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
Use
of
Methyl
Bromide
on
Dry
Cured
Pork
Product
Facilities
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:
26
July
2006
Page
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
(
EPA,
2006).
This
document
addresses
the
potential
impacts
to
fumigations
of
dry­
cured
pork.
Other
assessments
address
the
impacts
on
quarantine
commodities,
non­
quarantine
commodities,
and
structures/
food
processing
facilities.

BEAD
does
not
expect
significant
impacts
to
result
from
lowering
the
air
concentration
limit
of
occupational
exposure
from
five
(
5)
ppm
as
a
ceiling
to
one
(
1)
ppm
as
a
8­
hour
time
weighted
average,
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
significant
impacts
if
EPA
were
to
require
Fumigation
Management
Plans
(
FMP)
and
other
actions
that
focus
on
compliance
and/
or
enforcement.

It
appears
that
by
using
active
aeration
most
dry­
cured
pork
facilities
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,
because
curing
facilities
tend
to
be
located
in
rural
areas
and
may
not
need
to
have
employees
working
other
processes
during
fumigation,
treatment
buffers
are
likely
to
be
feasible
as
well
There
may
be
some
curing
facilities
that
will
need
to
modify
their
current
practices
to
meet
the
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.
However,
these
changes
will
entail
some
costs.

However,
if
curing
facility
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.
Page
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
weedy
pests.
Under
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA),
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
a
number
of
structural
conditions,
including
dry
cured
pork
processing
facilities.

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
initiated
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
significant
market
disruptions
would
occur
if
methyl
bromide
were
not
available.
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
use
addressed
in
this
document
has
received
a
critical
use
exemption
under
the
Montreal
Protocol
for
the
years
2005,
2006,
and
2007.
A
critical
use
exemption
of
2008
is
currently
being
evaluated
by
the
Parties
to
the
Montreal
Protocol.
This
represents
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
dry­
cured
hams,
and
consequently,
on
the
total
volume
that
can
be
fumigated
in
any
one
year
period.
Page
4
Risks
of
Concern
As
part
of
the
Office
of
Pesticide
Program's
determination
of
methyl
bromide's
eligibility
for
reregistration,
the
Office
conducted
risk
assessments
for
methyl
bromide
use
in
enclosures,
chambers,
and
food
processing/
storage
facilities.
There
are
no
aggregate
dietary
risks
of
concern.
However,
there
are
risks
of
concern
associated
with
the
use
of
methyl
bromide
via
occupational
exposure
during
both
treatment
and
aeration
and
via
bystander
exposure
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
extent
to
which
these
measures
can
also
contribute
to
reduction
in
ozone
depletion.
This
document
presents
OPP's
evaluation
of
various
risk­
reduction
strategies
according
to
these
factors.
However,
because
of
the
great
diversity
in
sites
being
treated
with
methyl
bromide,
OPP
has
limited
ability
to
make
a
quantitative
evaluation.

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.
Page
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
exceedences,
the
reporting
and
oversight
requirements
on
the
fumigator
and
state
and
local
regulators
would
be
onerous.

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

Command
and
Control:
Buffer
Zones:
The
second
strategy
represents
the
opposite
end
of
the
spectrum,
where
EPA
would
establish
a
single
option
to
encompass
all
sites.
The
most
likely
option
for
addressing
bystander
risk
would
be
to
require
treatment
and
aeration
buffer
zones,
based
on
the
total
amount
of
methyl
bromide
used,
that
would
result
in
a
reasonable
certainty
of
no
harm
for
all
possible
fumigation
scenarios.
To
account
for
all
potential
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
Page
6
buffer
zone,
but
the
size
of
the
buffer
would
depend
on
the
use
of
other
risk
management
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
of
these
factors
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
depletion.

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,
Page
7
including
the
establishment
of
buffer
zones
and
the
factors
that
determined
the
appropriate
size.
EPA
envisions
certification
so
that
the
FMP
conforms
to
the
label
requirements.

Currently,
most
fumigations
already
follow
some
kind
of
plan,
although
all
plans
would
now
have
to
be
brought
into
compliance
with
the
new
requirements
of
use.
Once
prepared
for
a
fixed
facility,
the
plan
would
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
currently
BEAD
has
no
way
of
predicting
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
are
not
likely
to
entail
significant
added
costs,
since
most
fumigations
are
already
closely
monitored.
Notices
that
a
commodity
has
been
treated
should
also
not
impose
significant
costs.

INDUSTRY
OVERVIEW
Since
2002,
EPA's
Methyl
Bromide
Critical
Use
Exemption
(
CUE)
process
reviews
and
nominates
various
commodities
for
critical
use,
in
this
case
ham
and
dry
cured
pork
products.
The
following
information
is
based
on
industry
applications
for
a
CUE
and
EPA
proprietary
data.

The
processed
or
cured
pork
industry
generates
almost
$
6
billion
in
annual
revenue.
(
U.
S.
Census,
2002)
Post
harvest
food
storage
is
an
integral
part
of
operations
because
in
many
cases
there
are
seasonal
effects
with
most
sales
during
holiday
seasons.
Therefore
it
is
imperative
for
these
industries
to
fumigate
in
order
to
maintain
the
commodity's
integrity
and
quality.
A
representative
facility
generates
about
$
48
million
in
annual
revenue
with
a
gross
margin
of
about
25%
and
a
net
profit
margin
of
about
3%.

DESCRIPTION
OF
FACILITIES
AND
DRY
CURED
PROCESS
Dry
Cure
Process
Curing
is
a
method
of
preserving
meat
that
prevents
harmful
micro­
organisms
from
developing.
Two
curing
methods
have
been
developed
 
wet
(
or
brine)
curing
and
dry
curing.
In
wet
curing,
the
curing
ingredients
were
mixed
with
boiling
water
to
form
"
pickling"
brine.
In
dry
curing,
the
ingredients
were
simply
rubbed
into
the
meat
several
times
over
the
period
of
the
cure.
Based
on
our
current
understanding,
methyl
bromide
is
used
only
for
dry
cured
pork
products
such
as
dry
cured
ham,
dry
cured
country
ham,
hard
salami,
pepperoni,
and
sausage.

Historically,
the
dry
curing
process
was
calendar
based
 
beginning
in
the
winter
months
and
ending
the
following
autumn.
Modern
commercial
production
now
controls
the
temperature
and
relative
humidity
to
mimic
the
historical
process
and
produces
the
product
year
round.
The
primary
steps
in
the
process
are
as
follows:
Page
8
"
Winter
Room"
­
Hams
are
typically
salted
and
sugared
using
a
dry
rub
method
and
kept
at
approximately
38
degrees
Fahrenheit
with
low
humidity
for
up
to
50
days.
The
salt
and
sugar
are
then
scraped
and
rubbed
off
of
the
ham.
The
high
salt
content
is
sufficient
to
keep
insect
pest
pressure
to
a
minimum.

"
Spring
Room"
­
Next,
hams
are
wrapped
in
cotton
netting
and
kept
at
approximately
50
­
55
degrees
Fahrenheit
at
50%
humidity
for
10
­
15
days.
The
low
temperature
and
the
short
time
in
this
stage
limits
insect
problems.

"
Summer
or
Aging
Room"
­
Hams
are
then
maintained
between
80
­
90
degrees
Fahrenheit
at
55%
humidity
for
up
to
120
days.
These
conditions
allow
for
the
development
of
the
characteristic
flavor.
Since
the
temperature
and
humidity
are
higher
in
this
room,
conditions
are
ideal
for
pest
problems.
It
is
at
this
stage
that
the
application
of
methyl
bromide
is
necessary
to
control
mite
and
insect
pests.

SITE
DESCRIPTIONS
Purpose
of
Methyl
Bromide
Fumigation
It
is
common
for
producers
of
dry
cured
pork
products
to
experience
pest
pressure
from
mites
and
insects
such
as
the
ham
skipper,
the
red
legged
ham
beetle,
and
dermestid
beetles
(
Table
1).
These
insects
infest
and
feed
on
the
meat
as
it
cures
and
ages.
Environmental
conditions
(
temperature
and
humidity)
in
and
around
the
facility
strongly
influence
the
level
of
pest
pressure.
Under
favorable
ambient
conditions,
such
as
those
seen
in
silo
curing,
pest
pressure
increases
and
a
regular
fumigation
schedule
is
recommended.
The
Food
and
Drug
Administration
(
FDA)
regulates
the
maximum
levels
of
live
or
dead
insects
or
insect
parts
that
may
be
present
in
stored
food
products.
Food
commodities
that
exceed
maximum
limits
allowed
are
considered
adulterated
by
FDA
and
thus
unfit
for
human
consumption.

TABLE
1:
KEY
PESTS
FOR
METHYL
BROMIDE
IN
HAM
Pests
for
Which
the
Use
of
Methyl
Bromide
is
Critical
Damage
Caused
Necrobia
rufipes
(
Red
Legged
Ham
Beetle
or
"
Ham
Borer")
Piophila
casei
(
Cheese/
Ham
Skipper)
Dermestes
spp.
(
Dermested
beetles)
Mite
species
(
Ham
Mites)
The
larvae
and
adults
feed
on
the
cured
meat.
The
larvae
burrow
into
the
meat
and/
or
fat.
Insect
infested
meat
is
adulterated
and
cannot
be
sold.
1
Mites
feed
and
breed
on
the
surface
of
cured
meats
and
burrow
into
the
meat.
Uncontrolled,
mite
populations
can
increase
rapidly,
reaching
enormous
numbers.

1
FDA
regulations
can
be
found
at:
http://
www.
fda.
gov/
opacom/
laws/
fdcact/
fdcact4.
htm
and
http://
www.
cfsan.
fda.
gov/~
dms/
dalbook.
html.
Additional
discussion
at
USA
(
2006).

There
are
currently
no
chemical
alternatives
registered
for
use
on
hams
in
the
U.
S.
that
would
provide
the
same
level
of
pest
control
(
Table
2)
and
not
affect
product
quality.
Other
than
sanitation,
no
alternative
techniques
are
being
used.
Sanitation
is
useful
in
increasing
the
time
between
methyl
bromide
fumigations
but
cannot,
when
used
alone,
replace
methyl
bromide
fumigations.
Page
9
TABLE
2:
SUMMARY
OF
FEASIBILITY
OF
ALTERNATIVES
FOR
DRY
CURED
PORK
PRODUCTS.
Methyl
Bromide
Alternative
Technical
Reasons
for
the
Alternative
Not
Being
Feasible
Phosphine
alone
&
in
combination
Does
not
control
mites.
North
Carolina
has
additional
use
restrictions.

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

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

Facilities
Based
on
currently
available
information,
there
are
approximately
80
facilities
that
produce
dry
cured
meat
products
in
the
United
States,
and
about
45
use
methyl
bromide
for
fumigations
(
Table
3).
BEAD
was
able
to
obtain
specific
address
information
for
ten
facilities.
Three
of
these
ten
facilities
are
located
in
the
US
Bureau
of
Census
Urban
Areas
or
Urban
Clusters1.
In
general,
these
facilities
are
located
in
the
southeastern
part
of
the
United
States,
primarily
in
Kentucky,
Missouri,
North
Carolina,
Virginia,
Tennessee,
and
South
Carolina
(
Figure
1).

Table
3:
Number
and
Location
of
Dry
Cured
Meat
Facilities
Total
Facilities
In
U.
S.
Number
Of
Facilities
Using
Methyl
Bromide
In
CUE
Process
Number
Of
Facilities
With
Location
Data
Number
Estimated
Urbanized
Area
Or
Urban
Cluster
Not
In
Urbanized
Or
Urban
Cluster
Approximately
80
Approximately
45
10
3
7
Source:
2002
Economic
Census
data.
Available
online
at
http://
www.
census.
gov/
prod/
www/
abs/
manuind2002
html
1
BEAD
identified
the
location
of
each
facility
and
compared
it
to
areas
defined
as
Urbanized
Area
or
Urban
Cluster
by
the
2000
US
Census
(
www.
census.
gov).
An
Urbanized
Area
consists
of
contiguous
census
blocks
and
block
groups
of
at
least
1,000
persons/
square
mile
that
together
encompass
a
population
of
at
least
50,000
people.
An
Urban
Cluster
consists
of
contiguous
census
blocks
and
block
groups
that
together
encompass
between
2,500
and
50,000
people.
Page
10
Urban
Facilities
Non­
Urban
Facilities
Urban
Areas
Ham
Facilities
and
Urban
Areas
Figure
1.
Location
of
facilities
for
which
BEAD
has
specific
addresses.
This
map
does
not
include
8
facilities
in
TN,
NC,
and
GA
for
which
specific
street
addresses
were
not
available.

Curing
facilities
are
up
to
2­
3
stories
in
height
and
typically
have
curing
rooms
that
use
either
wood
or
stainless
steel
racks
to
hang
the
hams.
The
curing
rooms
can
hold
up
to
4000
hams.
BEAD
has
information
on
seven
representative
facilities
from
the
Methyl
Bromide
Critical
Use
Exemption
process
(
USA,
2006).
One
facility
is
between
10,000
and
50,000
cubic
feet
in
size,
five
facilities
are
between
50,001
and
100,000
cubic
feet
in
size
and
one
facility
is
between
100,001
and
500,000
cubic
feet
in
size.
Average
volume
of
these
facilities
is
111,000
cubic
feet.

Use
and
Usage
of
Methyl
Bromide
The
information
on
the
usage
of
methyl
bromide
in
this
sector
is
primarily
based
on
the
methyl
bromide
critical
use
exemption
applications.
The
Methyl
Bromide
CUE
applicants
requested
rates
between
0.67
to
4.56
lb
methyl
bromide
per
1000
cubic
feet.
The
2008
nomination
(
USA,
2006)
under
the
Montreal
Protocol
requested
a
weighted
average
of
1.2
lb
methyl
bromide
per
1,000
cubic
feet.
The
fumigation
time
varies,
but
is
usually
24
hours.
Typically,
there
is
a
single
fumigation
per
product
cycle.
Based
on
production,
at
a
given
facility
there
can
be
from
2
to
8
fumigations
per
year
(
3
to
5
times
per
year
is
most
common).
The
distribution
of
total
methyl
bromide
use
corresponds
to
the
distribution
of
facility
sizes
(
Cal
DPR
data
2002­
2004
and
Methyl
Bromide
CUE
Bromide
Facility
Description
for
Ham,
USA,
2006).
For
the
2008
calendar
year,
43,325
pounds
of
methyl
bromide
were
requested
for
use
in
this
sector.
Page
11
IMPACTS
OF
BUFFER
ZONES
ON
FACILITIES
BEAD
examined
a
range
of
potential
facility
sizes
and
use
rates
to
explore
the
potential
impacts
of
treatment
and
aeration
buffer
zone
requirements.
Specifically,
we
examine
facilities
of
50,000
cu
ft,
100,000
cu
ft
and
250,000
cu
ft
with
treatments
of
1
to
3
lb
methyl
bromide
per
1,000
cu
ft.

Based
on
our
current
knowledge,
fumigated
curing
facilities
tend
to
be
located
in
more
rural
areas,
which
may
permit
relatively
extensive
buffer
zones.
Those
in
urban
areas,
however,
may
be
constrained
by
space.
Little
site­
specific
information
is
available
and
it
is
very
difficult
to
determine
feasible
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).

Imagine
a
facility
occupying
a
square
city
block.
Blocks
are
approximately
0.1
mile
or
about
500
feet
on
a
side.
If
this
facility
could
vent
methyl
bromide
near
the
center
of
the
space,
it
would
have
an
aeration
buffer
of
about
250
feet.
Any
aeration
buffer
larger
than
these
distances
would
require
the
facility
to
undertake
additional
mitigation
measures.
If
those
measures
would
not
reduce
the
aeration
buffer
below
the
maximum,
the
facility
would
be
unable
to
use
methyl
bromide.

However,
during
treatment,
gas
may
leak
from
any
point
in
the
facility,
not
just
from
the
center.
Therefore,
an
enforceable
treatment
zone,
measured
from
the
edge
of
the
building,
may
be
much
smaller.
In
fact,
in
some
cases
the
edge
of
the
building
may
be
near
the
property
line.
For
the
purpose
of
this
assessment,
BEAD
assumes
that
a
zone
of
10
to
50
feet,
about
one­
tenth
of
the
aeration
zone,
may
be
possible
for
a
facility,
depending
on
the
size
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
(
held
constant),
application
rate,
chamber/
enclosure
conditions
(
e.
g.,
gastightness
fumigated
volume,
the
use
of
stacks,
building
effects,
and
the
rate
and
type
of
aeration.
The
tables
of
buffer
distances
identify
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
Page
12
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
estimated
treatment
buffers.
The
treatment
buffer
depends
on
how
much
methyl
bromide
is
likely
to
escape,
which
depends
on
how
tightly
sealed
a
facility
is
against
loss
of
methyl
bromide
and
how
long
the
treatment
lasts.
Ventilation
systems
do
not
influence
the
treatment
zone.

It
is
difficult
to
estimate
a
likely
loss
from
curing
facilities.
Historically,
such
curing
sheds
were
probably
very
open.
However,
newer
facilities
may
be
quite
well
sealed
in
order
to
maintain
proper
temperature
and
humidity.
We
examine
a
range
of
loss
rates:
1,
5,
10
and
25%
of
the
gas
lost
over
24
hours.
The
1%
rate
is
likely
an
underestimate,
as
it
is
more
representative
of
vacuum
chambers.
The
California
system
assumes
that
3%
of
the
concentration
is
lost
in
an
hour
unless
specifically
measured.
Therefore,
a
12­
hour
treatment
would
lose
36%
of
the
fumigation
rate
while
a
24­
hour
treatment
would
lose
72%
of
the
concentration
rate.
Therefore,
our
estimates
may
be
somewhat
low.
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
and
some
limited
data
at
the
2
lb
rate.
Page
13
Table
4.
Estimated
Treatment
Buffer
Zones
(
feet)
Treat,
emt
Buffer
(
ft)
Site
(
cubic
ft)
Rate
(
lbs/
1000
ft3)
Loss
DuringTreatment
(%)
95
max
99
whole
99.9
whole
1%
0
0
0
5%
0
0
0
10%
140
0
120
1
25%
480
170
190
5%
140
0
120
2
10%
380
140
370
1%
0
0
0
5%
380
140
370
10%
680
250
640
50,000
4
25%
1,270
460
1,190
1%
0
0
0
5%
190
40
170
10%
410
150
380
1
25%
820
300
760
5%
410
150
380
2
10%
710
270
660
1%
120
0
100
5%
710
270
660
10%
1,100
400
1,050
100,000
4
25%
1,940
680
1,860
1%
0
0
0
5%
430
150
400
10%
780
300
710
1
25%
1,450
530
1,350
5%
780
300
710
2
10%
1,250
460
1,170
1%
330
100
320
5%
1,250
460
1,170
10%
1,920
690
1,830
250,000
4
25%
3,430
1,150
3,280
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.

Generally,
the
estimated
treatment
buffers
for
the
99
percentile
whole
field
appear
feasible
for
most
curing
facilities,
provided
loss
during
treatment
is
not
excessive
and
higher
rates
are
not
critical.

Other
mitigation
options
that
would
permit
smaller
treatment
zones
are
limited.
There
are
three
primary
ways
(
alone
or
in
combination)
that
a
facility
may
reduce
the
required
treatment
buffer:
(
1)
Reduce
the
rate
(
amount
of
methyl
bromide/
1,000
cu
ft),
(
2)
partition
the
facility
and
fumigate
smaller
volumes
and
(
3)
improve
the
gas
retention
of
the
structure.

Rate
Reductions:
Reducing
the
application
rate
may
not
be
practical
in
many
situations
because
certain
pests
will
not
be
destroyed
at
the
lower
rates.

Partitioning
Structures:
Fumigating
in
smaller
units
may
also
present
logistical
problems,
depending
on
the
facility.
Page
14
Improving
Gas
Retention:
Newly
constructed
facilities
are
likely
to
have
been
constructed
in
a
manner
that
would
lower
fumigant
loss
rates
during
treatment.
However,
it
may
be
very
difficult
for
older
facilities
to
improve
gas
retention
without
complete
and
costly
renovation.
With
very
large
structures,
there
are
likely
technical
limits
to
the
ability
to
avoid
losses,
even
with
newer
materials
and
construction
methods.
However,
this
may
be
the
most
direct
way
of
meeting
the
requirements
of
treatment
buffers
while
maintaining
operations.

Aeration
Buffers
Table
5
presents
the
estimated
aeration
zone
for
facilities
with
no
active
ventilation
system
(
passive
aeration)
for
different
regulatory
standards:
95
max,
99
whole,
and
99.9
whole
(
see
EPA
2006
for
details
about
the
interpretation
of
these
regulatory
standards).
BEAD
assumes
most
curing
facilities
currently
do
not
actively
vent
methyl
bromide
following
fumigation.
This
may
be
a
restrictive
assumption
as
facilities
would
normally
like
to
aerate
rapidly
in
order
to
return
to
business.
For
some
of
the
larger
facilities,
the
model
reaches
its
limit,
implying
that
the
buffer
would
have
to
be
calculated
by
different
means
but
would
exceed
4,725
feet
(
nearly
one
mile).

Table
5.
Estimated
Aeration
Buffer
Zone
(
feet),
No
Active
Ventilation
System
Rate
(
lb
MeBr/
1,000
cu
ft)
1.0
2.0
3.0
Volume
Treated
(
cu
ft)
95
max
99
whole
99.9
whole
95
max
99
whole
99.9
whole
95
max
99
whole
99.9
whole
50,000
1,260
460
1,180
1,920
690
1,840
2,475
850
2,360
100,000
1,950
670
1,850
2,990
1,020
2,850
3,870
1,260
3,690
250,000
3,430
1,150
3,280
*
1,690
*
*
2,150
*
Source:
EPA
2006.
*
Aeration
buffer
greater
than
4,730
ft,
the
maximum
the
model
can
calculate.

Even
assuming
EPA
selects
the
99
percentile
whole
field
as
the
regulatory
standard,
only
the
smaller
facilities
using
low
rates
would
find
these
aeration
buffers
feasible,
even
in
rural
areas.
Other
measures
would
have
to
be
taken
to
permit
a
smaller
aeration
buffer.

There
are
four
primary
ways
(
alone
or
in
combination)
that
a
facility
may
reduce
the
required
aeration
buffer:
(
1)
reduce
the
rate
(
amount
of
methyl
bromide
/
1,000
cu
ft),
(
2)
fumigate
smaller
volumes,
(
3)
install
an
active
aeration
system
including
stacks,
and
(
4)
install
a
capture
and
destruction
system.

Rate
Reductions:
Reducing
the
rate
may
not
be
practical
in
many
situations
because
certain
pests
will
not
be
destroyed
at
the
lower
rates.
Moreover,
this
option
may
not
be
sufficient
to
obtain
a
feasible
aeration
buffer.
As
shown
in
Table
5,
a
100,000
cubic
foot
facility
that
halves
the
rate
from
2
lb
methyl
bromide/
1,000
cubic
foot
to
1
lb
methyl
bromide/
1,000
cubic
foot
reduces
the
aeration
buffer
by
less
than
35%.
However,
the
necessary
buffer
will
still
exceed
the
likely
maximum
feasible
treatment
buffer.
Page
15
Fumigate
Smaller
Volumes:
It
may
be
possible
for
facilities
to
partition
their
curing
rooms
and
fumigate
only
part
at
a
time.
The
difficulty
with
this
approach
is
that
it
will
require
careful
sealing
or
insects
may
simply
escape
into
a
non­
fumigated
area
and
immediately
re­
infest
the
product.
Otherwise
reducing
the
volume
to
be
treated
would
necessitate
reducing
the
throughput
of
the
facility
and
reducing
revenues.

Active
Aeration
Systems:
Active
aeration
involves
using
fans
to
quickly
disperse
the
gas,
often
through
a
stack.
Table
6
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
facilities
and
has
not
yet
been
modeled.
Large,
permanent
stacks
can
also
help
to
achieve
reductions
in
the
aeration
buffer.
However,
the
air
exchange
rate
is
critical.

Table
6.
Estimated
Aeration
Buffer
Zone
(
feet),
Active
Ventilation
Aeration
Buffer
(
ft)
Site
(
cubic
ft)
Rate
(
lbs/
1000
ft3)
Air
Exchange
(
cu
ft/
min)
[
exchanges/
min]
Stack
Type
1
95
max
99
whole
99.9
whole
25,000
[
0.5]
Minimum
220
100
220
1
25,000
[
0.5]
Portable
0
0
0
25,000
[
0.5]
Minimum
380
220
350
2
25,000
[
0.5]
Portable
0
0
0
25,000
[
0.5]
Minimum
600
300
550
50,000
3
25,000
[
0.5]
Portable
0
0
0
50,000
[
0.5]
Minimum
360
210
350
50,000
[
0.5]
50
ft
0
0
0
20,000
[
0.2]
Minimum
480
250
460
1
20,000
[
0.2]
50
ft
150
0
140
50,000
[
0.5]
Minimum
1,040
380
910
50,000
[
0.5]
50
ft
270
0
250
20,000
[
0.2]
Minimum
1,370
460
1,270
2
20,000
[
0.2]
50
ft
460
220
450
50,000
[
0.5]
Minimum
1,790
550
1,600
50,000
[
0.5]
50
ft
480
230
460
20,000
[
0.2]
Minimum
2,170
690
2,020
100,000
3
20,000
[
0.2]
50
ft
820
370
730
125,000
[
0.5]
Minimum
840
280
740
125,000
[
0.5]
50
ft
0
0
0
50,000
[
0.2]
Minimum
940
430
970
1
50,000
[
0.2]
50
ft
940
230
810
125,000
[
0.5]
Minimum
1,960
510
1,710
125,000
[
0.5]
50
ft
480
0
430
50,000
[
0.2]
25
ft
2,380
730
2,200
2
50,000
[
0.2]
50
ft
2,020
510
1,780
125,000
[
0.5]
Minimum
3,240
730
2,810
250,000
3
125,000
[
0.5]
50
ft
820
300
780
Page
16
50,000
[
0.2]
25
ft
3,880
1,140
4,730
50,000
[
0.2]
50
ft
3,120
760
2,740
Source:
EPA
2006.
1
Minimum
stack
is
10
feet
above
the
highest
building
within
200
feet.
Portable
stack
is
50
feet
high
and
placed
200
feet
from
the
building.

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
soft
portable
stack,
including
ducts
and
fittings,
is
approximately
$
1,000,
and
adding
a
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.
A
factor
in
determining
the
viability
of
such
an
investment
is
that
many
facilities
fumigate
infrequently.

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
curing
sheds.

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
dry­
cured
pork
facilities
because
active
aeration,
with
a
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.

CONCLUSION
BEAD
does
not
expect
significant
impacts
to
result
from
lowering
the
air
concentration
limit
of
occupational
exposure
from
five
(
5)
ppm
as
a
ceiling
to
one
(
1)
ppm
as
a
8­
hour
time
weighted
average,
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
Page
17
significant
impacts
if
EPA
were
to
require
Fumigation
Management
Plans
(
FMP)
and
other
actions
that
focus
on
compliance
and/
or
enforcement.

It
appears
that
by
using
active
aeration
most
dry­
cured
pork
facilities
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,
because
curing
facilities
tend
to
be
located
in
rural
areas
and
may
not
need
to
have
employees
working
other
processes
during
fumigation,
treatment
buffers
are
likely
to
be
feasible
as
well
There
may
be
some
curing
facilities
that
will
need
to
modify
their
current
practices
to
meet
the
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.
However,
these
changes
will
entail
some
costs.

However,
if
curing
facility
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/
pur/
purmain.
htm
EPA.
2003.
Industrial
Economics,
Incorporated
report
entitled:
Financial
Profiles
and
Alternative
Costs
Report
2002
Methyl
Bromide
CUE
Application
from
Post­
Harvest/
Structure
Users
for
U.
S.
Environmental
Protection
Agency
Office
of
Pesticide
Programs
(
7503C).

EPA.
2006.
U.
S.
Environmental
Protection
Agency,
Office
of
Pesticide
Programs,
Docket
on
Methyl
Bromide
Risk
Assessment
for
Fumigant
Pesticide.
Docket
No.
EPA­
HQ­
OPP­
2005­
0123.
Available
at
http://
www.
regulations.
gov
.
Page
18
U.
S.
Census.
2002.
Meat
Processed
from
Carcasses:
2002
Economic
Census.
Manufacturing,
Industry
Series.
Available
at:
http://
www.
census.
gov/
prod/
ec02/
ec0231i311612.
pdf
U.
S.
Census
Bureau.
2000.
Urban
and
Rural
Classification.
Available
at
http://
www.
census.
gov/
geo/
www/
ua/
ua_
2k.
html
United
States
of
America.
2006.
Methyl
Bromide
Critical
Use
Nomination
for
Post
Harvest
Use
in
Ham
(
Submitted
in
2006
for
2008
Use
Season).
Available
at
http://
www.
epa.
gov/
ozone/
mbr/
2008_
nomination.
html.
