## METHYL BROMIDE CRITICAL USE RENOMINATION FOR

POST-HARVEST USE TREATMENT BY NATIONAL PEST

MANAGEMENT ASSOCIATION

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN12 POST HARVEST NATIONAL PEST MANAGEMENT ASSOCIATION (NPMA)

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Post Harvest Use by NPMA (Submitted in 2010 for 2012 Use Season)

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF

NOMINATION:

T ABLE 1. Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION



### Y EAR 

### N OMINATION 

### A MOUNT 

### (K ILOGRAMS 

### )

2012 17,365

(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: 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 critic al because the lack of availability of methyl bromide for this use would result in a significant market disruption. ■ Yes  No

Signature Name Date

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 1Title:

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

C ontact/Expert Person: Jack Housenger

Title: Division Director

Address: Biological and Economic Analysis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcode 7503P Washington, D.C. 20460

U.S.A. Telephone: (703) 308-8200 Fax: (703) 308-7042

E-mail: housenger.Jack@epa.gov

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

1. PAPER DOCUMENTS: Title of paper documents and appendices No. of pages Date sent to Ozone

Secretariat

USA CUN12 Post Harvest National Pest Management Association

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 CUN12 Post Harvest National Pest Management Association

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 2

## METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST USE TREATMENT BY NA TIONAL PEST MANAGEMENT

ASSOCIATION

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL USE

This sector includes cheese and food processi ng plants treated by Natio nal Pest Management Association (NPMA) members and are not included in the Commod ity or in the Food Facilities Chapters of the US nomination. Food Processing Facilities included in this application are: processed foods (such as chips, crackers, cooki es and pasta), spices and herbs, and cheese processing plants. Methyl bromide is typically u tilized in processed food and feed facilities as a space fumigant for treating the facility 1 to 3 times per year. As the need arises, methyl bromide is also used for trailer or warehouse fumigati ons of product or packaging material. These facilities are under intense pre ssure from many insect pests as well as rodents.

CHEESE: Methyl bromide fumigation for cheese occurs to ensure pest-free food and meet the strict requirements of the Food Sanitation Regulations. Cheese ma nufacturers may target their products during fumigations with methyl bromide when a mite infestatio n is identified by USDA inspection and a fumigation is ordered. Cheese does not have a technically and economically

feasible alternative available. Whereas su lfuryl fluoride and phosphine are the primary alternatives in most commodities, they are unsuitable for cheese facilities. Phosphine fumigations take much longer than methyl bromide fumigations and are not a feasib le alternative when rapid fumigations are needed; is corrosive to certain metals; is limited by temperature. Sulfuryl fluoride has been determined not to be efficacious on mites. Therefore, sulfuryl fluoride will not be able to replace methyl bromide in this sector. Also, adoption of not in kind alternatives, such as controll ed atmospheres, cold, and carbon dioxide under pressure, would require major investments for appropriate treatment units and /or retrofi tting of existing cheese manufacturing facilities.

FACILITIES: Primarily this sector is treating only th e portions of the faci lities that contain electronic components and have machinery with c opper and copper alloy part s. These facilities are under intense pressure from many insect pests. The majority of these food processors do not target any of their commodities to be fumiga ted with methyl bromide, although some may be present in the equipment during fumigation.

Food processing facilities in the United States have reduced the number of methyl bromide fumigations by incorporating many different techniques to contro l pests. The most critical strategy implemented is IPM, especially sanitation, in all areas of a facili ty. Facilities are now 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 (e.g. space treatments with fogging materials such as va pona, pyrethrins, IGR’s), spot treatments with heat or phosphine will be used in areas that ar e suitable. Incoming ingr edients are inspected for insect pests and may be treated with phosphine. These techniques do not di sinfest a facility but are critical in monitoring and managing pests, and hopefully preventing outbreaks. However, when all these methods fail to control a pest prob lem, facilities must rely on fumigation, to kill

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 3

### insects with in the equipment, inaccessible areas, a nd even the walls of the structure. There are two primary fumigants available to this indus try that may accomplish these tasks: methyl bromide and sulfuryl fluoride.

Herbs and Spices

Methyl bromide is requested for mills where herbs and spices are blended and mixed with grain based product into packages (such as for pi zza mixes, fish batter, biscuit mixes) or they may be packaged separately and then added to pre-packaged goods. These facilities are similar to food processing facili ties and mills in that there are silos, mixing areas, packaging areas, etc. These facilities utilize methyl brom ide to target pests pres ent in inaccessible areas of the structure, such as the equipment and bui ldings. The ingredients or finished products that may be stored on-site are not necessarily targeted for fumigation. However, the problem

in some of these facilities is that ingredients and products are all under one roof without any way to completely segregate the different areas.

Fumigants of choice for treating herb and sp ice commodities are ETO, PPO, irradiation and phosphine. These alternatives are not feasible to disinfect the facility itself.

See the discussion below on why SF is not a feasible alternative in herb and spice manufacturing

facilities.

T ABLE 2. N OMINATION A MOUNT

Processed Foods Spices and Herbs Cheese Processing Plants Sector Total /
Average

Quantity Requested for 2011: Amount (kgs) 14,498 1,055 1,812 17,365

Quantity Recommended by

MBTOC/TEAP for 2011 : Amount (kgs) 14,498 1,055 1,812 17,365

Amount (kgs) 14,498 1,055 1,812 17,365

Volume (1000 m 3 ) 1,676 122 91 1,889

Rate 9 9 20 9

Transition from 2011 Baseline Adjusted Value Percentage (%) 0% 0% 0% 0%

Amount (kgs) 

### 14,498 1,055 1,812 17,365

Volume (1000 m 3 ) 725 53 91 869

Rate 20 20 20 20 Quantity Approved by Parties for

2011:

Quantity Required for

2012 Nomination: SECTOR NPMA



### 2. SUMMARIZE WHY KEY ALTERNA TIVES ARE NOT FEASIBLE

This nomination is for facilities, or portions of facilities, that are unsuita ble for the alternatives, and where the alternatives are not economically f easible. Sulfuryl fluoride is highly dependent upon temperature, so should a facility need fumi gation during cold temperatures, this chemical may not be a cost-effective soluti on. In addition sulfur yl 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, es pecially in the comput ers and other electronic

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 4

### process control instrum entation. Heat is de pendent 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 ev enly distribute heated air; and the availability

of convenient and economical sources of heat. Also heat may not be a viable option for treatment of food products or commodities.

There are also some regulatory issues with sulf uryl fluoride related to the commodities that may be directly fumigated. For example, according to the Profume® label pasta is not listed as a material approved for direct treatment. Therefor e, the interpretation is that all pasta products would need to be removed from treatment areas or sufficiently protected to prevent the formation of sulfuryl fluoride residues with in the pasta products. The industr y is concerned that this would eliminate the possibility of u tilizing SF in warehousing or ingred ient storage areas as it would not be feasible to empty these spaces. Tarp ing items or tarping off warehouses still leaves facilities with liability issues as SF can penetrate plastic sealing material, or if the tarp were to fail, the product would be exposed.

The objection by the Fluoride Action Network, Beyond Pesticides, and Environmental Working Group against the tolerances of sulf uryl fluoride is still pending.

3. SUMMARY OF RECENT RESEARCH

Cheese There has been no research specific to cheese, as these facilities are only fumigated when mites are found during a USDA inspection. However, researchers investigating dry cured pork products are including cheese in their studies as the arthropod pests ar e the same. For the convenience of MBTOC, the research informati on from the US nomination for dry cured pork products appears below.

In the spring of 2007 a proposal was submitte d to USDA CSREES Integrated Research, Education, and Extension Competitive Grants Pr ogram- Methyl Bromide Transitions by several meat scientists and an entomologist. This proposa l was recently funded for th e next three years.

There are several objectives to this multiple year research program: First is to determine the

effectiveness of chemical contro ls (sulfuryl fluoride, phosphine, a nd methyl bromide) against all life stages of both mold mites ( Tyrophagus putrescentiae ) and red legged ham beetles ( Necrobia rufipes ). Second objective is to determine the e ffectiveness of carbon dioxi de and ozone against all life stages of both mold mites and red legged ham beetles. The third objective is to test the effects of sulfuryl fluoride, phosphine and methyl bromide on the quality and safety of the dry cured hams. The fourth objective is to conduct an economic analysis of the alternatives demonstrated to be technically viable alterna tives for methyl bromide in this industry.

The results of sulfuryl fluorid e efficacy investigations on Tyrophagous putrescentiae , ham mite,

and Necrobia rufipes , red-legged ham beetle, were presen ted at the 2008 MBAO Conference, in Orlando, Fl. The studies included eggs and a mixture of adults and nymphs of mites and eggs, large larvae, pupae and a dults of beetles. The experiments were conducted for 48 hours at 23° C

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 5

### at various co ncentrations of sulfuryl fluoride. The investigators achieved 100% mortality of redlegged ham beetle adults and pupae at about 4.0 g/m 3 

### , 100% mortality of larvae at 5.7 g/m 3



### . Eggs of red-legged ham beetles died at 24.0 g/m 3 

### of sulfuryl fluoride, well below the maximum label rate. (Phillips, et al. 2008) Mortality of ham mites required higher concentrations of sulfuryl fluoride. A con centration of about 100.3 g/m 3 

### was necessary to obtain 100% mortality of adults and nymphs under the test conditions. However this concentration obtained only a 95% mortality of mite eggs. This is about three time s the legal label rate. (P hillips, et al. 2008)

Facilities

Fumigants At the November 2009 Methyl Bromide Alterna tives Outlook Conference, the results of 2009 research conducted by Hartzer, et al, were presented. The 380,000 cubic foot mill at Kansas State University was fumigated 4 times in 2009 – twice each with methyl bromide and sulfuryl

fluoride.

Bioassays of all life stages of the red flour beet le were conducted from 25 locations in the mill.

The results were as follows:

Table 1. Summary of key resulting fumigati on parameters from the four experiments.

MB1 SF2 MB3 SF4
Starting time 6:40 PM May 6 th , 09 6:00 PM May 27 th , 09 2:50 PM Aug 11 th , 09 2:45 PM Aug 19 th , 09
Exposure (hr) 24 24 24 24 Total gas used (kg) 181.4 (400 lb) 567.0 (1250 lb) 159 (350 lb) 511 (1125 lb)

Indoor temp (C) 22 - 23 23 - 26 27 - 31 28 - 32 Outdoor temp (C) 15 - 29 14 - 26 19 - 34 16 - 27

Indoor RH (%) 39 - 50 34 - 44 40 - 60 40 - 55
Outdoor RH (%) 37 - 91 25 - 88 30 - 90 45 - 95 Avg wind spd (m/s) 1.65, 3.52, 7.12 3.67 2.16 3.0, 6.9
HLT (hr) 111, 16.4, 10.2 19.7 26 26.1, 9.9
Ct product (g-hr/m 3 ) 283 - 327 923 - 1191 268 - 318 663 - 1003 

### Source: Hartzer, et al. 2009

Note that the average quantity of methyl bromide used was 170.2 kg (375 pounds). The average quantity of sulfuryl fluoride used was 539 kg ( 1187.5 pounds), or about 317 percent greater. This presents an obstacle to wider adoption of su lfuryl fluoride, as i ndustry efforts toward environmental sustainability discourage pesticide usage.

However, also note that in the first sulfuryl fluoride fumigation (SF2) the temperature in the mill was an average of 24.5oC (76.1oF). At this temper ature, the SF Fumiguide instructs the user to apply 768 kg (1,694 pounds) of the fumigant for optimal results, a requi rement of about 451 percent more gas than need ed with methyl bromide.

Thus, a 5.6oC (10oF) lower temp erature increased the required SF dosage by an additional 42

percent.

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 6

### The results achieved with the lower dosage are in teres ting. At the lower dosage level, mortality of red flour beetle eggs was found to be as low as 42 percent, with an average egg mortality of less than 84 percent. Mortality rates on all life stages for both methyl bromide fumigations and the sulfuryl fluoride fumigation c onducted at 30oC (86oF) were vi rtually 100 percen t. It is, of course, theoretically possible to introduce auxilia ry heat to bring the mill temperature up to a

level that would facilitate a more effective SF tr eatment. However, that creates additional costs to a treatment that is already significantly more expensive, as describe d below in “4. Economic Impacts.”

Heat In 2009, Brijwani, et al. conducted research at the Kansas State University flour mill. They conducted two treatments, one in May and anothe r in August. Temperatures ranged from 50- 60oC (122-140oF).

At different locations within the mill it took from 9-22 hours (May treatment) and 6-22 hours (August treatment) to reach the target temperat ure of 50oC. Where mort ality was less than 100 percent, this was attributed to slow heating rates and/or not being able to hold temperatures

above 50oC for several hours.

Mortality of insects was 100 per cent for all life stages except for boxes in 9.2 percent of the compartments in the May treatm ent and 7.6 percent of the insect compartments in the August

treatment.

They concluded that heat is an effective treatmen t, so long as temperatures reach and are held at 50oC. The Kansas State University mill is nearly ne w, is of slipform concrete construction and is

small relative to the size of a co mmercial mill. Therefore it likely presents the best-case scenario for the effectiveness of high heat treatments. It would likely be more difficult to reach and hold that insecticidal temperature in a commercial mill, especially since most are older, constructed of various materials and are typically 1.0 – 2.0 milli on cubic feet in size. Achieving and holding the temperature at insecticidal levels in commerci al mills of that size would present significant technical and economical challenges.

4. ECONOMIC INFEASIBILITY OF ALTERNATIVES

T ABLE 2. E CONOMIC S UMMARY FOR EACH A LTERNATIVE


### M ETHYL


### B ROMIDE


### A LTERNATIVE 

### E CONOMIC 

### S UMMARY



### H EAT


### T REATMENT Heat treatments are technically and economically feasible in some cases. Most insects do not survive more than 12 hours when exposed to 45 o C or more than 5 minutes when exposed to 50 o C (Fields, 1992). In very cold regions, heat is costly and production time is lost for heat up. In old facilities, high heat could inflict structural damage. Also, this approach is not feasible for treating commercial-scale commodity volumes, as heat is a poor penetrator of packaging, boxes, and commodities. Also, structures w ith many concrete partitions are not good candidates for heat treatment becau se heat may not be evenly distributed;

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 7hence, efficacy is reduced.

Under laboratory conditions, brief exposure of commodities to high temperatures may eliminate insects without adversely affecti ng product quality. However, high heat can have an advers e affect on food quality (e.g., cheese).

For food processing facilities which are able to convert to heat treatment, there may be economic losses from additional production downtimes in cold facilities due to longer fumigation time. There are other food processing facilities in areas

of United States where heat treatment is not feasible. Economic losses due to downtime with heat treatment are persistent. However, some facilities experience better control with heat than fumigation due to leaky structures that allow gas to escape.



### P HOSPHINE 

### ( ALONE OR IN

COMBINATION 

### ) Although phosphine does kill insects, it is corrosive to metals, especially copper and its alloys (bronze and brass); these metals are important components of the electronics that run the manufacturing equipment. In addition, some equipment (e.g., motors, mixers, etc.) has metal parts that contain copper. This alternative is already being used in the areas without electronics and where temperatures are

not a factor.

Phosphine also requires a longer application time compared to methyl bromide. Phosphine fumigation takes 3-10 days, depending on temperature, compared to 1 day for MB (Hartsell et al., 1991, Zettler, 2002, Soderstrom et al., 1984, phosphine labels). An additional 2 da ys are needed for outgassing phosphine. Phosphine fumigation is least feasible during the colder winter months when, according to label directions, the minimum exposure periods increases to 8-10 days (plus two days for aeration) when commodity temperature decreases to 5 o C

- 12 o C. Phosphine is not used when commodity temperature drops below 5 o C (Phosphine and Eco2fume® labels). Phos phine is not a suitable alternative to methyl bromide when rapid fumigations ar e needed to meet customer timelines.

Resistance to this fumigant has also been reported for several stored product pests. Furthermore, cheese makers claim that phosphine causes damage to the cheese, “melting of the cheese” and may cause acid residue, acrid off-odors and

affect flavor.



### I RRADIATION Although rapid and effective, irradiation al one may result in living insects left in the treated product. Treated insects are sterilized and stop feeding but are not immediately killed. The high dosages n ecessary to cause immediate mortality in target insects may reduce product quality. Irradiation also requires major capital expenditures and irradiated food are not widely accepted by consumers.



### C ARBON


### D IOXIDE 

### ( HIGH

PRESSURE 

### ) Facilities in the United States are not airtight enough for modified atmospheres or carbon dioxide to be effective primarily due to age of the facility; specifically, most facilities are more than 25 years old.



### S ULFURYL


### F LUORIDE A portion of the food processing facilities can economically convert to sulfuryl

fluoride. Other facilities cannot due to economic losses that would result from higher treatment costs which arise at lower temperatures. For a small percentage, SF is not technically feasible due to cold temperatures. Adding heat to increase the efficacy of SF is also not an economically feasible option. In addition there are current label restrictions for food commodities (page 10 of

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 8USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 9 ProFume label).



### Sulfuryl Fluoride

Results of the assessment of usi ng sulfuryl fluoride as an alte rnative to methyl bromide are provided in Tables 2-4. For purpos es of this analysis, current prices of sulfuryl fluoride and methyl bromide were assumed equal and plant temperatures are assumed to be 29.44 degrees centigrade (85 degrees Fahrenheit). This analysis only covers cases where sulfuryl fluoride is a technically feasible alternative to methyl br omide and its use is not restricted by label

instructions or state re gulations. For example, sulfuryl fluor ide is technically feasible only in facilities that do not prepare mi xed products (e.g., cake mixes).Fum igation with sulfuryl fluoride at lower temperatures controlli ng all pest life stages is inf easible due to prohibitively high application rates and minimal efficacy.

Heat Treatment

Potential economic losses were estimated for th e food-processing facilitie s that have not been

converted to heat treatment. Th is analysis only cove rs cases where heat treatment is technically feasible; it does not cover situations where h eat would degrade the commodity being processed (those with fats and edible oils).

Production downtime is estimated at one additional day for cold facilities due to longer heat-up period. Costs of heat treatment include all labor, transportation, and fuel. Fuel used is generally propane and could increase significantly with fuel costs.TABLE3.ANNUALECONOMICIMPACTS OFMETHYLBROMIDEALTERNATIVES FORNPMASTRUCTURENPMA Structures(Spices & Food Processors)1UnitsMeBr2SF2Heat: 7oCHeat: 29 oCSF + 7oC HeatTotal Operating Costs$/yearnananananaTotal Fumigation/Heat Costs$/year$ 24,000.00$ 30,000.00$ 70,000.00$ 150,000.00$ 100,000.00Quantity of Fumigant(One treatment per year)kgs/facility5221,134nananaFumigant cost (i.e., gas)$/year$ 9,000.00$ 15,000.00nana$ 15,000.00Other fumigation costs(i.e., labor, equip., etc.)$/year$ 15,000.00$ 15,000.00$ 70,000.00$ 150,000.00$ 85,000.00Other Operating Costs$/yearnananananaTime Lostdays00010Total Loss (MeBr to alt)$/year$ -$ 6,000.00$ 46,000.00$ 126,000.00$ 76,000.00Average Facility Loss per KgMeBr Requested$/kg MBrequestedna$ 11.50$ 88.18$ 241.55$ 145.701Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility2Temperature at 29 degrees CSF costs vary depending on target pest, temp & HLT.USA CUN12 Post Harvest National Pest Management AssociationPage 10

### CITATIONS

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 Alternativ es Outlook Conference, San Diego, November

2009. Available at: http://mbao.org

.

Brijwani, M., B.Subramanyam, M. Hartzer, D. E. Maier, W. Chayaprasert, S. Savoldelli, P. Flinn, and J. Campbell. 2009. Efficacy of St ructural Heat Treatments Against Tribolium castaneum Life Stages. Presentation at Met hyl Bromide Alternatives Outlook Conference, San Diego, November 2009. Available at: http://mbao.org

.

USA CUN12 Post Harvest National Pest Management Association Page 11