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: 

TABLE 1. QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF NOMINATION

YEAR NOMINATION AMOUNT (KILOGRAMS) 

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 critical 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 1
Title: 

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS: 

Contact/Expert Person: Jack Housenger 

Title: Division Director 

Address: Biological and Economic Analysis Division 

Office of Pesticide Programs 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. Mailcode 7503P 

Washington, D.C. 20460 

 U.S.A. 

Telephone: (703) 308-8200 

Fax: (703) 308-7042 

E-mail: housenger.Jack@epa.gov

 

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

1. PAPER DOCUMENTS: 

Title of paper documents and appendices 

No. of pages Date sent to Ozone 

Secretariat 

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 NATIONAL PEST MANAGEMENT 

ASSOCIATION 

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

This sector includes cheese and food processing plants treated by National Pest Management 

Association (NPMA) members and are not included in the Commodity or in the Food Facilities 

Chapters of the US nomination. Food Processing Facilities included in this application are: 

processed foods (such as chips, crackers, cookies and pasta), spices and herbs, and cheese 

processing plants. Methyl bromide is typically utilized 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 fumigations of product or packaging material. These 

facilities are under intense pressure 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 manufacturers may target their 

products during fumigations with methyl bromide when a mite infestation is identified by USDA 

inspection and a fumigation is ordered. Cheese does not have a technically and economically 

feasible alternative available. Whereas sulfuryl 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 feasible 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 controlled atmospheres, cold, and carbon dioxide under pressure, would 

require major investments for appropriate treatment units and /or retrofitting of existing cheese 

manufacturing facilities. 

FACILITIES: Primarily this sector is treating only the portions of the facilities that contain 

electronic components and have machinery with copper and copper alloy parts. 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 fumigated 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 control pests. The most critical 

strategy implemented is IPM, especially sanitation, in all areas of a facility. 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 vapona, pyrethrins, IGR’s), spot treatments with 

heat or phosphine will be used in areas that are suitable. Incoming ingredients are inspected for 

insect pests and may be treated with phosphine. These techniques do not disinfest a facility but 

are critical in monitoring and managing pests, and hopefully preventing outbreaks. However, 

when all these methods fail to control a pest problem, facilities must rely on fumigation, to kill 

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 3
insects within the equipment, inaccessible areas, and even the walls of the structure. There are 

two primary fumigants available to this industry 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 pizza 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 facilities and mills in that there are silos, mixing areas, packaging 

areas, etc. These facilities utilize methyl bromide to target pests present in inaccessible areas 

of the structure, such as the equipment and buildings. 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 spice 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. 

TABLE 2. NOMINATION AMOUNT 

Processed Foods Spices and Herbs Cheese 

Processing Plants 

 Sector Total / 

Average 

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

Quantity Recommended by 

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

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

Volume (1000 m3) 122 1,676 91 1,889 

Rate 9 9 20 9 

Transition from 2011 Baseline 

Adjusted Value Percentage (%) 0% 0% 0% 0%

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

Volume (1000 m3) 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 ALTERNATIVES ARE NOT FEASIBLE 

This nomination is for facilities, or portions of facilities, that are unsuitable for the alternatives, 

and where the alternatives are not economically feasible. Sulfuryl fluoride is highly dependent 

upon temperature, so should a facility need fumigation during cold temperatures, this chemical 

may not be a cost-effective solution. In addition sulfuryl fluoride requires higher dosages for egg 

kill, a paramount concern in certain facilities. Phosphine can be explosive and is corrosive to 

many metals that are present in facilities, especially in the computers and other electronic 

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 4
process control instrumentation. Heat is dependent on several parameters: the structural 

composition, as different components expand and contract at different rates; the building 

design/layout factors, which affect the ability to evenly distribute heated air; and the availability 

of convenient and economical sources of heat. Also heat may not be a viable option for 

treatment of food products or commodities. 

There are also some regulatory issues with sulfuryl 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. Therefore, 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 within the pasta products. The industry is concerned that this would 

eliminate the possibility of utilizing SF in warehousing or ingredient storage areas as it would 

not be feasible to empty these spaces. Tarping 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 sulfuryl 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 are the same. For the 

convenience of MBTOC, the research information from the US nomination for dry cured pork 

products appears below. 

In the spring of 2007 a proposal was submitted to USDA CSREES Integrated Research, 

Education, and Extension Competitive Grants Program- Methyl Bromide Transitions by several 

meat scientists and an entomologist. This proposal was recently funded for the next three years. 

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

effectiveness of chemical controls (sulfuryl fluoride, phosphine, and 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 effectiveness of carbon dioxide 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 alternatives for methyl bromide in this industry. 

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

and Necrobia rufipes, red-legged ham beetle, were presented 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 adults of beetles. The experiments were conducted for 48 hours at 23° C 

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 5
at various concentrations of sulfuryl fluoride. The investigators achieved 100% mortality of redlegged ham beetle adults and pupae at about 4.0 g/m3

, 100% mortality of larvae at 5.7 g/m3. 

Eggs of red-legged ham beetles died at 24.0 g/m3 of sulfuryl fluoride, well below the maximum 

label rate. (Phillips, et al. 2008) Mortality of ham mites required higher concentrations of 

sulfuryl fluoride. A concentration of about 100.3 g/m3 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 times the legal label rate. (Phillips, et al. 2008) 

Facilities

Fumigants 

At the November 2009 Methyl Bromide Alternatives 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 beetle were conducted from 25 locations in the mill. 

The results were as follows: 

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

MB1 SF2 MB3 SF4 

Starting time 6:40 PM May 6th, 09 6:00 PM May 27th, 09 2:50 PM Aug 11th, 09 2:45 PM Aug 19th, 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/m3

) 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 sulfuryl fluoride, as industry 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 temperature, the SF Fumiguide instructs the user to 

apply 768 kg (1,694 pounds) of the fumigant for optimal results, a requirement of about 451 

percent more gas than needed with methyl bromide. 

Thus, a 5.6oC (10oF) lower temperature 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 interesting. 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 conducted at 30oC (86oF) were virtually 100 percent. It is, of 

course, theoretically possible to introduce auxiliary heat to bring the mill temperature up to a 

level that would facilitate a more effective SF treatment. However, that creates additional costs 

to a treatment that is already significantly more expensive, as described 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 another 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 temperature of 50oC. Where mortality 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 percent for all life stages except for boxes in 9.2 percent of the 

compartments in the May treatment and 7.6 percent of the insect compartments in the August 

treatment. 

They concluded that heat is an effective treatment, so long as temperatures reach and are held at 

50oC. The Kansas State University mill is nearly new, is of slipform concrete construction and is 

small relative to the size of a commercial 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 million cubic feet in size. Achieving and holding the 

temperature at insecticidal levels in commercial mills of that size would present significant 

technical and economical challenges. 

4. ECONOMIC INFEASIBILITY OF ALTERNATIVES 

TABLE 2. ECONOMIC SUMMARY FOR EACH ALTERNATIVE

METHYL 

BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

HEAT 

TREATMENT

Heat treatments are technically and economically feasible in some cases. Most 

insects do not survive more than 12 hours when exposed to 45o

C or more than 5 

minutes when exposed to 50o

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 with many concrete partitions are not 

good candidates for heat treatment because heat may not be evenly distributed; 

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 7
hence, efficacy is reduced. 

Under laboratory conditions, brief exposure of commodities to high 

temperatures may eliminate insects without adversely affecting product quality. 

However, high heat can have an adverse 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. 

 

PHOSPHINE 

(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 days 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 5o

C 

- 12 oC. Phosphine is not used when commodity temperature drops below 5o

C 

(Phosphine and Eco2fume® labels). Phosphine is not a suitable alternative to 

methyl bromide when rapid fumigations are 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. 

IRRADIATION

Although rapid and effective, irradiation alone 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 necessary 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. 

CARBON 

DIOXIDE (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. 

SULFURYL 

FLUORIDE

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 8
USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 9

ProFume label). 

Sulfuryl Fluoride

Results of the assessment of using sulfuryl fluoride as an alternative to methyl bromide are 

provided in Tables 2-4. For purposes 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 bromide and its use is not restricted by label 

instructions or state regulations. For example, sulfuryl fluoride is technically feasible only in 

facilities that do not prepare mixed products (e.g., cake mixes).Fumigation with sulfuryl fluoride 

at lower temperatures controlling all pest life stages is infeasible due to prohibitively high 

application rates and minimal efficacy. 

Heat Treatment

Potential economic losses were estimated for the food-processing facilities that have not been 

converted to heat treatment. This analysis only covers cases where heat treatment is technically 

feasible; it does not cover situations where heat 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. 
TABLE 3. ANNUAL ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FOR NPMA STRUCTURE

NPMA Structures (Spices & Food Processors) 1 Units MeBr 2 SF 2 Heat: 7oC Heat: 29 oC Total Operating Costs $/year na na na Total Fumigation/Heat Costs $/year $ 24,000.00 $ 30,000.00 $ 70,000.00 $ 150,000

Quantity of Fumigant (One treatment per year) kgs/facility 522 1,134 na Fumigant cost (i.e., gas) $/year $ 9,000.00 $ 15,000.00 na Other fumigation costs (i.e., labor, equip., etc.) $/year $ 15,000.00 $ 15,000.00 $ 70,000.00 $ 150,000

Other Operating Costs $/year na na na Time Lost days 000Total Loss (MeBr to alt) $/year $ - $ 6,000.00 $ 46,000.00 $ 126,000Average Facility Loss per Kg MeBr Requested 

$/kg MB 

requested na $ 11.50 $ 88.18 $ 241

1 Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility 

2 Temperature at 29 degrees C 

SF costs vary depending on target pest, temp & HLT. USA CUN12 Post Harvest National Pest Management Association Page 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 Alternatives 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 Structural Heat Treatments Against Tribolium 

castaneum Life Stages. Presentation at Methyl Bromide Alternatives Outlook Conference, 

San Diego, November 2009. Available at: http://mbao.org. 

USA CUN12 Post Harvest National Pest Management Association Page 11