METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

POST-HARVEST USE TREATMENT OF STRUCTURES – FOOD PROCESSING PLANTS

Nominating Party: The United States of America

FILE NAME: USA CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS

Brief descriptive Title of Nomination:

Methyl Bromide Critical Use Nomination for Post Harvest Use on
Structures -- Food Processing Plants (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	25,334 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 2658	

	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) 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:	 HYPERLINK "mailto:Housenger.Jack@epa.gov"
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 STRUCTURES - FOOD PROCESSING PLANTS















* Identical to paper documents



METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

POST-HARVEST USE TREATMENT OF STRUCTURES – FOOD PROCESSING PLANTS

1.  SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL 

Food processing facilities in the United States have reduced the number
of methyl bromide fumigations by incorporating a variety of different
techniques to control pests.  The most critical strategy implemented is
IPM, especially sanitation, and equipment design modifications to enable
cleaning and inspection in all areas of a facility.  Facilities are
being monitored for pest populations, using visual inspections,
pheromone traps, light traps, and electrocution traps.  When insect
pests are found, facilities will attempt to contain the infestation with
treatments of low volatility pesticides applied to both surfaces and
cracks and crevices; spot treatments with heat or phosphine will be used
in areas that are suitable.  Incoming ingredients are inspected for
insect pests and may be treated with phosphine if temperature and time
are sufficient, or contaminated ingredients may be rejected.  These
techniques do not disinfest a facility but are critical in monitoring
and managing pests, and preventing pest outbreaks.  However, when all
these methods fail to control a pest problem, facilities must still rely
on fumigation, to kill insects in the processing equipment, bins,
storage spaces and even the walls of the structure.  There are two
primary chemical fumigants available to this industry that may
accomplish these tasks: methyl bromide and sulfuryl fluoride.  Heat, a
non-chemical option, is also used in this industry to disinfest
facilities.  

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

Sulfuryl fluoride, as ProFume®, remains registered in the US for the
uses described in this nomination chapter.  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 nomination is for facilities, or portions of facilities, that are
unsuitable for the alternatives, or where the alternatives are not
economically feasible.  Sulfuryl fluoride is highly dependent upon
temperature, so should a facility need fumigation during cold
temperatures, this chemical may not be a cost-effective solution. 
Sulfuryl fluoride requires higher dosages for egg kill, a paramount
concern in certain facilities.  Phosphine can be explosive and is
corrosive to many metals that are present in facilities, especially in
the computers and other electronic process control instrumentation. 
Heat is dependent on several parameters: the structural composition, as
different components expand and contract at different rates; the
building design/layout factors, which affect the ability to evenly
distribute heated air; and the availability of convenient and economical
sources of heat.  In addition, heat may not be a viable option for
treatment of food products or commodities (i.e. rancidity of edible
oils).  

In addition, there is some confusion as to the materials that may be
directly fumigated with sulfuryl fluoride.  According to the Profume®
label pet food is not listed as a material approved for direct
treatment.  The intention of the label is to have as much product
removed as possible prior to fumigation.  This “incidental”
fumigation has resulted in problems with label interpretation.  Some
companies insist that all pet food products would need to be removed
from treatment areas or sufficiently protected to prevent the formation
of sulfuryl fluoride residues on the pet food products.  This is also a
factor for mills that produce mixes (e.g. cake mixes, muffin mixes,
etc.).  

Millers have reported that tarping off-sulfuryl fluoride label
ingredients and product is not practical because there could be dozens
of ingredients in the facility.  The ingredients and products that
cannot be treated would have to be staged together in an open area in
order to be covered with a tarp.  The industry claims that there is not
sufficient unused space in which to stage unlabeled ingredients and
product during a sulfuryl fluoride fumigation.

The industry reports that complete removal of non-sulfuryl fluoride
treatable ingredients and product from the target facility would present
significant logistical challenges, including multiple forklifts and
forklift drivers, plus rented truck trailers onto which the ingredients
could be loaded.  These trailers would then be removed from the
facility, most likely to available space in the parking lot.  A process
that would add labor and trailer rental costs as well as costs
associated with additional downtime needed to accomplish the ingredient
removal task.  

Heat is an alternative that may be used in some facilities.  In
addition, heat may be used in conjunction with sulfuryl fluoride. 
However, facilities constructed primarily from wood, about 25 percent of
the flour mills in the U.S., may not be able to use heat because of
warping of the wood.  There is also a high initial investment to
purchase heaters, modify sprinkler systems, and educate personal on heat
treatments.  

USG is requesting methyl bromide for this sector to allow time for the
industry to purchase equipment, modify structures, and/or practice using
alternatives.  The current registration of sulfuryl fluoride, as
ProFume®, remains unchanged in the US for the uses 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.  RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES

Fumigants

The 2010 MBAO presentations included reports of several structural
alternatives to methyl bromide.  One of those was by Horn (Horn, et al.
2010) regarding the use of Fosfoquim in structures.  To manage corrosion
they took multiple steps, including: using phosphine without ammonia;
used constant low concentrations of phosphine; painted exposed metals
(i.e. copper and its alloys); and wrapped electronic equipment in
plastics and injected fresh air.  The results presented by Horn (2010)
showed that efficacious levels of phosphine were maintained with their
diluphos system.  

Hartzer, et al. (2010) compared methyl bromide, sulfuryl fluoride, and
heat treatments in the Kansas State University flour mill.  The efficacy
results of the sulfuryl fluoride and methyl bromide treatments were not
significantly different.  However, the heat treatments were not as
efficacious, having some adult and larval survival (Hartzer, et al.,
2010).  

Arthur, et al. (2010) summarized the residual efficacy of pyrethrin plus
insect growth regulators aerosols on red and confused flour beetles. 
Confused flour beetles were less susceptible to the aerosols than were
red flour beetles.  The aerosol mixtures provided residual control, up
to 16 weeks, for the 3% pyrethrin plus methoprene.  Surface composition
also affected the variation of residual control of the mixtures.  The
researchers found that plastic overwrap provided longer control than did
paper bags.  (Arthur, et al., 2010)

Holcomb and McLean (2010) reported on an IPM approach in pet food
processing plants and warehouses.  The authors have had success in
controlling pests in these facilities for over 5 years.  They ensure
outside sanitation around plants and warehouses.  They also try to
reduce introducing pests by inspecting incoming ingredients and goods to
ensure they are “clean;” maintaining screens at windows and doors;
and placing lights so that insects are not attracted to openings. 
Microsanitation and pest control access are stressed in Holcomb and
McLean’s (2010) IPM approach.  Holcomb mentioned during his MBAO
(2010) presentation that companies need to hire a sanitation team to
ensure that the facility and all equipment could be thoroughly cleaned
every 30 days to break the life cycle of stored product pests (which is
typically about 45 days).  (Holcomb and McLean, 2010)

  ECONOMIC IMPACTS

Table 3.  Economic Summary for each Alternative

Methyl Bromide Alternative	Economic Summary

Heat Treatment	For most facilities, i.e., those not constructed
primarily of wood, it is feasible to switch to heat treatments.  Some
facilities experience better insect control with heat than fumigation
due to leaky structures that allow gas to escape.  

Sulfuryl Fluoride	Sulfuryl fluoride is an economically viable option for
most food processing facilities.  Exceptions include facilities that
manufacture products not on the ProFume® label, e.g. cake mixes, pet
food facilities.



Two economic analyses are conducted – one for pet food facilities and
one for other food processing facilities.  Pet food facilities are
conducted separately because the industry supplied its own revenue data.
 For other facilities, the only available data was a budget for a
500,000 cubic foot flour mill.

	

Sulfuryl fluoride is technically feasible only in facilities that do not
prepare mixed products (e.g., cake mixes) due to labeling.

Pet Food Facilities

Table 4. Analysis of transition to alternatives for pet food facilities
1

 	Methyl Bromide	Heat	Heat (after initial investment)

Size of facility to be treated (cu m)	28,317	28,317	28,317

Total Revenues/Sales	 $  40,600,000 	 $  40,600,000 	 $  40,600,000 

Cost of Disinfestation 	 $         37,200 	 $         55,600 	 $        
30,700 

Change in cost from MeBr to alternative	 	 $         18,358 	 $        
(6,551)

% change in gross revenue from MeBr	 	0.05%	-0.02%



1 Numbers may not add due to rounding; all figures are rounded to the
nearest hundred. 

2 Revenues from CUE application, based on value of average daily
production ($116,000) times 350 operating days per year.

3 Disinfestation costs for methyl bromide based on figures from Adam et
al. (2010), adjusted for changes in price of gas.  Analysis assumes two
fumigations per year for MeBr and three treatments per year of heat. 
Assumes gas price of $20.94 per kg and application rates of 24 kgs / tcm
for methyl bromide.         

4 Heat disinfestation costs came from TempAir.  The first heat column
assumes the facility is in an initial ten year investment phase when it
is paying for the heaters and the cost of energy and materials for
fumigation.  Initial cost of heaters for a 14,158 cubic meter facility
is approximately $249,000, or $14,900 spread over ten years.  The cost
of energy and materials for each fumigation of a 28,317 cubic meter
facility is approximately $10,229 after the initial investment period in
the heaters.



Mills and Other Food Processing Facilities

Revenue and cost data were available for a 14,158 cubic meter (500,000
cubic foot) flour mill.  Table 5 displays the economic analysis of
transition to sulfuryl fluoride and heat from methyl bromide.  

Table 5. Analysis of transition to alternatives for mills and other food
processors 1

 	Methyl Bromide	Sulfuryl Fluoride	Heat	Heat 

(after initial investment)

Size of facility to be treated (cu m)	14,158	14,158	14,158	14,158

Total Revenues/Sales 2	 $  32,835,700 	 $  32,835,700 	 $  32,835,700 	
$  32,835,700 

Operating Costs 	 $  28,281,000 	 $  28,281,300 	 $  28,287,100 	 $ 
28,274,600 

Mfg and Sales Costs	 $    1,537,300 	 $    1,537,600 	 $    1,543,400 	
$    1,530,900 

Disinfestation 3, 4	 $         23,000 	 $         23,300 	 $        
29,100 	 $         16,600 

Cost of Goods Sold	 $ 26,743,700 	 $  26,743,700 	 $  26,743,700 	 $ 
26,743,700 

Net Revenue	 $    4,554,700 	 $    4,554,400 	 $    4,548,600 	 $   
4,561,100 

Change in cost from MeBr to alternative	 	 $              300 	 $      
    6,100	 $        (6,400)

% change in net revenue from MeBr	 	-0.01%	-0.13%	0.14%



1 Numbers may not add due to rounding; all figures are rounded to the
nearest hundred. 

2 Revenues based on total cwt shipped of 2,450,000; Budget from Kenkel
and Holcomb (2010), 10-year avg, rounded to nearest hundred.

3 Disinfestation costs for methyl bromide and sulfuryl fluoride based on
figures from Adam et al. (2010), adjusted for changes in price of gas
and size of facility.  Analysis assumes two fumigations per year for
both MeBr and SF and three treatments per year of heat.  Assumes gas
price of $20.94 per kg and application rates of 24 kgs / tcm for methyl
bromide; $13.23 per kg 32 kgs / tcm for sulfuryl fluoride.         

4 Heat disinfestation costs came from TempAir.  The first heat column
assumes the facility is in an initial ten year investment phase when it
is paying for the heaters and the cost of energy and materials for
fumigation.  Initial cost of heaters for a 14,158 cubic meter facility
is approximately $125,000, or $12,500 spread over ten years.  The cost
of energy and materials for each fumigation of a 14,158 cubic meter
facility is approximately $5,531 after the initial investment period in
the heaters. 



CITATIONS:  

Brijwani, M., B.Subramanyam, M. Hartzer, D. E. Maier, W. Chayaprasert,
S. Savoldelli, P. Flinn, and J. Campbell.  2009.  Efficacy of structural
heat treatments against Tribolium castaneum life stages.  Presentation
at Methyl Bromide Alternatives Outlook Conference, San Diego, November
2009.  Available at:    HYPERLINK "http://mbao.org/2009/066Brijwani.pdf"
 http://mbao.org/2009/066Brijwani.pdf .   

Arthur, F. H., A. E. Sutton, K. Y. Zhu, and J. F. Campbell.  2010. 
Residual efficacy of pyrethrin-methoprene aerosols on packaging
surfaces.  Presentation at MBAO, Nov. 2-5, 2010, Orlando, Fl.  Available
at:  HYPERLINK "http://mbao.org/2010/64Arthur.pdf"
http://mbao.org/2010/64Arthur.pdf . 

Hartzer, M. Subramanyam, B., Brijwani, M., Chayaprasert, W., and Maier,
D. E.  2010.  Methyl bromide, sulfuryl fluoride and heat: effectiveness
against red flour beetle.  Presentation at MBAO, Nov. 2-5, 2010,
Orlando, Fl.  Available at:  HYPERLINK
"http://mbao.org/2010/67Hartzer.pdf" http://mbao.org/2010/67Hartzer.pdf
. 

Hartzer, M., B. Subramanyam, W. Chayaprasert, D. E. Maier, and S.
Savoldelli.  2009.  Methyl Bromide and Sulfuryl Fluoride Effectiveness
Against Red Flour Beetle Life Stages.  Presentation at Methyl Bromide
Alternatives Outlook Conference, San Diego, November 2009.  Available
at:    HYPERLINK "http://mbao.org/2009/072Hartzer.pdf" 
http://mbao.org/2009/072Hartzer.pdf .   

Holcomb, M. and M. McLean.  2010.  An IPM approach to methyl bromide
replacement: in pet food processing plants and warehouses.  Presentation
at MBAO, Nov. 2-5, 2010, Orlando, Fl.  Available at:  HYPERLINK
"http://mbao.org/2010/65Holcomb.pdf" http://mbao.org/2010/65Holcomb.pdf
.  

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