## United Nations Environment Programme Methyl Bromide Technical Options Committee

Structures and Commodities (SC)

MBTOC Co

- Chair:

Ms Michelle Marcotte (Canada) email: marcotteconsulting@comcast.net

February 2 5 , 2011

Mr. Marco Gonzalez

Executive Director

UNEP

– Montreal Protocol

and

Dr. John Thompson

Division Director

O ffice of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2657 Washington, D.C. 20520

U.S.A. Thompsonje2@state.gov

Good morning Marco and John,

MBTOC SC has completed its first level of review of the US postharvest CUNs, and the element of the research CUN pertaining to cured pork. As part of this process, MBTOC has some questions to assist us to continue the review. Our questions for the postharvest CUNs and the element of the research CUN which pertains to cured pork

are all in cluded in this one letter. I note, however, that MBTOC Soils may have further questions on the R esearch CUN, but if so, they will be found in the letter from Soils or QPS

.

Regulatory Issues

We acknowledge that USG has requested a bilateral meeting with MBTOC and we look

forward to it. We suggest Monday afternoon at 2:30 pm local time.

One important and cross

- cutting issue raised in all the reviews of postharvest CUNs

concerns the proposed regulatory change for SF. W e fully recogniz e that this domestic regulatory issue is entirely the purview of the USG

. MBTOC members have , however, raised numerous questions. Members have asked how or if this proposed regulation will
become law and when, what is the timeline for removing SF from use in various

commoditie s and sec t ors

, the implications for SF use during th e transition period

, and

the implication to increase MB use . Another concern is what the USG will do when PH3 resistant pests are found in commodities ? For example, does USG anticipate submitting

a CUN ba sed on control of resistant pests?MBTOC has received some information on these issues from the SF supplier and user

groups but really they need to hear the information from the government. It is possible that USG might not be able to answer these questio ns at this time , but they were raised, and so I am raising them here.

MBTOC is also charged with reviewing the economics of battling pest infestations in stored commodities and food processing structures and is very concerned about the

economics of dama ge, waste and food safety lapses that can be caused by infestation and subsequent affect on the returns to an industry. Thus, the proposed loss of SF to

this sector is a concern to us.

How will research projects be affected by the proposed SF regulation?

Additionally, s ince other Parties have Emergency Use provisions in domestic regulation, MBTOC members may assume that this is also true of the US . USG might want to explain the American laws and regulations concerning Emergency uses to members. It might affect CUN recommendations if members think that Emergency Use provisions might be used, so it would be best if the situation was clear.

US Commodities CUN

MBTOC notes the significant decrease (

- 66%) in volume of MB requested for 2013 in

transition from 2012 baseline.

The review team compared the US CUN Table 2 from 2010, versus the US CUN Table 2 from 2011, and found difference s in the intended dosage rates for all three commodity elements. Appendix A shows the two tables for ease of reference. W hat is the reason for the change in dosage rates, or has an error been made in the CUN13 Table 2?

The CUN notes that more time is needed to allow transition to the use of alternatives, specifically mentioning the need to purchase equipment, build or retro fit fumigation

chambers etc (CUN Section 2, page 4)

. The 2011 CUN requests MB for 2013, which should mean that there are two intervening years for equipment purchases. Please provide details of the annual equipment purchases, building or retrofitting of ch ambers accomplished each year and expected purchases, building retrofitting etc is required each year to accomplish total phase out in dried fruit sector particularly.

Is the research of Dr. Walse on pest control with SF in dates ongoing? ( See also
quest ion on research in regulatory questions above.)

Aside from the regulatory issues mentioned above, we have heard that the EU has either changed or revoked the tolerance for F residues resulting from SF use on in

- shell

walnuts. We do not know if this is ha ving

, or will have

, repercussions for the use of SF on walnuts for shipment to the EU holiday market. Could USG please inform us if the EU has changed F residue tolerances and whether this has impacted the demand for MB by

the walnut sector?

Additionally, members have raised examples where there may have been mistakes in the CUN, and the USG may want to fix these to improve our ability to understand the CUN. For example (1), last para on page 9 repeats "four hours for fumigation" when we think you mean 4 h ours for fumigation and 4 hours for ventilating, off gassing, unloading and reloading chamber. (Correct?)Example (2), table 6 has two lines for production, the one in MT shows 464,270 equaling

349,284,269 kg.

Example (3), line 13 of table 7 shows th e cost difference vs MB is (3,716) [13,646

- 17,363 from line 12] for SF corresponding to a lower cost for SF. So why is the phosphine value 3,932 also in parentheses which indicates a cost savings when the calculation is a higher cost compared to MB? T his illustration is applied the full investment cost of phosphine chambers in one year. At that rate i t would take 9 years to recover the additional investment cost for phosphine chambers. USG may wish to

comment.

US CUN Structures

The CUN nominates 4. 665 tonnes for pet food facilities. While acknowledging a very laudable 66% reduction for the 2013 nomination over the 2012 amount, MBTOC was surprised to have any nomination for pet food at all. Correspondence obtained last year

between the US NPMA and US EPA explaining a new interpretation on inadvertent fumigation during SF fumigation seemed to result in the withdrawal of the NPMA from the CUN process. We assumed that pet food facilities were essentially the same and that the interpretation and new guidan ce for inadvertent fumigation would also apply to

them. Could USG please explain the differences between food processing and pet food processing facilities that results in the need for pet food facilities to continue to nominate

MB? MBTOC notes the CUN (pa ge 5) cites Holcomb and McLean (2010) showing 5 yr pest control success with IPM without fumigation.

The CUN, Section 2, pages 4

- 5 are essentially the same as Section 2, in the 2010 CUN (with the exception of the SF regulatory note). What is the percenta ge breakdown of the adoption of SF versus heat treatment or other treatments in each sector? What is the rate of adoption of alternatives in each sector? Can USG provide data on the percentage of adoption of alternatives achieved by each sector per year ? W hat barriers remain to the continued adoption of alternatives in each sector? This will assist us to understand

transition rates and requirements.

As noted in the R egulatory I ssues section above, MBTOC is concerned about the possible effect of the propos ed phase out of SF in this sector. Section 2, Page 5 of the CUN notes that 25% of flour mills are thought to be unable to use heat treatment due to

wood construction. Is more information available about the number of mills and mill

volume that are wood con struction ? Does USG contend that this 25% of mills constitutes

an eventual baseline of MB use in this sector?

US CUN Cured Pork

MBTOC appreciates the detailed reporting and analysis of research in this sector and notes that ensuring ongoing research i s key to both supporting a CUN and resolving the difficult problems faced by the cured pork sector.

IPM enhancements may be the only avenue available to controlling pests in this sector

. R esearch that focuses on an evaluation of practical IPM enhancements may be needed

to allow reductions in MB use. Most meat processing facilities would incorporate pest control in a HACCP plan, so, the term IPM is not commonly used in meat processing. But, Southern cured pork seems to be a different scenario. MBTOC wants t o know specifically what IPM changes have been tried and found to be ineffective in this sector.Are there elements of the multi

- state cured pork research plan which test and evaluates

IMP elements specifically designed for cured pork establishments?

Pl ease also refer to comments in Research CUN concerning cured pork sector.

US CUN Research Amounts

– Cured Pork element

This CUN nominates 1.220 tonnes of MB for research in cured pork sector. This nomination represents an additional 32% of the total CUN for cured pork (3.730 tonnes)

. This nominated volume is so high that MBTOC feels certain it must be a mistake of at least one decimal point or more . Could USG please check the n omination and correct it?

Regardless of the nominated volume, this CUN is unsu pported by a research plan for the use of the MB and it must be supported before MBTOC can consider it. The citation of Decision IX/6 is insufficiently supportive of this CUN. MBTOC cannot proceed with an

evaluation of the research CUN without information on the research plan. Will this research be part of the multi

- state research program that has been ongoing in this

sector?

It might help if MBTOC understood what will happen to the remaining amount of MB if Parties were to grant the US an amount of MB for research, and the MB is not used for research in cured pork

.

Conclusion

Thank you for consideration of our information requests. MBTOC will next meet in Antalya Turkey March 14

- 19 ; we would appreciate receiving answers to our questions

ahead of the mee ting but we recognize there are delays in the CUNs and correspondence this year

.

Yours sincerel y,

Michelle Marcotte

MBTOC Co

- ChairA PPENDIX A

US C OMMODITY CUN SUBMITTED IN 2010

T ABLE 2

. N OMINATION A MOUNT



### US Commodity CUN submitted in 201 1

T ABLE 2

. N OMINATION A MOUNT