USA CUN11 POST HARVEST COMMODITIES Page 1 of 12



### NOMINATING PARTY: The United States of America

FILE NAME: USA CUN11 POST HARVEST USE FOR COMMODITIES

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Post Har vest Use on Commodities (Submitted in 2008 for 2011 Use Season)

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR O F

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

2011 10,041 kilograms

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat we bsite under Decision Ex. I/4(8).)

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomi nation 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 Pa rty need not re-submit that earlier information.

NOMINATING PARTY CONTACT DETAILS: Contact Person: Hodayah Finman Title: Foreign Affairs Officer Address: Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2657 Washington, D.C. 20520

U.S.A. Telephone: (202) 647-1123 Fax: (202) 647-5947

E-mail: FinmanHH@state.gov

Following the requirements of Decision IX/6 paragra ph (a)(1) The United States of America has determin ed that the specific use detailed in this Critical Use Nominati on is critical because the lack of availability of methyl bromide for

this use would result in a significant market disru ption. 

## ■ Yes  No

Signature Name Date

Title:USA CUN11 POST HARVEST COMMODITIES Page 2 of 12

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger Title: Director (Acting) 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 CUN11 POST HARVEST: COMMODITIES 12

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming conventi on see notes above) No. of kilobytes Date sent to Ozone

Secretariat

USA CUN11 POST HARVEST - Commodities

* Identical to paper documentsUSA CUN11 POST HARVEST COMMODITIES Page 3 of 12



## METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONM ENT)

COMMODITIES

1. SUMMARY OF NEED FOR METHYL BROMIDE

Commodity fumigation with methyl bromide is used pr imarily at harvest time, when rapid fumigation is needed to keep up with the large volu mes of incoming commodities. Methyl bromide is also used in some situations requiring r apid fumigation prior to shipping.

The USG has applied an aggressive transition rate w hich is reflected in the nomination amount

and detailed in Table 2.

T ABLE 

### 2. N OMINATION 

### A MOUNT

California Bean
Shippers California Dried

Plum Board California Walnut

Commission California Date

Commission Sector Total /
Average

Quantity Requested for 2010: Amount (kgs) 1,984 9,399

5,850

2,009

19,242

Quantity Recommended by

MBTOC/TEAP for 2010 : Amount (kgs) 1,984 9,399

5,850

2,009

19,242

Amount (kgs) 1,984

9,399

5,850

2,009

19,242

Volume (1000 m 3 ) 99 392 130 97 718

Rate 20

24

45

21

27

Transition from 2010 Baseline
Adjusted Value Percentage (%) -70% -60% -95% 0% -77%

Amount (kgs) 

### 595

6,266

1,170

2,009

10,041

Volume (1000 m 3 ) 30 261 26 96 413

Rate 20

24

45

21

24 

## 2011 Methyl Bromide Usage Newer Numerical Index (BU NNI)

Transition Use Reduction Description Spreadsheet

Quantity Required for

2011 Nomination: Quantity Approved by Parties for

2010: SECTOR COMMODITIES



### 2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

This sector includes walnut, dried fruit (prunes, r aisins, figs), dates, and dried beans, all of which are subject to infestation by several insect pests. Since infestation begins in the field, methyl bromide is used to rapidly fumigate harvested commo dities on arrival at processing plants on a daily basis. Most fumigation occurs over several w eeks, during the peak production season, as

the bulk of the harvest moves from the field into s torage and shipping channels. Upon arrival from the field, each load is fumigated with methyl bromide in preparation for shipment to national and international markets. Any one load o f commodities is fumigated with methyl bromide only once.

Preliminary research with sulfuryl fluoride indicat es that this fumigant is a likely methyl bromide

alternative for most commodities. Studies have sho wn that under vacuum or atmosphericUSA CUN11 POST HARVEST COMMODITIES Page 4 of 12



### conditions, sulfuryl fluoride is effective against adult, pupal, and larval stages of insects infestin g walnuts, although somewhat less effective against t he egg stage. These studies, however, have all been conducted using modified, small testing ch ambers, and results are just beginning to be validated commercially.

Walnuts - Preliminary tests show that sulfuryl flu oride fumigation is comparable to methyl bromide fumigation in its ability to kill diapausin g larvae of codling moth, Cydia pomonella

, inside walnuts. While codling moth eggs are somewh at more tolerant than larvae to sulfuryl fluoride fumigation, they do not occur naturally on walnuts at the time of harvest. The navel

orangeworm, Amyelois transitella , is primarily a scavenger, but will also infest wa lnuts after hull split, especially in areas that support high orange worm populations. Occasionally, larvae emerging from eggs laid directly on walnuts shortly before harvest may penetrate and infest the nutmeat through cracks in the hull. Although insec t eggs are relatively more tolerant of fumigants than other life stages, sulfuryl fluoride fumigation is lethal to three-day navel orangeworm eggs when used at the rate of approximat ely 56.5 mg/L (3.5 lb/1,000 cubic feet) for 24 hours, at normal atmospheric pressure.

Dry Beans - Sulfuryl fluoride is now labeled for us e on dry beans, and the California Bean Shippers have plans to test its efficacy in 2009. According to Dow AgroSciences’ Fumiguide, sulfuryl fluoride is effective against the cowpea w eevil when used at rates of approximately 25.7 mg/L (1.6 lb/1,000 cubic feet), for 24 hours, at no rmal atmospheric pressure and 80oF (26.6oF).

Dates - Methyl bromide is used primarily to control the carob moth and other insects infesting dates. Sulfuryl fluoride is currently labeled for use on dried dates, but most dates grown in the

California are harvested fresh. The California Dat e Commission reports that it is currently testing the efficacy of sulfuryl fluoride on dates, with preliminary results showing less than adequate egg kill, even when the amount used is twi ce that needed for a comparable methyl bromide fumigation.

Dried Fruit – Sulfuryl fluoride is currently labele d for use on dried fruit for control of several insects. However, no efficacy data specific to the se commodities are readily available. The California Dried Plum Board has expressed that, whi le sulfuryl fluoride appears to have potential as a methyl bromide replacement, various technical and economic issues remain unresolved, and it is, therefore, too early to discuss plans for it s adoption.

The potential use of sulfuryl fluoride for commodit y fumigation is unrelated to the use of this chemical for structure fumigation. In the fist cas e, it is the commodities themselves that are fumigated, only once, and just before being shipped to their intended markets. In the second, it is a storage or food processing facility (i.e. a bu ilding) that is fumigated periodically, as neededUSA CUN11 POST HARVEST COMMODITIES Page 5 of 12



### 3. SUMMARY OF RECENT RESEARCH

Sulfuryl fluoride

Walnuts

Quick turn-around time for walnuts at harvest time is the primary justification for methyl bromide use in this sector. Vacuum fumigation with methyl bromide may take 4-6 hours and atmospheric fumigation approximately 24 hours. The methyl bromide use rate for this sector is 3 lb/1,000 cubic feet. Phosphine gas fumigation take s approximately three days and is being used to fumigate walnuts in storage.

Sulfuryl fluoride has been shown to be effective ag ainst the adult, pupal, and larval stages of several insect pests of stored products, although s omewhat less effective against the egg stage (Fields and White, 2002, Schneider et al ., 2003). Preliminary tests show that sulfuryl flu oride fumigation is comparable to methyl bromide fumigati on in its ability to kill diapausing larvae of codling moth, Cydia pomonella , inside walnuts (Leesch, undated). Methyl bromide fumigation of in-shell walnuts has targeted primarily diapausi ng codling moth larva because this is the most tolerant life stage that may infest the nut at harv est. Data recently submitted to EPA by Dow AgroSciences (Muhareb and Hartsell, undated) indica te that vacuum fumigation with sulfuryl fluoride for four hours is effective against diapau sing codling moth larvae at rates of 25 mg/L (1.5 lb/1,000 cubic feet), at 15.6oC (60.1oF) and 1 7-20 mg/L (1.06 - 1.25 lb/1,000 cubic feet), at 25oC (77.0oF). While codling moth eggs are somewha t more tolerant than larvae to sulfuryl fluoride fumigation, they do not occur naturally on walnuts at the time of harvest (Wood, 1999; Zettler and Leesch, 2000; Zettler and Gill, undated ).

The navel orangeworm, Amyelois transitella , is primarily a scavenger, but will also infest walnuts after hull split, especially in areas that support high orangeworm populations. Occasionally, larvae emerging from eggs laid direct ly on walnuts shortly before harvest may penetrate and infest the nutmeat through cracks in the hull. Although insect eggs are relatively more tolerant of fumigants than other life stages, sulfuryl fluoride fumigation has been shown to be lethal to three-day navel orangeworm eggs when u sed at the rate of approximately 56.5 mg/L (3.5 lb/1,000 cubic feet) for 24 hours, at normal a tmospheric pressure (Zettler and Gill, undated). USDA/ARS researchers plan to continue testing the e fficacy and practicality of using sulfuryl fluoride, relative to methyl bromide, to control po st-harvest pests of nuts and dried fruit. Sulfuryl fluoride thus appears to be an effective m ethyl bromide alternative for in-shell walnuts.

Dry Beans

Rapid fumigation at harvest time and during shippin g continues to be the primary justification for the use of methyl bromide on dry beans, at the rate of 2.75 lb/1,000 cubic feet. Methyl bromide fumigation targets primarily the Indianmeal moth, Plodia interpunctella , cowpea weevil, Callosobruchus maculatus , and bean weevil, Acanthoscelides obtectus . Sulfuryl fluoride is currently labeled for control of these pests on dry beans, and the California Bean Shippers have plans to test its efficacy in 2009. According to Dow AgroSciences’ Fumiguide, sulfuryl fluoride is effective against the cowpea weevil whe n used at rates of approximately 25.7 mg/L (1.6 lb/1,000 cubic feet), for 24 hours, at normal atmospheric pressure and 80oF (26.6oF).USA CUN11 POST HARVEST COMMODITIES Page 6 of 12



### Dates

Methyl bromide is used to rapidly fumigate Californ ia dates at harvest time, when up to a million pounds per day are being harvested within a relativ ely tight timeframe during the fall. Methyl

bromide is used on dates at the rate of 1.5 lb/cubi c feet. Although several insect may infest dates, the carob moth, Ectomyelois ceratoniae , is the more damaging species. The majority of dates grown in the United States are fresh dates an d sulfuryl fluoride is currently labeled for use on dried dates only. Still, the California Date Co mmission, in collaboration with Dow AgroSciences, is currently testing sulfuryl fluorid e as a methyl bromide replacement. The California Date Commission reports that it is curre ntly testing the efficacy of sulfuryl fluoride on dates, with preliminary results showing less than a dequate egg kill, even when the amount used is twice that needed for a comparable methyl bromid e fumigation.

Dried Fruit

A quick turn-around time for dried fruit at harvest time is the primary justification for the current use of methyl bromide, at the rate of 1.5 lb/1,000 cubic feet. Phosphine gas is used for stored dried fruit fumigation. Sulfuryl fluoride is curre ntly labeled for use on dried fruit for control of Indianmeal moth, raisin moth, Cadra figulilella , dried fruit beetles, Carpophilus hemipterus

, navel orangeworm, and other insects that infest the se commodities. Efficacy data are not readily available for sulfuryl fluoride fumigation of dried fruit, although the efficacy of this fumigant against some insect pests of stored products has be en demonstrated. The California Dried Plum Board has expressed that, while sulfuryl fluoride a ppears to have potential as a methyl bromide replacement, various technical and economic issues remain unresolved, and it is, therefore, too early to discuss plans for its adoption. According to the Dow AgroSciences Fumiguide, sulfuryl fluoride is effective against the Indianmeal moth w hen used at a rate of approximately 21 mg/L (1.3 lb/1,000 cubic feet) at normal atmospheric pre ssure, for 24 hours, at 80oF (26.6oF).

Sulfuryl fluoride and propylene oxide

Wample (2006) is investigating the feasibility of u sing sequential or combined treatments with sulfuryl fluoride and propylene oxide (PPO) as a me thyl bromide alternative for control of pest of stored products. It is anticipated that this li ne of research will determine if combinations of sulfuryl fluoride and PPO will be more efficacious and cost effective than methyl bromide, especially regarding the egg stage of several econo mically important insects that infest tree nuts

and dried fruit.

Propylene Oxide

The U.S. EPA has established tolerances for propyle ne oxide on prunes, figs, and raisins. However, no comparative efficacy data for commodity fumigation seems to be currently

available.USA CUN11 POST HARVEST COMMODITIES Page 7 of 12



### Vacuum

Exposure to vacuum in flexible PVC chambers (“cocoo ns”) is being explored as a means to disinfest cowpeas, dried beans, and other legumes i n storage, targeting mainly the cowpea weevil, Callosobruchus maculatus (Phillips et al ., 2006).

Electromagnetic Energy

Ongoing research focusing on the technical feasibil ity of using radio frequency energy to control insect pests infesting in-shell walnuts is yielding promising results. Wang et al. (2006) have demonstrated that radio frequency treatment of waln uts can achieve 100% mortality of fifthinstar navel orangeworm larvae at an average walnut surface temperature of 60°C.

Phosphine

Most commodity operations in the U.S. currently use phosphine, alone and in combination, whenever feasible. Phosphine is suitable for fumig ating commodities in storage, where fumigation time is not a factor, but it is generall y too slow for treating large commodity volumes that need to be processed rapidly. Phosphine is al so corrosive to certain metals, and this characteristic limits its use in some processing pl ants, especially those outfitted with electronic sorting and processing control equipmentUSA CUN11 POST HARVEST COMMODITIES Page 8 of 12



### 4. ECONOMIC INFEASIBILITY OF ALTERNATIVES

T ABLE 

### 3. E CONOMIC 

### S UMMARY FOR EACH 

### A LTERNATIVE

M ETHYL B ROMIDE
A LTERNATIVE E CONOMIC S UMMARY

P HOSPHINE Economic losses from additional production downtime s due to longer fumigation time and

from capital expenditures required to adopt an alte rnative. Economic losses due to downtime with phosphine are persistent.

S ULFURYL

F LUORIDE SF is a viable alternative to MeBr; costs per lb ar e comparable but application rates may be

higher. Walnuts have inelastic demand; cost increa se can be passed to consumers. Higher application rates will not change.



### A separate economic analysis of alternatives was co nducted for each commodities sub-sector; in each case, phosphine was not found to be economical ly feasible for any of the commodities. For phosphine, production downtime was estimated to be 84 days per year on average; total capital expenditures for electrical modifications due to co rrosive nature of phosphine was assumed to be $215 per 1000 m 3 

### . The potential economic losses associated with the use of phosphine mainly originate from the cost of production delay. The e stimated economic losses are shown in Tables E.1 through E.3. The estimated economic losses as a percentage of net revenue are over 100% for all CUE applicants in the commodity sector; tha t is, all applicants experience negative net revenues with use of phosphine.

Sulfuryl fluoride was found to be technically and e conomically feasible for walnuts, dried fruit,

and dried beans.

Walnuts The United States walnut industry is concentrated i n the state of California where production averaged 332,000 short tons of walnuts per year fro m 2003-2007. The largest processor is the Diamond Foods in Stockton, California that processe s walnut harvest from 1,700 growers in California – accounting for approximately 50% of th e post-harvest market. 1 

### The United States is one of the world’s largest exporters of both shelle d and in-shell walnuts. 2 

### Both production and sales peak in the fall in anticipation of the holid ay season in December. Approximately 25 percent of walnuts are sold in the shell. 3 

### Those that are packed and shipped to European mar ket within a couple of days of the fumigation treatment qualify for quarantine exemptions for Methyl Bromide use. Those that are sold domestically or n ot immediately shipped may apply for a CUE. The remaining 75 percent of walnuts are proce ssed further to create a variety of packaged shelled products. These walnuts must be fumigated b efore they are put in long-term storage or continue in the processing chain due to the key pes ts

. Phosphine can be used for the 75 percent of walnuts that are allocated for packaged shelled products because turnaround time is not

crucial.

1 http://www.diamondfoods.com/growers/

2 http://www.fas.usda.gov/htp/horticulture/Tree%20Nut s/Walnuts.pdf

3USA CUN11 POST HARVEST COMMODITIES Page 9 of 12



### The economic analysis is conducted on a per 1,000 c ubic meter basis. Phosphine for the in-shell product results in down-time that leads to decrease d prices after market window. Sulfuryl fluoride results in slightly higher costs due to hi gher application rates but there is no additional downtime. Prices per lb for methyl bromide and sul furyl fluoride are comparable. Use of sulfuryl fluoride results in a 1.65% decrease in ne t revenue assuming that no costs are passed on to the consumer. Given that walnuts have a price e lasticity of demand of -0.28 (Russo et al., 2008), the additional cost of SF fumigant gas could be passed on to the consumer.

T ABLE 4: A NNUAL E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES F OR W ALNUT

Walnuts Units MB Phosphine SF

Total Commodity Treated kg 301,548,208 301,548,208 301,548,208

1,000 cubic meters treated kcm 941.25 941.25 941.25

Avg Mkt Price $/kg $ 1.89 $ 1.55 1 $ 1.89

Gross Revenue $/kcm $ 6,635.34 $ 497,440.98 $ 606,635.34

Total Operating Costs $/kcm $ 531,233.52 $ 529,714.86 $ 532,479.97

Total Fumigation Cost (1x) $/kcm $ 6,934.61 $ 5,200.96 2 $ 7,220.40

Kg Fumigant per kcm kg/kcm 48.06 na 56.06

Fumigant Cost (i.e., gas) $/kcm $ 1,697.93 na $ 1,980.86 Other fumigation costs (i.e., tarps, etc.) $/kcm $ 5,236.68 $ 5,200.96 $ 5,239.54

Other Operating Costs $/kcm $ 524,298.90 $ 524,513.89 $ 525,259.57

Net Revenue $/kcm $ 75,401.83 $ (32,273.88) $ 74,155.36

Time Lost days 0 84 0

Total Loss (MeBr to alt) $/kcm $ - $ 107,675.71 $ 1,246.46

Loss per Lb MeBr Requested $/kg

MeBr $ - $ 2,240.66 $ 25.94

Loss as % of GR with MeBr na 17.75% 0.21%

Loss as % of NR with MeBr na 142.80% 1.65%

1 Time lost with phosphine is assumed to result in a lower average market price for walnuts because less would be treated during peak prices, and increased supply at other t imes would depress off-peak prices.

2 Total fumigation costs; breakdown for gas and opera ting costs not available.



### Dried Fruit The dried fruit industry has already replaced a lar ge portion of methyl bromide with phosphine in processing dried fruits.

As in previous analyses, EPA reviewers estimated th at having to rely on phosphine alone would require an additional 84 days treatment time. In a ddition to the production loss, there are increased costs from using phosphine. Additional e xpenditures are required to adopt phosphineUSA CUN11 POST HARVEST COMMODITIES Page 10 of 12



### for accelerated replacement of plant and electronic equipment due to the corrosive nature of phosphine. The net effect of production losses and cost increases is shown in Table 3.

T ABLE 5: A NNUAL E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES F OR D RIED F RUIT

Dried Fruit Units MB Phosphine SF

Kgs of commodity Treated kg 405,882,980 292,235,746 1 405,882,980

1,000 cubic meters treated kcm 1,266.92 912.18 1,266.92

Avg Mkt Price $/kg $ 1.17 $ 0.96 $ 1.17

Gross Revenue $/kcm $ 374,457.83 $ 307,055.42 $ 374,457.83

Total Operating Costs $/kcm na na na

Total Fumigation Costs $/kcm $ 446.75 $ 544.28 $ 542.87

Quantity of Fumigant per unit Kgs/kcm 24.03 na 40.05

Fumigant Cost (i.e., gas) $/kcm $ 144.17 $ 144.17 $ 240.28 Other fumigation costs (i.e., tarps, etc.) $/kcm $ 302.59 $ 302.59 $

302.59

Other Operating Costs $/kcm na $ 97.52 na

Time Lost days 0 84 0

Total Annual Loss (MeBr to alt) $/kcm $ - $ 67,499.93 $ 96.11

Annual Loss per Lb MeBr Requested $/kg MB requested $ - $ 2,809.26 $ 4.00

Loss as % of GR with MeBr na 18.03% 0.03%

1 Time lost with phosphine is assumed to result in a lower dried fruit produced overall resulting in low er gross revenues.USA CUN11 POST HARVEST COMMODITIES Page 11 of 12



### Dried Beans In previous analyses, no economic analysis was cond ucted for dried beans because the industry is subject to a market window and there were no fas t alternatives. Now that the MRLs for sulfuryl fluoride have been resolved, this chemical is a viable alternative to methyl bromide.

T ABLE 6: A NNUAL E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES FOR D RIED B EANS

Dried Beans Units MB SF

Kgs of Commodity (1 sack = 45 kgs) kg 45 45

Gross Revenue (per sack) $/sack $ 30.00 $ 30.00

Total Operating Cost (per sack) $/sack $ 26.00 $ 26.34

Total Fumigation Cost $/sack $ 5.00 $ 5.34

Quantity of Fumigant per unit Kgs/kcm 44.05 56.06

Fumigant gas (i.e., gas) $/sack $ - $ - Other fumigation costs (i.e., tarps, etc.) $/sack $ - $ -

Other Operating Costs $/sack $ 21.00 $ 21.00

Net Revenue $/sack $ 4.00 $ 3.66

Time Lost days 0 0

Total Loss (MeBr to alt) $/sack $ - $ 0.34

Loss per Kg MeBr Requested $/kg MB requested $ - $ 0.01

Loss as % of GR with MeBr na 1.13%

Loss as % of NR with MeBr na 8.50%



### Dates An economic analysis was not done for dates because sulfuryl fluoride is labeled specifically for “dates, dried” and efficacy tests have not been con ducted for this alternative.USA CUN11 POST HARVEST COMMODITIES Page 12 of 12



## CITATIONS

Fields, P. and N. D. G. White. 2002. Alternatives to methyl bromide treatments for storedproduct and quarantine insects. Annual Review of E ntomology 47:331-59.

Leesch, J.G. undated. The use of 3 fumigants on w alnuts to control diapausing codling moth larvae. USDA-ARS report. At: http://www.mbao.org/1999airc/76leesch.pdf

Muhareb, J. and P. Hatsell. undated. Laboratory e valuation of the toxicity of sulfuryl fluoride in vacuum fumigations for diapausing larvae of the cod ling moth, Cydia pomonella , and larvae of the navel orangeworm, Amyelois transitella , in plugged walnuts. Dow AgroSciences internal report.

Phillips, T., P. Bolin, and G. Mbata. 2006. Vacuum for post harvest disinfestation of insects from

durable and fresh commodities. CSREES Funded Post-h arvest project. At: http://www.oardc.ohio-state.edu/nc213/PR06.pdf

Russo, C., Green, R.D. & Howitt, R.E. “Estimation o f Supply and Demand Elasticities of California Commodities”. Department of Agricultural and Resource Economics University of California, Davis, Working Paper No. 08-001, June 2008.

Schneider, S.M., E.N. Rosskopf, J.G. Leesch, D.O. C hellemi, C.T. Bull, and M.Mazzola. 2003. United States Department of Agriculture – Agricultu ral Research Service research on alternatives to methyl bromide: pre-plant and post- harvest. Pest Manag. Sci. 59:814-826.

Wample, R.L. 2006. Efficacy with the combination of sulfuryl fluoride and propylene oxide as replacement for methyl bromide fumigation of storedfood product. CSREES Funded Postharvest project. At: http://cris.csrees.usda.gov/cgibin/starfinder/0?path=icgpmbtlink.txt&id=anon&pass= &search=CG=*-51102- *%20and%20gy%3e1999&format=WEBTITLESG

Wang, S., M. Monzon, J.A. Johnson, E.J. Mitcham, an d J. Tang. 2007. Industrial-scale radio frequency treatments for insect control in walnuts II: Insect mortality and product quality.

Postharvest Biol Technol 45:247-253.

Wood, M. 1999. Walnut pests foiled by fumigant, s tudies show. News & Events, USDA/ARS.

At: http://ars.usda.gov/is/pr/1999/991105.htm

Zettler, J.L. and J.G. Leesch. 2000. Sulfuryl flu oride: A disinfestation treatment for walnuts and almonds. USDA/ARS. Vol. 6, No. 2. A t: http://www.ars.usda.gov/is/np/mba/apr00/sulf.htm

Zettler, J.L. and R.F. Gill. undated. Sulfuryl fl uoride: A disinfestation treatment for walnuts and almonds. USDA/ARS report. At: http://mbao.org/1999airc/108zettl.pdf