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 25, 2011

Mr. Marco Gonzalez

Executive Director 

UNEP – Montreal Protocol

and

Dr. John Thompson

Division Director

Office 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 included in this one letter. I note, however, that MBTOC Soils may have further 

questions on the Research 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. We fully recognize 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 

commodities and sectors, the implications for SF use during the 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 based 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 questions 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 damage, 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, since 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 differences in the intended dosage rates for all three commodity 

elements. Appendix A shows the two tables for ease of reference. What 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 retrofit 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 chambers 

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 

question 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 having, 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 hours 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 the 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? This illustration is applied the full 

investment cost of phosphine chambers in one year. At that rate it 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 USEPA 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 guidance 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 (page 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 percentage 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? What 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 Regulatory Issues section above, MBTOC is concerned about the 

possible effect of the proposed 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 construction? 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 is 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. 

Research 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 to 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?

Please 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 nomination and correct it?

Regardless of the nominated volume, this CUN is unsupported 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 meeting but we recognize there are delays in the CUNs and 

correspondence this year.

Yours sincerely,

Michelle Marcotte

MBTOC Co-Chair

 
APPENDIX A

US COMMODITY CUN SUBMITTED IN 2010

TABLE 2. NOMINATION AMOUNT 

 California Dried 

Plum Board 

 California Walnut 

Commission 

 California Date 

Commission 

 Sector Total / 

Average 

Quantity Requested for 2011: Amount (kgs) 6,266 1,170 2,009 9,445

Quantity Recommended by 

MBTOC/TEAP for 2011 : Amount (kgs) 3,317 620 1,063 5,000

Amount (kgs) 3,317 620 1,063 5,000

Volume (1000 m3) 392 130 97 619

Rate 8 5 11 8

Transition from 2011 Baseline 

Adjusted Value

Percentage (%) 0% 15% 0% -2%

Amount (kgs) 3,317 527 1,063 4,907

Volume (1000 m3) 138 12 51 201

Rate 24 45 21 24

Quantity Required for 

2012 Nomination:

Quantity Approved by Parties for 

2011:

SECTOR

COMMODITIES

US Commodity CUN submitted in 2011

TABLE 2. NOMINATION AMOUNT 

 California 

Dried Plum 

Board 

 California 

Walnut 

Commission 

 California Date 

Commission 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 3,317 558 1,063 4,938

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 829 527 1,063 2,419

Amount (kgs) 829 527 1,063 2,419

Volume (1000 m3) 392 130 97 619

Rate 2 4 11 4

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -66% -66% -66% -66%

Amount (kgs) 282 179 361 822

Volume (1000 m3) 138 12 51 201.4

Rate 2 14 7 4

Quantity Required for 

2013 Nomination:

Quantity Approved by Parties for 

2012:

SECTOR

COMMODITIES