cured pork product with the attendant flavor
differences.  

Transition to newly available alternatives:  Sulfuryl fluoride recently
received a Federal registration on July 15, 2005.  Studies are underway
to determine if this will be an effective alternative for all the pests
of these products in commercial settings.  

Delay in plant operations: e.g., the use of some 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. 

It is common for producers of cured pork products to experience pest
pressure from insects such as the ham skipper, the red legged ham
beetle, dermestid beetles, and mites.  These insects infest and feed on
meat as it cures and ages.  Environmental conditions (temperature and
humidity) in and around the facility strongly influence the level of
pest pressure.  Under favorable ambient conditions, such as those seen
in silo curing, pest pressure increases and a regular fumigation
schedule is recommended.  In the U.S., the Food and Drug Administration
(FDA) regulates the maximum levels of live or dead insects or insect
parts that may be present in stored food products.  Food commodities
that exceed maximum limits allowed are considered adulterated by FDA and
thus unfit for human consumption.  There are currently no alternatives
registered for use on hams in the U.S. that would provide the same level
of pest control.

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

	National Country Ham Association	American Association of Meat
Processors	Gwaltney of Smithfield	Nahunta Pork Center

Amount of Request

	2008	Kilograms

	1,242	168,283	1,905	91

Amount of Nomination*

	2008	Kilograms

	709	18,144	726	91

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

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



Table 6.1: Methyl Bromide Consumption for the Past 5 Years and the
Amount Required in the Year(s) Nominated (American Association of Meat
Processors)  TC "Table 6.1: Methyl Bromide Consumption for the Past 5
Years and the Amount Required in the Year(s) Nominated (American
Association of Meat Processors)" \f F \l "1"  

	Historical Use1	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2007

Amount of MB (kg)	Information not provided	168,283

Volume Treated 1000 m³	Information not provided	7,004

Formulation of MB	Information not provided

	Dosage Rate (kg/1000 m³)	Information not provided	24.03

Actual (A) or Estimate (E)	Information not provided

	1 American Association of Meat Processors did not provide historical
data.  

Table 6.2: Methyl Bromide Consumption for the Past 5 Years and the
Amount Required in the Year(s) Nominated (National Country Ham
Association)  TC "Table 6.2: Methyl Bromide Consumption for the Past 5
Years and the Amount Required in the Year(s) Nominated (National Country
Ham Association)" \f F \l "1"  

	Historical Use1	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2007

Amount of MB (kg)	749	694	802	791	791	791	1,242

Volume Treated 1000 m³	38	33	45	43	43	43	17

Formulation of MB	Information not provided

Dosage Rate (kg/1000 m³)	19.68	21.03	18.01	18.60	18.60	18.60	73.10

Actual (A) or Estimate (E)	Information not provided



Table 6.3: Methyl Bromide Consumption for the Past 5 Years and the
Amount Required in the Year(s) Nominated (Nahunta Pork Center)  TC
"Table 6.3: Methyl Bromide Consumption for the Past 5 Years and the
Amount Required in the Year(s) Nominated (Nahunta Pork Center)" \f F \l
"1"  

	Historical Use1	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2007

Amount of MB (kg)	363	109	218	109	109	109	91

Volume Treated 1000 m³	16	5	9	5	5	5	4

Formulation of MB	Information not provided

Dosage Rate (kg/1000 m³)	23.3	23.3	23.3	23.3	23.3	23.3	23.3

Actual (A) or Estimate (E)	Actual



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

	Historical Use1	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2007

Amount of MB (kg)	363	1,361	907	2,177	1,361	3,266	1,905

Volume Treated 1000 m³	21	21	21	21	177	177	177

Formulation of MB





	Information not provided

Dosage Rate (kg/1000 m³)	17.09	64.07	42.72	102.52	7.70	18.48	10.78

Actual (A) or Estimate (E)





	Information not provided



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



There more than 1,650 pork production facilities in the United States. 
Of these, approximately 850 facilities require the use of methyl bromide
to fumigate dry cured pork products.  The other facilities smoke their
products and smoking prevents insects from invading their facilities.  

General location information for the following facilities is known:
Kentucky (Cadiz, Greenville counties), Missouri (California county),
North Carolina (Boone, Goldsboro, Smithfield, Wayne counties), Virginia
(Surry county), Tennessee (various locations), and South Carolina
(various locations).

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



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

Genus and species for which the use of Methyl Bromide is critical	Common
Name	Specific Reason why Methyl Bromide is Needed

Necrobia rufipes – common pest	Red Legged Ham Beetle (“Ham Borer”)
The adults feed on the cured meat.  The larvae burrow into the meat and/
or fat.  Insect infested meat is adulterated and cannot be sold.1

Piophila casei – common pest	Cheese/Ham Skipper	The Skippers are
larval stages of small flies that burrow into the cured meat.

Dermestes spp-common pests	Dermested beetles

	Mite species -- common pest	Ham Mites	These mites feed and breed on the
surface of cured meats.  Uncontrolled, mite populations can increase
rapidly, reaching enormous numbers.

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

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

	Jan	Feb	Mar	Apr	May	June	July	Aug	Sept	Oct	Nov	Dec

Raw Material In	X	X	X	X	X	X	X	X	X	X	X	X

Fumigation Schedule (MB)	X	X	X	X	X	X	X	X	X	X	X	X

Retail Target Market Window	X	X	X	X	X	X	X	X	X	X	X	X



Raw pork product material can come into a curing facility in any month
of the year.

The Methyl Bromide fumigation schedule will vary depending on several
factors such as:  

1.  Type of pork product - Bone-in products have a higher probability of
pest infestation since the pests are attracted to the bone, and these
products typically age for longer periods of time.

2.  Type of structure/facility - Typically, older curing facilities have
a higher probability of pest infestations, which could be attributed to
the lack of air tightness of the facility.  A majority of the newer
facilities have lower pest pressure due to increased air tightness. 
Additionally, silo facilities, those that are two to three stories in
height, have a higher probability of insect infestations when compared
to a single story facility.  

A single curing and ham storage operation can typically process
10,307,878 kilograms (11,362.5 U.S. tons) of pork products each year. 
The curing facilities are fumigated with methyl bromide when pests are
detected in the product or the smokehouses.  This fumigation typically
occurs about three to five times during a typical year.  During this
process the curing house, typically a small building (e.g. four
stories), is covered with tarp and fumigated while full of hams.

3. Type of curing - Curing can be achieved by either temperature
controlled room curing, or by ambient curing.  Ambient curing, which
involves uncontrolled environmental conditions, typically requires a
regular fumigation schedule due to consistently high levels of pest
infestations. 

4.  Location/climate of structure/facility - These curing facilities are
located in southeastern states, where the temperature and humidity are
higher for longer periods of time throughout the year and, therefore,
there is a greater opportunity for pests to be active for longer periods
of time. As the pest pressure increases, so does the need to fumigate
with methyl bromide.  Curing facilities are located near slaughter
houses and feed lots, thereby having high insect populations nearby.  

The retail target market window varies, but there are higher demands for
cured pork products around holidays such as Thanksgiving, Christmas, and
Easter.

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



Table 9.1(a.): Dry Cured Pork Products  TC "Table 9.1(a.): Dry Cured
Pork Products" \f F \l "1"    

Methyl Bromide Dosage (g/m³)	Exposure Time (hours)	Temp. (ºC)	Number
of Fumigations per Year	Proportion of Product Treated at this Dose	Fixed
(F), mobile (M) or Stack (S)

24	Varies	Varies with facility, but typically in excess of 27°C (80°F)
Varies from 2-8 fumigations per year.  3-5 times per year common	Up to
100% in some facilities.	Fixed



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

Type of Construction and Approximate age in Years	Vol (m³) or Range
Number of Facilities (e.g. 5 silos)	Gastightness Estimate*

More than 850 curing facilities use methyl bromide.  The age of the
facilities varies.	Varies	Ranges from 1 story to silo facilities.	Varies



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"   



Currently, other than sanitation, no alternative techniques are being
used.  Sanitation is useful in increasing the time between methyl
bromide fumigations but cannot, when used alone, replace methyl bromide
fumigations.

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



Sulfuryl fluoride recently received a federal registration (July 15,
2005) for this use.  The industry, in cooperation with USDA, university
professors, and state researchers, is developing research to determine
the effectiveness of sulfuryl fluoride against pests, especially mites,
of cured meat products.  For further information regarding the
investigations see Section 16.  

Phosphine, alone and in combination with carbon dioxide, does not
control mites, a major pest in dry cured pork products.  Additionally,
according to the phosphine label, the state of North Carolina has
further restricted the use of this alternative.  According to state
regulations, phosphine may only be used to control rats and mice, but
not insects.  

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"  

No.	Methyl Bromide Alternative	Technical reason (if any) for the
alternative not being Feasible	Estimated month/year when the technical
Constraint could be solved

1	Phosphine alone & in combination	Does not control mites.  North
Carolina has additional use restrictions.

	2	Propylene oxide	Not registered for this use in the U.S.

	3	Contact insecticides	None registered for this use in the U.S.

	4	Irradiation	See Note below

	5	Sulfuryl fluoride	Recently received federal registration (July 15,
2005).  Sulfuryl fluoride adsorbs to fats.  Efficacy studies in
commercial settings against the insect and mite pests are being planned.
Unknown 



Note: Irradiation does not readily kill exposed insects, but rather
prevents further feeding and reproduction.  Although unable to feed or
reproduce, the surviving insects would still create phytosanitary
problems and the high doses required to kill exposed insects may affect
product quality.  Consumer acceptance of irradiated food would hinder
the adoption of this method.

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

Nahunta and Gwaltney of Smithfield have built new facilities that are
very gas tight and consolidated buildings to reduce their request of
methyl bromide.  In addition, members of this sector are participating
in research to improve the gastightness and sanitation of their
facilities in order to reduce emissions and number of fumigations.  

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



Sulfuryl fluoride received a federal registration for use on cured pork
products in the U.S on July 15, 2005.  This pesticide is being
registered by states and is being investigated for efficacy on mites and
other pests of dry cured meats.  Because of the recent registration,
economic information is not yet available; therefore, no economic
analysis was conducted.

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"  



An economic analysis has not been conducted because prior to July 2005
this sector did not have an alternative registered.  This industry is
awaiting results of trial to control mites, a key pest for this sector.

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



Sulfuryl fluoride received a federal registration for use on cured pork
products in the U.S on July 15, 2005.  This pesticide is being
registered by states and is being investigated for efficacy on mites and
other pests of dry cured meats.  Because of the recent registration,
economic information is not yet available; therefore, no economic
analysis was conducted.

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



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



Some of the applicants are constructing new facilities and consolidating
buildings to reduce their emissions and minimize the use of methyl
bromide in the future.  

North Carolina State University and Mississippi State University
Extension and research personnel are in the process of planning an
industry-wide survey of country ham plants throughout North Carolina,
Virginia, Kentucky, Tennessee, and Missouri.  The survey will consist of
various questions related to methyl bromide use.  This will include:
method, reason, frequency of use, total amount used, seasonal usage and
application rate.  In addition, questions regarding facility
infrastructure as it affects methyl bromide utilization will be
solicited.  In January-February of 2006 audit teams will visit each
plant applying for an exemption to survey plant conditions to ascertain
possible deficits in facilities that might lead to poor methyl bromide
utilization.

Members of this industry are cooperating with the registrant of sulfuryl
fluoride to investigate the efficacy of this chemical under commercial
conditions.  Experiments are being planned to study the effects in
curing facilities of sulfuryl fluoride on ham skippers, red-legged ham
beetles, and mites.  

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"   

Now that sulfuryl fluoride received a federal registration July 15, 2005
for this use, investigations are beginning to understand how to
incorporate this new alternative into the dry cured meat product pest
management plans.

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"  

Bell, C.H.  2000.  Fumigation in the 21st Century.  Crop Protection,
19:563-69. 

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

U. S. Dry Cured Pork Products	  PAGE  7 

