METHYL BROMIDE CRITICAL USE RENOMINATION FOR POST-HARVEST -- Commodities


Nominating Party: The United States of America

FILE NAME: USA CUN13 POST HAVEST USE FOR COMMODITIES

Brief descriptive Title of Nomination:

Methyl Bromide Critical Use Nomination for Post Harvest Use on
Commodities (Submitted in 2011 for 2013 Use Season)

Quantity of methyl bromide requested in each year of nomination:

Table 1: Quantity of Methyl Bromide Requested in Each Year of Nomination

Year	Nomination Amount (kilograms)

2013	822 kg



(Details on this page are requested under Decision Ex. I/4(7), for
posting on the Ozone Secretariat website under Decision Ex. I/4(8).) 

In assessing nominations submitted in this format, TEAP and MBTOC will
also refer to the original nomination on which the Party’s first-year
exemption was approved, as well as any supplementary information
provided by the Party in relation to that original nomination.  As this
earlier information is retained by MBTOC, a Party need not re-submit
that earlier information.   

NOMINATING PARTY CONTACT DETAILS:

Contact Person:	John Thompson	

Title:	Division Director	

Address:	Office of Environmental Policy	

	U.S. Department of State	

	2201 C Street, N.W. Room 2657

	Washington, D.C. 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:	Jack Housenger	

Title:	Division Director 	

Address:	Biological and Economic Analysis Division			

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	1200 Pennsylvania Avenue, N.W. Mailcode 7503P

	Washington, D.C. 20460

	U.S.A.	

Telephone:	(703) 308-8200		

Fax:	(703) 308-7042	

E-mail:	Housenger.Jack@epa.gov

		

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION
PACKAGE:

1.  PAPER DOCUMENTS:  

Title of paper documents and appendices	No. of pages	Date sent to Ozone
Secretariat

















2.  ELECTRONIC COPIES OF ALL PAPER DOCUMENTS:  

*Title of each electronic file (for naming convention see notes above)
No. of kilobytes 	Date sent to Ozone Secretariat

USA CUN13 Post harvest: commodities















* Identical to paper documents



METHYL BROMIDE CRITICAL USE RENOMINATION FOR POST-HARVEST -- Commodities


1.  SUMMARY OF NEED for methyl bromide

Commodity fumigation with methyl bromide is used primarily at harvest
time, when rapid fumigation is needed to keep up with the large volumes
of incoming commodities and when commodities are in storage.  

USG is requesting methyl bromide for this sector to allow time for the
industry to purchase equipment, build chambers, modify structures,
and/or practice using alternatives.  

Sulfuryl fluoride, as ProFume®, remains registered for the uses
included in this nomination in the US.  However, EPA has published a
prepublication copy of the proposed order to revoke tolerances.  For
additional information, please refer to the links on EPA’s website: 
HYPERLINK
"http://www.epa.gov/oppsrrd1/registration_review/sulfuryl-fluoride/evalu
ations.html"
http://www.epa.gov/oppsrrd1/registration_review/sulfuryl-fluoride/evalua
tions.html .  

Table 2.  Nomination Amount 

2.  SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

This sector includes walnut, dried fruit (prunes, raisins, figs), and
dates, all of which are subject to infestation by several insect pests. 
Since infestation begins in the field, methyl bromide is used to rapidly
fumigate harvested commodities and to disinfest commodities in storage. 
Most fumigation occurs over several weeks, during the peak production
season, as the bulk of the harvest moves from the field into storage and
shipping channels.  Upon arrival from the field, each load is fumigated
with methyl bromide in preparation for shipment to national and
international markets.  

Research with sulfuryl fluoride indicates that this fumigant is a
potential methyl bromide alternative for commodities, provided
fumigation occurs at temperatures above 70 ºF.  Recent studies have
shown that under vacuum or atmospheric conditions, sulfuryl fluoride is
effective against adult, pupal, and larval stages of stored product
pests.  The ovicidal efficacy of sulfuryl fluoride is dependent upon
temperature and exposure time.  

Walnuts – Quick turn-around time for walnuts at peak harvest time is
the primary justification for methyl bromide use in this sector.  Vacuum
fumigation with methyl bromide may take 4-6 hours and atmospheric
fumigation approximately 8-24 hours.  Phosphine gas fumigation takes
approximately three days and is being used to fumigate walnuts in
storage.   

The industry experts further observe that the walnut industry fumigates
during 6 months of the year at or below 50 °F and provide supporting
temperature data for the San Joaquin and Sacramento Valleys of
California, their main production areas.  

Dates - Methyl bromide is used to rapidly fumigate California dates at
harvest time, when up to a million pounds per day are being harvested
within a relatively tight timeframe during the fall.  Although several
insect may infest dates, the carob moth, Ectomyelois ceratoniae, is the
more damaging species.  The California Date Commission reports that it
is currently testing the efficacy of sulfuryl fluoride on dates, in
collaboration with Dow AgroSciences and Dr. Spencer Walse of USDA.  The
applicant reports that preliminary results show less than adequate egg
kill, even when the amount used is twice that needed for comparable
methyl bromide fumigation.  Phosphine takes longer to fumigate dates,
and during this time fermentation and off-flavor can occur.  

Dried Fruit – Methyl bromide is used to disinfest dried fruit in
storage when the fruit is stored at processing facilities.  Phosphine
would corrode the electrical and electronic equipment in the processing
areas.  Phosphine also takes longer to fumigate and would consequently
shut down the processing area as well.  Sulfuryl fluoride is currently
labeled for use on dried fruit; however, research results presented at
the 2009 MBAO meeting (Walse et al., 2009), the indicate that under low
temperatures and current label rates efficacy is inadequate against
dried fruit beetle, red flour beetle, and Indianmeal moth eggs.  The
California Dried Plum Board reports that commodities cannot always be
treated at 80 ºF and that control of egg stages of target pests is
imperative.  

USG is requesting methyl bromide for this sector to allow time for the
industry to purchase equipment, build chambers, modify structures,
and/or practice using alternatives.  The current registration of
sulfuryl fluoride, as ProFume®, remains unchanged in the US for the
uses included in this nomination.  However, EPA has published a
prepublication copy of the proposed order to revoke tolerances.  For
additional information, please refer to the links on EPA’s website: 
HYPERLINK
"http://www.epa.gov/oppsrrd1/registration_review/sulfuryl-fluoride/evalu
ations.html"
http://www.epa.gov/oppsrrd1/registration_review/sulfuryl-fluoride/evalua
tions.html .  

3.  Summary of recent research 

Walse, et al. (2009) have demonstrated that sulfuryl fluoride does not
readily kill egg stages of navel orangeworm or the eggs of several
stored product insects at temperatures below 70° F at or below maximum
label rates.  USDA/ARS researchers plan to continue testing the efficacy
and practicality of using sulfuryl fluoride, relative to methyl bromide,
to control post-harvest pests of nuts and dried fruit.  Sulfuryl
fluoride thus appears to be an effective methyl bromide alternative for
in-shell walnuts.  

The applicants believe that further research is needed on the ovicidal
efficacy of sulfuryl fluoride at temperatures below 70 °F, as well as
on the ovicidal efficacy of propylene oxide/sulfuryl fluoride
combinations.  The California Walnut Commission is providing funding to
the Dried Fruit Association of California to continue its investigations
of combinations of PPO and sulfuryl fluoride and carbon dioxide. 
Muhareb, et al. (2009) presentation at the 2009 MBAO that adding carbon
dioxide increased the larval efficacy of the PPO+SF mixture.  The
combination also was more efficacious on eggs.  

Past data showed RFB larvae fumigated with PPO had an LD95 using 606
mg.h/l SF is just the opposite requiring higher CT product for the eggs,
LD95 966 mg.h/l,10% CO2 was the most effective. Without CO2, combining
the two fumigants together showed a LD95 of 432 on RFB eggs and a LD95
of 353 on RFB larvae. Adding 10% CO2 reduces the dosages by about
two-thirds of the fumigants used alone. The CO2 along with the synergy
of the blend reduces cost, lowers environmental emission and provides
greater safety.  

Reichmuth and Klementz presented at the 2009 MBAO possible
investigations to overcome the egg weakness of sulfuryl fluoride.  These
included combinations of gases such as sulfuryl fluoride with phosphine,
or carbon dioxide.  They also proposed using heat to increase the
efficacy of sulfuryl fluoride.  Their preliminary data demonstrated that
these combinations show promise for many stored product pests of dried
fruits and tree nuts.   

Reichmuth, also at the 2009 MBAO, presented data regarding sulfuryl
fluoride efficacy on the eggs of the rice moth Corcyra cephalonica.  He
showed that older eggs were more tolerant of sulfuryl fluoride than were
the young eggs.  His data show that increasing the exposure time the
difference between the ages of the eggs is reduced and disappears.   

Full control was achieved at a concentration of 4.19 mg/l only after 5
days of fumigation (ct=120 x 4.19mgh/l=502mgh/l) 5.24 mg/l were
sufficient to control all investigated eggs with exposure of 4 days
(ct=503 mgh/l) and 5 days (ct=628 mgh/l), as well as three days old eggs
with 3 d fumigation (ct=377 mgh/l). 3 days fumigation served to kill all
eggs of all ages with 6.24 mg/l (ct=449mgh/l).  These ct-products are in
range with corresponding values for lethal ct products for the other
related stored product pest moths Ephestia kuehniella, Plodia
interpunctella and Ephestia elutella (Baltaci et al., 2006). “

Williams (2009),of Dow AgroSciences, presented the results of sulfuryl
fluoride investigations on carob moth (Ectomyelosis ceratonia) in
freshly harvested dates.  Complete mortality of eggs and larvae was
achieved with 332 oz-h/MCF (g-h/m3) CT (concentration x time) dosage of
ProFume at 21°C (70°F) during a 14-h exposure.  Compare that to 1.5
lb/MCF of MB, for chambers with a moderate HLT of 20 h and a short,
overnight exposure of 16 h.  

Chamber fumigation needing a quick overnight turnaround represents ( 30%
of the production fumigation.  The remaining 70% of the fumigations
occur in 5.0-MCF stacks of bins under tarps in the open yard, when time
is not critical and the tarps may be kept sealed for weeks or even
months.  With the anticipated 50+ h HLT actually measured with the tarps
by this PI in 2007, a fumigation using only 1.3 lb/MCF of ProFume would
require 16 h to achieve 300 oz-h/MCF for carob moth control.  Further
gas savings can occur by extending the exposure time.  At 50-h HLT and
72-h exposure, a 300 oz-h/MCF CT dosage for ProFume can be achieved
applying only 0.4 lb MCF.  

These considerations of CM efficacy at 300 oz-h/MCF CT dosages combined
with good HLT, which can be achieved with good structural sealing
techniques, demonstrate that ProFume is an equivalent (weight: weight)
alternative to MB in fresh dates for short-exposure overnight
fumigations.  When extended exposures are possible in tarped stacks,
ProFume becomes superior (weight: weight) to MB.  This research
demonstrates that in all aspects (technical, practical & economical),
ProFume is a viable alternative to MB for fumigation in dates and is
available as an immediate industry replacement for MB. 

Hosoda (2009), of Cardinal Professional Products, presented an update of
sulfuryl fluoride uses in post-harvest at both the 2009 and 2010 MBAO
conferences.  Mr. Hosoda reported that walnuts began to transition to
sulfuryl fluoride in 2008, and made rapid progress in 2009 away from
methyl bromide.  Mr Hosoda reported:

One of the concerns with some of the major processors was the control of
the egg stage of the Navel orangeworm, which is primarily a field pest
that comes in with the product after harvest.  It has recently been
found that it is critical to control the egg stage of the Navel
orangeworm, when it was once considered to be a field pest that cannot
proliferate in storage.  Dow AgroSciences funded a project with the
Dried Fruit and Tree Nut Association (American Council for Food Safety
and Quality) to evaluate ProFume’s® efficacy on walnuts infested with
Navel orangeworm eggs.  The results showed that ProFume®, when applied
under vacuum, will effectively control over 99% of the egg stage.  USDA
recently performed efficacy studies under similar conditions with methyl
bromide, and found egg survival to be 31%-43% depending on the dose. 
These data created a comfort level for the last few processors to make
the conversion to ProFume®.

Dr. Thoms, of Dow AgroSciences, also provided an update on ProFume at
MBAO in 2008 (Williams and Thoms, 2008):

Dow AgroSciences continues to work with post-harvest processors to
document commercial suitability of ProFume for fumigating commodities. 
As a follow-up to the initial commercial fumigation trials in fresh
dates reported at this conference last year, product bins full of dates
and stacked in the same 142 m3 (5 Mcf) commercial fumigation chamber
used in previous trials were exposed to ProFume for 15.6 hours at 21° C
(70° F) in April 2008.  All-life-stage culture bioassays of dried fruit
beetle (Carpophilus hemipterus) buried about 30 cm (1 ft) deep in
separate bins in the stacks showed 100% control in three of the four
culture replicates exposed to a range of 536-636 g-h/m3 (oz-h/Mcf) and
98.5% control in the fourth replicate exposed to 598 g-h/m3.  These
results are more favorable in both performance and subsequent economics
than previous findings.  Following necessary repairs to the fumigation
chamber to again provide the 35-h HLT observed in the first set of
trials in 2006, the same average 582 g-h/m3 observed in this trial would
be achieved with an equivalent of 32 g/m3 (2.0 lb/Mcf).  This would be
an arguably cost-effective 1.5X the historically standard MB dose of 21
g/m3 (1.3-lb/Mcf) that could provide nearly 100% control of all life
stages of dried fruit beetle infesting fresh dates.

However, investigations into other alternatives have been reported at
MBOA as well.  Mr. Hosoda, (2008) reported that ECO2FUME and VAPORH3
were also being used as methyl bromide alternatives in many different
commodities.  

Although most phosphine applications require a longer exposure period
than methyl bromide, users have made adjustments in their production
schedules and have invested in additional fumigation chambers to
accommodate the use of these alternatives.  

A major nut processor made the transition to VAPORPH3OS® in their
long-term nut storage bins where short term fumigations are not
required.  This company initially converted to ECO2FUME® for these
applications, but required such a large volume of cylinders, it made
economical sense (by purchasing a Fosfoquim HDS-200®) to implement
VAPORPH3OS®in their fumigation program.  This use eliminated
approximately 50,000 lbs. of methyl bromide per year.

Almond, pistachio, fig, bean and raisin processors have all replaced
thousands of pounds of methyl bromide with ECO2FUME®/VAPORPH3OS®. 
Wherever short term fumigations are not absolutely necessary,
cylinderized phosphine fumigants have become a suitable option, and are
very economical to use.   International acceptance of phosphine residues
(MRL) also make phosphine a logical choice as an alternative fumigant.

4.  ECONOMIC Analysis of Transition to Alternatives

Table 3.  Economic Summary for each Alternative

Methyl Bromide Alternative	Economic Summary

Phosphine	PO3 is a viable alternative for walnuts and dried fruit but
not for dates.  In the case of both walnuts and dried fruit, use of
phosphine as a primary fumigant will require purchase of additional
fumigation chambers due to longer fumigation time.  Economic losses will
be incurred initially as a result of investment in additional chambers. 
This loss will be greater for walnuts. 

Sulfuryl Fluoride	SF is a viable alternative for walnuts, dried fruit,
and dates.  SF costs less per lb than MeBr, but application rates may be
higher.  Higher application rates will not change.



A separate economic analysis of alternatives was conducted for each
commodities sub-sector: walnuts, dried fruit, and dates.  The economic
analyses of transition to alternatives are based on the cost of
transitioning the total commodity treated with quantity granted by the
Parties for 2012 to the technically feasible alternatives.  For the year
2012, the Parties granted 527 kgs for walnuts, 829 kgs for dried fruit,
and 1,063 kgs for dates.    

The analyses focus on the differences in the cost of fumigant gas and
the cost of fumigation space (i.e., fumigation chambers) between methyl
bromide and alternatives.  The analysis of fumigation space is
applicable to a transition to phosphine for walnuts and dried fruit. 
Transition to phosphine in these sectors would require an initial
investment in additional chambers.  In dried fruit, the number of
chambers needed is expected to be small since there is not a “harvest
window” issue.  The chambers are needed to avoid the need to fumigate
in the storage warehouse.  In the case of walnuts, many more additional
chambers will be needed to accommodate the throughput during the harvest
window.  Since phosphine takes five times as long as methyl bromide or
sulfuryl fluoride, five times as many chambers would be necessary.  Due
to the need to purchase additional fumigation space, there would be an
initial investment cost in the first year to purchase additional
fumigation chambers.  After the first year, however, the cost of
fumigating with phosphine would be lower than fumigating with methyl
bromide because the cost of the gas and the application rates are
considerably lower.  The cost to transition to SF is negligible for both
walnuts and dried fruit. 

In the case of dates, sulfuryl fluoride is the only viable alternative. 
Fumigation with sulfuryl fluoride requires slightly higher application
rates, but the transition results in a small cost savings due to its
lower price relative to methyl bromide. 

Walnuts

The United States walnut industry is concentrated in the state of
California where production averaged 366,000 short tons of walnuts per
year from 2005-2009.  Both production and sales peak in the fall in
anticipation of the holiday season in December.  Approximately 11
percent of walnuts are sold in the shell.  The remaining 75 percent are
shelled and processed further to create a variety of packaged shelled
products.  All walnuts must be fumigated before they are put in to
long-term storage or continue in the processing chain.  Phosphine can be
used for the 75 percent of walnuts that are allocated for packaged
shelled products because turnaround time is not crucial.  For the 25
percent that are sold in-shell, they are sold in a short period of time
very close to harvest time.  A rapid fumigant is needed to accommodate
the throughput during this critical window.       

Table 4 displays information on the walnut industry and methyl bromide
granted.  Over the period from 2005 through 2009, approximately 345,000
metric tons of walnuts were produced, valued at more than $643 million. 


Table 4. Summary information on walnut industry and methyl bromide

Production, Value, and Cost

Commodity Metric Tons Produced per Year 1	345,093

Commodity Kilograms Produced per Year	345,093,075

Gross Revenue per Metric Ton 2	 $                   1,866 

Total Annual Gross Revenue	 $        643,636,799 

Operating Costs per Metric Ton 3	 $                      805 

Total Annual Operating Costs 	 $        277,866,004

Net Revenue per Metric Ton	 $                   1,060 

Total Annual Net Revenue	 $        352,328,837 

MeBr Granted

MeBr Granted by Parties 2012 (kg) 	527

Commodity Treated with 2012 Granted MeBr (cu m) 4	21,958



1 Five year average from USDA NASS, 2005-2009.  

2 Based on five-year average price from USDA NASS of $1,692 per U.S.
short ton, 2005-2009

3 CUE applicant provided total operating cost of $731 per ton in
worksheet 2-D of the CUE application.  Converted to cost per metric
tons.

4 Based on use rate of 1.5 lbs per 1,000 cubic feet, 24 kgs per 1,000
cubic meters. 



The results of the analysis for walnuts are presented in Table 5.    

A sulfuryl fluoride treatment can be conducted in roughly the same
amount of time as a methyl bromide treatment, which is assumed to be
eight hours total, four hours for fumigation and four hours for
fumigation.  Assuming a 24 hour cycle, three fumigations per day are
conducted during peak harvest for both methyl bromide and sulfuryl
fluoride.  Although the sulfuryl fluoride column displays a cost for
fumigation chambers, it is assumed that this number of chambers or
equivalent space is already available for methyl bromide fumigation and
could be transitioned to sulfuryl fluoride use with no additional cost. 
No additional chambers are needed.  The analysis indicates a small cost
savings each year ($2,360) from a transition to sulfuryl fluoride.  

Previous analyses indicated that a switch to phosphine would require an
additional 84 days of treatment time.  This is due to the longer
treatment time for phosphine compared to methyl bromide.  The current
analysis examines the cost of purchasing additional fumigation chambers
to accommodate the throughput of walnuts during peak harvest time.  The
analysis assumes that all in-shell walnuts are fumigated within 45 days.
 Assuming that all walnuts are harvested in this short period likely
overestimates the number of additional chambers that will be needed
since not all walnuts harvested are fumigated within a 45-day window.

Based on this analysis, the cost to transition the commodity treated by
527 kgs to phosphine would be a $90,000 initial investment in chambers. 
After the initial investment in additional chambers, the industry will
experience a small cost savings each year ($10,200) from using
phosphine.   

Table 5. Analysis of transition to alternatives for walnuts treated with
methyl bromide 

	 	Methyl 

Bromide	Sulfuryl Fluoride	Phosphine

1	Cubic meters treated with 2012 granted MeBr 1	21,933	21,933	21,933

2	Capacity of fumigation chamber (cu m) 2	125	125	125

3	Days of harvest 3	45	45	45

4	One day capacity of each chamber (cu m) 4	374	374	25

5	Total chambers needed 5	2	2	20

6	Total Cost of Fumigation Chambers (@ $5,000 each) 6	$          10,000 
$          10,000	$        100,000 

7	Cost difference between MeBr and alternative 	na 	$                  
-   	$          90,000 

8	Total gas for cubic feet needing fumigation (kgs) 7	527	703	88

9	Price of fumigant gas ($ / kg) 8	 $           20.94 	 $          
12.35 	 $             9.37 

10	Total cost of fumigant gas ($)	 $         11,037 	 $           8,675 
 $              823 

11	Cost difference between MeBr and alternative	 	 $        (2,362)	 $ 
    (10,214)

12	Total cost of fumigation space and fumigant	 $         21,037 	 $    
    18,675 	 $       100,823 

13	Total cost difference between MeBr and alternative	 	 $       
(2,362)	 $         79,786 

14	Cost difference as % of gross revenue (from Table 4)	 	0.00%	-0.01%

15	Cost difference as % of net revenue (from Table 4)	 	0.00%	-0.02%



1 From Table 4.

2 Size of fumigation chamber (5,500 cubic feet or 156 cubic meters)
based on size of dry freight van trailer found at  HYPERLINK
"http://www.pensketruckrental.com/commercial-truck-rentals/trailer-truck
/" www.pensketruckrental.com/commercial-truck-rentals/trailer-truck/ ,
(Accessed Jan 6, 2011); reduced by 20% to  account for air space in
fumigation chamber.    

3 Assumes that all commodity to be treated is treated within this time
period.

4 Using methyl bromide and sulfuryl fluoride, each chamber can be used
three times (Line2 x 3 = Line4); for phosphine, each fumigation takes 5
days (15 times longer than MeBr and SF), so each chamber can be used the
equivalent of 1/5 of a time per day (Line2 ÷ 5 = Line 4).  Also, the
capacity of each chamber is reduced so that only 80% of it is used for
commodity.  

5 Divide commodity to be treated (Line1) by harvest capacity of each
chamber (line 

6 One-time cost to purchase chambers.  Approximate cost of dry van
trailer that could be used for fumigation available from American
Trailer Exchange, See Dry Van Trailers at  HYPERLINK
"http://www.amtrex.net/AMTREXsalesinventory.htm"
www.amtrex.net/AMTREXsalesinventory.htm , Accessed Jan 6, 2011.

7 Assumes rate of 1.5 lbs / mcf [24 kgs / tcm] for methyl bromide, 2 lbs
/ mcf [32 kgs / tcm] for sulfuryl fluoride, and 0.25 lbs / mcf [4 kgs /
tcm] for phosphine.   



Dried Fruit

The dried fruit industry has already replaced a large portion of methyl
bromide with phosphine in processing dried fruits.  The CUE application
states that methyl bromide is still needed for dried fruit because the
industry still does not “have an alternative where processing
equipment/storage treatments are made” and that sulfuryl fluoride is
not as effective “at low temperatures and egg kill of target pests.”
 

Table 6 displays information on the dried fruit industry and methyl
bromide granted.  Over the period from 2005 through 2008, approximately
464,000 metric tons of dried fruit (which included raisins, prunes, and
figs) were produced, valued at more than $535 million.  

Table 6. Summary information on dried fruit industry and methyl bromide

Production and Value

Commodity Metric Tons Produced per Year 1	464,270

Commodity Kilograms Produced per Year 	349,284,269

Total Annual Gross Revenue 2	 $          535,434,200 

MeBr Granted 

MeBr Granted by Parties 2012 (kg) 	829

Commodity Treated with 2012 Granted MeBr (cu m) 3	34,502



1 Four year average from USDA NASS, 2005-2008.  

2 Based on four-year average of combined total crop values, 2005-2008

3 Based on use rate of 1.5 lbs per 1,000 cubic feet, 24 kgs per 1,000
cubic meters.



The results of the analysis for dried fruit are presented in Table 7.   
  

The analysis indicates a small cost savings each year ($3,700) from a
transition to sulfuryl fluoride.  No chambers are necessary because
sulfuryl fluoride, like methyl bromide can be used indoors without
damaging electrical equipment.     

Table 7. Analysis of transition to alternatives for dried fruit treated
with methyl bromide

	 	Methyl Bromide	Sulfuryl Fluoride	Phosphine

1	Cubic meters treated with 2012 granted MeBr 1	34,502	34,502	34,502

2	Capacity of fumigation chamber (cu m) 1	125	125	125

3	Time available to fumigate (days) 2	365	365	365

4	One day capacity of each chamber (cu m) 3	na	na	31

5	Total chambers needed 3	0	0	4

6	Total Cost of Fumigation Chambers (@ $5,000 each) 1	$                 
 -	$                   -	$          20,000 

7	Cost difference between MeBr and alternative	 	$                   - 
 	$          20,000

8	Total gas for cubic feet needing fumigation (kgs) 1	829	1,105	138

9	Price of fumigant gas ($ / kg) 	$            20.94 	$            12.35
	$              9.37 

10	Total cost of fumigant gas ($)	$          17,363 	$          13,646 
$            1,295 

11	Cost difference between MeBr and alternative	 	$         (3,716)	$  
    (16,068)

12	Total cost of fumigation space and fumigant	$          17,363 	$     
    13,646 	$          21,295 

13	Total cost difference between MeBr and alternative	 	$        
(3,716)	$         (3 932)

14	Cost difference as % of revenue	 	0.00%	0.00%



1 See notes for this Line from Table 5. 

2 Assumes that fumigation occurs year-round; no time constraint.

3 No chambers are needed for methyl bromide and sulfuryl fluoride
because they can be used in existing storage facilities.  Chambers are
only needed for phosphine because it is corrosive to electrical
equipment.  



The analysis for phosphine examines the cost of purchasing fumigation
chambers to fumigate dried fruit outside of the storage warehouse. 
Assuming that fumigation can occur year-round and there is no particular
time when the majority of it is fumigated, the industry will need to
purchase four fumigation chambers at a total cost of $20,000.  After the
initial investment in fumigation chambers, the industry will save on
fumigation each year (approximately $16,000) from switching to
phosphine.

Dates

Table 8 displays information on the dried fruit industry and methyl
bromide request.  Over the period from 2005 through 2008, almost 16,000
metric tons of dates were produced, valued at more than $32 million.  

Table 8. Summary information on date industry and methyl bromide

Production and Value

Commodity Metric Tons Produced per Year 1	15,898

Commodity Kilograms Produced per Year	15,898,413

Total Annual Gross Revenue 1	 $         32,179,500 

MeBr Granted

MeBr Granted by Parties 2012 (kg) 	1,063

Commodity Treated with 2012 Granted MeBr (cu m) 2	44,241



1 Four year average from USDA NASS, 2005-2008.  

2 Based on use rate of 1.5 lbs per 1,000 cubic feet, 24 kgs per 1,000
cubic meters.



The results of the analysis for dates are presented in Table 9.

      

Sulfuryl fluoride is the only alternative considered for dates.  A
transition to sulfuryl fluoride will result in cost savings for the
industry of more than $4,000 per year.

Table 9. Analysis of transition to alternatives for dates treated with
methyl bromide

	 	Methyl Bromide	Sulfuryl Fluoride

1	Cubic meters to be treated (CUE request) 	44,241	44,241

2	Total gas needed for fumigation (kgs) 1	1,063	1,417

3	Price of fumigant gas ($ / kg)	$           20.94 	$           12.35 

4	Total cost of fumigant gas ($)	$         22,263 	$         17,498 

5	Cost difference between MeBr and alternative	 	$         (4,765)

6	Cost difference as % of gross revenue (from Table 8)	 	0.01%



1 Assumes rate of 1.5 lbs / mcf [24 kgs / tcm] for methyl bromide, 2 lbs
/ mcf [32 kgs / tcm] for sulfuryl fluoride



Citations

Barakat, D. A., D. Klementz, and C.  HYPERLINK
"http://mbao.org/2009/061Reichmuth.pdf" Reichmuth,.  2009.  Response of
Eggs of Corcyra cephalonica towards Sulfuryl Fluoride .  Presentation at
2009 MBAO, Nov. 10-12, 2009, San Diego, CA.  Available online at: 
HYPERLINK "http://mbao.org/2009/061Reichmuth.pdf"
http://mbao.org/2009/061Reichmuth.pdf . 

Hosoda, Ed.  2009.  California ProFume Update, 2009. Presentation at
2009 MBAO, Nov. 10-12, 2009, San Diego, CA.  Available online at:  
HYPERLINK "http://mbao.org/2009/069Hosada.pdf" 
http://mbao.org/2009/069Hosada.pdf . 

Hosoda, Ed.  2008.  Eco2Fume® and VaporPH3OS®.  Presentation at 2008
MBAO, Nov. 11-14, 2008, Orlando, Fl.  Available at:  HYPERLINK
"http://mbao.org/2008/125Hosoda.pdf" http://mbao.org/2008/125Hosoda.pdf 


 HYPERLINK "http://mbao.org/2009/064Muhareb.pdf" Muhareb, Jeannette. 
2009.  Evaluation of Combining Sulfuryl Fluoride, Propylene Oxide & CO2
for Stored Product Insect Control .  Presentation at 2009 MBAO, Nov.
10-12, 2009, San Diego, CA.  Available online at:   HYPERLINK
"http://mbao.org/2009/064Muhareb.pdf" 
http://mbao.org/2009/064Muhareb.pdf . 

Russo, C., Green, R.D. & Howitt, R.E.  “Estimation of Supply and
Demand Elasticities of California Commodities”. Department of
Agricultural and Resource Economics University of California, Davis,
Working Paper No. 08-001, June 2008.

 HYPERLINK "http://mbao.org/2009/060Walse.pdf" Walse, Spencer, J.G.
Leesch, and S. Tebbets.  2009.  Ovicidal Efficacy of Sulfuryl Fluoride
to Stored-Product Pests of Dried Fruits .  USDA/ARS, San Joaquin Valley
Agricultural Sciences Center, Parlier, CA 93648.  Presentation at 2009
MBAO, Nov. 10-12, 2009, San Diego, CA.  Available online at:   HYPERLINK
"http://mbao.org/2009/060Walse.pdf" http://mbao.org/2009/060Walse.pdf . 

 HYPERLINK "http://mbao.org/2009/063Williams.pdf" Williams, Robert. 
2009.  Control of Carob Moth (Ectomyelosis ceratonia) in Fresh Dates
Fumigated with ProFume® .  Presentation at 2009 MBAO, Nov. 10-12, 2009,
San Diego, CA.  Available online at:   HYPERLINK
"http://mbao.org/2009/063Williams.pdf" 
http://mbao.org/2009/063Williams.pdf .  

Williams, R. and E. Thoms.  2008.  ProFume® gas fumigant update:
post-harvest commercial acceptance and performance in North America. 
Presentation at 2008 MBAO, Nov. 11-14, 2008, Orlando, Fl.  Available at:
 HYPERLINK "http://mbao.org/2008/084Thoms.pdf"
http://mbao.org/2008/084Thoms.pdf  

 On average, approximately 39,000 metric tons are sold in-shell out of
345,000 metric tons total production.  (USDA NASS, 2005-2009)

  PAGE  9  

USA CUN13 POST HARVEST COMMODITIES

