UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Qualitative
Assessment
of
the
Impact
of
Changes
in
the
Use
of
Methyl
Bromide
on
Non­
Quarantine
Commodities
in
Support
of
the
Reregistration
Eligibility
Decision
(
RED)

FROM:
Jonathan
Becker,
Senior
Science
Advisor
William
Chism,
Senior
Agronomist
Colwell
Cook,
Biologist
Monisha
Kaul,
Biologist
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503P)

David
Donaldson,
Economist
Elisa
Rim,
Economist
T
J
Wyatt,
Agricultural
Economist
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503P)

THRU:
Arnet
Jones,
Chief,
Biological
Analysis
Branch
Istanbul
Yusuf,
Acting
Chief,
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503P)

TO:
John
Leahy,
Senior
Policy
Analyst
Eric
Olson,
Team
Leader
Steven
Weiss,
Chemical
Review
Manager
Special
Review
and
Registration
Division
(
7508P)

PRODUCT
REVIEW
PANEL
DATE:
July
26,
2006
2
SUMMARY
As
part
of
the
reregistration
of
methyl
bromide,
the
Biological
and
Economic
Analysis
Division
(
BEAD)
assessed
the
potential
impacts
of
risk
mitigation
and
enforcement/
compliance
options.
These
options
were
outlined
in
the
EPA
Federal
Register
Notice
of
March
29,
2006.
This
document
addresses
the
potential
impacts
to
fumigations
of
non­
quarantine
commodities,
except
for
dry­
cured
pork.
Other
assessments
address
the
impacts
on
quarantine
uses,
dry­
cured
pork
and
structural
and
food
processing
facilities
uses.

BEAD
does
not
expect
substantial
impacts
to
result
from
lowering
the
air
concentration
limit
of
occupation
exposure
from
five
(
5)
ppm
as
a
ceiling
limit
to
one
(
1)
ppm
as
a
8­
hour
TWA,
provided
facilities
have
the
option
to
utilize
air
purifying
respirators
to
protect
employees
when
air
concentrations
are
between
these
points.
BEAD
also
does
not
expect
substantial
impacts
if
EPA
were
to
require
FMPs
and
other
actions
that
focus
on
compliance
and/
or
enforcement.

It
appears
that
by
using
active
aeration
most
commodity
chambers
would
be
able
to
accommodate
aeration
buffers.
This
conclusion
is
based
on
the
assumption
that
the
99
percentile
whole
field
buffer
is
used
for
the
regulatory
decision
making.
Further,
if
these
facilities
are
located
in
rural
areas
and
do
not
have
employees
working
other
processes
during
fumigation,
treatment
buffers
are
likely
to
be
feasible
as
well,
except
for
large
enclosures
or
high
rates.

There
are
some
facilities
that
will
need
to
modify
their
current
practices
to
meet
these
proposed
buffer
requirements.
There
are
several
ways
to
meet
these
requirements;
for
example,
site
specific
modeling
can
be
used
by
the
facilities
to
select
methods
to
implement
that
would
result
in
the
reduction
of
buffers.
In
most
cases,
facilities
could
potentially
achieve
the
greatest
buffer
reduction
by
using
a
combination
of
methods.
Treatment
buffers
may
be
reduced
by
methods
such
as
improved
gas
retention,
lower
rates
or
treating
smaller
volumes
of
commodities.
Aeration
buffers
may
be
reduced
by
methods
such
as
improved
ventilation
systems
(
greater
air
exchanges
per
minute,
taller
stacks),
lower
rates,
treating
smaller
volumes,
or
installing
a
capture
and
destruction
system.
BEAD
anticipates
that
using
a
combination
of
these
mitigation
options
most
facilities
will
be
able
to
meet
the
buffer
requirements.
However,
these
changes
will
entail
some
costs.

However,
if
commodity
facilities
cannot
meet
the
buffer
requirements,
even
with
the
adoption
of
additional
equipment,
they
would
not
be
able
to
use
methyl
bromide.
Since
2005,
use
of
methyl
bromide
is
only
permitted
under
the
Montreal
Protocol
for
certain
uses,
including
those
that
have
been
designated
as
a
critical
need.
EPA
and
USDA
have
evaluated
exemption
requests
and
found
that
there
are
no
technically
and
economically
feasible
alternatives
to
the
use
of
methyl
bromide
in
this
sector
(
USA,
2006a,
2006b).
Therefore,
if
buffers
are
infeasible,
some
facilities
may
have
to
cease
operation.
This
may
impact
producers
and
consumers,
as
well
as
the
local
economy.
BEAD
does
not
have
adequate
data
about
the
specific
site
characteristics
of
these
facilities
to
quantify
the
distribution
and
magnitude
of
these
impacts.
However,
BEAD
anticipates
that
by
using
a
combination
of
mitigation
options
most
facilities
will
be
able
to
meet
the
buffer
requirements.
.
3
BACKGROUND
Methyl
bromide
is
an
odorless,
colorless
gas
that
is
widely
used
as
a
soil
and
structural
fumigant
to
control
a
range
of
insect,
fungal
and
weed
pests.
Under
the
Food
Quality
Protection
Act,
the
Office
of
Pesticide
Programs
(
OPP)
is
presently
making
a
determination
of
methyl
bromide's
eligibility
for
reregistration.
In
this
process,
OPP
is
assessing
the
risks
and
benefits
of
methyl
bromide
use
to
control
pests
in
various
commodities.
This
document
addresses
non­
quarantine
commodity
treatments.

The
Montreal
Protocol
on
Ozone
Depleting
Substances
Methyl
Bromide
has
been
identified
as
an
ozone
depleting
substance
under
the
Montreal
Protocol
on
Ozone
Depleting
Substances
to
which
the
United
States
is
a
party.
The
Montreal
Protocol
is
an
international
treaty
developed
to
protect
the
earth
from
the
detrimental
effects
of
ozone
stratospheric
depletion.
Initially
signed
in
1987
by
the
United
States
and
26
other
countries,
there
are
now
189
signatories
to
the
treaty.
The
Parties
to
the
Montreal
Protocol
have
agreed
to
specific
reduction
steps
that
lead
to
the
phaseout
of
production
and
use
of
ozonedepleting
substances,
including
methyl
bromide.
The
Protocol
required
an
incremental
reduction
in
methyl
bromide,
leading
to
a
complete
phase
out,
in
industrialized
nations,
by
January
1,
2005.
Developing
countries
are
to
phase
out
use
by
January
1,
2015.

However,
there
are
some
cases
where
there
are
no
available
alternatives
that
are
technically
and
economically
feasible
and
acceptable
from
a
public
health
standpoint.
The
treaty
allows
for
exemptions
to
the
phase
out
for
critical
uses,
quarantine
and
preshipment
uses,
and
emergency
uses.
Critical
uses
are
those
situations
where
there
are
no
technically
and
economically
feasible
alternatives
and
market
disruptions
would
occur
if
methyl
bromide
were
not
available.
They
are
reviewed
in
EPA's
Methyl
Bromide
Critical
Use
Exemption
(
CUE)
process.
Quarantine
and
preshipment
uses
of
methyl
bromide
are
often
required
by
national
and
international
law
to
prevent
the
introduction
of
exotic
pests
into
new
areas.
Unanticipated
emergency
use
of
methyl
bromide,
for
example
to
address
public
health
problems,
is
authorized
by
the
Montreal
Protocol,
if
there
are
no
technically
and
economically
feasible
alternatives
and
the
quantity
used
does
not
exceed
20
metric
tons.

The
uses
addressed
in
this
document
have
received
critical
use
exemptions
under
the
Montreal
Protocol
for
the
years
2005,
2006,
and
2007.
A
critical
use
exemption
for
2008
is
currently
being
evaluated
by
the
Parties
to
the
Montreal
Protocol.
These
represent
situations
of
severe
or
unique
pest
problems
for
which
the
available
alternatives
are
not
feasible
and
will
result
in
severe
market
disruptions
if
methyl
bromide
is
not
available.

Parties
to
the
Montreal
Protocol
approve
an
amount
of
methyl
bromide
for
post­
harvest
and
soil
use;
that
amount
is
the
maximum
amount
that
can
be
newly
produced
methyl
bromide
or
used
from
critical
use
stockpiles.
Entities
that
are
users
of
"
critical
use"
methyl
bromide
do
not
have
access
to
the
general
use
methyl
bromide
stockpiles
(
i.
e.,
those
methyl
bromide
stocks
generated
before
January
1,
2005.
This,
therefore,
sets
an
upper
limit
on
the
amount
of
methyl
bromide
that
is
allocated
to
the
post­
harvest
sector
and
can
be
used
for
non­
quarantine
commodities,
and
consequently,
on
the
total
volume
that
can
be
fumigated
in
any
one
year
period.
4
Risks
of
Concern
As
part
of
OPP's
determination
of
methyl
bromide's
eligibility
for
reregistration,
OPP
conducted
risk
assessments
for
methyl
bromide
use
in
enclosures,
chambers,
and
food
processing/
storage
facilities.
There
are
no
aggregate
dietary
and
water
risks
of
concern.
However,
there
are
risks
of
concern
associated
with
the
use
of
methyl
bromide
for
occupational
exposure
during
both
treatment
and
aeration
and
for
bystanders
during
aeration
(
EPA
2006).
Occupational
exposure
may
occur
to
fumigant
applicators
during
and
immediately
after
treatment
and
to
certain
employees
at
the
treated
sites,
especially
those
handling
treated
commodities.
Bystanders
refer
to
site
employees
and
people
unaffiliated
with
the
treated
site
who
are
present
in
the
general
vicinity.
EPA's
Office
of
Air
and
Radiation
has
also
assessed
the
potential
impacts
on
the
incidents
of
skin
cancer
due
to
stratospheric
ozone
depletion
caused
by
the
use
of
methyl
bromide
for
non­
soil
fumigations.

OPP
is
evaluating
various
means
of
managing
the
risks
of
concern
from
occupational
and
bystander
exposure.
In
determining
an
appropriate
risk
management
strategy,
OPP
considers
a
number
of
factors
including
efficacy
of
the
measures,
enforceability,
the
impact
on
users
of
methyl
bromide
and
the
qualitative
extent
to
which
these
measures
can
also
contribute
to
reduction
in
ozone
depletion.
This
document
presents
OPP's
evaluation
of
various
riskreduction
strategies
according
to
these
factors.
However,
because
of
the
great
diversity
in
sites
being
treated
with
methyl
bromide,
OPP
has
limited
ability
to
make
quantitative
evaluations.

RISK
MANAGEMENT
STRATEGIES
Bystander
and
Occupational
Exposure
During
Treatment
and
Aeration
Broadly
speaking,
there
are
three
risk
management
strategies
for
addressing
bystander
risk
to
be
considered.
Within
these
broad
strategies
some
or
all
of
the
17
different
options
(
EPA
2006)
suggested
by
EPA
for
public
comment
may
be
included.
The
broad
strategies
are
adoption
of
a
performance
standard,
command
and
control,
and
a
hybrid
approach
that
sets
certain
minimum
requirements
but
permits
flexibility
to
accommodate
site­
specific
characteristics.
EPA
believes
the
third
option
best
addresses
all
the
factors
to
be
considered.

Performance
Standard:
EPA
sets
maximum
air
concentrations
at
reference
points;
sets
criteria
for
determining
reference
point;
sets
criteria
for
monitoring;
establishes
penalties
for
exceedences.

Under
this
approach,
EPA
would
establish
performance
standards
to
limit
exposure
to
methyl
bromide
during
treatment
and
during
post­
treatment
aeration.
Essentially,
this
would
entail
defining
how
appropriate
reference
points
(
potential
bystanders)
would
be
chosen,
setting
a
maximum
air
concentration
at
those
reference
points,
and
establishing
criteria
for
monitoring
at
the
reference
points.
Fumigators
would
be
responsible,
via
whatever
means
available,
including
those
suggested
by
EPA
(
EPA
2006),
to
insure
that
air
concentrations
of
methyl
bromide
do
not
exceed
limits.
EPA
would
also
establish
methods
to
ensure
compliance.
5
The
main
advantage
of
this
strategy
is
that
it
provides
maximum
flexibility
to
methyl
bromide
users
to
meet
the
safety
standard
and,
therefore,
minimizes
the
impacts
on
the
regulated
community.
That,
in
turn,
means
that
it
would
have
the
least
impact
of
the
three
options
on
the
total
amount
of
methyl
bromide
used
and
released
into
the
atmosphere.

The
primary
disadvantage
of
this
strategy
is
the
basic
question
of
whether
it
can
be
implemented
effectively.
Unless
the
number
and
location
of
bystanders
is
limited
and
well­
defined,
extensive
monitoring
both
horizontally
and
vertically,
around
the
treated
facility,
would
be
necessary
to
insure
that
the
statutory
requirement
of
reasonable
certainty
of
no
harm
is
met.
Further,
because
compliance
would
depend
on
post­
treatment
penalties
for
exceedances,
the
reporting
and
oversight
requirements
on
the
fumigator
and
state
and
local
regulators
would
be
burdensome.

EPA
does
not
believe
a
pure
performance
standard
can
be
reliably
implemented
in
a
costeffective
manner.

Single
Approach:
Buffer
Zones:
The
second
strategy
represents
the
opposite
end
of
the
spectrum,
where
EPA
would
establish
a
command
and
control
strategy
to
encompass
all
sites.
The
most
likely
option
for
addressing
bystander
risk
would
be
to
require
treatment
and
aeration
buffer
zones
that
would
be
dependent
on
the
amount
of
methyl
bromide
used
in
a
24­
hour
period
that
would
result
in
a
reasonable
certainty
of
no
harm
for
all
possible
fumigation
scenarios.
To
account
for
all
situations,
the
buffer
zone
would
have
to
be
substantial.

This
strategy
would
be
relatively
easy
to
enforce
because
it
would
depend
on
so
few
factors.
With
minimal
effort
by
EPA
and
State
and
local
regulators,
EPA
could
also
be
assured
that
all
use
of
methyl
bromide
would
meet
the
statutory
safety
requirement
 
in
fact,
most
uses
would
substantially
surpass
what
would
be
necessary
to
meet
the
requirements.
This
strategy
would
also
result
in
the
greatest
decrease
in
the
total
amount
of
methyl
bromide
used
and
released
into
the
atmosphere
of
the
three
strategies
because
many
facilities
would
be
unable
to
comply
with
a
large
buffer
zone
and
would
have
to
use
alternative
pest
control
methods
or
cease
operation.

However,
the
inability
of
many
facilities
to
comply
with
this
strategy
would
lead
to
large
impacts
on
methyl
bromide
users.
As
explained
in
this
document
and
the
U.
S.
nomination
of
critical
use
exemptions
to
the
Montreal
Protocol,
use
of
methyl
bromide
remains
necessary
in
many
situations.
Without
methyl
bromide,
there
would
be
serious
disruptions
in
global
and
interstate
trade
and
many
items
would
be
unable
to
meet
federal
health
requirements
for
safe
and
unadulterated
food
products.
Consumers
could
face
substantially
higher
costs
for
goods
and
some
goods
would
probably
not
be
available
year
around.

EPA
does
not
believe
such
a
simplistic
strategy
would
be
a
cost­
effective
means
of
insuring
the
safe
use
of
methyl
bromide.

Flexible
Approach:
Buffer
Zones
as
a
Function
of
Other
Mitigation
Actions:
The
third
strategy
combines
the
flexibility
of
the
performance
standard
with
the
relative
simplicity
of
clear,
minimum
standards.
Some
of
the
options
suggested
by
EPA
(
EPA
2006)
could
be
used
in
concert
to
achieve
the
statutory
human
health
requirement.
The
basic
requirement
would
be
for
a
buffer
zone,
but
the
size
of
the
buffer
would
depend
on
the
use
of
other
risk
management
6
options.
EPA's
concept
is
for
two
buffers:
a
treatment
buffer
during
fumigation
and
an
aeration
buffer
following
treatment
as
the
gas
is
vented.
The
size
of
each
buffer
would
be
positively
related
to
the
amount
or
rate
of
methyl
bromide
used
and
the
size
of
the
facility/
enclosure
fumigated.
Reductions
in
any
would
permit
a
smaller
required
buffer.
The
size
of
the
treatment
buffer
would
be
negatively
related
to
the
retention
of
gas
in
the
fumigated
enclosure.
The
tighter
the
enclosure,
the
less
gas
would
escape
and
the
smaller
the
treatment
buffer.
The
size
of
the
aeration
buffer
would
be
negatively
related
to
the
relative
height
of
the
point
methyl
bromide
is
vented
(
a
stack)
and
the
speed
of
aeration
(
i.
e.,
as
defined
by
air
exchange
rate),
which
improves
mixing
and
reduces
air
concentrations.
Increases
in
either
of
these
factors
would
permit
a
smaller
buffer
for
bystanders.
The
air
exchange
rate
can
also
be
manipulated
instead.

As
with
the
first
possible
strategy,
this
approach
can
reduce
the
cost
of
complying
with
the
regulation
by
providing
different
facilities
the
ability
to
reduce
bystander
exposure
according
to
the
specific
characteristics
of
the
site.
The
clear,
minimum
requirements
make
it
relatively
easy
to
enforce
and
insure
that
the
safety
standards
will
be
achieved.
Some
reductions
in
the
total
amount
of
methyl
bromide
will
likely
occur,
contributing
to
reductions
in
ozone
depletions.

The
strategy
will
entail,
however,
some
costs
to
the
regulated
community
and
to
consumers
of
treated
commodities.
Some
facilities
may
have
to
alter
their
fumigation
practices
or
invest
in
mitigation
measures.
Despite
its
relative
flexibility,
some
facilities
may
not
be
able
to
meet
the
requirements
with
the
use
of
methyl
bromide.
They
will
be
obligated
to
use
other
pest
control
measures
or
will
be
unable
to
operate.
Some
of
these
impacts
will
be
passed
on
to
consumers.
This
document
describes
in
more
detail
the
extent
of
EPA's
information
regarding
these
impacts.

Occupational
Exposure
Fumigators
and
employees
who
handle
treated
commodities
soon
after
treatment
may
also
be
exposed
to
levels
of
methyl
bromide
exceeding
EPA's
level
of
concern.
Current
practice
is
that
levels
of
methyl
bromide
are
monitored
and
if
concentrations
are
greater
than
five
(
5)
ppm,
respirators
must
be
worn.
Immediately
after
treatment,
enclosures
are
often
actively
aerated
to
lower
concentrations.
Treatment
buffers
may
also
be
enforced.

EPA's
current
plan
is
to
lower
the
permissible
concentration
limit
to
one
(
1)
ppm
(
8­
hr
TWA).
Levels
above
this
limit
will
require
the
use
of
respirators.
Use
of
respirators
may
be
burdensome
for
employees,
especially
in
hot
conditions,
but
should
not
otherwise
significantly
affect
applicators
or
the
operation
of
the
facilities
since
it
is
common
practice.
Facilities
would
have
the
option
of
increasing
aeration
time
to
avoid
the
use
of
respirators,
but
where
that
would
impinge
on
the
movement
of
commodities,
respirators
can
be
used.

Enforcement/
Compliance
Mechanisms
The
Agency
is
also
considering
several
mechanisms
to
aid
in
enforcement
and
compliance.
Chief
among
these
would
be
a
requirement
to
prepare
and
follow
a
Fumigation
Management
Plan.
The
FMP
would
detail
how
a
specific
fumigation
would
comply
with
the
label
restrictions,
including
the
establishment
of
buffer
zones
and
the
factors
that
determined
the
appropriate
size.
EPA
envisions
a
certification
scheme
to
ensure
that
the
FMP
conforms
to
the
label
requirements.
7
Currently,
most
fumigations
already
follow
some
kind
of
plan,
although
all
plans
would
now
have
to
brought
into
compliance
with
the
new
requirements
of
use.
Once
prepared
for
a
fixed
facility,
the
plan
may
need
few
modifications
for
repeated
fumigations.
Therefore,
BEAD
anticipates
few
impacts
on
applicators
or
facilities
in
preparing
the
FMP.
The
certification
of
the
FMP
may
entail
added
cost
to
the
fumigation,
but
BEAD
cannot
predict
that
cost.

Other
compliance
mechanisms
include
record
keeping
requirements
and
posting
notices
of
fumigation,
both
on
treated
commodities
and
to
the
general
public
prior
to
the
treatment
of
facilities
or
commodities.
Record
keeping
requirements
may
not
entail
substantial
added
costs,
since
most
fumigations
are
already
closely
monitored.
Notices
that
a
commodity
has
been
treated
should
also
not
impose
substantial
costs.

INDUSTRY
OVERVIEW
Since
2002,
EPA
has
reviewed
and
nominated
various
commodities
for
methyl
bromide
critical
use
exemption.
The
following
information
is
based
on
industry
applications
for
a
critical
use
exemptions
and
EPA
proprietary
data.

The
critical
use
exemption
commodities
include
walnuts,
dried
fruit
(
prunes,
raisins,
and
figs),
dates,
dried
beans
(
garbanzo
and
black­
eyed
peas),
and
pistachios
produced
and
fumigated
in
California.
These
industries
combined
generate
over
$
855
million
in
annual
sales
revenue.
The
commodities
treated
with
methyl
bromide
may
constitute
up
to
99%
of
market
share
in
the
U.
S.
and
up
to
70%
of
world
market
share.
Post
harvest
food
storage
is
an
integral
part
of
operations
because
in
many
cases
the
growing
season
is
separated
from
the
peak
demand
season.
Therefore
it
is
imperative
for
these
industries
to
fumigate
in
order
to
maintain
the
commodity's
integrity
and
quality.

Dried
Fruit:
California's
dried
fruit
industry
generates
annual
revenues
of
approximately
$
350
million
and
produces
99%
of
the
domestic
supply
of
prunes
(
dried
plums),
raisins
and
figs.
They
export
up
to
46%
of
production
and
ship
to
over
50
global
markets,
mainly
Europe
and
Japan.
California
produces
70%
of
the
global
supply
of
prunes,
40%
of
the
global
supply
of
raisins,
and
20%
of
the
global
supply
of
figs.
The
California
Dried
Plum
Board
represents
approximately
1,400
growers
and
21
packers.
The
average
business
generates
about
$
11
million
in
annual
sales
revenue
with
a
gross
margin
of
about
28%
and
a
net
profit
margin
of
about
5%.
Gross
margin
is
defined
as
gross
sales
revenue
less
cost
of
goods
sold
(
cost
of
raw
materials)
divided
by
gross
sales
revenue.
The
net
profit
margin
is
defined
as
gross
sales
revenue
less
total
expenditures
(
cost
of
goods
sold
plus
other
costs)
divided
by
gross
sales
revenue.

Walnuts:
California's
walnut
industry
generates
annual
sales
revenues
of
approximately
$
280
million
and
produces
almost
100%
of
the
domestic
supply
of
walnuts.
Nearly
25%
of
the
inshell
walnut
market
is
exported
to
Europe
for
the
Christmas
season.
The
representative
facility
generates
about
$
238
million
in
annual
sales
revenue
with
a
gross
margin
of
about
28%
and
a
net
profit
margin
of
about
5%.
8
Dates:
California's
date
industry
generates
annual
revenues
of
approximately
$
38
million
and
produces
95%
of
the
domestic
supply
of
dates.

Dried
Beans:
California's
dried
bean
industry
generates
annual
sales
revenues
of
approximately
$
7
million
and
produces
72%
of
the
domestic
supply
of
black­
eyed
peas
and
12%
of
the
domestic
supply
of
garbanzo
beans.

Pistachios:
California's
pistachio
industry
generates
annual
sales
revenues
of
approximately
$
180
million
and
produces
99%
of
the
domestic
supply
and
30%
of
the
global
supply
of
pistachios.
The
pistachio
industry
is
a
very
concentrated
market
with
few
processors
where
processors
both
grow
and
process
the
commodity.
The
representative
user
(
in
this
case
the
largest
producer
of
pistachios)
generates
about
$
150
million
in
annual
sales
revenue
with
a
gross
margin
of
about
43%
and
a
net
profit
margin
of
less
than
2%.

SITE
DESCRIPTION
Purpose
of
Fumigation
Commodities
are
fumigated
to
control
insect
pests
that
attack
foods
in
storage.
Some
of
the
key
pests
are
presented
in
Table
1.
Insects
cause
the
direct
loss
of
products
and
cosmetic
damage,
making
stored
food
unsightly
and
reducing
its
value.
The
insect
pests
also
contaminate
food
with
their
excrement,
body
parts,
and
exuviae,
which
violates
US
Food
and
Drug
Administration
regulations
(
FDA
regulations
can
be
found
at:
http://
www.
cfsan.
fda.
gov/~
dms/
dalbook.
html
and
http://
www.
fda.
gov/
opacom/
laws/
fdcact/
fdcact4.
htm).
In
addition
several
insect
pests
pose
health
hazards
either
because
they
can
cause
choking
in
small
children
or
because
they
can
cause
allergic
reactions.

TABLE
1:
SOME
KEY
PESTS
FOR
METHYL
BROMIDE
IN
COMMODITIES
Genus
and
Species
of
Major
Pests
Common
Name
Cydia
pomonella
Codling
Moth
Amyelois
transitella
Navel
Orangeworm
Plodia
interpunctella
Indianmeal
Moth
Tribolium
castaneum
Red
Flour
Beetle
Cadra
figulilella
Raisin
Moth
Carpophilus
sp.
Dried
Fruit
Beetle
Ectomyelois
ceratoniae
Carob
Pod
Moth
Carpophilus
spp.,
Haptoncus
spp.
Nitidulid
Beetles
Callosobruchus
maculates
Cowpea
Weevil
Source:
United
States
of
America,
2006a.

Use
and
Usage
of
Methyl
Bromide
Typically
methyl
bromide
is
being
used
to
treat
these
commodities
during
the
peak
production
season
when
time
is
critical.
Shortly
after
harvest
or
prior
to
processing,
the
commodity
is
treated
to
prevent
pests
from
infesting
and
degrading
it
in
storage
or
during
shipping.
The
available
time
for
treatment
can
be
compressed
when
harvest
occurs
close
to
key
market
9
windows,
such
as
holiday
markets
for
certain
types
of
dried
fruits,
nuts,
and
beans.
Methyl
bromide
is
the
only
suitable
fumigant,
when
time
is
critical,
because
it
is
effective
within
a
short
period
of
time,
unlike
other
control
measures
that
may
take
three
to
four
times
as
long.
(
United
States
of
America,
2006a,
2006b)

Commodities
in
the
United
States
may
be
fumigated
in
chambers,
containers,
bins,
or
under
tarps.
Some
commodities
are
fumigated
at
the
farm
locations;
however,
some
growers
ship
their
produce
to
a
processing
plant
that
will
fumigate
the
product
before
it
enters
their
facility.
Each
grower
or
processor
will
have
chambers
or
bins
built
to
his
own
specifications.
Farmers
with
small
acreage
will
invest
in
smaller
containers
or
have
companies
fumigate
their
produce
under
tarps.
Some
of
the
major
processors
will
invest
in
larger
chambers
in
order
to
process
multiple
shipments
in
a
short
amount
of
time.
In
addition,
walnuts
in
shells
are
typically
fumigated
in
vacuum
chambers
in
order
to
decrease
time
spent
in
fumigation
during
harvest.
Consequently,
there
is
no
standard
size
for
fumigation
enclosures.
Table
2
presents
the
range
of
sizes,
in
cubic
feet
of
fumigated
commodities.

TABLE
2.
COMMODITY
FUMIGATION
FACILITY
SIZE
Facility
Size
(
cubic
feet)

<
5,000
5,001
to
10,000
10,001
to
50,000
50,001
to
100,000
100,001
to
500,000
500,000
to
1
million
1
million
to
5
million
over
5
million
Site
Small
Medium
Large
Median
Treated
Volume
(
cubic
feet)

Dried
Fruit
23%
5%
9%
5%
49%
8%
1%
0%
200,000
Walnuts
28%
7%
25%
9%
23%
9%
0%
0%
130,000
Dried
Beans
16%
3%
34%
25%
22%
0%
0%
0%
70,000
Source:
Cal
DPR,
2002­
2004.
Cubic
feet
information
was
not
available
on
dates.

Average
rates
of
methyl
bromide
for
commodity
fumigations
range
from
1.25
pounds
of
methyl
bromide
per
1000
cubic
feet
to
3
pounds
per
1000
cubic
feet
(
Table
3).
Walnuts,
in
shells,
use
higher
rates
because
gas
must
penetrate
the
walnut
shell
in
order
to
control
codling
moth
larvae
within.
Dried
beans
also
use
slightly
higher
rates
to
control
insect
pests
that
will
penetrate
the
bean
to
feed
internally.
Other
commodities
tend
to
have
insect
pests
that
feed
primarily
on
the
surface
or
do
not
penetrate
very
deep
into
the
commodity.
Fumigations
typically
last
about
24
hours
but
if
the
fumigations
are
under
a
vacuum,
they
can
be
accomplished
in
3­
4
hours
of
exposure
plus
4
hours
of
aeration,
with
the
same
amount
of
methyl
bromide
(
United
States
of
America,
2006a,
2006b).

TABLE
3:
COMMODITIES
FUMIGATION
USE
INFORMATION
Commodity
Average
Rate
(
lb/
1000
cubic
ft)
Treatment
Time
(
hours)
Aeration
Time
(
hours)
Dried
Fruit
1.4
12­
24
12­
24
10
Walnuts
3.0
24
(
conventional)
3­
4
(
vacuum)
4
Dates
1.5
12­
24
12­
24
Dried
Beans
2.75
12
4
Cocoa
Beans
1.25
12­
24
12­
24
Source:
United
States
of
America,
2006a,
2006b.

Location
Most
of
the
commodities
considered
here
are
fumigated
on­
farm,
at
processing
facilities
and/
or
at
points
of
shipment
in
California.
Locations
include
relatively
rural
areas
and
urbanized
or
industrialized
zones.
In
addition
to
fumigation,
processing
and
shipping
facilities
will
have
many
other
activities
occurring
in
the
general
area.
The
variety
of
locations
makes
it
difficult
to
determine
the
maximum
buffer
zone
that
would
be
feasible.
Rural
or
on­
farm
locations
would
be
able
to
implement
larger
buffer
zones
than
urban
or
processing
facilities.

IMPACTS
OF
BUFFER
ZONES
IN
COMMODITIES
BEAD
examined
a
range
of
potential
chamber
sizes
and
use
rates
to
explore
the
potential
impacts
of
treatment
and
aeration
buffer
zone
requirements.
Specifically,
we
examine
chambers
of
5,000
cubic
feet,
50,000
cubic
feet,
100,000
cubic
feet
and
250,000
cubic
feet
with
treatments
of
1
to
3
or
4
lb
methyl
bromide
per
1,000
cubic
feet.
The
4­
lb
rate
is
somewhat
high,
but
treatment
buffers
have
not
yet
been
estimated
for
the
3­
lb
rate.

Little
site­
specific
information
is
available
for
the
location
of
fumigation
chambers,
consequently
it
is
very
difficult
to
determine
feasible
buffer
distances.
This
assessment
is,
by
necessity,
very
qualitative.
There
may
also
be
differing
capacity
to
enforce
a
buffer
zone
during
fumigation
(
treatment
buffer)
and
during
venting
(
aeration).

The
California
regulatory
system
requires
a
10­
foot
treatment
buffer
for
pressurized
or
vacuum
chambers.
For
other
enclosures,
the
facility
may
conduct
a
retention
test
or
assume
a
loss
rate
of
3%
of
the
application
rate
per
hour.
Therefore,
an
untested
enclosure
is
assumed
to
lose
about
36%
of
the
application
rate
over
a
12­
hour
period.
Treatment
buffers
are
then
determined
from
a
table
(
Cal
DPR,
1994).
At
a
rate
of
1
lb/
1,000
cu
ft
(
about
0.4
lb/
1,000
cu
ft
lost),
the
treatment
buffer
may
be
as
much
as
250
feet
for
a
250,000
cu
ft
enclosure.
At
a
rate
of
4
lb/
1,000
(
about
1.6
lb/
1,000
cu
ft
lost),
the
treatment
buffer
would
be
740
feet
for
a
250,000
cu
ft
enclosure.

The
California
aeration
buffer
depends
on
the
concentration
of
methyl
bromide
retained,
which
in
the
absence
of
testing
is
assumed
to
be
90%.
At
a
rate
of
1
lb/
1,000
cu
ft
(
retaining
0.9
lb/
1,000
cu
ft),
the
aeration
buffer
for
a
250,000
cu
ft
enclosure
would
be
almost
1,000
feet.
At
a
3­
lb
rate
(
retaining
about
2.8
lb/
1,000
cu
ft),
the
buffer
would
be
about
1,700
feet
for
a
250,000
cu
ft
enclosure.
These
buffers
assume
passive
aeration
without
a
stack.
With
active
aeration
and
a
minimal
exhaust
stack
(
15
feet),
the
buffers
could
be
reduced
to
about
600
feet
and
1,400
feet,
respectively.
However,
with
sufficiently
high
air
exchange,
even
with
a
minimal
stack,
the
aeration
buffer
can
be
reduced
to
only
10
feet.
11
Given
the
existing
California
requirements,
BEAD
assumes
that
most
facilities
could
impose
a
buffer
for
both
treatment
and
aeration
of
around
250
feet
(
roughly
half
a
city
block)
and
facilities
in
more
rural
areas
would
find
larger
buffers
feasible.

Calculated
Buffers
The
Agency
used
the
PERFUM
air
model
to
estimate
buffer
distances
(
EPA,
2006).
Two
buffers
were
calculated
 
a
treatment
buffer
(
which
accounts
for
the
amount
of
methyl
bromide
leaking
from
the
chamber
during
fumigation)
and
an
aeration
buffer
(
which
accounts
for
the
amount
of
methyl
bromide
vented
at
the
completion
of
the
treatment).

The
estimation
of
these
buffers
depend
on
a
number
of
input
parameters
to
the
model
such
as
atmospheric
conditions,
application
rate,
chamber/
enclosure
conditions
(
e.
g.,
gas­
tightness),
fumigated
volume,
the
use
of
stacks,
building
effects,
and
the
rate
and
type
of
aeration.
The
tables
of
buffer
distances
identify
the
various
combinations
of
these
input
factors.

The
PERFUM
model
generates
distributions
of
buffers.
Two
distributions
of
buffers
were
developed
from
the
model
 
a
"
maximum
buffer"
distance
and
the
"
whole
field
buffer"
distance.
Three
values
are
presented
in
this
document
 
the
95th
percentile
of
the
maximum
buffer
distribution
(
abbreviated
herein
as
"
95
max"),
the
99th
percentile
of
the
whole
field
buffer
distribution
("
99
whole")
and
the
99.9th
percentile
of
the
whole
field
buffer
distribution
("
99.9
whole").
For
more
detail
on
the
models
and
the
results,
please
refer
to
EPA's
risk
assessment
(
EPA,
2006).

Treatment
Buffers
Table
4
presents
the
treatment
zones
estimated
for
different
percentile
of
exposures.
BEAD
believes
the
estimated
treatment
zones
reflect
an
assumption
that
most
of
the
escaping
gas
is
lost
within
the
first
hour.
12
TABLE
4.
ESTIMATED
METHYL
BROMIDE
FUMIGATION
TREATMENT
BUFFERS
(
FEET)
Treatment
Buffer
(
ft)
Volume
Treated
(
cu
ft)
Rate
(
lbs/
1000
cu
ft)
Loss
During
Treatment
(%)
95
max
99
whole
99.9
whole
1%
0
0
0
5%
0
0
0
10%
0
0
0
1
25%
0
0
0
5%
0
0
0
10%
80
0
80
5,000
4
25%
100
0
100
1%
0
0
0
5%
0
0
0
10%
130
0
120
1
25%
480
170
190
5%
380
140
370
10%
680
250
640
50,000
4
25%
1,270
460
1,190
1%
0
0
0
5%
180
30
170
10%
410
150
380
100,000
1
25%
830
300
760
1%
0
0
0
5%
430
150
400
10%
780
300
710
250,000
1
25%
1,450
530
1,350
Source:
EPA
2006.
Note:
BEAD
anticipates
that
some
minimum
buffer
zone
would
be
established
for
situations
listed
as
zero.
California
currently
has
a
10­
foot
minimum.

Table
4
examines
a
range
of
loss
rates:
1,
5,
10
and
25%
of
the
gas
lost
over
24
hours.
Low
loss
rates,
1
to
5%
per
24­
hour
period,
represent
well­
sealed
or
vacuum
chambers
while
higher
loss
rates,
10
to
25%
per
24
hours,
are
more
representative
of
tarped
enclosures.
Due
to
data
limitations,
we
currently
are
limited
to
estimating
treatment
buffers
for
rates
of
1
and
4
lb
methyl
bromide/
1,000
cubic
feet.

Treatment
buffers
under
the
99
percentile,
whole
field
regulatory
standard
(
99
whole)
would
be
unlikely
to
impose
impacts
on
small
facilities
or
enclosures
of
5,000
to
10,000
cubic
feet,
even
at
higher
rates
and/
or
loss
during
treatment
(
Table
4).
Moderate
size
enclosures
would
also
likely
find
treatment
buffers
feasible
for
low
rates
and
minimum
loss
of
gas.
However,
moderate
sized
enclosures
are
likely
to
find
treatment
buffers
burdensome
for
fumigations
requiring
higher
rates.
Treatment
buffers
for
facilities
treating
250,000
cubic
feet
or
more
would
likely
be
infeasible
unless
they
could
use
vacuum
chambers
(
i.
e.
very
gas
tight).

Other
mitigation
options
that
would
permit
smaller
treatment
zones
are
limited.
Essentially,
facilities
could
to
reduce
application
rates,
fumigate
in
smaller
amounts,
and/
or
increase
the
gastightness
of
their
chambers.
Since
these
commodities
are
typically
fumigated
at
harvest
and
there
are
large
volumes
product
that
needs
to
move
rapidly,
downsizing
the
size
of
the
chambers
13
may
not
be
practical.
In
addition,
the
rates
target
the
insect
pests
that
need
to
be
controlled.
Therefore,
reducing
application
rates
and
fumigating
in
small
amounts
are
also
likely
to
have
substantial
impacts
on
commodity
fumigations.

Aeration
Buffers
Table
5
presents
estimated
aeration
buffers
when
active
air
exchange
and
ventilation
stacks
are
employed.
Many
facilities
in
California
probably
employ
some
kind
of
active
aeration
for
many
commodities
in
order
to
move
products
more
swiftly
into
storage
or
into
the
market.
However,
a
venting
stack
some
distance
above
ground
may
not
be
so
common
although
it
appears
to
be
required
for
reasonable
aeration
buffers.
For
chambers
larger
than
250,000
cu
ft,
of
which
there
may
be
a
few,
the
model
reaches
its
limit,
implying
that
the
buffer
would
have
to
be
calculated
by
different
means
but
would
exceed
4,730
feet
(
nearly
one
mile).

TABLE
5.
METHYL
BROMIDE
FUMIGATION
AERATION
BUFFER
DISTANCES
Air
Exchange
Aeration
Buffer
(
ft)
Site
(
cu
ft)
Rate
(
lbs/
1000
cu
ft)
Stack
type
1
Speed
(
cu
ft/
min)
[
exchnge/
min]
95
max
distance
99
whole
field
99.9
whole
field
Passive
260
0
250
Minimal
2,000
[
0.5]
100
0
80
1
Portable
2,000
[
0.5]
0
0
0
Passive
610
200
580
Minimal
2,000
[
0.5]
200
70
200
5,000
3
Portable
2,000
[
0.5]
0
0
0
Passive
460
150
430
Minimal
5,000
[
0.5]
130
0
130
1
Portable
5,000
[
0.5]
0
0
0
Passive
940
310
890
Minimal
5,000
[
0.5]
300
120
250
10,000
3
Portable
5,000
[
0.5]
0
0
0
Passive
1,270
460
1,190
Minimal
25,000
[
0.5]
210
100
210
1
Portable
25,000
[
0.5]
0
0
0
Passive
n/
a
n/
a
n/
a
Minimal
25,000
[
0.5]
590
300
540
50,000
3
Portable
25,000
[
0.5]
0
0
0
Passive
1,950
680
1,870
Minimal
50,000
[
0.5]
360
210
350
100,000
1
Portable
50,000
[
0.5]
0
0
0
Passive
3,450
1,160
3,300
Minimal
125,000
[
0.5]
840
280
740
250,000
1
Portable
125,000
[
0.5]
0
0
0
Source:
EPA
2006.
1
Minimum
stack
is
10
feet
above
the
highest
building
within
200
feet.
Portable
stack
is
50
feet
high.

BEAD
has
identified
four
ways
that
a
facility
may
reduce
the
required
aeration
buffer:
(
1)
reduce
the
rate
(
amount
of
methyl
bromide
/
1,000
cubic
feet),
(
2)
fumigate
smaller
volumes,
(
3)
14
install
an
active
aeration
system
including
stacks,
and
(
4)
install
a
capture
and
destruction
system.

Rate
Reductions:
Rate
reduction
may
not
be
practical
in
many
situations
because
certain
pests
will
not
be
destroyed
at
the
lower
rates.
Moreover,
this
option
may
not
obtain
a
feasible
aeration
buffer.
A100,000
cubic
foot
chamber
with
a
rate
of
1
lb
of
methyl
bromide/
1,000
cubic
feet
still
has
a
significant
aeration
buffer.

Fumigate
Smaller
Volumes:
Fumigating
in
smaller
units
would
only
be
feasible
if
EPA's
regulatory
scheme
imposed
buffers
on
the
basis
of
individual
treatments,
and
not
on
the
total
volume
treated
in
a
24­
hour
period.
Many
of
these
commodities
are
fumigated
during
the
peak
harvest
season
and
fumigating
in
smaller
units
would
significantly
increase
the
time
to
treat
them
and
lead
to
substantial
economic
impacts.

Active
Aeration
Systems:
Active
aeration
involves
using
fans
to
quickly
disperse
the
gas,
often
through
a
stack.
Table
5
presents
estimated
buffers
for
different
facilities
and
rates.
The
most
effective
system
is
to
use
a
portable
stack
that
vents
the
gas
200
ft
from
the
structure.
It
is
not
clear
whether
this
system
would
work
for
larger
structures
such
as
warehouses.
Large,
permanent
stacks
can
also
help
to
achieve
reductions
in
the
aeration
buffer.
However,
the
air
exchange
rate
is
critical.

The
cost
to
improve
the
active
aeration
of
fumigated
facilities
is
not
known
but
some
representative
costs
are
available.
Information
submitted
through
the
public
comment
process
indicates
that
the
cost
of
a
50­
foot
portable
stack,
including
ducts
and
fittings,
is
approximately
$
1,000,
and
adding
a
permanent
stack
to
a
100,000
cubic
foot
warehouse
would
cost
approximately
$
30,000.
The
comments
did
not,
however,
indicate
the
height
or
airflow
capacity
of
these
stacks.
Fan
costs
range
from
$
500
to
$
850
and
range
in
capacity
from
10,000
to
40,000
cubic
feet
per
minute,
but
often
require
special
engineering
and
design
that
can
multiply
the
cost
(
EPA,
2006).

Multiple
fans
increase
air
exchange
in
an
additive
fashion,
therefore
larger
facilities
may
achieve
sufficient
air
flow
through
a
large
enough
stack
to
reduce
the
aeration
buffer
to
a
feasible
distance.

Capture
and
Destruction
Technology:
A
capture
and
destruction
system
"
scrubs"
the
exhaust
stream
to
remove
methyl
bromide.
Some
of
the
early
systems
were
not
commercially
viable;
however
newer
systems
are
now
available.
These
systems
could
reduce
aeration
buffers
if
the
EPA
regulatory
scheme
permits
captured
methyl
bromide
to
be
subtracted
from
total
quantity
used
when
calculating
the
buffer.

There
are
several
companies
that
are
marketing
or
have
previously
marketed
methyl
bromide
capture
and
destruction
systems.
Currently,
these
systems
are
primarily
marketed
for
small
commodity
and
quarantine
treatments.
Based
on
available
information,
it
is
not
clear
to
what
extent
they
would
be
feasible
for
structures
such
as
warehouses.
15
However,
even
if
some
proportion
of
the
methyl
bromide
could
be
captured,
the
estimated
aeration
buffer
could
be
reduced
substantially.
Further,
these
systems
reduce
the
amount
of
methyl
bromide
released
into
the
atmosphere
and
could
have
an
impact
on
ozone
depletion.

BEAD
concludes
that
aeration
zones
are
not
likely
to
cause
significant
impacts
on
commodity
fumigation
chambers
because
active
aeration,
with
a
portable
stack,
appears
feasible
and
capture
and
destruction
technology
has
improved
and
could
offer
an
additional
means
of
reducing
the
amount
of
methyl
bromide
vented
into
the
air.

Alternatives
to
Methyl
Bromide
in
Post­
Harvest
There
are
other
fumigants
that
are
available
for
use
in
the
post­
harvest
sector.
Phosphine
is
often
used
when
time
is
not
critical,
because
it
usually
takes
longer
for
a
fumigation.
In
addition,
phosphine
is
corrosive
to
certain
metals
and
has
temperature
constraints.
Sulfuryl
fluoride
was
registered
in
January
of
2004
in
the
U.
S.
and
in
California
in
May
of
2005,
for
use
in
mills
of
cereal
grains,
dried
fruits,
and
tree
nuts.
Use
sites
were
extended
in
July
of
2005
by
the
Federal
government,
but
not
by
California.
Research
is
ongoing
to
determine
its
capability
to
replace
methyl
bromide
in
all
its
critical
uses.
Sulfuryl
fluoride
is
currently
undergoing
review
by
the
Codex
Alimentarius
Commission
to
establish
maximum
residue
levels
(
MRL)
from
the
use
of
quarantine
fumigations
and
by
the
Committee
for
the
Agreement
on
the
Application
of
Sanitary
and
Phytosanitary
Measures
to
set
standards
for
its
use.
If
approved
by
Codex
MRLs
would
be
established
for
foods
such
as:
dried
fruits
and
tree
nuts,
bran,
cereal
grains,
and
flour
(
e.
g.
maize,
rye,
and
wheat).
Propylene
oxide
is
another
alternative
to
methyl
bromide
that
is
being
investigated
for
insect
control
in
tree
nuts
(
Leesch,
personal
communication).
Currently
it
is
used
to
sanitize
the
surface
of
tree
nuts
to
primarily
manage
mold,
yeast,
and
bacteria
(
Yourman
&
Donaldson,
2006).

Other
options
for
controlling
pests
in
the
post­
harvest
sector
include
(
but
are
not
limited
to):
manipulations
of
temperature,
such
as
heat
or
cold;
controlled
atmospheres,
such
as
ozonation,
carbon
dioxide;
irradiation,
and
increased
sanitation,
especially
micro­
sanitation.
Research
is
continuing
in
this
field,
however,
to
date,
alternatives
are
not
technically
feasible
or
are
prohibitively
expensive.
Methyl
bromide
remains
the
only
suitable
fumigant
for
periods
when
time
is
critical.

CONCLUSION
BEAD
does
not
expect
substantial
impacts
to
result
from
lowering
the
air
concentration
limit
of
occupation
exposure
from
five
(
5)
ppm
as
a
ceiling
limit
to
one
(
1)
ppm
as
a
8­
hour
TWA,
provided
facilities
have
the
option
to
utilize
air
purifying
respirators
to
protect
employees
when
air
concentrations
are
between
these
points.
BEAD
also
does
not
expect
substantial
impacts
if
EPA
were
to
require
FMPs
and
other
actions
that
focus
on
compliance
and/
or
enforcement.

It
appears
that
by
using
active
aeration
most
commodity
chambers
would
be
able
to
accommodate
aeration
buffers.
This
conclusion
is
based
on
the
assumption
that
the
99
percentile
whole
field
buffer
is
used
for
the
regulatory
decision
making.
Further,
if
these
facilities
are
16
located
in
rural
areas
and
do
not
have
employees
working
other
processes
during
fumigation,
treatment
buffers
are
likely
to
be
feasible
as
well,
except
for
large
enclosures
or
high
rates.

There
are
some
facilities
that
will
need
to
modify
their
current
practices
to
meet
these
proposed
buffer
requirements.
There
are
several
ways
to
meet
these
requirements;
for
example,
site
specific
modeling
can
be
used
by
the
facilities
to
select
methods
to
implement
that
would
result
in
the
reduction
of
buffers.
In
most
cases,
facilities
could
potentially
achieve
the
greatest
buffer
reduction
by
using
a
combination
of
methods.
Treatment
buffers
may
be
reduced
by
methods
such
as
improved
gas
retention,
lower
rates
or
treating
smaller
volumes
of
commodities.
Aeration
buffers
may
be
reduced
by
methods
such
as
improved
ventilation
systems
(
greater
air
exchanges
per
minute,
taller
stacks),
lower
rates,
treating
smaller
volumes,
or
installing
a
capture
and
destruction
system.
BEAD
anticipates
that
using
a
combination
of
these
mitigation
options
most
facilities
will
be
able
to
meet
the
buffer
requirements.
However,
these
changes
will
entail
some
costs.

However,
if
commodity
facilities
cannot
meet
the
buffer
requirements,
even
with
the
adoption
of
additional
equipment,
they
would
not
be
able
to
use
methyl
bromide.
Since
2005,
use
of
methyl
bromide
is
only
permitted
under
the
Montreal
Protocol
for
certain
uses,
including
those
that
have
been
designated
as
a
critical
need.
EPA
and
USDA
have
evaluated
exemption
requests
and
found
that
there
are
no
technically
and
economically
feasible
alternatives
to
the
use
of
methyl
bromide
in
this
sector
(
USA,
2006a,
2006b).
Therefore,
if
buffers
are
infeasible,
some
facilities
may
have
to
cease
operation.
This
may
impact
producers
and
consumers,
as
well
as
the
local
economy.
BEAD
does
not
have
adequate
data
about
the
specific
site
characteristics
of
these
facilities
to
quantify
the
distribution
and
magnitude
of
these
impacts.
However,
BEAD
anticipates
that
by
using
a
combination
of
mitigation
options
most
facilities
will
be
able
to
meet
the
buffer
requirements.

REFERENCES
CAL
DPR.
2006.
California
Department
of
Pesticide
Regulation
Pesticide
Use
Reporting
(
PUR)
data
base.
Available
at
http://
www.
cdpr.
ca.
gov/
docs/
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