OMB Control # 2060-0482

Expires 10/31/2011

EPA Form # 5900-137 Post-harvest

For EPA Use Only ID # _______

SECTOR ___________________ 

UNITED STATES 

ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

2011 Application for Critical Use Exemption of Methyl Bromide 

for Post Harvest Use in the United States in 2014

WHY IS THIS 

INFORMATION 

NEEDED?

Under the Clean Air Act and the international treaty to protect 

the ozone layer (the Montreal Protocol on Substances that 

Deplete the Ozone Layer), the production and import of methyl 

bromide was phased out in the United States on January 1, 

2005. This application seeks information to support a U.S. 

request to produce and import methyl bromide for certain critical 

uses and circumstances beyond this 2005 phaseout date.

The information in this application will be used to review 

whether your use of methyl bromide is "critical" because no 

technically and economically feasible alternatives are available. 

In order to estimate the loss as a result of not having methyl 

bromide available, EPA needs to compare data (commodity 

prices, revenues, and costs) for your use of methyl bromide with 

uses of alternative pest control regimens. 

The information contained in this application is critical to process and assess the need for 

methyl bromide. Filling out this application in its entirety will bolster the U.S. government's 

ability to strengthen the nomination package for the international review boards. 

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose 

or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing

and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any 

previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; 

search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. 

Public reporting burden for this collection of information is estimated to average 38 hours per response and assumes a large 

portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may 

not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current 

OMB control number.
OMB Control # 2060-0482

Expires 10/31/2011

EPA Form # 5900-137 Post-harvest

INSTRUCTIONS

The information provided by you in this application will be used to evaluate the requested methyl bromide use. The 

U.S. and other countries that are parties to the Montreal Protocol On Substances That Deplete The Ozone Layer 

decided that: "a use of methyl bromide should qualify as "critical" only if the nominating Party determines that:

(i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a 

significant market disruption; and 

(ii) There are no technically and economically feasible alternatives available to the user that are acceptable from 

the standpoint of environment and health and are suitable to the crops and circumstances of the nomination ..." 

WHO 

APPLIES?

If you anticipate that you will need methyl bromide in 2014 because you believe there are no 

technically and economically feasible alternatives, then you should apply for the critical use 

exemption. This application may be submitted either by a consortium representing multiple 

users or by individual users. We encourage users with similar circumstances of use to 

submit a single application (for example, any number of post harvest users with similar 

commodity, pest, and structural conditions can submit a single application.)

If a consortium is applying for multiple methyl bromide users, the economic data should be for 

a representative or typical user within the consortium unless otherwise noted. If economic or 

technical factors (such as types of commodities) affecting the ability of this "representative 

user" to use alternatives are significantly different than other users in the consortium, more 

than one application should be submitted to reflect these differences.

Please contact your local, state, regional, or national commodity association and/or state 

representative agency to find out if they plan on submitting an application on behalf of your 

commodity group.

WHAT 

INFORMATION IS 

REQUIRED?

Critical use exemptions are valid for only one year and do not renew automatically. Users 

desiring to obtain an exemption for 2014 must apply to EPA. Because of the latest changes 

in registrations, costs, and economic aspects for producing critical use crops and 

commodities, all applicants will be required to fill out the application form completely. If these 

Worksheets are not submitted, EPA will not include the application in the U.S. nomination 

submitted for international consideration. 

HOW DO 

I APPLY?

You may either complete an electronic (Microsoft Word or Excel) or a printed version of the 

application. Please fill out each section in the application as completely as possible. If you 

are completing the printed version and need extra space you may attach additional sheets as 

needed. 

IS MY 

INFORMATION 

CONFIDENTIAL?

The applicant may assert a business confidentiality claim covering part or all of the 

information in the application by placing on (or attaching to) the information, at the time it is 

submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form of notice 

employing language such as trade secret, proprietary, or company confidential. Allegedly 

confidential portions of otherwise non-confidential documents should be clearly identified by 

the applicant, and may be submitted separately to facilitate identification and handling by 

EPA. If the applicant desires confidential treatment only until a certain date or until the 

occurrence of a certain event, the notice should so state. Information covered by a claim of 

confidentiality will be disclosed by EPA only to the extent, and by means of the procedures 

set forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no 

claim of confidentiality accompanies the information when it is received by EPA, it may be 

made available to the public by EPA without further notice to the applicant. 

Applicants submitting their application via e-mail assume responsibility for the confidentiality 

of the electronic message transmission.

WHEN IS THE 

INFORMATION 

NEEDED?

This application must be postmarked to the EPA address below no later than August 12.
OMB Control # 2060-0482

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EPA Form # 5900-137 Post-harvest

WHERE DO I 

SUBMIT THE 

APPLICATION?

Electronic address for applications: arling.jeremy@epa.gov

When submitting an application electronically, you should also sign Worksheet 1 

and email or fax it to 202-343-2338

Mailing address for applications 

being submitted by mail directly to 

the EPA:

US Environmental Protection Agency

Methyl Bromide Critical Use Exemption

Office of Air and Radiation

Stratospheric Protection Division

(6205 J)

1200 Pennsylvania Ave, NW

Washington, DC 20460

Address for applications being sent by 

courier or non-U.S. Postal overnight 

express delivery to the EPA:

US Environmental Protection Agency

Methyl Bromide Critical Use Exemption

Office of Air and Radiation

Stratospheric Protection Division

1310 L Street, NW

Suite 1047E

Washington, DC 20005

HOW CAN I 

RECEIVE 

ADDITIONAL 

INFORMATION?

If you have general questions about this application call:

Stratospheric Ozone Hotline at 1-800-296-1996

More information is also at http://www.epa.gov/ozone/mbr
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WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST 

INFORMATION FOR 2014

The following information will be used to determine the amount of methyl bromide requested and the 

contact person for this request. It is important that we know whom to contact in case we need additional 

information during the review of the application.

Is this information Confidential Business Information: Yes ___ No ___

If yes, the applicant assumes responsibility for the secure transmission of electronic submissions.

Applicant Name: 

Primary Contact: 

Contact Name: 

Address: 

Daytime Phone:

Cell:

Fax:

Email Address

Specialty: (check one) Agronomic ___ Economic ___

Alternate Contact: 

Contact Name: 

Address: 

Daytime Phone: 

Cell: 

Fax: 

Email Address: 

Specialty: (check one) Agronomic ___ Economic ___

I certify that all information contained in this document is factual to the best of my knowledge.

Signature: ______________________________________________ Date: _______

Print Name: _____________________________________________ Title: _______

Information in this application may be aggregated with information from other applications and used by 

the United States government to justify claims in the national nomination package that a particular use of 

methyl bromide be considered "critical" and authorized for an exemption beyond the 2005 phaseout. By 

signing below, you agree now to assert any claim of confidentiality that would affect the disclosure by 

EPA of aggregate information based in part on information contained in this application.

Signature: ______________________________________________ Date: _______

Print Name: _____________________________________________ Title: _______

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or 

disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; 

develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying 

information, processing and maintaining information, and disclosing and providing information; adjust the existing 

ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond 

to a collection of information; search data sources; complete and review the collection of information; and transmit or 

otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 

39 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many 

individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond 

to, a collection of information unless it displays a current OMB control number.
OMB Control # 2060-0482

Expires 10/31/2011

EPA Form # 5900-137 Post-harvest

WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST 

INFORMATION FOR 2014 (continued)

1. Location of Facility(ies): Enter the name and physical address of the facility(ies) where the proposed 

critical use of methyl bromide will take place. Provide more details about the location if relevant to the 

feasibility of alternatives to methyl bromide.

2. Commodity: Include all commodities that benefit from the application of methyl bromide in a 

fumigation cycle. 

3. Range of structure/facility size by processors included in this application: Insert number or 

percentage of users in each category.

0 to 1,000 (1,000 cu ft) 10,000 to 50,000 (1,000 cu ft)

1,000 to 5,000 (1,000 cu ft) 50,000 to 100,000 (1,000 cu ft)

5,000 to 10,000 (1,000 cu ft) over 100,000 (1,000 cu ft)

4. Climate Average Minimum Temperature: Individual users should enter their climate zone designation 

by reviewing the U.S. climate zone map located at the end of this workbook or it can be reviewed online 

at http://www.usna.usda.gov/Hardzone/ushzmap.html. If a consortium is submitting this application, 

please indicate the estimated percentage of consortium users in each climate zone. Please check all that 

apply.

1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b____ 7a____ 

7b____ 8a____ 8b____ 9a____ 9b ____ 10a____ 10b____ 11____

5. Is this applicant eligible for Quarantine and Preshipment (QPS) uses of methyl bromide:

Yes ___ No ___ If yes, indicate amount: ____ lbs

6. Has this applicant previously applied for Critical Use Exemption of methyl bromide:

Yes ___ No ___ If yes, indicate CUE #: ________

7. What is the amount of methyl bromide being requested by this application: (Do NOT include 

QPS amounts) If a consortium is submitting this application, the data should be the total for the 

consortium.

2013 2014 2015

A. Total Pounds Active Ingredient (a.i.) of Methyl 

Bromide

B. Total Actual Volume (1000 cu. ft.) Treated

C. Formulation (Ratio of MB/Pic) to be Used for the 

CUE

D. Use Rate (lbs a.i./1000 cu. ft.)

8. Please explain why there may be variations in the pounds or volume (1,000 cu ft) treated from 

year to year, especially if the request is higher this year than in previous years:

9. Please explain why methyl bromide is being requested:
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10. Do you anticipate that you will have any methyl bromide in storage after January 1, 2013:

Yes ___ No ___ If yes, please specify amount: _______ lbs

11. Have you adjusted the request for the following issues:

Regulatory Issues: Yes ___No ___ Pest Pressure: Yes ___No ___

Adoption of Alternatives: Yes ___No ___ Other (Please Explain): Yes ___No ___

_______________________________________________________________________
OMB Control # 2060-0482

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WORKSHEET 2: METHYL BROMIDE

Purpose of Data: To establish a baseline estimate of commodity treated, gross profits, and costs using 

methyl bromide. 

Instructions specific to each worksheet are located at the top of each sheet.

Worksheet Title

2-A Methyl Bromide - Pest and Commodity Information

If a consortium is submitting this application, the data for this table should reflect the 

representative user for the consortium. 

The purpose of this worksheet is to determine pest infestation and commodity 

information where methyl bromide is used. This forms the baseline for evaluating the 

impacts of using an alternative to replace methyl bromide.

2-B Methyl Bromide - Historical Use 2006 - 2010

If a consortium is submitting this application, all data should reflect the actual data for 

the consortium.

This worksheet provides data in actual usage for 2006 - 2010. 

2-C Methyl Bromide - Commodity Treated and Gross Profits for 2006 - 2010

If a consortium is submitting this application, the data for this table should reflect the 

representative user for the consortium. 

This worksheet provides commodity treated and gross profits for 2006 through 2010.

The purpose of this worksheet is to determine past gross profits when methyl bromide is 

used. This forms the baseline for evaluating the revenue impacts of using an alternative 

to replace methyl bromide.

2-D Baseline - Operating Costs for 2010

If a consortium is submitting this application, the data for this table should reflect the 

representative user for the consortium. 

This data is needed to estimate a baseline for operating costs in order to estimate 

changes in costs and the impact on operating profit and short-run economic viability as 

a result of not using methyl bromide.

The purpose of this worksheet is to determine operating expenses when methyl bromide 

is used. This forms the baseline for evaluating the cost impacts of using an alternative to 

replace methyl bromide. The data requested are designed to help you identify how your 

operation would change if methyl bromide were unavailable, which will be shown in 

Worksheet 3-B. 
OMB Control # 2060-0482

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WORKSHEET 2-A: METHYL BROMIDE – PEST & PROCESSING 

INFORMATION

1. Commodity or Consortium: 

2. What month does your fumigation cycle start: Please check only one.

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

3. Fumigation Timeline: Indicate when fumigation, major commodity and pest management practices 

typically occur. If the fumigation cycle is longer than one year, change the months to an appropriate 

interval.

Beginning Fumigation Cycle Time Interval ______________________ 

(e.g. WEEKS/MONTH/YEAR/SEASON)

(please define time periods)

Facility Preparation

Sealing

Cleaning

Fumigation Timeline

Reception of Raw Materials

Processing

Storage

Raw Materials

Finished Product

Packing

Shipping

Retail Market Window

Other Pest Treatments

Other 

4. Please provide a simplified schematic diagram which illustrates the basic steps of the 

commodity moving through the process from raw material to finished product:

4a. Provide a narrative of market channel for each commodity, where it is fumigated, and how the 

fumigation effects market availability and commodity sale:
OMB Control # 2060-0482

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5. Target Pest(s) or Pest Problem(s): Please identify the key target pests or pest problems for which 

methyl bromide is requested. Provide at least common name and genus and species if possible. 

Additional pests or pest problems can be provided as an attachment. Please also explain the specific 

reasons why methyl bromide is being requested for each pest [e.g., effective herbicide is available, but 

not registered for this crop; mandatory requirement to meet certification for disease tolerance].

Common Name Genus Specific Reasons why Methyl Bromide is Needed

Pest 1

Pest 2

Pest 3

Pest 4

Pest 5

6. Pest Economic Threshold: Please provide the economic threshold information for each pest. 

Describe year and source of information such as survey or expert estimate.

Threshold Units (e.g. 

pests/sq ft) Year Source

Pest 1

Pest 2

Pest 3

Pest 4

Pest 5

7. Target Pest Infestation: Please estimate the percentage of this user's total structural/facility volume 

with a moderate to severe problem with these pests. Describe source of information such as a survey or 

expert estimate.

Percentage of Total 

Structure/Facility Source

Pest 1 %

Pest 2 %

Pest 3 %

8. Representative User: Please provide descriptive factors appropriate for your operation.

a. Number of Facilities: _____

b. Gastightness Estimate (if available):* _________

* Give gastightness estimates where possible according to the following scale: good - less than 25% gas loss within 24 hours or half 

loss time of pressure difference greater than 1 minute; medium - 25-50% gas loss within 24 hours or half loss time of pressure 

difference greater than 10 seconds; poor - 50-90% gas loss within 24 hours or half loss time of pressure difference 1-10 second; 

very poor - more than 90% gas loss within 24 hours or a pressure half loss time of less than 1 second.

9. In what part and phase of the operation does the methyl bromide fumigation take place: Please 

check all that apply and indicate exposure time.

Structure / Facility: _________

Fumigation Chamber: _________

Commodity: _________

Prior to Storage: _________

Storage: _________

Prior to Shipping: _________

All: _________

Other: _________
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10. For what percentage of the operation have alternative(s) replaced methyl bromide in 

processing this commodity and if so, during what phase of the process:

Alternative % Replaced Phase of 

Process Details

Phosphine (Alone)

Heat Treatment

Phosphine in Combination

Sulfuryl Fluoride

Other

11. Please provide a brief description of any equipment fumigated in this operation:
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WORKSHEET 2-B: METHYL BROMIDE – HISTORICAL USE 2006 - 2010

Row A: Total Actual Pounds a.i. of Methyl Bromide Applied 

Enter the total actual pounds active ingredient (a.i.) of methyl bromide applied. Note: This 

number should be the total pounds a.i. applied by the individual user or the entire consortium, 

for the year indicated. Include only the pounds active ingredient of methyl bromide. 

Row B: Total Actual Volume (1,000 cu ft) Treated

Enter the total actual volume (1,000 cu ft) treated. Note: This number should be the total 

actual volume (1,000 cu ft) treated by the individual user or total actual volume (1,000 cu ft) 

treated for the entire consortium, for the year indicated. 

Row C: Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE

Enter the formulation of methyl bromide used (e.g. MB 98:2; MB/Pic 70:30).

Row D: Use Rate (lbs a.i./1000 cu. ft.)

Enter the use rate in pounds a.i. of methyl bromide per area.

For the years shown specify: 2006 2007 2008 2009 2010

A.

Total Actual Pounds a.i. of Methyl 

Bromide Applied

B.

Total Actual Volume (1,000 cu ft) 

Treated

C.

Formulation (Ratio of MB/Pic 

Mixture) to be Used for the CUE

D. Use Rate (lbs a.i./1000 cu. ft.)

What is the frequency of methyl bromide applied per volume (1,000 cu ft): (1x / year, 2x / year, 1x / 3 

years, etc.)

_______ times per _______

If there is a variation (greater than 10%) in the quantity a.i., the acres treated or average 

application rate from year to year, please explain the reasons for the variation: 

Comments:
OMB Control # 2060-0482

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EPA Form # 5900-137 Post-harvest

WORKSHEET 2-C: BASELINE – METHYL BROMIDE – COMMODITY 

TREATED & GROSS PROFIT FOR 2006 - 2010

Column A: Year

Be sure to enter the year. Use as many rows as needed for each year for all the commodities in the 

fumigation cycles from 2006 to 2010. If a fumigation cycle overlaps more than one calendar year, then 

the year of the fumigation cycle is the year methyl bromide was applied.

Column B: Commodity

Enter all commodities that benefit from methyl bromide in the fumigation cycle (interval between 

fumigations). See the Definitions page for a comprehensive definition of the fumigation cycle.

If someone other than the applicant benefits from the application of methyl bromide in the fumigation 

cycle and you do not have the quantitative data for the commodity treated in the same facility/structure, 

please indicate so in the comments section below.

Column C: Market Categories

Enter marketing categories that determine prices received, for example, grade (quality, taste, color) or 

timeliness (holiday market season, early season, late season). Itemize or aggregate these factors to the 

extent appropriate if lack of methyl bromide would affect the price in each category. 

Column D: Unit of Commodity

Enter the unit of measurement for each commodity (lbs, tons, cwt). If not by weight, specify in the 

comments section the average weight of the measure. For the international review board, all measures 

will be converted to metric.

Column E: Total Commodity Treated

Enter the total units of commodity treated with methyl bromide and processed/sold per area.

Column F: Price

Enter average prices received by the users for that commodity and category. For the total line, you do not 

have to enter a price. Average price over all categories can be calculated separately, if needed. If a 

commodity treated is never owned by the facility, indicate the fees charged for all services.

Column G: Cost of Goods Sold

Enter the total cost of goods sold (raw materials purchased) during the period. If this expense is not 

relevant to your post-harvesting operation, please skip this column.

Column H: Gross Profit

Gross profit may be calculated using the data you entered as the Total Commodity Treated times Price 

minus the Cost of Goods Sold. If gross profit is not equal to total commodity sold times price subtracted 

by cost of goods sold ((Column E * Column F) - Column G), you may override the formula and enter a 

different revenue amount. Please explain why this gross profit amount is different in the comment section 

below.

A B C D E F G H

Year Commodity

Market 

Category

(grade, 

time, end 

use)

Unit of 

Commodity

(e.g., lbs, 

tons)

Total 

Commodity 

Treated 

(per unit of 

commodity)

Price

(per unit of 

commodity)

Cost of 

Goods Sold

(per unit of 

commodity)

Gross 

Profit

(per unit of

commodity)

Comments: 
OMB Control # 2060-0482

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EPA Form # 5900-137 Post-harvest

WORKSHEET 2-D: METHYL BROMIDE – OPERATING COSTS FOR 2010

The purpose of this section is to determine operating expenses when methyl bromide is used. This forms 

the baseline for evaluating the cost impacts of using an alternative to replace methyl bromide. The data 

requested are designed to help you identify how your operation would change if methyl bromide were 

unavailable, which will be shown in Worksheet 3-B. Please fill in the unshaded areas. The shaded 

areas can be used if the information is known.

Column A: Operating Expense Items

Identify the operations to which the costs apply. You may add or delete lines as necessary. The 

operating expense items listed here are not meant to be exhaustive or be representative of your 

specific operating system. Other operating expenses include, but are not limited to, wage/salary, 

advertising and selling, utilities, rent and lease, insurance, and supplies. Be as precise as necessary 

to explain how lack of methyl bromide would affect your operation, otherwise you may aggregate 

operating expenses. These are meant to provide suggestions and to help you identify how your 

operation would change if methyl bromide were unavailable. 

Column B: Quantity Used per Volume (1,000 cu ft) or Weight (tons (short))

This field is required only for methyl bromide. However you may include specific amounts of other 

inputs or operations if you believe it helps to document the additional costs you would incur by using 

an alternative fumigant. 

Column C: Units (lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Column D: Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all 

costs of applying methyl bromide, including any material costs (e.g. tarps). If custom applied and 

separate costs are unavailable, write 'custom' and enter total cost in Column E.

Column E: Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (tons (short))

Enter all appropriate costs of operations per volume (1,000 cu ft) or weight (tons (short)). You may 

add or delete lines as necessary. 

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A B C D E

Operating Expense Items

Quantity Used per 

Volume (1,000 cu. 

ft.) or Weight (tons 

(short))

Units 

(lbs., 

hours, 

etc.)

Unit 

Cost 

($)

Cost ($) per Volume 

(1,000 cu. ft.) or Cost 

($) per Weight (tons 

(short))

1. Pest Management Costs (a+b+c+d)

a) Sanitation 

b) Pest Control

c) Methyl Bromide Fumigation (c1+c2)

c1) Product

c2) Application

d) Other Pest Management Costs

2. Repairs / Maintenance / Replacement

3. Interest

4. Depreciation for Plant Assets

5. Other Operating Expenses

TOTAL OPERATING COST
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WORKSHEET 3: ALTERNATIVES – FEASIBILITY OF ALTERNATIVE 

PEST CONTROL REGIMENS

Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs to 

compare data (commodity prices, gross profit, operating expenses, etc.) on the use of methyl bromide 

and alternative pest control regimens.

Complete Worksheet 3-A for each alternative pest control regimen. Please indicate the name of the 

specific alternative pest control regimen addressed and add additional pages as required.

Enter all alternative pesticides and pest control methods (and associated cost and yield data) that would 

replace one treatment of methyl bromide throughout the fumigation cycle. See the Definitions page for a 

comprehensive definition on fumigation cycles.

Worksheet Title

3-A Alternatives - Technical Feasibility of Alternatives to Methyl Bromide

You must complete one worksheet for each alternative. Please insert the name of the 

alternative in the area on top of the page. If you prefer, you may provide the information 

requested in this worksheet in a narrative review. However, you must fill in the information 

in Question #1 or we will assume no production or quality loss.

3-B Alternatives - Changes in Operating Costs

If a consortium is submitting this application, the data for this table should reflect the 

representative user for the consortium. 

This data is needed to estimate a baseline for operating costs in order to estimate changes 

in costs and the impact on operating profit and short-run economic viability as a result of 

not using methyl bromide and to provide required information to the international review 

board.

Please fill out this worksheet for each alternative for which the economic evaluation 

would bolster the case that methyl bromide is needed.

The purpose of this worksheet is to determine operating expenses when alternatives are 

used for evaluating the cost impacts of using an alternative to replace methyl bromide. The 

data requested are designed to help you identify how your operation would change if methyl 

bromide were unavailable. 

3-C Alternatives - Economic Feasibility of Alternatives to Methyl Bromide

If a consortium is submitting this application, the data for this table should reflect the 

representative user for the consortium. 

Please include in this worksheet data for each alternative included in worksheets 3-A 

and 3-B.
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WORKSHEET 3-A: ALTERNATIVES – FEASIBILITY OF ALTERNATIVE PEST CONTROL 

REGIMENS

Name of Alternative: 

1. Pest Control When Comparing This Alternative to Methyl Bromide: Provide numerical estimates where possible.

Study # Pest Being Tested Relative % Pest 

Control 

Scale of Study (e.g. 

pilot, plot)

Resulting Damages (please 

specify)

1

2

3

4

5

2. Study Information: For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is 

attached and if it is on the EPA website.

Study # Copy? EPA?

Month/Year project started and 

finished (e.g. Nov '06 - Oct '09) Details

1

2

3

4

5

3. Are there any production delays (downtime) associated with this alternative? Yes ___ No ___

If yes, please continue with 3a, 3b, 3c.

3a. Please specify the number of days per year of downtime: _________ days/year

3b. What is the cost of production delays or downtime per year? $ _________ per year

3c. Please explain the details of going into downtime and why it is necessary with this alternative:
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4. What is the estimated probability of the commodity not meeting consumer quality standards 

with and without methyl bromide or alternative treatments: Please explain.

5. Restrictions/Limitations on Alternative Use: This information will be used to determine the amount 

of methyl bromide needed.

% of 

Structure/Facility/Volume Details

Regulatory Restriction 

 - Label Restriction 

Climate Restriction

Pest Resistant To Alternative

Structural Limitations

Facility Limitations

Other Restrictions/Limitations (Describe)

6. Why is this alternative not suitable to replace 100% of methyl bromide use in processing this 

commodity:

7. Use Rate of Chemical Alternative:

Active Ingredient 

(a.i.)

Name of Product and 

Formulation

Quantity per 

Volume 

(1,000 cu ft)

Units 

(gals, lbs, 

etc.)

Volume 

(1,000 cu ft) 

Treated

# of 

Applications 

per Year

8. Non-Chemical Pest Control: Please describe.
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EPA Form # 5900-137 Post-harvest

9. Fumigation Timeline: Indicate when fumigation, major commodity and pest management practices 

typically occur. If the fumigation cycle is longer than one year, change the months to an appropriate

interval.

Fumigation Cycle Time Interval (e.g. WEEKS/MONTH/YEAR)

1 2 3 4 5 6 7 8 9 10 11 12

Facility Preparation

Sealing

Cleaning

Fumigation Timeline

Reception of Raw Materials

Processing

Storage

Raw Materials

Finished Product

Packing

Shipping

Retail Market Window

Other Pest Treatments

Other

Comments:
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EPA Form # 5900-137 Post-harvest

WORKSHEET 3-B: ALTERNATIVE – CHANGES IN OPERATING 

EXPENSES

Name of Alternative: 

Column A: Operating Expense Items

Identify the operations to which the costs apply. You may add or delete lines as necessary. The 

operating expense items listed here are not meant to be exhaustive or be representative of your 

specific operating system. These are meant to provide suggestions and to help you identify how your 

operation would change if methyl bromide were unavailable. 

Column B: Quantity Used per Volume (1,000 cu ft) or Weight (tons (short))

This field is required only for alternatives. However you may include specific amounts of other inputs or 

operations if you believe it helps to document the additional costs you would incur by using an 

alternative fumigant. 

Column C: Units (lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Column D: Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs 

of applying alternatives, including any material costs (e.g. tarps). If custom applied and separate costs 

are unavailable, write 'custom' and enter total cost in Column E.

Column E: Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (tons (short))

Enter all appropriate costs of operations per volume (1,000 cu ft) or weight (tons (short)). You may add 

or delete lines as necessary. 

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A B C D E

Operating Expense Items

Quantity Used per 

Volume (1,000 cu 

ft) or Weight 

(Tons (short))

Units (lbs., 

hours, etc.)

Unit Cost 

($)

Cost ($) per 

Volume (1,000 cu. 

ft.) or Cost ($) per 

Weight (tons 

(short))

1. Pest Management Costs (a+b+c+d)

 a) Sanitation 

 b) Pest Control

 c) Fumigation (c1+c2)

 c1) Product

 c2) Application

 d) Other Pest Management Costs

2. Repairs / Maintenance / Replacement

3. Interest

4. Depreciation for Plant Assets

5. Other Operating Expenses

 TOTAL OPERATING COST
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EPA Form # 5900-137 Post-harvest

4. What are the additional new investments (structures, facilities, equipment, fumigation 

chambers, etc.) needed to utilize this alternative: Establish necessary capital expenditures required 

for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include

installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting 

other components to make them amenable to heat treatment.

Type of Investment Total 

Investment ($)

Life of Investment

(# of years)

Salvage 

Value ($)

Interest 

Rate (%)

Comments:
OMB Control # 2060-0482

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EPA Form # 5900-137 Post-harvest

WORKSHEET 4: EMISSION CONTROL

1. How do you currently minimize use and/or emissions of methyl bromide, and how do you plan 

to further reduce use and/or emissions in the future: For all use/emissions reduction technique that 

you use, please fill out the text, where provided, or state the adoption rate and/or describe changes.

What use/emission reduction methods are 

presently adopted?

Please state the emission reduction amounts 

for each listed year

What further use/emission reduction steps 

will be taken for the methyl bromide used 

for critical uses? Please project the 

reduction amounts for each listed year.

Methyl Bromide 

Dosage 

Reduction

2006

_____________ lbs/acre 2011_____________ lbs/acre

2010 _____________ lbs/acre 2015 _____________ lbs/acre

Less Frequent 

Application

2006 ____ times per____ 2011 ____ times per____

2010 ____ times per____ 2015 ____ times per____

Formulation 

Changes 

(please specify)

2006 _________% MeBr, _________% Pic 2011 _________% MeBr, ________% Pic

2010 _________% MeBr, _________% Pic 2015 _________% MeBr, ________% Pic

Reclamation

2006 2011

2010 2015

Sealing 

Buildings

2006 2011

2010 2015

Integrated Pest 

Management 

(IPM)

2006 2011

2010 2015

Cultural 

Practices 

(please specify)

2006 2011

2010 2015

Other Pesticides 

(please specify)

2006 2011

2010 2015

Non-Chemical 

Methods (please 

specify)

2006 2011

2010 2015

Other Measures 

(please specify)

2006 2011

2010 2015

2. If methyl bromide emission reduction techniques are not being used, or are not planned for the 

future, state reasons:
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WORKSHEET 5: FUTURE RESEARCH PLANS

1. Identify the top 3 to 5 target pests for your research:

1. 

2. 

3. 

4. 

5. 

2. Provide a list of alternative chemicals or cultural practices that have been tested:

1. 

2. 

3. 

4. 

5. 

3. Prioritize the alternative chemicals or cultural practices to be tested:

1. 

2. 

3. 

4. 

5. 

4. What would be the best currently available alternative if methyl bromide were not available:

5. Are there any other potential alternatives under development which are being considered to 

replace methyl bromide:

6. Are there technologies being used to produce the crop which avoid the need for methyl 

bromide? Please explain whether such technologies could replace a proportion of proposed 

methyl bromide use:

7. Please provide an overview/timeline of the plan to transition away from using methyl bromide:

8. Will you include incidence reports where a commodity fails:
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9. Please describe the management strategies that are in place or proposed to eliminate the use of 

methyl bromide for the nominated critical use, e.g., measures to avoid any increase in methyl 

bromide consumption, measure to encourage the use of alternatives, information on the market 

penetration of newly deployed alternatives and alternatives that may be used in the near future:

10. What is the cumulative amount spent and the types of contributions this consortium has made 

to fund research to develop alternatives to methyl bromide since 1992, e.g. consortium dues, 

direct research funding, etc.: Please add additional rows if necessary.

Years Name of Organization / Research Institution Amount ($)

11. Other total investments, if any, made to reduce your reliance on methyl bromide: $ ________

Describe each investment and its associated costs (e.g. specialized machinery, etc.). Please add 

additional rows if necessary.

Investment Cost

13. Grant requests made to USDA, EPA, state, or other funding group:
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For EPA Use Only ID # _________

SECTOR _____________________

WORKSHEET 6: SUMMARY

This section may be posted on the web to notify the public of requests for critical use exemptions 

beyond the 2005 phaseout for methyl bromide. Therefore, this section cannot be claimed as CBI.

1. Consortium Name:

2. Location:

3. Crop:

4. Pounds of Methyl Bromide Requested: 2013 ______ lbs. 2014 ________ lbs.

5. Volume Treated with Methyl Bromide: 2013 ______ (1,000 cu. ft.) 2014 ________ (1,000 cu. ft.)

6. If methyl bromide is requested for additional years, reason for request:

2013 ___________ lbs. Volume Treated ___________ (1,000 cu. ft.)

2014 ___________ lbs. Volume Treated ___________ (1,000 cu. ft.)

2015 ___________ lbs. Volume Treated ___________ (1,000 cu. ft.)

7. Summary of Alternatives Not Feasible: Place an "X" in the column(s) labeled "Not Technically 

Feasible" and/or "Not Economically Feasible" where appropriate. Use the "Reasons" column to describe 

why the potential alternative is not feasible. Please add additional rows if necessary.

Potential 

Alternative

Not 

Technically 

Feasible

Not 

Economically 

Feasible

Reasons
OMB Control # 2060-0482

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Definitions:

Fumigation cycle: The period of time between methyl bromide fumigations.

Year:

If a fumigation cycle overlaps more than one calendar year, "year" refers 

to the calendar year when methyl bromide is applied (or the beginning of 

the cycle).

Comparable data:

In order to compare revenues and costs with and without methyl 

bromide, data on alternatives for pest control, yields, revenues, and 

costs must be for the same time interval as the methyl bromide 

fumigation cycle. If, however, quantitative data, is not available for the 

entire fumigation cycle, then to be comparable, the quantitative data for 

the alternatives should cover the same portion of the fumigation cycle as 

the quantitative data for methyl bromide, and the rest of the cycle should 

be discussed in the comments sections.

2-year example:

If a methyl bromide fumigation is made every 2 years, then the 2003 

fumigation cycle began in 2003 and would end in 2005. The data should 

cover the methyl bromide costs and usage for the methyl bromide 

fumigation made in 2003, and all yields and revenues received and other 

costs incurred during the 2 year period. To be comparable, the data on 

alternatives should cover a similar 2 year period beginning at the same 

time of year when a methyl bromide fumigation would be made. The 

data should cover all methyl bromide alternatives used, and all yields 

and revenues received during that 2-year interval. Other pest control 

and other costs would only need to be provided for that interval if they 

would change from what they were with methyl bromide.

Other beneficiary example

If someone other than the applicant benefits from a methyl bromide 

fumigation, you should comment on these benefits if you do not have 

quantitative data for the entire fumigation cycle. For example, if a 

rotational crop in the second year benefits from a methyl bromide 

fumigation a year earlier, but there is quantitative data only on the first 

crop, then the data on the alternatives should cover only the first crop, 

and the benefits of methyl bromide and the additional pesticides that 

would have to be used on the rotational crop should be discussed in the 

comments sections.

Crop cycle change example:

If in a one year interval, methyl bromide is applied, tomatoes are grown 

and harvested followed by peppers, then the fumigation cycle would be 

one year including the tomatoes and peppers. If, however, without 

methyl bromide, it is not possible to follow tomatoes with peppers in the 

same one year interval, then the alternative data on pesticides, costs, 

yields, and revenues should just cover tomatoes. The loss of profit from 

not being able to grow peppers with the alternatives would be part of the 

loss from not having methyl bromide.

Crop Grouping

The applicant can group similar crops together if: 

(i) Crops would experience similar yield and quality losses in the 

absence of methyl bromide; and 

(ii) Crops are grown on the same fumigation and cultivation cycle with 

similar operating costs.

For example, nursery crops including various flower or tree species can 

be aggregated, with average yields per acre and prices. However, if 

crops are distinctly different in revenues and operating costs, or the 

cycles, the applicant may want to present yield, price and operating

costs for each crop separately and also indicate the proportion of land 

area allocated to each crop.
OMB Control # 2060-0482

Expires 10/31/2011

EPA Form # 5900-137 Post-harvest