# MONTREAL PROTOCOL

ON SUBSTANCES THAT DEPLETE

THE OZONE LAYER



# UNEP

R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC 

# A SSESSMENT 

# P ANEL



# O CTOBER 

# 2005

E VALUATIONS OF 

# 2005 C RITICAL 

# U SE 

# N OMINATIONS FOR 

# M ETHYL



# B ROMIDE AND 

# R ELATED 

# M ATTERS



# F INAL 

# R EPORT

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 

# iii Montreal Protocol

On Substances that Deplete the Ozone Layer



# Report of the

UNEP Technology and Econom ic Assessment Panel

October 2005

E VALUATIONS OF 

# 2005 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE AND 

# R ELATED 

# M ATTERS



# The text of this report is composed in Times New Roman.

Co-ordination: Methyl Bromide Technical Options Committee

Composition and layout of the report:

Jonathan Banks, Nahum Marban Mendoza,

Michelle Marcotte and Ian Porter

Reproduction: UNON Nairobi

Date: October 2005

Under certain conditions, printed copies of this report are available from:

UNITED NATIONS ENVIRONMENT PROGRAMME

Ozone Secretariat, P.O. Box 30552, Nairobi, Kenya

Normally from SMI Distribution Service Ltd., Stevenage, Hertfordshire, UK, fax: + 44

1438 748844

This document is also available in portable document format from

http://www.unep.org/ozone/teap/Reports/MBTOC/

No copyright involved. This publication may be freely copied, abstracted and cited, with

acknowledgement of the source of the material.

ISBN: **********

# October 2005 TEAP Report on 2005 CUNs: 

# final Report iv 

# Disclaimer

The United Nations Environment Programme (UNEP), the Technology and Economic

Assessment Panel (TEAP) cochairs and members, and the Methyl Bromide Technical Options

Committee (MBTOC) cochairs and members, and the companies and organisations that employ

them do not endorse the performance, worker safety, or environmental acceptability of any of the

technical options discussed. Every industrial ope ration requires consideration of worker safety

and proper disposal of contaminants and w aste products. Moreover, as work continues -

including additional toxicity evaluation - more information on health, environmental and safety

effects of alternatives and replacements will b ecome available for use in selecting among the

options discussed in this document.

UNEP, TEAP cochairs and members, and the MBTOC cochairs and members, in furnishing or

distributing this information, do not make an y warranty or representation, either express or

implied, with respect to the accuracy, completen ess, or utility; nor do they assume any liability of

any kind whatsoever resulting from the use or reliance upon any information, material, or

procedure contained herein, including but not lim ited to any claims regarding health, safety,

environmental effect or fate, efficacy, or perfo rmance, made by the source of information.

Mention of any company, association, or produc t in this document is for information purposes

only and does not constitute a recommendation of any such company, association, or product,

either express or implied by UNEP, TEAP cochai rs and members, and the MBTOC cochairs and

members or the companies or organisations that employ them.

Acknowledgement

The Technology and Economic Assessment Panel a nd its Methyl Bromide Technical Options

Committee acknowledges with thanks the outstandi ng contributions from all of the individuals

and organisations who provided support to Panel and Committee cochairs and members. The

opinions expressed are those of the Panel and the Committee and do not necessarily reflect the

reviews of any sponsoring or supporting organisation.

# October 2005 TEAP Report on 2005 CUNs: Final Report v 

# UNEP

O CTOBER 

# 2005 R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC



# A SSESSMENT 

# P ANEL



# E VALUATIONS OF 

# 2005 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE AND 

# R ELATED 

# M ATTERS



# F INAL 

# R EPORT

# October 2005 TEAP Report on 2005 CUNs: 

# final Report vi 

# UNEP

O CTOBER 

# 2005 R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC



# A SSESSMENT 

# P ANEL



# E VALUATIONS OF 

# 2005 C RITICAL 

# U SE 

# N OMINATIONS FOR 

# M ETHYL



# B ROMIDE AND 

# R ELATED 

# M ATTERS



# F INAL 

# R EPORT



# T ABLE OF 

# C ONTENTS



# 1. Scope of this report ..................................................................................................... 1

2. Critical Use Nominations for Methyl Bromide .......................................................... 3

2.1 Introduction to MBTOC Evaluation of Critical Use Exemptions ...................... 3

2.1.1 Mandate....................................................................................................... 3

2.2 Evaluations of CUNs – 2005 round for 2006 and 2007 exemptions .................. 5

2.3 Critical Use Nominations Review ...................................................................... 6

2.3.1 Consideration of alternatives ...................................................................... 6

2.3.2 Period of nominations................................................................................. 7

2.3.3 Plans to develop, register and deploy alternatives...................................... 7

2.3.4 Standard presumptions used in asse ssment of nominated quantities.......... 8

2.3.5 Low permeability barrier films ................................................................. 10

2.3.6 Adjustments for standard dosage rates ..................................................... 10

2.3.7 Rate of adoption of alternatives ................................................................ 16

2.3.8 Fulfilment of Decision IX/6...................................................................... 17

2.3.9 Sustainable Alternatives............................................................................ 17

2.3.10 Frequency.................................................................................................. 17

2.4 Final evaluations of CUNs submitted in 2005.................................................. 18

2.4.1 Details of evaluations................................................................................ 18

2.4.2 Minority evaluation................................................................................... 18

3. Registration and Reregistration of Alternatives........................................................ 67

3.1 Registration status of soil alternatives .............................................................. 67

3.2 Registration status of postharves t and structural alternatives........................... 69

3.3 Reregistration of MB and alternatives .............................................................. 71

4. MBTOC Work plan for 2006.................................................................................... 73

4.1 Introduction....................................................................................................... 73

4.2 Summary report of the activiti es carried out in 2005 ....................................... 73

4.3 Allocation of the Funds under Decision XVI/5 ................................................ 73

4.4 MBTOC Workplan for 2006 - Details.............................................................. 73

4.5 Summary Report of the Activities Carried out by MBTOC in 2005................ 76

4.6 Allocation of the Funds provi ded under Decision XVI/5................................. 77

4.7 Management and Personnel Issues ................................................................... 78

4.8 Proposed changes to standard presumptions..................................................... 79

# October 2005 TEAP Report on 2005 CUNs: Final Report vii 

# 5. References................................................................................................................. 8 5

5.1 References for main text ................................................................................... 85

5.2 Additional references for minority evaluation (Section 2.4.2) ......................... 90

# October 2005 TEAP Report on 2005 CUNs: 

# final Report viii 

# Glossary of Acronyms

1,3-D 1,3-dichloropropene

A5 Article 5(1) Party

CUE Critical Use Exemption

CUN Critical Use Nomination

EC European Commission

EMOP Extraordinary Meeting of the Parties

EPA Environmental Protection Agency

EPPO European Plant Protection Organisation

IPM Integrated Pest Management

LBP Low Permeability Barrier Film

MB Methyl bromide

MBTOC Methyl Bromide Technical Options Committee

MITC Methyl isothiocyanate

MOP Meeting of the Parties

MS Metham sodium

Pic Chloropicrin

QPS Quarantine and Pre-shipment

SF Sulfuryl fluoride

TEAP Technology and Economics Assessment Panel

US United States of America

VIF Virtually Impermeable Film

# October 2005 TEAP Report on 2005 CUNs: Final Report 1 

# 1. Scope of this report

This 2005 final report provides MBTOC/TEAP final evaluations on CUNs submitted by

Parties in 2005, in accordance with the timetable set out in the Annex I referred to by

Decision XVI/4. It includes evaluation of one CUN submitted in 2004, which was held

over until 2005 for evaluation at the request of the nominating Party.

Additionally, this report contains a chapter on registration status of chemical alternatives

to methyl bromide (MB) and of MB reregi stration, addressing Decisions Ex. I/4(9,i) and

Ex. I/4(9,j), and a work plan for MBTOC for 2006 as required under the Annex 1 referred

to in Decision XVI/4. The work plan includes suggested changes to the standard

presumptions used by MBTOC/TEAP in evaluations of CUNs.

# October 2005 TEAP Report on 2005 CUNs: Final Report 3 

# 2. Critical Use Nominations for Methyl Bromide

2.1 Introduction to MBTOC Evaluati on of Critical Use Exemptions

2.1.1 Mandate

Under Article 2H of the Montreal Protocol the production and consumption (defined as

production plus imports minus exports) of methyl bromide is to be phased out in Parties

not operating under Article 5(1) of the Protoc ol, by 1 January 2005. However, the Parties

agreed to a provision enabling exemptions for those uses of methyl bromide that qualify

as critical. Parties established criteria, under Decision IX/6 of the Protocol, which all

such uses need to meet in order to be granted an exemption. The Decision IX/6 states:

1. To apply the following criteria and procedure in assessing a critical

methyl bromide use for the purposes of control measures in Article 2 of the

Protocol:

(a) 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 or

substitutes 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;

(b) That production and consumption, if any, of methyl bromide for critical

uses should be permitted only if:

(i) All technically and economically feasible steps have been taken to

minimise the critical use and any associated emission of methyl

bromide;

(ii) Methyl bromide is not available in sufficient quantity and quality

from existing stocks of banked or recycled methyl bromide, also

bearing in mind the developing countries’ need for methyl bromide;

(iii) It is demonstrated that an appropriate effort is being made to

evaluate, commercialise and secure national regulatory approval

of alternatives and substitutes, taking into consideration the

circumstances of the particular nomination and the special needs of

Article 5 Parties, including lack of financial and expert resources,

institutional capacity, and information. Non-Article 5 Parties must

demonstrate that research programmes are in place to develop and

deploy alternatives and substitutes. Article 5 Parties must

demonstrate that feasible alternatives shall be adopted as soon as

they are confirmed as suitable to the Party’s specific conditions

and/or that they have applied to the Multilateral Fund or other

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 4 

# sources for assistance in identifying, evaluating, adapting and

demonstrating such options;

2. To request the Technology and Economic Assessment Panel to review

nominations and make recommendations based on the criteria established in

paragraphs 1 (a) (ii) and 1 (b) of the present decision;

3. That the present decision will apply to Parties operating under Article 5

and Parties not so operating only after the phase-out date applicable to those

Parties.

Para. 2 of Decision IX/6 does not assign TEAP the responsibility for determining the

existence of “significant market disruption” specified in paragraph 1(a)(i).

TEAP assigned its Methyl Bromide Technical Options Committee (MBTOC) to

determine whether there are no technically and economically feasible alternatives or

substitutes 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 , and to

address the criteria listed in Decision IX/6 1(b).

All reviews of CUNs made in 2005 are to be in accordance with the ‘Annex I’ referred to in

Decision XVI/4. This annex also sets out the schedule for the annual review of critical use

nominations. In addition to the criteria for the evaluation provided in Decision IX/6, the Parties

have given further guidance for the review of CUNs in Annex 1 of 16 MOP meeting report.

Inter alia, this requires that TEAP and MBTOC pr ovide a clear description of why any part of

a nomination is not recommended, including references to the relevant studies used as the basis

for such a decision. Para. 32 emphasises that exemptions must fully comply with Decision

IX/6 and other relevant decisions, and are intended to be limited to the levels needed for

critical use exemptions. These are considered as temporary derogations from the phaseout of

methyl bromide in that they are to apply only until there are technically and economically

feasible alternatives that otherwise meet the criteria in Decision IX/6, and that MBTOC should

take a precise and transparent approach to the application of the criteria, having regard,

especially, to paragraphs 4 and 20 of Annex I.

Paragraphs 4 and 20 read:

4. Although the burden of proof remains with the Party to justify a request for a

critical-use exemption, MBTOC will provide in its report a clear explanation of its

operation with respect to the process of making determinations for its recommendations,

and clearly state the approach, assumptions and reasoning used in the evaluation of the

critical-use nominations. When cuts or denials are proposed, the description should

include citations and also indicate where alternatives are technically and economically

feasible in circumstances similar to those in the nomination, as described in

decision Ex.1/5, paragraph 8.

20. In line with paragraph 4 above, in any case in which a Party makes a

nomination which relies on the economic criteria of decision IX/6, MBTOC

should, in its report, explicitly state the central basis for the Party’s economic

# October 2005 TEAP Report on 2005 CUNs: Final Report 5 

# argument and explicitly explain how it addressed that factor, and, in cases in

which MBTOC recommends a cut; MBTOC should also provide an explanation of

its economic feasibility.

2.2 Evaluations of CUNs – 2005 round for 2006 and 2007 exemptions

MBTOC met 11-15 April 2005 in Buenos Aires, Argentina and for a second time in

Melbourne, Australia, from 29 August to 2 September, 2005. These meetings were held

as required by the time schedule for considerations of CUNs given in Annex I referred to

in Decision XVI/4.

MBTOC made an initial assessment of the 62 new or additional critical use nominations

for 2006 and 27 nominations for 2007, totalling 324.68 and 8088.32 metric tonnes

respectively. Of the 89 new or supplementary CUNs considered during its April 2005

meeting in Buenos Aires, MBTOC was unable to assess 26 nominations. Some of the

larger and more complex nominations were in this category. It did not recommend two

nominations. MBTOC submitted questions relating to those nominations classified as

‘unable to assess’ in Buenos Aires that w ould assist their further evaluation during its

September 2005 meeting in Melbourne. Two Parties made arrangements to meet with

MBTOC during the Melbourne meeting for disc ussions with regard to their outstanding

CUNs, in accordance with paragraph 8 of Annex 1 referred to in Decision XVI/4.

In paragraph 20 of Annex 1 referred to in Decision XVI/4, Parties, inter alia, specifically

requested that MBTOC explicitly state the central basis for the Party’s economic

argument relating to CUNs. Table 4 provides this information for each CUN.

MBTOC has sometimes suggested quantities of MB for 2006 or 2007 different from that

nominated. Grounds used for these changes are given in detail after the relevant CUNs in

Table 4. The adjustments follow the standard presumptions given in Tables 1 and 2,

unless indicated otherwise.

In general, CUNs resulted mainly from the following issues: regulatory restrictions on

alternatives, scale up of alternatives, and economic issues. For the most part technical

alternatives exist, but often at a less developed state than methyl bromide. MBTOC has

been unable to identify alternatives, or has inadequate information for the following

applications: fresh high-moisture dates, some seeds when rapid turn around is required

for immediate planting, cheese stores, dry cu re ham treatment, and unmovable historical

artefacts especially where fungi are of concern. The Parties are requested to consider

focusing some research on these applications to identify and, where required, register

effective alternatives.

Further to the normal Disclosure of Interest required under the TEAP/TOC terms of

reference, MBTOC members made an additional disclosure relating specifically to their

level of national, regional or enterprise involvement in the CUN process. This was

required to ensure that those with a high level of involvement and interest in developing a

particular nomination did not bias the process of evaluation through participation in the

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 6 

# detailed review. Some MBTOC members were disqualified from review of specific

nominations as a result of this process.

A soil subcommittee in MBTOC considered the nominations relating to the use of MB

for soil fumigation, while a post-harvest subcommittee considered the nominations

relating to the use of MB for fumigation of commodities, structures and objects. Drafts

arising from the subcommittees were considered in plenary. This report and decisions of

the committee were by consensus, except for one particular issue on which agreement

was not reached. A minority evaluation on this issue, relating to some portions of US

CUNs for 2007 for cucurbits, eggplant, peppers, strawberry fruit and tomatoes, has been

included below (Sect. 2.4.2).

As part of internal process of MBTOC, check-list style evaluation forms were generated

to allow the Committee to assess the large number of nominations efficiently and

equitably. These evaluation forms include the questions asked in the Handbook on

Critical Use Exemptions for Methyl Bromide and relevant sections of guidance of the

Parties, in particular, Decision IX/6. All nom inations were treated similarly, independent

of the size of the exemption requested. Specific circumstances of each nomination were

taken into account.

The CUEs approved by 1EMOP and 16MOP for 2005 were used as the baseline data

when considering CUNs for 2006. For those nominations relating to 2007 use the

baseline was the most recent approval arising from 2EMOP, 1EMOP and/or 16MOP.

2.3 Critical Use Nominations Review

In considering the CUNs submitted in 2005, MBTOC applied the standards contained in

Annex I of 16MOP. In particular MBTOC s ought to provide consistent treatment of

CUNs within and between Parties while at the same time taking local circumstances into

consideration for specific crops and situations, and to provide transparency in its

processes and conclusions.

2.3.1 Consideration of alternatives

In considering alternatives to methyl bromide, MBTOC used the guidance given in

Annex I where ‘alternatives’ were defined as any practice or treatment that can be used in

place of methyl bromide. ‘Existing alternatives’ are those alternatives in present or past

use in some regions; and ‘potential alternatives’ are those alternatives in the process of

investigation or development. MBTOC also used information on the suitability of

alternatives for a nomination by considering the commercial adoption of alternatives in

regions nominating for CUNs. Also, adoption in regions with similar climatic zone and

cropping practices was used as an indication of the feasibility (technical and economic)

of an alternative in a particular region. For example, 1,3-dichloropropene/chloropicrin

(1,3-D/Pic), metham sodium alone or in combination with Pic, dazomet, substrates and

the use of resistant varieties (for solanaceous crops, melons and cucurbits) have been

adopted to replace MB for several crops and in several regions where MB was once used.

# October 2005 TEAP Report on 2005 CUNs: Final Report 7 

# MBTOC is ‘unable to assess’ nominations that do not explain why these major

alternatives are unsuitable for the circumstances of a nomination.

In evaluating the CUNs for soil treatments, MBTOC assumed that a technically feasible

alternative to MB would need to provide sufficient pest and weed control for continued

production of that crop to existing market standards. For commodity and structural

applications, it was assumed that a technically feasible alternative would provide

disinfestation to a level that met the objectives of a MB treatment, e.g. meeting

infestation standards in finished product from a mill. Technically feasible alternatives do

not necessarily provide superior pest control results than are achieved in practice by MB.

2.3.2 Period of nominations

CUNs in this report relate to CUEs sought for 2006 and 2007. No nominations in this

particular round were submitted for longer periods.

One Party, in bilateral consultations with MBTOC, emphasised the need for CUEs for

2007 from this round in order to be able to complete their regulatory processes for

allocations in that year. It also stated that the allocation process for MB use under a CUE

allowed adjustment of the allocated quantity downwards as a result of developments in

availability of alternatives subsequent to approval of particular amounts for a CUE by the

Parties.

2.3.3 Plans to develop, register and deploy alternatives

To qualify for a CUE, Decision IX/6 in part states that Parties must demonstrate that

“...an appropriate effort is being made to evaluate, commercialise and secure national

regulatory approval of alternatives and substitutes, taking into consideration the

circumstances of the particular nomination...” and “...must demonstrate that research

programmes are in place to develop and deploy alternatives and substitutes...”

In many nominations in the 2005 round, as in previous rounds, plans to identify

alternatives were often not adequate and future plans to phase out MB were not given.

As with the 2004 round, MBTOC did not use lack of phaseout plans as a basis to ‘not

recommend’ a nomination.

Decision Ex. I/4 requires Parties that make “a critical-use nomination after 2005 to

submit a national management strategy for phase-out of critical uses of methyl bromide

to the Ozone Secretariat before 1 February 2006”. MBTOC awaits these reports. In this

round of nominations, some Parties identified alternatives and reduced their nominations

to allow for phase-in of alternatives. MBTOC did not reduce a Party’s requested amount

for phase-in of alternatives without technical and economic evaluation and suitable

justification.

MB is a mature technology and a considerable knowledge base exists for its use. On the

other hand, many alternatives need continued efforts for correct and efficacious use and

adaptation to local commercial circumstances. MBTOC incurred difficulties in assessing

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 8 

# nominations when there were insufficient published studies on alternatives, proven

effective in other regions, conducted under local conditions. This leads to difficulties in

true comparison of the feasibility of alternatives as the newer alternatives and their

application may not be fully developed, may not have achieved economies of scale, and

may have fewer years of documented pest control success. Some latitude is needed in

evaluating the feasibility of alternatives to take this problem into account.

2.3.4 Standard presumptions used in assessment of nominated quantities.

The tables below (Tables 1,2) are explicit statements of standard presumptions applied by

MBTOC/TEAP in assessing this round of CUNs, and both the 2004 and 2005 round of

CUNs, where continued methyl bromide use is sought. Previous statements of these

presumptions have been given in TEAP reports of October 2003, June 2004 and October

2004.

Proposed changes to these standard presumptions with supporting documentation are

being provided in conformity with para. 2 of Annex 1 referred to in Decision XVI/ 4 for

consideration at the 17MOP. The proposed changes are given in summary in the work

plan for MBTOC for 2006 (Section 4.5).

The rates and practices adopted by MBTOC are, in general, conservative. For soil

treatments, the dosage levels of methyl bromide given in these presumptions exceed that

required in good agricultural practice in all but exceptional circumstances, particularly

when used in conjunction with low gas permeability barrier films (LBF), such as various

VIF and metallised barrier films (e.g. CANSLIT). To assist the adoption of lower dosage

rates, researchers and extension specialists need to continue to build grower confidence in

the effectiveness of lower dosage levels and optimise the methods for application of low

permeability barrier films in the field. Practical permeabilities for low permeability

barrier films are reported by suppliers and offer opportunities for different films with

differing permeabilities and handling characteristics to suit particular applications whilst

adequate retention of fumigant to permit lowered MB dosages.

# October 2005 TEAP Report on 2005 CUNs: Final Report 9 

# Table 1. Standard presumptions used in assessment of CUNs – soil treatments.

Comment CUN adjustment Exceptions

1. Dosage rates Maximum guideline rates for

MB:Pic 98:2 – 45 g/m2 (cold,

heavy soils) or 35 g/m2 (sandy

soils), both with barrier films (VIF

or equivalent); for MB/Pic 67:33 -

20g MB/m2, under barrier films.

Exceptionally, where VIF or

equivalent is not feasible,

maximum guideline rates for

MB:Pic 98:2 – 60 g/m2. All rates

on a ‘per treated hectare’ basis. Amount adjusted to maximum

guideline rates. Maximum rates

set dependent on formulation

and soil type and film

availability. Higher rates accepted if

specified under national

legislation or where the Party

had justified otherwise.

2. Barrier films All treatments to be carried out

under low permeability barrier film

(e.g. VIF) Nomination reduced

proportionately to conform to

barrier film use. Where barrier film

prohibited or restricted by

legislative or regulatory

reasons

3. MB/Pic

Formulation:

Pathogen control Unless otherwise specified, MB/Pic

50:50 (or similar) was considered

to be the standard effective

formulation for pathogen control,

as a transitional strategy to replace

MB/Pic 98:2. Nominated amount adjusted for

use with MB/Pic 50:50 (or

similar). Where MB/Pic 50:50 is not

registered, or chloropicrin

(Pic) is not registered

4. MB/Pic

Formulation:

Weeds/nutgrass

control Unless otherwise specified, MB/Pic

67:33 (or similar) was used as the

standard effective formulation for

control of resistant (tolerant)

weeds, as a transitional strategy to

replace MB/Pic 98:2. Nominated amount adjusted for

use with MB/Pic 67:33 (or

similar). Where chloropicrin or

chloropicrin-containing

mixtures are not registered

5. Strip vs. Broadacre Fumigation with MB and mixtures

to be carried out under strip Where rates were shown in

broadacre hectares, the CUN

was adjusted to the MB rate

relative to strip treatment (i.e.

treated area). If not specified,

the area under strip treatment

was considered to represent 67%

of the total area. Where strip treatment

was not feasible e.g.

some protected

cultivation or open

field production of

high health

propagative material

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 10 

# Table 2. Standard presumptions used in assessment of CUNs – post-harvest treatments

Comment CUN Adjustment Exception

Dosage rate -

structural 20 g/m 3 

# Nominations using higher

dosage rates were reduced

proportionally Where approved label

rates require higher

dosage rate or where

substantiated by the Party

Dosage rate –

commodities EPPO standard for bulk

commodities as given in

MBTOC (1994, 1998) Nominations using higher

dosage rates were reduced

proportionally Where approved label

rates require higher

dosage rates or where

substantiated by the Party



# 2.3.5 Low permeability barrier films

Decision IX/6 states in part that critical uses should be permitted only if ‘all technically

and economically feasible steps have been taken to minimise the critical use and any

associated emission of methyl bromide’. In its evaluations, MBTOC assessed CUNs

where possible for reductions in MB application rates and deployment of MB emission

reduction technologies, such as use of low permeability barrier films, including VIF, or

other appropriate sealing and emission control techniques.

Technical discussion on barrier films is given in MBTOC 2002 Assessment Report

(MBTOC 2002). Results of some field experiments and demonstrations with low

permeability barrier films are discussed in Section 2.3.6. The observations under field

conditions with low permeability films, includi ng VIF, support use of reduced dosages of

methyl bromide compared with those used under normal polyethylene sheeting, without

loss of effectiveness.

2.3.6 Adjustments for standard dosage rates

MBTOC assessed CUNs for appropriate MB application rates and deployment of MB

emission reduction technologies, such as use of low permeability barrier films or

appropriate sealing techniques.

Decision IX/6 requires that critical uses should be permitted only if ‘all technically and

economically feasible steps have been taken to minimise the critical use and any

associated emission of methyl bromide’. Decision Ex.II/1 also mentions emission

minimization techniques, requesting Parties “...to ensure, wherever methyl bromide is

authorized for critical-use exemptions, the use of emission minimization techniques such

as virtually impermeable films, barrier film technologies, deep shank injection and/or

other techniques that promote environmen tal protection, whenever technically and

economically feasible.”

# October 2005 TEAP Report on 2005 CUNs: Final Report 11 

# One key transitional strategy has been the adoption of MB:Pic formulations with lower

concentrations of methyl bromide (e.g. MB:Pic 50:50 or less). These formulations are

considered to be equally as effective in controlling soilborne pathogens as formulations

containing higher quantities of methyl bromid e (e.g. 98:2, 67:33) (e. g. Porter et al 1997;

Melgarejo et al 2000; Lopez-Aranda et al 2003). Formulations containing high

proportions of chloropicrin in mixtures with methyl bromide have been adopted widely

by non-Article 5 countries to meet Montr eal Protocol restrictions where such

formulations are registered or otherwise permitted. Their use can be achieved with

application machinery which allows co-injection of methyl bromide and chloropicrin or

by use of premixed formulations.

In the soils sector, some CUNs still involve the use of MB with low or high density

polyethylene sheeting (tarping). This process is known to lead to high rates of emission

of MB in the absence of specific measures such as deep injection. MB use and emission

rates can be reduced substantially through use of less pervious tarping (MBTOC, 2002),

such as low permeability barrier films (LBF). Low permeability barrier films (e.g. VIF or

equivalent), allows increased retention of MB, extended effective exposure periods for

the pests, and effective reduced MB application rates compared with use of conventional

sheeting. It has been long recognised that the use of low permeability barrier films

coupled with reduced dosages effectively reduces methyl bromide emissions (e.g. Wang

et al. 1997). Recent advancements in the cost and technical performance of barrier films

have extended their suitability for use with methyl bromide and also some of the

alternatives. The key advantage is that they allow for a substantial reduction in dosage

rate of methyl bromide compared with the minimum effective rate under polyethylene

film. Typically the reduction in effective methyl bromide dosage can be 25 – 50%, for

both 98% methyl bromide and methyl bromide/chloropicrin formulations.

Table 3 reviews the relative effectiveness of different rates and formulations of methyl

bromide under barrier films compared to standard commercial treatments under

polyethylene. The references shown represent studies from 1998 to 2004 where barrier

films (e.g. VIF) were compared to the standard MB/Pic using standard polyethylene film.

The trials were conducted under a wide range of situations, but consistently show

improved performance (reduced dosage and thus emissions) under barrier film without

loss of effectiveness. The equivalent effec tiveness of different dosages of MB under the

barrier films compared to MB/Pic standard polyethylene treatment from Table 3 is

plotted in Figure 1. It shows the scatter about the line of 100% relative effectiveness as

expected from field data from biological/agricultural systems.

The use of low permeability barrier films, meeting VIF specifications is compulsory in

the 25 member countries of the European Union (EC Regulation 2037/2000). The State

of California in the US, however, prohibits the use of VIF (California Code of

Regulations Title 3 Section 6450(e)) over concerns of possible worker exposure to MB

when the film is removed or when seedlings are planted, and altered flux rates of MB in

practice.

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 12 

# In 2003 (TEAP 2003), MBTOC/TEAP evaluations of CUNs used conservative maximum

allowable dosage rates for use with standard films and barrier films. Since then, high

levels of success have been demonstrated in many countries at lower rates of methyl

bromide with barrier films. For this reason, new guidelines for reduced effective dosage

rates with barrier films and standard film s are being proposed in this TEAP report of

October 2005 for consideration by the Parties at the 17MOP, as required by the Decision

XIV/2.October 2005 TEAP Report on 2005 CUNs: Final Report13Table 3. Relative effectiveness of MB/Pic formulations applied incombination with low permeability barrier films compared to thecommercial standard MB/Pic formulation applied under standard low density polyethylene films.Country Region Commodity Barrier Film TypeUntreated Methyl Bromide/ChloropicrinMixtures (Product rate per treated area)Notes ReferenceStd film Barrier Film -Relative yield compared to standard polyethyleneYieldMB/PicFormuln.ProductRateNotSpec 98:2 98:2 67:33 67:33 67:33 67:33 67:33 67:33 50:50 33:67kg/ha 300 400 300 98 196 200 294 336 392 200 200MB Dosage rate (g/m2)392 294 66 131 134 197 225 263 100 66SpainVinderosStrawb. RunnerVIF - NotSpec7450:5040093De Cal et al 2004Navalmanzano7850:5040080Fusarium,Phytophthora,Pythium,Rhizoctonia andVerticilliumSpainVinderosStrawb. RunnerVIF - Not Spec6850:50400114102Melgarejo et al 2003Navalmanzano3450:504007675Fusarium,Cladosporium,RhizoctoniaSpainAvitorejoStrawb. FruitVIF - Not Spec50:50400972003 resultsLopez-Aranda et al 2003Malvinas50:50400991998 FusariumSpainValenciaStrawb. FruitVIF - Not Spec59Not Spec60094at 10cm &30cmBartual et al 200253Not Spec600931999 resultsSpainAvitorejoStrawb. FruitVIF - Not Spec8067:33400112Lopez-Aranda et al 2001aTariquejo5467:33400106Meloidogyneand weeds(unspec.)SpainMoguer/CartayaStrawb. RunnerVIF - Not Spec50:5039299Inoculum notspecifiedLopez-Aranda et al 2001bSpainCabeza, Nav.Strawb. RunnerVIF - Not Spec7467:33400105, 921998 Two sitesMelgarejo et al 2000Arevalo, Nav.8450:50400104, 1041999 results,nurseriesVinaderos, Nav.4950:5040095, 1232000 results,nurseriesSpainHuelvaStrawb. FruitVIF - Not Spec8267:334001011997-1998Inoc.unspecifiedLopez-Aranda et al 20007267:334001021998-1999 Inoc.unspecified6867:334001091999-2000 Inoc.unspecifiedOctober 2005 TEAP Report on 2005 CUNs:finalReport14SpainMoncadaStrawb. FruitVIF - Not Spec6098:260095Cebolla et al 19995498:2600911998 No majorpathogens butFusarium buried10cm&30cm.FranceDouvilleStrawb. FruitVIF - Not Spec65Not Spec80099Inoculum notspecifiedFritsch 1998NZHavelock NorthStrawb. FruitVIF - Not Spec8367:3350098PhytophthorapresentHorner 1999USAFloridaPepperVIF Plastopil6967:3339278NutgrassGilreath et al 2005VIF Plastopil6967:3339299presentVIF Vikase6967:3339283VIF Vikase6967:3339286USAFloridaStrawb Fruit,CantaloupeBarrier - Pliant,Metallised98:267:33Trials on 18 Commercial Farms between 2000-2004; no increase in disease or weedswhen rates reduced up to 50% under VIF wrt. polyethyleneNutgrass andpathogenspresentNoling and Gilreath 2004USACalifornia7267:33336108Inoculum notspecifiedAjwa et al 2004Strawb. FruitVIF - Not Spec8067:3339296USAFloridaTomatoVIF - Not Spec3167:3339211193114Nutgrass androotknotnematodesHamill et al 2004USACaliforniaStrawb. FruitVIF - Not Spec7567:33392106Ajwa et al 20038367:333921116567:33392102Watsonville,high pathogenpressureUSAFloridaTomatoVIF - Not Spec67:33392"No significant reduction in yield"Noling et al 2001USACaliforniaStrawb. FruitVIF - Not Spec4567:33364116Duniway et al 1998Unweighted averages (relative % yield)669499939310210310810491

# October 2005 TEAP Report on 2005 CUNs: Final Report 15 0 20 40 60 80 100 120 140

0 50 100 150 200 250 300 350

MB dosage rate (kg/ha) under barrier filmRelative Yield



# Figure 1. Relative yield of crops (strawberries, tomatoes, peppers, cantaloupes) grown

under barrier films with different MB/Pic formulations compared to the standard

commercial treatment using standard polyethylene from trials between 1998 and 2004

( ▲ MB/Pic 98:2; ● MB/Pic 67:33; ♦ MB/Pic 50:50; ■ MB/Pic 33:67). Data from Table

3.

As in the evaluations in previous years, MBTOC reduced quantities of MB in particular

nominations to a standard rate per treated area. MBTOC considers the maximum MB

application rate for 98% MB to be 

# either 350 kg/ha (warm sandy soils) or 450 kg/ha

(heavier cool soils), in conjunction with low barrier permeability films (e.g., VIF or

equivalent), combined with extended exposure periods, as effective in most

circumstances when well applied. In cases where use of high chloropicrin-containing

mixtures (approximately MB:Pic/67:33 or 50:50) were feasible, maximum dosage rates

of 200kg/ha (260 kg/ha for moderate to severe nutgrass regions) have been previously

used by MBTOC to assess nominations. As a consequence of new studies with low

permeability barrier films, reviewed in Table 3, new maximum guideline standards of

175 kg MB/ha where nutgrass is the key pest and 150 kg/ha for pathogens are regarded as

reasonable and are being proposed as revised standard presumptions.

The indicative rates used by MBTOC were maximum guideline rates, for the purpose of

calculation only. MBTOC recognises that the actual rate appropriate for a specific use

may vary with local circumstances, soil conditions and the target pest situation. Some

nominations were based on rates lower than these indicative rates.

Quantities in CUNs were recalculated to conform to these specifications, including use of

low permeability barrier films (e.g. VIF or equivalent). Reductions were not made if the

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 16 

# Party provided a substantive argument otherwise (e.g. unusually tolerant pests) or there

were regulatory requirements to use specific rates.

In applications where broadacre or ‘flat fume’ coverage occurs (e.g. some plant nurseries,

nematode control in protected floricultu re and vegetables, ginger production), MBTOC

acknowledged that though films and glues are available for most situations, sealing may

be difficult with barrier films under some particular conditions, and that further work or

trials may be required in some situations to determine acceptable materials.

In structures, it is feasible to reduce MB use and emissions by the use of improved

sealing techniques, with monitoring to ensure only the minimum effective dosage is used,

and longer exposure periods. The average dosage rates now quoted in the CUNs,

typically around 20 g/m 3 

# for mills and similar structures, are reasonable.

In commodities, methyl bromide dosage rates vary with commodity temperature and by

commodity sorption rates. Accordingly, MBTOC uses the dosage rates published by the

European Plant Protection Organization (EPPO) and found in annexes to the MBTOC

Assessment Reports published in 1995, 1998 and 2002. Parties are encouraged to use the

lowest possible dosage rate appropriate for the circumstances and as allowed by the label.

2.3.7 Rate of adoption of alternatives

MBTOC recognizes that time is needed to effect phase-in of alternatives and accepts this

as a reasonable technical argument for lack of availability to the end user sensu Decision

IX/6.

Some CUNs in the 2006 round argued that time was required to allow the relevant

industry to transition to available alternatives. Some CUNs showed a reduction in

nominated quantity requested from that of the preceding year, reflecting progressive

adoption of alternatives; while others had the same or similar quantities of MB nominated

to the preceding CUNs. In some cases alternatives at varying stages of readiness for

adoption were identified in the CUN and in others they were identified by MBTOC.

There is limited guidance and data available on what is a reasonable rate of transition to

existing and available alternatives, though para. 35 of Annex I referred to in Decision

XVI/4 states that “In situations where MBTOC recommends a nomination on grounds

that it is necessary to have a period for adoption of alternatives, the basis for calculating

the time period must be explained fully in the TEAP report and take fully into account the

information provided by the nominating Party, the supplier, the distributor or the

manufacturer. Relevant factors for such a calculation include the number of enterprises

that need to transition, e.g., the number of fumigation and pest control companies,

estimated training time assuming full effort, opportunities for importing alternative

equipment and expertise if not available locally, and costs involved.” Improved guidance

from the Parties, giving expected rates of adoption of alternatives following registration,

would assist MBTOC in evaluation of CUNs in future.

# October 2005 TEAP Report on 2005 CUNs: Final Report 17 

# 2.3.8 Fulfilment of Decision IX/6

Decision XVI/2 directed MBTOC to indicate whether all CUNs fully met the

requirements of Decision IX/6. When the requirements of Decision IX/6 were met,

MBTOC recommended the full amount of the request. Where some of the conditions

were not fully met, MBTOC recommended a decreased amount, depending on its

technical and economic evaluation. MBTOC reduced a nomination when a technical

alternative was considered effective or when the Party had failed to show that it was not

effective. Where the criteria of Decision IX/6 were not satisfied to a substantial extent,

MBTOC did not recommend the nomination. In this round of CUNs, MBTOC

considered answers submitted by Parties in response to questions previously sent, and

which explained why the nominations had been placed in the ‘unable to assess’ category.

There is one section of Decision IX/6 th at MBTOC did not evaluate, and one MBTOC

evaluated less stringently. These are use of stockpiles (para. 1 (b) (ii)) and the need for

the Party to conduct sufficient research on altern atives (para. 1 (b) (iii) in part)). MBTOC

or the Ozone Secretariat has not collected data on level of stocks or stockpiles present in

various countries and Parties did not provide such data for individual nominations. Thus,

MBTOC did not use that element in its evaluation. MBTOC also found some applicants

did not, themselves, conduct sufficient research to fully meet Decision IX/6. Sometimes

a Party reviewed and reported on similar or pertinent research in other countries or

situations. MBTOC also found, in far fewer instances, and generally only where the

applicant was a small operator, no research was conducted, possibly reflecting inability

on the part of the applicant to do so because of cost. In those instances, MBTOC relied

more heavily on its own knowledge of the research and on developments and usages in

related crops or situations, and evaluated this section of the Decision less stringently.

2.3.9 Sustainable Alternatives

In most CUNs, the most currently appropriate alternatives are chemical fumigant

alternatives, which themselves, like MB, have issues related to their long term suitability

for use. MBTOC urges Parties to consider the long term sustainability of treatments

adopted as alternatives to MB, to continue to adopt chemical and non-chemical

alternatives for the short to medium term a nd to develop sustainable IPM or non-chemical

approaches for the longer term.

2.3.10 Frequency

In the CUN round for 2005, reductions in MB for both preplant soil and postharvest use

could be achieved in some nominations, where effective alternatives were identified, by

reducing the frequency of MB. In some countries, present regulations already restrict the

frequency of use of MB (e.g. to every second year) on similar crops and circumstances to

those nominated by other Parties. MBTOC suggests that in these and other instances MB

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 18 

# only be required every 2, 3 or 4 years and suggests that Parties further consider

reductions where appropriate. Alternation of control measures may also help provide or

extend user confidence and experience in alternatives. New control measures may also

be good agricultural practice, reducing risk of development of tolerance and providing

control of a wider spectrum of pests.

2.4 Final evaluations of CUNs submitted in 2005

2.4.1 Details of evaluations

MBTOC/TEAP reassessed the 26 CUNs and placed in the ‘unable to assess’ category in

the interim report published in May 2005 (TEAP 2005). In most cases, additional

information was received by MBTOC to contribute to their reassessment. MBTOC

reassessed these CUNs on the basis of the original application and further information

provided, taking into account the pertinent decisions.

Additionally MBTOC reassessed two CUNs that had been evaluated as ‘not

recommended’ in the May report of TEAP (TEAP 2005) and one CUN, initially for 130

tonnes, that had been made in 2004 for 2006, but had not been evaluated previously at

request of the nominating Party.

An additional total of 404.12 tonnes of MB has been recommended and 98.145 not

recommended for 2006 use, and a total of 7465.89 tonnes of MB has been recommended

and 686.703 not recommended for 2007 use.

Evaluations of each CUN, and of the nominations placed in the unable to assess category

are given in detail in Table 4. Table 4 also includes all evaluations of CUNs made in the

interim report on the 2005 round of nominations. No changes were made to these

evaluations where the outcome had been a recommendation. Thus only CUNs that

received an ‘unable to assess’ or ‘not r ecommended’ evaluation in TEAP (2005) have had

revised evaluations.

2.4.2 Minority evaluation

MBTOC did not reach a consensus on several nominations for cucurbits, eggplant,

pepper, strawberry fruit and tomato submitted by the US for 2007, particularly relating to

some parts of Florida and southeastern states. When critical use nominations were

reviewed at the MBTOC meeting in August 2005, 25 members voted to recommend these

CUNs (with reduced doses of MB), while 3 members voted to classify the CUNs as

'unable to assess' pending further examination and clarification.

# October 2005 TEAP Report on 2005 CUNs: Final Report 19 

# The 16 th 

# Meeting of the Parties provided new working procedures for MBTOC (Annex I

of Decision XVI/4) 1 

# . Annex I states, inter alia, that “Exemptions must comply fully with

Decision IX/6 and other relevant decisions, and are intended to be limited to the levels

needed for critical use exemptions, temporary derogations from the phase-out of methyl

bromide in that they are to apply only until there are technically and economically

feasible alternatives that otherwise meet the criteria in Decision IX/6. MBTOC should

take a precise and transparent approach to the application of the criteria...” (para. 32),

and that “MBTOC should categorize the nomination as ‘unable to assess’ if there is

insufficient information to make an assessment...” (para. 10).

The minority held that further assessment by MBTOC is needed in order to determine

which parts (i.e. areas) of the CUNs comply with Decision IX/6. Until further assessment

occurs, the minority group believes that MBTOC is not in a position to calculate or

‘recommend’ to the Parties an appropriate tonnage that complies with Decision IX/6.

The CUNs should therefore be classified as ‘unable to assess’, pending further

clarification and assessment, in accordance with Annex I procedures.

Scientific studies conducted over a number of years in the US and other countries have

demonstrated that certain alternatives provide statistically similar crop yields compared to

methyl bromide, when applied using appropriate or improved application methods (refer

to TEAP Progress Report (May 2005) and reference list (Section 5.2) for examples).

This applies in many situations of high pest pressure from nematodes and fungal

pathogens and low to moderate nutsedge pressure 2 

# . While the CUNs cited high yield

losses, high yield losses are not supported by a body of studies, particularly those using

improved application methods. Commercial use of alternatives on farms has also shown

that alternatives provide similar yields to MB when they are applied in an appropriate

manner.

Alternatives are available for parts of the CUN area. Annex I of Decision XVI/4 says

“understanding of the concept of ‘availability’ shall be primarily guided by the

alternative’s market presence in sufficient quantities and accessibility, taking into

account, among other things, regulatory constraints” (para. 18). Alternatives are used by

some growers who have the same circumstances as MB users, and sell their products to

the same markets as MB users. Further clarification is needed to quantify the areas that

could adopt alternatives prior to, and during, 2007. Areas requiring further assessment

include sites of low nutsedge pressure on karst topography, and areas of moderate pest

pressure, for example. More information therefore needs to be examined from the

applicant and other sources before MBTOC can determine which parts of the CUNs

comply with Decision IX/6. In addition, MB TOC needs to calculate a feasible rate of

adoption of alternatives using the factors listed by the Parties in paragraph 35 of Annex

I 3 

# . The minority group therefore concluded that the five CUNs should be classified as

1 

# ‘Working Procedures of the Methyl Bromide Technical Options Committee relating to the evaluation of

nominations for critical uses of methyl bromide’ UNEP/OzL.Pro.16/17. Annex I, pp.74 – 79.

2 

# Recent studies indicate that certain alternatives ma y also address high nutsedge pressure, and this matter

requires further examination.

3 

# Paragraph 35 of Annex I of Decision XVI/4 says:

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 20 

# ‘unable to assess’, pending further information and assessment, in accordance with

Annex I Procedures (1)



# .

“ In situations where MBTOC recommends a nominati on on grounds that it is necessary to have a period

for adoption of alternatives, the basis for calculating the time period must be exp lained fully in the TEAP

report and take fully into account the information provided by the nominating Party, the supplier, the

distributor or the manufacturer. Relevant factors for such a calculation include the number of enterprises

that need to transition, e.g., the number of fumigation and pest control companies, estimated training time

assuming full effort, opportunities for importing alternative equipm ent and expertise if not available

locally, and costs involved.”October 2005 TEAP Report on 2005 CUNs: Final Report21Table 4. Final evaluations of new or supplemental CUNs submitted in 2005 for 2006 or 2007Symbol ‘*’ in column 9 denotes a new or changed evaluation subsequent to TEAP May 2005 reportParty Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyAustralia Rice(consumerpacks)6.15 6.15 6.15 6.15 4.92*MBTOC recommends 4.92 tonnes of MB for packaged rice inAustralia for 2007. Although the Party has reduced its dosage rate forrice in the past few years, MBTOC further reduced the Party’snomination to conform to a dosage rate of 20 g/m3. This is aconservative interpretation of theEPPO standard for rice. Rice ismethyl bromide fumigated before marketing to ensure Sitophilus eggs(which might otherwise survive processing) will be killed before therice is received by the customer.No economic data onalternatives givenAustralia Strawberryrunners35.75 30 7.5 35.75 35.75*MBTOC recommends 35.75 tonnes to be approved for thisnomination. The CUN states that MB is required to meet industrycertification standards (disease tolerance levels), but this is notmandatory. The CUN states that plugplants are a technically feasiblealternative but that the costs associated with this technology areregarded as too high. New trials are presently being conducted. Apossible key alternative, 1,3-D/Pic, has been phytotoxic to runners incertain circumstances due to the heavy, wet and cold soil conditionsand recent trials to improve control with herbicides have beenunsuccessful. High winds and coolconditions have previouslyprevented adoption of LPF barrier films. Trials to reduce dosage ofMB 50:50 in conjunction with new LPF barrier films are beingconducted. The Party states that these trials will be completed by mid2007. Dosage rates of 250kg/ha MB used for this crop are aboveMBTOC standards, however the Party has verified that this isnecessary to meet certification fordisease and weed control in heavysoil types.CUN states data is notyet available to enable aneconomic evaluation ofalternatives.Belgium Antiquestructuresandfurniture0.319 0.199 0.199 MBTOC recommends a CUE of 0.199 tonnes for these uses in 2006.This application is for the treatment of unmovable historical antiquesand antique furniture. The Party has reduced the applicant's request inconsideration of the partial availability of alternatives. Corrodiblemetal components and church location disallows the use of phosphine.SF is not registered.CUN states nitrogen isnot economic. Cost is7.4 times cost of methylbromide.October 2005 TEAP Report on 2005 CUNs:finalReport22Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyBelgium Artefactsandstructures0.59 0.307 0.307 MBTOC recommends a CUE of 0.307 tonnes for this use in 2006.Metal components and church location disallow the use of phosphine.Additionally this application is for treatment of wood boring insectswhich requires a higher than usual dosage of MB.CUN states phosphineand contact insecticidescosts less but heat costsmore than three timesmore than MB treatment,because of energy costs.Belgium Asparagus 0.63 0.225 0.225 MBTOCrecommends that a CUE of 0.225 tonnes be approved in2006 for this use. The MB requested is to be restricted to a small partof the total production (seedbeds and open fields) with recalcitrantpest problems, not controllable by other means. Alternatives arealready in use where applicable (99.7 % of the cropping area). Thenomination aims only where no alternatives are available because oftechnical and economical reasons. The need for high plant health ofplanting material is recognised, andat present MB is appropriate forthis specific use (cool conditions, high pathogen incidence). The areais characterized by soil grown asparagus with high disease pressure,small size farms and high input from family capital. MBTOCsuggests that the Party take steps to help these remaining growers tophase out use of MB by using the available alternatives.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricesreductions when thereare multiple orrecalcitrant pestproblems.Belgium Berry fruit 0.621 0.621 MBTOCrecommends that a CUE of 0.621 tonnes be approved in2006 for this use. The MB requested is for treatment of PerennialCrop Replant Disorder in all berry fruit in open fields, exceptstrawberries. The Party states that fumigants are used to establishnew plantings once every 5 years,and that the key alternatives,metham sodium and 1,3-D, are used on approximately 20% of thecrops, but that growers need MB to ensure that pathogens do not buildup in soils. Only 8.3% of plantings are treated annually and MBTOCacknowledges that disease control is difficult as a key alternative,chloropicrin, is not registered yetwith these alternatives. MB/Picmixtures are registered, although further adoption may be limitedbecause Party is concerned about crop damage to adjacent crops.MBTOC acknowledges the efforts made by the Member State torestrict MB use further by using strip fumigation and MB/Picmixtures.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricesreductions when thereare multiple orrecalcitrant pestproblems.October 2005 TEAP Report on 2005 CUNs: Final Report23Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyBelgium Chicory 0.18 0.18 0.18 MBTOC recommends that a CUE of 0.180 tonnes be approved in2006 for this use. Alternatives are already in use where applicable(99.7 % of the cropping area). The nomination aims only wherealternatives are not available because of technical and economicalreasons. The area is characterizedby soil grown chicory with highdisease pressure, small size farms and high input from family capital. .MBTOC suggests the Party take steps to help these remaining growersto phase out use of MB by using the available alternatives particularlysubstrates.CUN notes high cost toconvert to soillesssystems. Except forsteam, alternative soiltreatments are less costlythan methyl bromide.CUN states that incertain circumstancestechnical necessity leadsto use of more costlymethyl bromide.Belgium Churches,monuments and ships'quarters0.15 0.059 0.059 MBTOC recommends a CUE of 0.059 t be approved for this use. TheParty reduced this year's nomination to 30% of its request for 2005 byreducing dosage and in consideration of the potential to adoptalternatives. The applicant has conducted research on alternatives forthis use finding that metal components disallows use of phosphine,inert gases were unsuccessful in some locations and that there was arisk to the antiques if heat was used in combinationwith MB in anattempt to reduce dosage. Good gastightness was reported with plansfor further improvement. Sulfuryl fluoride is not registered for thisuse.No economic data onalternatives given.Belgium Chrysanthemums1.12 0.72 0.0*MBTOC does not recommend this nomination. The CUN is for 7%of the crop, when both root knotnematodes and fungal pathogens(primarily Verticillium) are found inmobile or fixed greenhouses insmall-scale operations. The CUN is for contingency purposes and didnot substantiate the infeasibilityof alternatives for the specificcircumstances. Alternatives areused for this crop in similarcircumstances, notably cold, wet soils in small greenhouses. Steam,for example, has been adopted on more than 900 ha chrysanthemumsin the region (LEI 2004) and is technically and economically feasiblein the specific circumstances of this nomination (Runia 2005c, IKAT1992, Runia 2000). The use of steam may is impacted by regulatoryrequirements for certification of the equipment after it is moved fromone location to another. The CUN concluded that certain chemicalalternatives (e.g. MS + 1,3-D or other nematicide) are alsoeconomically feasible.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricereductions when thereare multiple orrecalcitrant pestproblems.October 2005 TEAP Report on 2005 CUNs:finalReport24Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyBelgium Cucumber 0.61 0.545 0.545 MBTOCrecommends that a CUE of 0.545 tonnes be approved in2006 for this use. Alternatives arealready in use where applicable.The nomination is only for uses where, according to the nomination,alternatives are not available because of technical and economicreasons. The area is characterisedby soil grown cucumber with highdisease pressure, small size farms and high input from family capital.MBTOC suggests that the Party take steps to help these remaininggrowers to phase out use of MB by using the available alternativesparticularly substrates and grafting.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricesreductions when thereare multiple orrecalcitrant pestproblems.Belgium Cutflowers4 1.956 1.956 MBTOC recommends 1.956 tonnes for this nomination. The criticaluse is required because of restriction imposed by small farm size andmixed number of crops, and restrictions on alternative use because ofcool soil temperatures and extended plant back times. MBTOCappreciates the additional information sent by the Party as it helpsclarify the nature ofthis nomination. For future nominations, theParty is encouraged to collectand submit statistical informationregarding technical and economical validation of alternatives for thecritical uses involved in this nomination.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricesreductions when thereare multiple orrecalcitrant pestproblems.Belgium Electronicequipment0.1 0.035 0.035 MBTOC recommends a CUE of 0.035 tonnes for this use in 2006.Phosphine cannot be used in this situation and SF not registered. TheParty reduced the applicant's request to ensure minimal emissions anduses the MBTOC standard dosage rate.No economic data onalternatives given.Belgium Empty silo 0.05 0.043 0.043 MBTOC recommends a CUE of 0.043 tonnes for this use in 2006.The Party reduced the applicant's request to eliminate structures ofpoor gastightness. Contact pesticides, heat, cold, and heat plus MBare already in use. SF is not registered. Phosphine cannot be used inmany facilities since they includecorrodible equipment. Applicanthas reduced MB use to very low levels and low frequency offumigationEnergy costs for heattreatment are higher.Costs of IPM withpheromone trapping andspray treatment aregreater than costs ofmethyl bromide.October 2005 TEAP Report on 2005 CUNs: Final Report25Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyBelgium Endive 1.65 1.65 MBTOC recommends that a CUE of 1.65 tonnes be approved in 2006for this use. The nominated quantity amount is less than the quantityused in 2003 (2.08 tonnes). Alternatives are already in use (98.1%) ofthe cropping area. The nomination isonly for uses where, accordingto the nomination, alternatives are not available because of economicreasons. The endive area is characterized by soil grown crops grownin areas with high disease pressure, small size farms and high inputfrom family capital. MBTOC suggests that the Party take steps tohelp these remaining growers to phase out use of MB.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricesreductions when thereare multiple orrecalcitrant pestproblems.Belgium Flour mill 0.072 0.072 MBTOC recommends a CUE of 0.072 tonnes for this use in 2006.The applicant has reduced dosage, emissions and minimises MB useby using it during times of high ambient temperature. This applicanthas reduced MB use and frequency to a very low level.CUN reports heat willcost 2.63 times morethan methyl bromideBelgium Flour mills 4.17 4.17 MBTOCrecommends a CUE of 4.17 tonnes for this use in 2006.Party has reduced dosage to MBTOC standard for structuraltreatments and in consideration of use of alternatives and frequency offumigation, and reduced the applicant's request in consideration ofthose mills that need improvement in gastightness. Party has takenmeasures to ensure good gastightness through mill improvements insome mills. SF not registered.CUN reports phosphinewill cost 50% more, heatwill cost 6.5 times moreand modified atmospherewill cost 10 times thanmethyl bromide.Sulfuryl fluoridetreatment is more costlythan methyl bromide.Belgium Foodpremises0.3 0.3 0.03 0.03 MBTOC recommends a CUE of 0.030 tonnes for this use for 2006.This CUN relates to fumigation of 21 premises. Applicant hasreduced MB use to very low levelsand low frequency of fumigation.No economic data onalternatives given.October 2005 TEAP Report on 2005 CUNs:finalReport26Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyBelgium Foodprocessingpremises0.03 0.03 0.03 MBTOC recommends a CUE of 0.030 tonnes for this use for 2006.Applicant has reduced MB use to very low levels and low frequencyof fumigation.CUN reports IPM willcost more than 3 timesand sprays will cost 3times more than MB;energy costs too high forheat treatmentBelgium Foodstorage(dry)structure0.12 0.12 0.12 MBTOC recommends a CUE of 0.120 tonnes for this use in 2006.The applicant has reduced MB use and frequency of fumigation to avery low level.IPM alone will cost 3.7times more than MB.Spray insecticides 3times cost of methylbromide.Belgium Leek &onionseeds0.66 0.155 0.155 MBTOC recommendsthat a CUE of 0.155 tonnes be approved in2006 for this use. Alternatives are already in use where applicable(99.7 % of the cropping area). The nomination is only for uses where,according to the nomination, alternatives are not available because oftechnical and economic reasons. The CUN is characterized by leekand onion seed crops grown in soils with high disease pressure, smallsize farms and high input from family capital. MBTOC suggests thatthe Party take steps to help the remaining growers to phase out use ofMB by using the available alternatives, particularly substrates.CUN notes alternativechemical treatments areless costly than methylbromide but in cases ofcombined pest pressure,their technicalperformance is notassured. CUN statessteam is not costeffective.October 2005 TEAP Report on 2005 CUNs: Final Report27Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyBelgium Lettuce 25.19 22.425 0.0*MBTOC does not recommend this nomination. The CUN is for heavybutterhead lettuce grown in soils with high disease pressure. Thenomination covers about 2% of the heavy butterhead lettuce crop area,where alternatives are consideredinfeasible because of technical,economic and regulatory constraints, such as the presence of bothnematodes and soilborne fungi, cold, wet conditions, small size farmsand high input from family capital.The nomination did not providedata that substantiated the infeasibilityof alternatives.Alternatives(e.g. dazomet applied uniformly, effective methods of steaming) areavailable and are used for this crop in the same conditions in thisgeographical region (Runia 2005ab). The CUN also providedsupporting evidence of the viabilityof steam, and noted that steamprovides other commercial advantagesthat are able to offset thehigher cost, such as a longer growing period which can permit anadditional crop per year. The use of steam is impacted by regulatoryrequirements for certification of the equipment after it is moved fromone location to another.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricereductions when thereare multiple orrecalcitrant pestproblems.Belgium Mills 0.2 0.2 MBTOC recommends a CUE of 0.2 tonnes for this use in 2006. TheParty has reduced dosage to MBTOC standard for structuraltreatments and reduced the applicant's request in consideration ofthose mills that need improvement ingastightness, use of alternativesand frequency of fumigation. Party has taken measures to ensuregood gastightness through mill improvements in some mills. SF notregistered.IPM alone will cost 3.7times more than MBBelgium Nursery 0.9 0.384 0.384*MBTOC recommends 0.384 tonnes for this nomination in 2006. Thisnomination is for production of ‘clean’ planting material. Economicalinfeasibility of producing the cropsinvolved in this nomination insubstrates or as “plug plants” has not been substantiated by theMember State. In spite of this lackof information there is a need toproduce nursery stock that meets stringent disease-free standards.Failure to meet these standards poses a risk of encounteringsubstantial losses. MBTOC urges the Party to provide a bettertechnical and economic assessment ofthe alternatives above.CUN provides cost datafor soil fumigation withmethyl bromide andalternative chemicals andsteam. No yield or pricedata were reported.CUN states the economicconsequences of nurserystock that is not healthyand free of pathogens aredramatic loss of yieldand revenueOctober 2005 TEAP Report on 2005 CUNs:finalReport28Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyBelgium Oldbuildings0.306 0.306 MBTOC recommends a CUE of 0.306 tonnes for this use in 2006.The Party reduced the applicant’s request to ensure emissions controlswere improved and to take into consideration use of MBTOC standarddosage rates and current available alternatives. Applicant notes thatMB use is restricted to incidents where IPM has failed. SF is notregistered.CUN reports high energycosts for heat or coldtreatment. Phosphinemarginally lower cost butpresents technicalproblem.Belgium Oldbuildings0.282 0.282 MBTOC recommends a CUE of 0.282 tonnes for this use in 2006.MB use is restricted to where IPM has failed. Phosphine cannot beused because of risk of damage toold materials. SF is not registered.No economic data onalternatives givenBelgium Pepper &egg plant3 1.35 1.35 MBTOC recommends that a CUE of 1.35 tonnes be approved in 2006for this use. This recommendation is made on the basis of economicissues. Most production of this crop does not rely on methyl bromide.The remaining production of eggplant and pepper using methylbromide is characterised by cropping in soils with high diseasepressure, with small size farms and high input from family capital.MBTOC suggests that the Party help these remaining growers totransition out of MB use, using the available alternatives and,particularly, substrates.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricesreductions when thereare multiple orrecalcitrant pestproblems.Belgium Strawberryrunners3.4 0.9 0.9 MBTOC recommends a CUE of 0.9 tonnes be approved for this use in2006.The Party is requested to provide a copy of the Flemishcertification handbook for strawberry runners. The nomination isbased on the grounds that registered alternatives are not suitable forthe specific pest combinations andconditions. The Party states thatalternatives are usedwhenever feasible. MBTOC notes with concernthat the Party states thatin the last 10 years inBelgium there has beenno research on soil fumigation and MB alternatives for strawberryrunner production. The Party states that plug plants are currently notused, and that possibly in the future there will be a place for plugplants. MBTOC recognises the substantial MB reductions made inthis sector recently, from 4.0 tonnes in 1998 to 0.9 tonnes in currentnomination.CUN provides cost datafor soil fumigation withmethyl bromide andalternative chemicals andsteam. No yield or pricedata were reported.CUN states the economicconsequences of nurserystock that is not healthyand free of pathogens aredramatic loss of yieldand revenueOctober 2005 TEAP Report on 2005 CUNs: Final Report29Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyBelgium Tomato(protected)5.7 4.5 4.5 MBTOC recommendsthat a CUE of 4.5 tonnes be approved in 2006for this use. This is similar to the amount of MB used in 2003 (4.6tonnes). This recommendation is made on the basis of economicissues. Alternatives are already in use where applicable,predominantly soilless culture on72% of the cropping area. Thenomination is only for uses where, according to the nomination,alternatives are not available because of economic constraints. Theproduction is characterised by growing in soils with high diseasepressure, with small size farms and high input from family capital.MBTOC suggests that the Party help these remaining growers totransition out of MB use using the available alternatives, particularlysubstrates and grafting.CUN provides a netrevenue analysis showingdecreased net revenuerelative to methylbromide if alternativesare used in situationswhere they are notsuitable. CUN notespotential yield, quality,and market pricesreductions when thereare multiple orrecalcitrant pestproblems.Belgium Treenursery0.23 0.155 0.155 MBTOC recommendsthat a CUE of 0.155 tonnes be approved for2006 for this use. Clean propagative material is recognised asimportant in the reduction of needfor fumigation of production fields.Party is requesting 155 kg to treat 0.5 ha (1% of the tree nurseryproduction area). This is a reduction of 33% from the amountapproved for 2005. Dosage ratesare consistent with MBTOC'sguideline standards. MBTOC notesthat, according to the Party (EC),lack of technical and economically feasible alternatives has not beenvalidated and efforts to find, register and deploy alternatives havebeen insufficient.CUN provides cost datafor soil fumigation withmethyl bromide andalternative chemicals andsteam. No yield or pricedata were reported.CUN states the economicconsequences of nurserystock that is not healthyand free of pathogens aredramatic loss of yieldand revenueBelgium Woodworkingpremises0.3 0.101 0.101 MBTOC recommends a CUE of 0.101 tonnes for this use in 2006.The Party has reduced the applicant's requested amount to use MBstandard dosage rate and availability of alternatives. The amountnominated is already reduced to one third of the 2005 CUE.CUN reports IPM andpheromone trapping willcost over 3 times andspray treatment will costover twice the cost ofmethyl bromideOctober 2005 TEAP Report on 2005 CUNs:finalReport30Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyCanada Flour mills (a) 27.8 7.030.167 30.167 MBTOC recommends a CUE of30.167 tonnes for this use in 2007.The Party has reduced its MB use over 2006 levels. Considerableresearch has allowed for a shift toheat treatments where possible.IPM improvements and full site heat trials are on going. MBTOCstandard dosage is used. SF is not registered.Research submittedindicates that heat islikely to be 2-6 timesmore expensive than MBtreatmentCanada Strawberryrunners(PEI)(a) 8.666(b) 7.995 7.995 MBTOC recommends a CUE of 7.995 tonnes for this use in 2007.This nomination is for strawberry runners for which nationalregulatory controls are in place in both the nominating Party and theParties that receive shipment of this material. The Party hasdetermined that the usage covered by this CUN does not fall underQPS. MBTOC acknowledges that the ban of 1,3-D in the nominatedregion is a significant impediment to the Party in the transition awayfrom MB. The Party is urged to consider use of reduced rates of MBwith barrier films as a transition strategy.CUN provided noeconomic data. CUNbased on technicalfeasibility reasons.Canada Strawberryrunners(Quebec)(a) 1.826 1.826 MBTOC recommends a CUE of 1.826 tonnes for this use in 2007.This nomination is for strawberry runners for which nationalregulatory controls are in place in both the nominating Party and theParties that receive shipment of this material. The Party hasdetermined that the usage covered by this CUN does not fall underQPS. The Party is urged to consider use of reduced rates of MB withbarrier films as a transition strategy.CUN provided noeconomic data. CUNbased on technicalfeasibility reasons.Germany Artefacts 0.25 0.1 0.1 MBTOC recommends a CUE of 0.1 tonnes for this use (control offungi in immovable historical artefacts) in 2006. MBTOC does notknow of any technically effective alternatives for this use under theparticular circumstances.No economic data onalternatives givenOctober 2005 TEAP Report on 2005 CUNs: Final Report31Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyGermany Mills andProcessors45 19.35 19.35 MBTOC recommends a CUE of 19.35 tonnes for this use in 2006.The Party reduced the applicant'srequested amount to take intoconsideration that SF is newly registered, balanced by theconsideration that there is no MRL for fluorine. This application isonly for MB use when neither heat nor phosphine can be used.SF costs for millstreatment areinsufficiently known andheat treatment in largemils costs more and mustbe done more frequentlyfor same level of controlof MB.Greece Dried fruit 4.283.081 3.081*MBTOC recommends 3.081 tonnes of MB for dried figs and raisinsfor Greece for 2006. National legislation requires treatment by MB forfigs and raisins when harvested, but treatment during storage isconducted with phosphine. MB fumigation is required at harvest totreat large volumes of figs and raisins quickly before holiday seasonmarketing.CUN reports direct costsof phosphine are lowerthan methyl bromide, buttreatment takes muchlonger resulting indowntime or need formore chamber capacity.Party also reportsinstallation and operatingcosts of cold treatmentare high compared tomethyl bromide.Greece Cucurbits 30 19.2 19.2 MBTOC recommends that a CUE of 19.2 tonnes be approved in 2006for this use. Alternatives are already in use where applicable (89.5 %of the cropping area). The nomination aims only where noalternatives are available becauseof economical reasons. The area ischaracterized by high disease pressure, small size farms and highinput from family capital. MBTOC suggests that the Party take stepsto help these remaining growers to phase out use of MB by using theavailable alternatives particularlychemicals, substrates and grafting.CUN reports costs ofchemical and nonchemical alternatives formethyl bromide. Partialbudget analysis showsthat chemical alternativesresult in gross margin(net revenue) decreasesof 50 percent or morecompared to methylbromide.October 2005 TEAP Report on 2005 CUNs:finalReport32Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyGreece Cutflowers14 14 6 6*MBTOC recommends a CUE of 6 tonnes for this use in 2006. Thenomination is for treatment of fungiand nematodes in three flowertypes, carnations (mostly open field), roses and gypsophila.Requested amounts have been significantly reduced from 14 to 6tonnes from the previous year. The Party did not fully substantiate thetechnical and economical infeasibility of alternatives, but MBTOCacknowledges that chloropicrin and mixtures thereof are not registeredin Greece for cut flower production,limiting the range of alternativesavailable. The Party states that although substrates are technicallyfeasible they are economically infeasible. Research conducted inGreece has identified substrates aseconomically feasible for someflower types (Graffiadellis etal., 2000, Savvas and Passam 2002).CUN reports 30% yieldloss with metham sodiumor dazomet compared tomethyl bromide. Partyreports these alternativeswill result in net revenuedecreases of 16 to 27percent compared tomethyl bromide. Soillessproduction is in use for25 percent of roseproduction. Initial costof establishing soillesssystems is a majorconstraint on furtheradoption.Greece Mills andProcessors23 16 15.445 MBTOC recommends a CUE of 15.445 tonnes for this use in 2006.The minimum label dosage rate inGreece is higher than the MBTOCstandard dosage rate for fumigation of structures. No dosageadjustments are proposed, but the Party may wish to instructfumigators to use the minimum dosage rates in the range given on thelabel to minimise emissions and MB usage. It is suggested that theParty continue research and development on heat treatments combinedwith IPM improvements as a priority.CUN reports thatphosphine costs 3 timesmore than MB treatmentGreece Rice andlegumes2.355 2.355 MBTOC recommends a CUE of 2.355 tonnes of MB for packagedrice and legumes for 2006. The sector is in transition to thealternatives phosphine and vacuum packaging. The MB recommendedis for the remaining product that will not be able to switch toalternatives by 2006. The Party uses the EPPO standard dosage rates.High capitol costs formodified atmospherepackaging equipment.Recent decreased cost ofMB in comparison withphosphine. Lengthy timein phosphine treatmentdelays shipment.October 2005 TEAP Report on 2005 CUNs: Final Report33Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyGreece Tomatoes 156 73.6 73.6 MBTOC recommends a CUE of 73.6 tonnes for this use in 2006. TheParty states the nomination is restricted to where alternatives are notavailable because of economic reasons. Alternatives are already inuse on 53-63 % of the cropping area. The area relating to thenomination is characterised by highdisease pressure, with small sizefarms and high input from family capital. MBTOC suggests that theParty takes steps to help these remaining growers to phase out use ofMB using the available alternatives, particularly 1,3 D+ Pic, substratesand grafting.CUN reports costs ofchemical and nonchemical alternatives formethyl bromide. Partialbudget analysis showsthat chemical alternativesresult in gross margin(net revenue) decreasesof 45 percent or morecompared to methylbromide.Ireland Mills 0.888 0.888 MBTOC recommends a CUE of 0.888 tonnes for this use in 2006.The Party reduced the applicant's request to adjust to MBTOCstandard dosage rates. Full scale heat treatment trials are underway.Difficulty in achieving good pest control results with alternatives inlarger mills has been observed.CUN notes sulfurylfluoride will be at least2.5 times cost of methylbromide. No accuratecost of heat available.Losses from additionaldowntime whenalternatives are used.Italy Mills andProcessors160 130 (c) 65*MBTOC recommends a CUE of 65 tonnes of MB for this use for2006. The Party reduced its original nomination by 50% to accountfor and encourage adoption of the newly registered fumigant sulfurylfluoride. The Party provided location and number of facilities andtheir volumes, frequency of fumigation and historical use data. TheParty uses MBTOC standard dosage rate of 20/gm3 MB forstructures.Party deferredassessment.Japan Chestnuts 7.1 6.5 0.3 6.5 0.3 6.5 MBTOC recommends a supplemental CUE of 0.3 tonnes for this usein 2006 and a CUE of 6.5 tonnes for this use in 2007. MBTOC doesnot know of any alternatives for disinfestation of fresh chestnuts inshell. Japan is encouraged to continue research into alternatives.No economic data onalternatives givenOctober 2005 TEAP Report on 2005 CUNs:finalReport34Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyJapan Cucumber 88.3 87.6 1.2 72.4 1.2 72.4 MBTOC recommends a supplemental CUE of 1.2 tonnes for 2006 anda CUE of 72.4 tonnes for 2007 for this use. The supplemental CUNfor 2006 is for areas of crop that did not apply in the previousnomination round. This is based on the recognition that both thecropping system and pathogen (Kyuri Green Mottle Mosaic Virus)targeted by methyl bromide are unique. Methyl bromide use permitsmultiple cropping within a year while managing risk of diseasecarryover. Several potential alternatives have been trialled, but havenot performed adequately. Basic practices have been in place formany years, with farmers using low technology systems, includingapplying MB from small canisters. The latter system has beensuperseded in many developed countries on grounds of safety andefficacy. MBTOC acknowledges the effort to transition growers touse VIF. However, in spite of rates conforming with MBTOCguidelines, MBTOC urges the Party to consider further reductions indosage rates, together with a more rapid transition to barrier films, asa transitional strategy while alternatives are developed.CUN reports noeconomic data onalternatives. CUN stateshydroponic systems arenot economicallyfeasible.October 2005 TEAP Report on 2005 CUNs: Final Report35Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyJapan Ginger -field119.4 119.4 112.2 109.701*MBTOC recommends a reduced CUE of 109.701 tonnes for this usefor 2007. This CUN was reevaluated at request of the Party. Thereduction is based on a decrease in effective dose by 25% due to theuptake of low permeability barrierfilms (LPF) on 9% of thenominated area by 2007. The nomination is for control of Pythiumspp. (Pythium ultimum var. ultimum, Pythium zingiberium). MB(99.5%) is applied using small cans. The Party states that chloropicrinis registered in Japan and that application equipment is available foruse on farms with small or large production areas. However, the Partyclaims that the plantback time for chloropicrin is 40 days which coulddisrupt crop scheduling and result indelays in planting and loweryields compared to MB treatment. In addition, the proximity ofresidential areas limits the use ofchloropicrin in some areas.According to the Party, metalaxyldoes not control Pythium efficientlyas resistant strains to this fungicide have been reported. Party statesthat metalaxyl is effective for 20 daysand is restricted by regulationsto only 3 applications during the 200 day growing cycle. Therefore,this fungicide is not widely used on ginger to control Pythium. TheParty reported that the pathogen is soil borne and the rhizomes usedare pathogen free. They are raised in fumigated fields and then dippedin fungicide solution (Captan wettable powder). Strip treatmentcannot be used because the large rootsystems grow into the infestednon-fumigated soils between beds. MBTOC considers otheralternatives may provide effective control of Pythium: chemicalcontrol with granules, powders or drenches (fenaminosulf, etridiazole,propamocarb, hymexazol, metalaxyl for non resistant fungi,furalaxyl), cultural practices (soil drainage, sowing date, organicamendments (Smith et al 1988)) and that there is scope for using Picon flat areas that are not in close proximity to residential areas. Therealso appears to be scope for further reduction in MB amount byadoption of MB/Pic mixtures in flatareas where mechanisation can beused. Also, LPF films are technically feasible and available and canbe used for at least part of thisnomination with associated reduceddosage rate and control of emissions. MBTOC notes that the use ofLPF films (VIF) have been widely adopted as required undermandatory regulation in Europe and sealing and laying problems ofolder type films have been overcome. In Japan, VIF are used forfumigation in some vegetables crops (cucurbits and pepper) (adoptionup to11.7 %) at the same rates as standard films (200 to 400 kg/ha).At present, VIFs are not used for fumigating soils for ginger. The rateof MB used varies between 250 and 300 kg/ha according to theregion.CUN estimates highercosts and lower yieldwith Chloropicrin.Dazomet has lower costthan methyl bromide butalso lower estimatedyield. Estimatedreduction in net revenuewith alternatives is -22 to-30 percent.October 2005 TEAP Report on 2005 CUNs:finalReport36Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyJapan Ginger -protected22.9 22.9 14.8 14.471*MBTOC recommends a reduced CUE of 14.471 tonnes for this usefor 2007. This CUN was reevaluated at request of the Party. Thereduction is based on a decrease in effective dose by 25% due to theuptake of low permeability barrier films (LPF) on 9% of thenominated area by 2007. The nomination is for control of Pythiumspp. (Pythium ultimum var. ultimum, Pythium zingiberium). MB(99.5%) is applied using small cans. The Party states that chloropicrinis registered in Japan and that application equipment is available foruse on farms with small or large production areas. However, the Partyclaims that the plantback time for chloropicrin is 40 days which coulddisrupt crop scheduling and result indelays in planting and loweryields compared to MB treatment. In addition, the proximity ofresidential areas limits the use of chloropicrin. According to the Party,metalaxyl does not control Pythium efficiently, as resistant strains tothis fungicide have been reported. Party states that metalaxyl iseffective for 20 days and is restricted by regulation to only 3applications during the 200 day growing cycle. Therefore, thisfungicide is not widely used on ginger to control Pythium. The Partyreported that the pathogen is soil borne and the rhizomes used arepathogen free. They are raised in fumigated fields and then dipped infungicide solution (Captan wettable powder). Strip treatment cannotbe used because the large root systems grow into the infested nonfumigated soils between beds. MBTOC considers other alternativesmay provide effective control of Pythium: chemical control withgranules, powders or drenches (fenaminosulf, etridiazole,propamocarb, hymexazol, metalaxyl for non resistant strains,furalaxyl), cultural practices (soil drainage, sowing date, organicamendments (Smith et al 1988)) and that there is scope for using Picon flat areas that are not in close proximity to residential areas. Therealso appears to be scope for further reduction in MB amount byadoption of MB/Pic mixtures in flatareas where mechanisation can beused. Also, LPF films are technically feasible and available and canbe used for at least part of thisnomination with associated reduceddosage rate and control of emissions. MBTOC notes that the use ofLPF films (VIF) have been widely adopted as required undermandatory regulation in Europe and sealing and laying problems ofolder type films have been overcome. In Japan, VIF are used forfumigation in some vegetables crops (cucurbits and pepper) (adoptionup to11.7 %) at the same rates as standard films (200 to 400 kg/ha).At present, VIFs are not used for fumigating soils for ginger. The rateof MB used varies between250 and 300 kg/ha according to theregion.CUN estimates highercosts and lower yieldwith Chloropicrin.Dazomet has lower costthan methyl bromide butalso lower estimatedyield. Estimatedreduction in net revenuewith alternatives is -22 to-30 percent.October 2005 TEAP Report on 2005 CUNs: Final Report37Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyJapan Melon 194.1 171.6 32.3 182.2 32.3 182.2 MBTOC recommends a supplemental CUE for 32.3 tonnes for 2006and a CUE of 182.2 tonnes for 2007 for this use. The supplementalCUN for 2006 is for areas of crop that did not apply in the previousnomination round. This is based on the recognition that both thecropping system and pathogens (Melon necrotic spot virus andCucumber green mottle mosaic virus)targeted by methyl bromide areunique. Methyl bromide use permits multiple cropping within a yearwhile managing risk of disease carryover. Several potentialalternatives have been trialled, buthave not performed adequately.Basic practices have been in place for many years, with farmers usinglow technology systems, including applying MB from small canisters.The latter system has been superseded in many developed countriesand grounds of safety and efficacy. MBTOC also acknowledges theeffort to transition growers to useVIF. However, in spite of ratesconforming with guideline standards, MBTOC urges the Party toconsider further reductions in dosage rates, together with a more rapidtransition to VIF or equivalent films, as a transitional strategy whilealternatives are developed.Technical reasons forCUN citing particularvirus situation. Noeconomic data on methylbromide alternatives.October 2005 TEAP Report on 2005 CUNs:finalReport38Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyJapan Peppers(green andhot)187.2 112.3 74.9 13.5 169.4 13.5 156.7 MBTOC recommends that a supplementary CUE for 13.5 tonnes for2006 and a reduced CUE of 156.7 tonnes for 2007. The nominationis based on the stated need to control a particular virus of peppers.Pepper mild mottle tobamovirus is transmitted by mechanicalinoculation, grafting andcontact between plants and by seeds, and cansurvive in crop debris, especially in fumigated soils. The problemappears to exist because of continuous cropping with peppers and iscontrolled in other countries by appropriate crop rotation, better cropsanitation and use of pathogen free seeds. The virus has been reportedin many countries. In spite of the high severity of this virus in most ofthese countries, MB has never been used or requested for its control.MBTOC recognises the unique farming system used for peppers inJapan in place for many years. MBtreatment is apparently essentialto economic health of these growers. MBTOC notes that the culturalpractices adopted for pepper production in Japan result in need forMB for this virus and that no other country is using MB to control thisvirus. The Party is urged to demonstrate progress in developingstrategies to eradicate the pathogen, particularly from the crop debris.VIF technology is currently being introduced. The Party claims thatthe minimum rate of adoption of VIF is 5% per year and is achievable,although a higher rate may be possible. Based on the Party statement,MBTOC sees that by 2007, 15% ofthe growers will be adopting VIFat a dosage of 200 kg/ha for those currently using high rates of 400kg/ha. A 7.5 % reduction of the nomination for 2007 is thusrecommended.Technical reasons forCUN citing particularvirus situation. Noeconomic data on methylbromide alternatives.October 2005 TEAP Report on 2005 CUNs: Final Report39Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyJapan Watermelon 129.0 60.9 38 94.2 38 94.2 MBTOC recommends a supplemental CUE of 38 tonnes for 2006 anda CUE of 94.2 tonnes for 2007 for this use. The supplemental CUNfor 2006 is for areas of crop that did not apply in the previousnomination round. This is based on the recognition that both thecropping system and pathogen (Cucumber green mottle mosaic virus)targeted by methyl bromide are unique. Methyl bromide use permitsmultiple cropping within a year while managing risk of diseasecarryover. Several potential alternatives have been trialled, but havenot performed adequately. Basic practices have been in place formany years, with farmers are using low technology systems, includingapplying MB from small canisters. The latter system has beensuperseded in many developed countries on grounds of safety andefficacy. MBTOC acknowledges the effort to transition growers touse VIF. However, in spite of rates conforming with standards,MBTOC urges the Party to consider further reductions in dosagerates, together with a more rapid transition to VIF films, as atransitional strategy while alternatives are developed.Technical reasons forCUN citing particularvirus situation. Noeconomic data on methylbromide alternatives.Latvia Grains 2.502 2.502*MBTOC recommends a CUE of 2.502 tonnes for this use for 2006.This sector is characterized by older, traditional grain silos lackingsealing and modern circulation systems, making the use of alternativesdifficult. The amount recommended by the Party (EC) resulted from acalculation that reduced frequency offumigation and dosage rate to alow rate. The Party isencouraged to ensure technical efficacy offumigations through the selectionof appropriate dosage rates.CUN reports phosphinecosts twice as much, andthe additional costs forimproved ventilationequipment to allow useof phosphine would beprohibitive.October 2005 TEAP Report on 2005 CUNs:finalReport40Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyMalta Cucumber 0.127 0.127 MBTOC recommends a CUE of 0.127 tonnes of MB in 2006 for thisuse. MBTOC recognises that farmers in Malta intend to transition toalternatives as suggested by the Party by 2007 (dazomet, methamsodium and solarisation) and that any stocks of methyl bromide wouldbe used for any remaining critical uses.The CUN reports one setof economic informationin a single CUN forcucumber, eggplant,strawberry and tomatoes.The CUN reports costs ofmethyl bromidetreatment, steam, andsolarisation. Gross andnet revenues for methylbromide, steam, andsolarisation are reported.Significantly lower netrevenues result from thealternatives. However,because the data are notcrop specific, it is notpossible to evaluate theeconomic feasibility ofthe alternatives.Malta Eggplant 0.17 0.17 MBTOC recommends a CUE of 0.170 tonnes of MB in 2006 for thisuse. MBTOC recognises that farmers in Malta intend to transition toalternatives suggested by the Party by 2007 (dazomet, metham sodiumand solarisation) and that any stocksof methyl bromide would be usedfor any remaining critical uses.The CUN reports one setof economic informationin a single CUN forcucumber, eggplant,strawberry and tomatoes.The CUN reports costs ofmethyl bromidetreatment, steam, andsolarisation. Gross andnet revenues for methylbromide, steam, andsolarisation are reported.Significantly lower netrevenues result from thealternatives. However,because the data are notcrop specific, it is notpossible to evaluate theeconomic feasibility ofthe alternatives.October 2005 TEAP Report on 2005 CUNs: Final Report41Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyMalta Strawberry 0.212 0.212 MBTOC recommends 0.212 tonnes for 2006 of MB in 2006 for theseuses for open field and greenhouse.MBTOC recognises that farmersin Malta intend to transition to alternatives suggested by the Party by2007 (metham sodium combined withresistant cultivars, methamsodium + short solarisation and low cost substrates) and that anystocks of methyl bromide would be used for any remaining criticaluses.The CUN reports one setof economic informationin a single CUN forcucumber, eggplant,strawberry and tomatoes.The CUN reports costs ofmethyl bromidetreatment, steam, andsolarisation. Gross andnet revenues for methylbromide, steam, andsolarisation are reported.Significantly lower netrevenues result from thealternatives. However,because the data are notcrop specific, it is notpossible to evaluate theeconomic feasibility ofthe alternatives.Malta Tomatoes 0.594 0.594 MBTOC recommends a CUE of 0.594 tonnes of MB in 2006 for thisuse. MBTOC recognises that farmers in Malta intend to transition toalternatives suggested by the Party by 2000 (metham sodiumcombined with resistant cultivars, metham sodium + short solarisationand low cost substrates) and that any stocks of methyl bromide wouldbe used for any remaining critical uses.The CUN reports one setof economic informationin a single CUN forcucumber, eggplant,strawberry and tomatoes.The CUN reports costs ofmethyl bromidetreatment, steam, andsolarisation. Gross andnet revenues for methylbromide, steam, andsolarisation are reported.Significantly lower netrevenues result from thealternatives. However,because the data are notcrop specific, it is notpossible to evaluate theeconomic feasibility ofthe alternatives.October 2005 TEAP Report on 2005 CUNs:finalReport42Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyNetherlands Strawberryrunners -postharvest0.12 0.12 0.12 MBTOC recommends a CUE of 0.120 tonnes for 2006 for this use(control of bacteria in bare root strawberry plantlets). The applicanthas stated there are complete MBcapture systems in place and as aresult there are no MB emissions. To date control has not beenachieved through alternatives. Party is encouraged to continue itsresearch program.No economic data onalternatives givenPoland Coffee,cocoabeans2.160 2.160 MBTOC recommends a CUE of 2.160 tonnes for this use (control ofmites in 2006 in imported cocoa and coffee beans). MBTOCrecognises that controlling mites ismore difficult than other pests andthe need for dockside treatmentat cold temperatures furthercomplicates treatment. The Party has reduced the applicant's requestto account for lower dosage rates, and the applicant has plans toreduce their dosage rates even further.The Party is encouraged tocontinue their investigation and/or adoption of rapidly generatedforms of phosphine gas.No economic data givenon alternatives, but CUNindicates capitol costs forfast generating phosphinemachines (a technicallyeffective alternative), andcold are too expensive.Portugal Cutflowers50 8.75 8.75 MBTOC recommends that a CUE of 8.75 tonnes of MB for 2006 forthis use. MBTOC appreciates the new information sent by the Partyto further clarify thenature of this nomination. For any futuresubmissions MBTOC requests that the Party more explicitly state thepests and pathogens orenvironmental conditions that make MBcritical for the portion of the cropping area where alternatives havebeen difficult to adopt. MBTOC notes that, according to the Party(EC), lack of technical and economically feasible alternatives has notbeen validated and efforts to find,register and deploy alternativeshave been insufficient.CUN reports lower costsfor dichloropropenealone and in combinationwith metham sodiumwith accompanying yieldlosses of 50 to 90 percentcompared to methylbromide. Steameffective but near 3 timesthe cost of methylbromide. Emphasis ontechnical basis for CUN.Spain Rice Between22 and5042.065*MBTOC recommends 42.065 tonnes of MB for packaged rice forSpain in 2006. This sector is in transition to alternatives and facilitiesare under construction, but will notbe completed by 2006. Incorrespondence subsequent to the initial CUN, the Party provided itsMB nomination as a range, and also later provided the total ricevolume treated by MB under vacuum and in atmospheric conditionsrespectively. MBTOC calculated the amount recommended usingEPPO standard dosage rates (50 g/m3 under vacuum and 20 g/m3 inatmospheric conditions) under these conditions of treatment and withthese product volumes.Phosphine fumigant costsequivalent to MB, butrequires longer treatmenttimes. Modifiedatmosphere chamberscapital costs high.Vacuum packagingtreatment (technicallyeffective alternative)increases consumer costs$0.20/kg of riceOctober 2005 TEAP Report on 2005 CUNs: Final Report43Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUK Cerealprocessingplants(a) 8.131 8.131 MBTOC recommends a CUE of 8.131 tonnes for this use in 2006.The Party is quickly adopting heat and SF where possible, but SF isnot registered for silos that are integral to the flour mills in the case ofthe structures within this CUN.The applicant should be encouragedto change logistics to enable emptying of silos before fumigation toallow for increased use of SF.CUN reports that heat orSF would cost 200%more than MB treatmentUK Cheesestores1.6 1.248 1.248 MBTOC recommendsa CUE of 1.248 tonnes this use (traditionalcheese stores with cheese in situ) in 2006. MBTOC knows noalternatives for mites in cheese under these conditions. The applicanthas made significant efforts inimproving gastightness and iscontinuing a research programme.CUN states there are noeconomically feasiblealternatives based onlack of technicallyfeasible alternatives.CUN presents noeconomic data oranalysis.UK Cutflowers7.56 6.05*MBTOC recommends a reduced CUN of 6.05 tonnes for this use for2006. The nomination is mainly for stocks, tulips and lilies grown inground beds under cover and affectedby soilborne fungi and otherpests. Major alternatives, particularly 1,3-D, chloropicrin and theircombinations are not registered in the United Kingdom for thisparticular use (1,3-D for outdoor use only). The Party identifiesalternatives such as steam and substrates as being feasible, but time isneeded to increase their commercial uptake. MBTOC considers thatsubstrates are now a standard technology for production for tulips andlilies in similar regions of the world and did not recommend MB for20% of the nomination representing these crops (Tribulato and Noto,2001; Van Bruggen and Duinveld, 1995;Van Os et al. 1999; Berg,2000; Puchooa et al. 1999; Sochakiand Chojnowska, 2005; Drakes etal, 2001). MBTOC notes that whilst some of the problems describedby the Party involve a soil-borne stage (e.g. thrips, Mycosphaerella),proven options exist for their efficient management and control(Powell and Lindquist, 1997; Van Driesche et al. 2004; Anon, 2001).MBTOC notes that, according to the Party (EC), lack of technical andeconomically feasible alternativeshas not been validated and effortsto find, register and deploy alternatives have been insufficient.CUN yield losses withalternatives dazomet andmetham sodium, but noyield loss with steam.Steam alternative isreportedly too costlycompared to methylbromide. The CUNpresents a partial budgetanalysis showingdazomet results in a 95percent decrease in GrossMargin (net revenue)compared to methylbromide.October 2005 TEAP Report on 2005 CUNs:finalReport44Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUK Driedcommodities(rice, fruitsand nuts)Whitworths2.4 1.256 1.256 MBTOC recommends a CUE of 1.256 tonnes for this use in 2006.The Party indicated that VIF instack fumigation and chambers areused to reduce emissions. The applicant is encouraged to assess howchanged marketing logistics will allow a higher percentage to betreated with phosphine thereby reducing MB use. MBTOC also notesthat SF is not approved for these commodities.CUN presents noeconomic information onmethyl bromide oralternatives. The Party'sresponse to EC notesdiscussed economic costsof phosphine.UK Herbs andspices0.035 0.037 0.037 MBTOC recommends a CUE of 0.037 tonnes for this use in 2006.The Party has reduced the applicant's request to encourage adoption ofalternatives and IPM. MBTOC suggests that improvements in IPMpractices, together with pest management prior to import be continuedso as to reduce the need for MB for this nomination.CUN states thatphosphine or CO2 wouldcost 5 times andirradiation would cost 7times the cost of MBtreatment, CUN noteslosses would result fromadditional downtimewhen alternatives areused.UK Mills(NABIM)(a) 10.195 10.195 MBTOC recommends a CUE of 10.195 tonnes for this use in 2006.The Party has reduced the applicant's request by 60 percent toencourage faster adoption of alternatives. Given the difficultiesidentified in the adoption of alternatives, specifically heat, in largemills, no further reductions are suggested.CUN reports heat willcost 2.5 times more thanMB and although costsof SF are unclear at thistime, it is estimated tocost 2.5 - 6 times the MBtreatment costs.UK Mills andProcessors(biscuits)2.525 1.787 1.787 MBTOC recommends a CUE of 1.787 tonnes for this use in 2006.The Party has reduced the application to account for potential to usealternatives. The applicant has also made improvements in facilitygastightness, reduced dosage rates to MBTOC standards and upgradedIPM practices to enable decreased fumigation frequency. Theapplicant also has an active researchprogramme. SF is not registeredfor this purpose.CUN states that SFwould cost 200-300%more and heat would cost200-400% than MBtreatment.UK Structures(herbs andspices)3.0 1.872 1.872 MBTOC recommends a CUE of 1.872 tonnes for this use in 2006.The Party has reduced the nomination to account for the potential tocontinue adoption of heat treatment. SF is not registered for thispurpose.CUN states heat or SFtreatment would cost200% more than MBtreatment.October 2005 TEAP Report on 2005 CUNs: Final Report45Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUK Structures,processorsand storage(Whitworths)1.1 0.880 0.880 MBTOC recommends a CUE of 0.880 tonnes for this use in 2006.The Party is encouraged to develop industry standards for efficacy ofheat treatments sufficient to comply with UK food safety legislationand to continue to develop alternatives such as appropriate packagingand phosphine treatment.CUN reports noeconomic data onalternatives. Party'sresponse to EC statescosts for SF would be upto 5 times the costs ofmethyl bromide.October 2005 TEAP Report on 2005 CUNs:finalReport46Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Cucurbits -field1187.8 747.839 598.927 592.891*MBTOC recommends a reduced CUE of 592.891 tonnes for this usefor 2007. This represents 26.261 tonnes for Michigan, 364.359 tonnesfor the SE, 201.330 tonnes for Georgia and 0.941 tonnes for research.A minority of MBTOC evaluated the parts of this CUN relating toGeorgia and SE as ‘unable to assess’ (see Section 2.4.2). The Party’snomination was adjusted to accountfor 5% of the nominated areausing barrier films and MB:Pic (50:50) at 175 kgMB/ha when treatingareas with moderate to severenutsedge and 150 kg/ha for pathogencontrol .In Michigan, the key pests arePhytophthora capsiciandFusariumoxysporum. The Party states that 1,3-D/chloropicrin may be aneffective alternative, but growers will miss the optimal marketwindow due to longer plant back times. According to the Party, thistreatment cannot be applied in autumn when soils are warm becauseof climatic conditions and damage bydeer and other animals to plasticmulches and irrigation tapes.In SE and Georgia, the key pest is mainly nutsedge and some rootknot nematodes and fungal pathogens. 1,3-Dichloropropene +chloropicrin + herbicides (trifluralin, napropamide, halosulfuron andS-metolachlor) are the most promising alternatives. Karst topographylimits the use of alternatives which includes 1,3-D on 8% of thegrowing acreage.The Party states that metham sodium or methampotassium are promising alternatives but still do not provideconsistent control and require further trials, which are underway.Other studies however, have demonstrated the efficacy of methamsodium + chloropicrin in areas with low to moderate nutsedgepressure for cucurbits and similar crops in the region (Locascio et al2000; Nelson et al 2002, Gilreath et al 2005). MBTOC anticipates thatthere will be adoption of this alternative to replace methyl bromide inkarst areas with low nutsedge infestation by 2007.In addition, theParty states that trials are underway to investigate lower MB/Picformulations such as 50:50 as there are no regulatory restrictions tothe use of these formulations.The Party states that LPF barrier films are still not being widelyadopted on a commercial scale due tolack of availability, cost andtechnical problems with laying the films. Versions of metallised filmsare being widely tested by several researchers and growers and showpromise. MBTOC believes that LPF barrier films are technically andeconomically viable for this nomination. All of the technicalproblems reported by the Party appear to have been solved inEuropean countries where the use of VIF barrier films is mandatory.CUN states next bestalternative in all regionsis 1,3-D withchloropicrin withexpected yield losses of 6percent in Michigan and29 percent inSoutheastern States andGeorgia. CUN states1,3-D with chloropicrinis considered technicallyfeasible inMichigan.However, CUN notedthat for Michigan inaddition to the yield loss,delayed planting andharvest with thealternatives results loweraverage price receivedfrom missed marketwindows and negativenet revenue. Inremaining regions yieldlosses significantlyreduce net revenues.CUN notes other regionsmay also experiencelower prices because ofmissed market windows.October 2005 TEAP Report on 2005 CUNs: Final Report47Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Cucurbits –field(continued)Grower scale trials have demonstrated the success of a 50% reductionin rate with LPF film (Gilreath and Santos 2004, 2005). In fields withmoderate to heavy nutsedge pressure, Santos and Gilreath (2005) haveshown that the standard MB/Pic 67:33 at a rate of 350 kg/ha can bereduced by 25 % (to 175 kg/ha MB) under LPF film with equivalentyields and nutsedge control. In the past year, there has beensubstantial commercial adoption of LPF film in the southeast of USA(Bruno Rimini Ltd, pers. comm.). MBTOC has recommended areduction in the nomination as shown above to account for decreaseddosage rates in areas with low disease pressure from nutgrass inanticipation of the likely increased implementation of emissioncontrol technologies, including adoption of LPF barrier films, by2007.USA Driedbeans7.07 7.07*MBTOC recommends a supplemental request for a CUE of 7.07tonnes for this use in 2006. A nomination for this use was includedwith other dry commodities in the 2003 round of CUNs for 2005 use,but was omitted from the 2004round for 2006 use. Beans areproduced in high quantity and short time in California. Between 60-90% of black eye beans are consumedat New Year festival (January),yet they are harvested in October and November. Use of phosphinewould require longer fumigation times, but treatment facilities arecurrently inadequate to handle the high volumes harvested in the shorttime between harvest and need tomarket for the holiday. With thenext harvest the bean sector will begin trials of cylinderized phosphineand the newly registered sulfuryl fluoride.No economic data onalternatives given.October 2005 TEAP Report on 2005 CUNs:finalReport48Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Dried fruitand nuts(walnuts,pistachios,dried fruitand datesand driedbeans)89.166 80.649 91.299 78.983*MBTOC recommends a CUE of 78.983 tonnes for these uses for2007. This recommended amount comprises 45.401 tonnes forwalnuts; 18.234 tonnes for dried fruit; 3.016 tonnes for dates; 5.262tonnes for pistachios and 7.070 tonnesfor beans (garbanzos and blackeye beans). The amounts of methyl bromide requested for this sectorby the Party are the same amounts of methyl bromide used in 2001-2002. MBTOC reduced the amount nominated for walnuts to utilize adosage rate of 48 g/m3 used in 2006 by the Party, instead of the 61g/m3 requested for 2007, in the absence of data justifying the need foran increased dosage rate. Phosphine is the commonly used fumigantfor pistachios. There has been considerable adoption of gaseousphosphine by the largest Californian processor to reduce the treatmenttime for pistachios Fumigation with phosphine takes longer thanfumigation with MB and the Party has indicated a need for MB whenquick turn around is demanded and when that demand cannot besatisfied by available phosphine-treated pistachios. Beans and walnutsare produced in high quantity and short time in California. Between60-90% of black eye beans are consumed at New Year festival(January), yet they are harvested in October and November. Use ofphosphine would require longer fumigation times, but treatmentfacilities are currently inadequate to handle the high volumesharvested in the short time between harvest and need to market for theholiday. With the next harvest thebean sector will begin trials ofcylinderized phosphine and the newly registered sulfuryl fluoride.MBTOC has ascertained that the dates referred to in the CUN arefreshly harvested dry dates. Phosphineis not registered for use on thisproduct and sulfuryl fluoride has only been recently been registeredfor this sector. The Partystated that further adoption of alternatives by2007 will be taken into consideration during its allocation publicrulemaking process.Economic data onalternatives given forwalnuts, pistachio anddried fruit other thandates. Phosphinefumigant costs 10-30%higher but problem isphosphine takes longer toaccomplish and its usewould not allow sellersto reach Decemberholiday export marketwindow since product isharvested in autumn.CUN states walnuts,pistachio, and dried fruitall experience substantialadditional downtime andsubsequent lost revenuesif phosphine is used.October 2005 TEAP Report on 2005 CUNs: Final Report49Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Drycommodities/structures(cocoabeans)61.519 46.139 15.38 64.082 64.082*MBTOC recommends a CUE of 64.082 tonnes for this use for 2007.This nomination has been takenout of the NPMA food processingfacilities CUN and has been dealt with separately. The amount of MBnominated for cocoa beans represents an increase for 2007 over 2006,based on forecasted increase incocoa bean imports. MBTOC’srecommendation is based on cocoa beans being fumigated once onimport and once again immediately before shipment to chocolatemanufacturers and that cocoa beanwarehouses comply with thewarehouse quality control program ofthe Cocoa Merchants. The Partyuses MBTOC’s standard dosage rate or 20g/m3 MB for structures.Under the circumstances of cocoabean storage in the US phosphinecannot currently be used because oflabel restrictions on entry to thewarehouse during fumigations and because phosphine requiresunacceptably longer fumigation times at the temperatures experiencedin the warehouses. Sulfuryl fluoride has only been recently beenregistered for this sector. The Party stated that further adoption ofalternatives by 2007 will be taken into consideration during itsallocation public rulemaking process.No data on costs ofalternatives. CUN notesadditional fumigationtime needed withphosphine, and costs ofretrofitting facilities forheat treatment.USA Drycommodities/structures(processedfoods,herbs andspices,dried milkand cheeseprocessingfacilities)NPMA83.344 56.253 27.091 83.238 82.771*MBTOC recommends a CUE of 82.771 tonnes for these uses for2007. The original CUN also includedcocoa beans, but these are dealtwith separately. MBTOC recommends 74.884 tonnes for foodprocessing facilities,4.891 tonnes for spice and herb processingfacilities and 2.996 tonnes for cheese processing facilities. MBTOCdoes not recommend the 0.467 tonnes nominated for the drycommodity sector of this CUN (the ‘other’ category) because thetechnically effective alternatives ofethylene oxide gas, irradiation,phosphine and propylene oxide are registered and in broadcommercial use for this purpose. These commodities can be treated atcontract fumigation or irradiation facilities. The Party’s nominationalready uses MBTOC standard dosage rates. The Party has madesome progress adapting heat and other fumigants in this sector.Sulfuryl fluoride has only recently beenregistered for this sector. TheParty reduced their applicant’s nomination by about 20% over 2006levels to take into considerationadoption of alternatives. The Partystated that further adoption of alternatives by 2007 will be taken intoconsideration during its allocation public rulemaking process.No data on costs ofalternatives. CUN notesadditional fumigationtime needed withphosphine, and costs ofretrofitting facilities forheat treatment.October 2005 TEAP Report on 2005 CUNs:finalReport50Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Dry cureporkproducts(buildingandproduct)67.907 40.854(c)40.854 18.998*MBTOC recommends 18.998 tonnes of MB for US dry cure porkproducts composed of 18.144 tonnes for American Association ofMeat Processors; 0.709 tonnes for National Country HamAssociation; and 0.145 tonnes for Nahunta Country Pork Center. Thistraditional and regionally important food product is produced byloosely organized small processors. Consequently, the Party has beenunable to provide historical MB use data. MBTOC’s discussions withMB distributors indicate the likely use of MB in this sector is about18.144 tonnes (40,000 lbs) but the National Country Ham Associationand Nahunta Pork Center were ableto give specific information onproduct volumes and dosage rates. Consequently MBTOC was able torecommend specific amounts for those organizations. MBTOC isunable to assess the additional 21.856 tonnes requested, pendingsubmission of specific information of the amount of MB used andrequired by the Party for dry cure pork. MBTOC has not identifiedany alternatives forthis specific and specialised use, wherefumigations of structures are conducted in the presence of curinghams. The nomination did not indicate any research to developalternatives. The Party is requested to gather use data to support thisnomination and to adjust the quantity nominated for any unusedallocations from previous CUEs. MBTOC has concerns over the lackof emission controls in this use.No economic data onalternatives given.October 2005 TEAP Report on 2005 CUNs: Final Report51Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Eggplant -field76.721 81.253 20.933 96.48 85.363*MBTOC recommends a reduced CUE of 85.363 tonnes for 2007 forthis use. Recommendations comprise 3.799 tonnes for Michigan,58.824 tonnes for Florida, 22.307 tonnes for Georgia and 0.433 tonnesfor research. A minority of MBTOC evaluated the parts of this CUNrelating to Georgia and Florida as ‘unable to assess’ (see Section2.4.2). The Parties nomination for Georgia and Florida was adjustedto account for 5% of the nominated area using barrier films andMB:Pic (50:50) at 175 kgMB/ha when treating areas with moderate tosevere nutsedge. The nominated quantity for Florida was also reducedto conform with standard dosages of 260 and 200 kgMB/ha withchloropicrin for high/moderate andlow nutsedge regions respectively.In Michigan, the key pest is Phytophthora capsici. The Party showsthat 1,3-D/chloropicrin is an effective alternative, but that growerswill miss the optimal market windowdue to longer plant back times(28 days) with this alternative. According to the Party, this treatmentcannot be applied in autumn becauseof the bad climatic conditionsand damage by deer and other animals to the plastic mulch andirrigation tape.In Florida and Georgia, the key pests are nutsedge, root knotnematodes and some fungal pathogens. Southern blight, pythiumdamping off and verticillium wilt arealso managed with MB. Karsttopography limits the use of alternatives containing 1,3-D on 48% ofthe growing acreage. The Party statesthat metham sodium or methampotassium are promising alternatives but still do not provideconsistent control under the circumstances of the nomination andrequire further trialling. In addition,the Party states that trials areunderway to investigate lower MB/Pic formulations, such as 50:50, asthere are no regulatory restrictions to the use of these formulations.The Party shows that 1,3-D/Pic incombination with herbicides is apossible effective alternative fornon-karst areas with pathogen andnutsedge pressure (Cortright andHausbeck, 2004) and that methamcombined with Pic is effective forlow to moderate nutsedge pressurein similar crops and regions (e.g. Ajwa et al 2003, 2004, McMillanand Bryan 1998, Johnson and Webster2001, Gilreath et al 2005 bc).MBTOC acknowledges that longer plant back times for 1,3-D andmetham may cause loss by missing market windows in Georgia andFlorida but considers uptake of these alternatives is possible for aproportion of future nominations. MBTOC also considers thatmetham combined with Pic is a possible effective alternative for karstareas and urges the Party to continue further studies.CUN states next bestalternative in all regionsis 1,3-D withchloropicrin withexpected yield losses of 6percent in Michigan and29 percent in Georgiaand Florida. CUN states1,3-D with chloropicrinis considered technicallyfeasible inMichigan.However, CUN notedthat for Michigan inaddition to the yield loss,delayed planting andharvest with thealternatives results loweraverage price receivedfrom missed marketwindows and negativenet revenue. In Floridaand Georgia yield lossessignificantly reduce netrevenues. CUN notesFlorida and Georgiaproducers may alsoexperience lower pricesbecause of missedmarket windows.October 2005 TEAP Report on 2005 CUNs:finalReport52Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Eggplant –field(continued)The Party states that LPF films are still not being widely adopted on acommercial scale due to lack ofavailability, cost and technicalproblems with laying the films. Versions of metallised LPF barrierfilms are being tested by several researchers and growers and showpromise. MBTOC believes that LPF barrier films are technically andeconomically viable for this nomination. All of the technicalproblems reported by the Party appear to have been solved inEuropean countries where the use ofVIF barrier film is mandatory.Grower scale trials have demonstrated the success of a 50% reductionin rate with LPF barrier film (Gilreath and Santos 2004, 2005). Infields with moderate to heavy nutsedge pressure, Santos and Gilreath(2005) have shown that the standard MB/Pic 67:33 at a rate of 350kg/ha can be reduced by 25-50% (to 175 kg/ha MB or less) under LPFbarrier film with equivalent yields and nutsedge control. Recentlythere has been substantial commercial adoption of LPF barrier film inthe southeast of USA (Bruno Rimini Ltd). MBTOC has recommendeda reduction in the nomination as shown above to account fordecreased dosage rates in areas with low disease pressure fromnutgrass in anticipation of the likely increased implementation ofemission control technologies, including adoption of LPF barrier filmsby 2007.October 2005 TEAP Report on 2005 CUNs: Final Report53Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Forestnurseryseedlings192.515 157.694 152.629 122.032*MBTOC recommends a reduced CUE of 122.032 tonnes be approvedfor this use for 2007. Regions B (22.279 t) and E (9.637 t) arerecommended without change, but amounts have been adjusted inregions A (61.88 t), C (1.820 t), D (8.58 t), F (8.736 t), G (5.98 t) andH (3.12 t) to conform with MBTOC guidelines with use of MB/Picmixtures (i.e. 67:33 – 260 kg/ ha for control of nutgrass and 200 kg/hafor pests and pathogens other thannutgrass), which the Party indicatesis an effective formulation. The CUN is based on economicinfeasibility of using substrates andthe lack of effective alternativesfor control of nutsedge and a rangeof fungal pathogens. It coverscertified seedling production in 7 forest nursery regions and oneregion in Michigan growing herbaceous perennials. Certificationrequires that seedlings must be pest/pathogen free. The Party statesthat all regions use broadacre fumigation, but with different mixturesand rates of MB/Pic. MBTOC recognizes that the key pest isnutsedge. Research is ongoing to determine if Pic with metham, 1,3-Dand /or herbicides can provide acceptable control of moderate tosevere levels of nutsedge. To date, metham sodium and chloropicrinin combination showed promising results, but when used withoutplastic sheeting caused severe crop injury. The Party acknowledgedthat this treatment (and others) when covered with plastic films,particularly LPF barrier films, may provide an effective technicalalternative and avoid crop injury. MBTOC considers new films andglues are available for broadacre tarping under most conditions,however the Party will need time to trial and scale up this alternative.Although no further reductions have been made by MBTOC to thenomination, the Party is urged to consider adoption of LPF barrierfilms to reduce dosage rates in regions where their use is permitted.Broadacre use of LPF barrier films exists in other regions worldwide.MBTOC also considers glyphosate can be used as a pretreatment toreduce pressure from nutgrass and 1,3-D/Pic + metham sodium (orglyphosate) should be further evaluated for control of nutsedge asresults in trials have been promising (Culpepper and Langston, 2004).The nomination states that containerised plants are not economicallyfeasible for regions A through G. MBTOC considers substrates to bean effective technical alternative for most forest nurseries, howeverunderstands that present costs ($US0.12 vs. $0.04 per seedling) makethis practice economically infeasible at the present time.Alternatives have 3-5%decrease in yield andhigher costs resulting inestimated decreases innet revenue that variedfrom 6 percent to 42percent with the next bestalternative. CUN statesnumerical analysis doesnot include additionalimpact of quality lossesand indirect yield lossesresulting fromlengthening theproduction cycle.October 2005 TEAP Report on 2005 CUNs:finalReport54Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Mills andProcessors483 394.843 111.139 401.889 401.889*MBTOC recommends an amount of 401.889 tonnes for 2007 for theUS mills and food processors. MBTOC recommends 274.650 tonnesfor flour mills; 64.150 tonnes for rice mills; 39.275 tonnes for pet foodestablishments, and 23.814 tonnes for bakeries. The recommendedamount includes an increase for bakery sector where a companyowning several large facilities suffered equipment and structuraldamage and pest control failure as a result of failure of heat treatmentspecific to the design of the facilities. The Party’s nomination alreadyuses MBTOC standard dosage rate of 20g/m3 MB for structures. TheParty has made some progress adopting and adapting heat, sulfurylfluoride (where registered), and other fumigants in this sector. TheParty reduced their applicant’s nomination by 15% over 2006 levels totake into consideration adoption ofalternatives. Further adoption ofalternatives by 2007 will be takeninto consideration by the Partyduring its allocation public rulemaking process.The CUN reports heatwill cost 1.5 times andsulfuryl fluoride costs 1.3times the cost of MBtreatment. Heattreatment is reported toresult in lost operatingdays and thus lowerthroughput and grossrevenues.October 2005 TEAP Report on 2005 CUNs: Final Report55Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Nurserystock -fruit trees,raspberries,roses45.800 64.528 31.014 28.275*MBTOC recommends 28.275 tonnes for this nomination for 2007,including 2.100 tonnes for roses, 16.279 tonnes for fruit and nut trees,1.506 tonnes for research and a reduced amount from 10.952 to 8.39tonnes for the raspberry nursery portion of this nomination. MBTOChas reduced the amount nominated for raspberry to conform withMBTOC’s standard rate of 200 kg/haand to allow for adoption of thealternative 1,3-D on 10% of the area in Washington state. Forraspberry nurseries the nomination is for certified propagativematerial that is not shipped outside the geographical border where itwas produced. A large proportion, i.e. 60, 99 and 92% for raspberries,roses, and fruit and nut industries respectively, have been exemptedunder QPS criteria. Certification is mandatory for California and isvoluntary in Washington. The crop has no value if it is not certified.MBTOC acknowledges the difficulty inprotecting raspberry roots to1.5m depths. MBTOC acknowledgesthat MB/Pic formulations 67:33and 50:50 were used in other countriesand urges the Party to considerthese alternatives as a transition strategy to reduce MB dosage in theabsence of effective alternatives. Further validation of theireffectiveness is sought in future nominations. MBTOC has identifiedstudies (McKenry, 1999) which indicate that 1,3-D at high rates(greater than 390 kg/ha) can be effective at controlling pests andkilling old perennial roots up to1.5m deep. Although, these highrates are not allowed by regulation in California, it appears that thehigh rates would be allowed in Washington. MBTOC has reduced theamount of methyl bromide requested by raspberry nurseries toaccount for implementation of use of 1,3-D on 10% of the nominatedarea. In California, the standards require the propagative material tobe “commercially clean” and only list methyl bromide or 1,3-D(Telone II) as preplant soil disinfestation treatments to meet thisstandard. In Washington, the tolerance is 0.1% incidence fornematodes and “practically free” for disease. MBTOC urges the Partyto consider LPF barrier films toreduce dosage rates in regions whererestrictions permit their use. Broadacre use of LPF barrier films existsin other regions worldwide.CUN cites lack oftechnically feasiblealternatives. CUN notesmost economic lossescannot be quantified.CUN notes certificationrequirements that wouldresult in yield losses ofup to 100 percent ifnursery stock cannot becertified as pest free andsubsequent economicconsequences. CUNnotes potential increasein pesticide use andpotential lower yields offruits and nuts fromplants and trees placed inproduction.October 2005 TEAP Report on 2005 CUNs:finalReport56Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Orchardreplant706.176 527.6 300.4 405.4 405.4*MBTOC recommends 405.4 tonnes for this nomination whichincludes 1.66 tonnes for research. The CUN is for 3 situations:Orchard/vineyard replant disorder of unknown aetiology; heavy soilsor soils which cannot be dried to asufficient depth to effectively usethe reduced rates of 1,3-D now allowed in California; and areas inwhich Township caps prevent the use of 1,3-D in some areas.Regulatory restraints (maximum labeled rate) prevent the use of 1,3-Dat the rates needed foreffective kill of old roots and the associatedpathogens in deeper soil layers for heavier (fine-textured) soils.Regulatory restraints further prevent the use of LPF barrier films withmethyl bromide in California. MBTOC acknowledges that MB/Picformulations as low as 50:50 wereused in other countries and urgesthe Party to consider these alternatives as a transition strategy toreduce MB dosage in the absence ofeffective alternatives. Furthervalidation of their effectiveness issought in any future nominations.MBTOC notes that the nominated amount is a 24% reduction from theamount approved by the Partiesfor 2006 and a 43% reduction fromthe amount approved by the Parties for 2005.CUN cites lack oftechnically feasiblealternatives. CUN notesmost economic lossescannot be quantified andlists factors thatcontribute to lossesincluding delayedplanting, tree loss,additional use ofherbicides, yield lossesof fruit or nuts.October 2005 TEAP Report on 2005 CUNs: Final Report57Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSAOrnamentals154162.817(c )149.965 137.835 MBTOC recommends a reduced CUE of 137.835 tonnes in total forthis nomination, being 75.145 tonnes for California and a reducedCUE of 58.63 tonnes for Florida,and 4.06 tonnes for associatedresearch. MBTOC recognises the effort made by the Party insubmitting more complete information; this is essential inunderstanding the specific circumstances of the complex and diverseUS ornamental industry, particularly the fact that uses have now beendisaggregated by region. 52% of this nomination is for California andcorresponds to areas impacted by regulatory issues (township caps).There are no available in-kind alternatives for these areas. 48% of thenomination is for Florida. Ofthis, 40% is impacted by karsttopography, denying use of 1,3-D and is recommended by MBTOCon the basis of lack of feasible alternatives. It is suggested that thedosage for this part of the nomination be reduced from 350 to 200kg/ha in line with MBTOC presumptions for MB:Pic 67:33, but theremainder of the Florida nomination (60%) exceptionally be left at thehigh rate for treatment of soils ofvery high organic matter content.There is scope for reduction of the MB used using barrier films,provided the fumigation sheets can be joined satisfactorily. The Partystates that the alternatives are noteconomically feasible because thedecline in yields in all nominatedregions leads to a substantialreduction in net revenue. This is based on the assumption that thequoted reduction in yields is technically realistic.CUN reports yield lossesof 20-25 percent withalternatives. Operatingcosts were assumed sameas with methyl bromide.CUN reports substantialdecreases in gross andnet revenues. Negativenet revenues predictedfor calla lilies and bulbsin California and forcaladiums in Florida.October 2005 TEAP Report on 2005 CUNs:finalReport58Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Peppers -field1094.782 806.877 694.497 1151.751 1106.753*MBTOC recommends a reduced CUE of 1106.753 tonnes for 2007for this use, being 11.325 tonnes for Michigan, 0 tonnes forCalifornia, 65.099 tonnes for the Southeast, 176.100 tonnes forGeorgia, 851.385 tonnes for Florida and 2.844 tonnes for research. Aminority of MBTOC evaluated theparts of this CUN relating toGeorgia, the Southeast and Florida as ‘unable to assess’ (see Section2.4.2). The Party’s nomination was reduced on 5% of the nominatedarea in Florida, Georgia and the South East Region to account for theuse of dosage rates of MB of 175kg/ha for nutsedge in combinationwith low permeability barrier films and further for Florida to conformwith dosages of 260 and 200 kgMB/ha with chloropicrin forhigh/moderate and low nutsedgeregions respectively. MBTOCacknowledges the reduction by the Party of the nominated quantity ofapprox 7- 9 % for uptake of alternatives by 2007. In Michigan, thekey pest isPhytophthora capsici. The Party states that 1,3-D/chloropicrin may be an effective alternative but growers will missthe optimal market window due to longer plant back times. Accordingto the Party, this treatment cannotbe applied in autumn because ofclimatic conditions and damage bydeer and other animals to plasticmulches and irrigation tapes. Inaddition, a fall application ofalternatives is not feasible because, over the autumn and wintermonths, deer and other animals damagethe plastic and irrigation tape.In California the key pest isPhytophthora capsici. Township capsaffect the adoption of alternativesutilizing 1,3-dichloropropene. TheParty states that 1,3-D is difficultto use on hillsides. According to2003 data from the California Dept. ofPesticide Registration, methamsodium is used (alone or with other treatments) on nearly as manyacres as methyl bromide and therefore is considered a viablealternative for hillsides and in areasaffected by township caps (CDPR2003, Ajwa et al 2003, 2004, Gilreath et al. 2003b, 2005b, Johnsonand Webster 2001). In Florida and Georgia the key pests are yellowand purple nutsedge,Phytophthora capsiciand root knot nematode.Karst topography limits the use of alternatives have 1,3-D as acomponent, though they are the best alternatives for these pests on40% of the growing acreage. The Party states that 1,3-D/Pic alongwith either herbicides (e.g. clomazone and metolachlor) or followedby Pic or metham sodium application may be the best alternativeoutside karst areas. Also metham sodium or metham potassium arepromising alternatives but still do notprovide consistent control underthe circumstances of the nomination and require further trials, whichare underway.CUN states next bestalternative in all regionsis 1,3-D withchloropicrin withexpected yield losses of 6percent in California andMichigan and 29 percentin other regions. CUNstates 1,3-D withchloropicrin isconsidered technicallyfeasible in California andMichigan. CUN notedthat for California thedistribution of yield lossacross individual growersand the yield riskassociated withalternatives was notaccounted for thenumerical economicassessment. Numericalassessment showed 14percent decrease in netrevenue. In Michigandelayed planting andharvest with thealternatives results loweraverage price receivedfrom missed marketwindows and negativenet revenue.October 2005 TEAP Report on 2005 CUNs: Final Report59Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Peppers –field(continued)Other studies however, have demonstrated the efficacy of methamsodium + chloropicrin in areas with low to moderate nutsedge pressurein pepper and similar crops and the regions of the nomination .(Gilreath et al 2003b, 2005b). MBTOC anticipates that there will beadoption of this alternative to replace methyl bromide in karst areaswith low nutsedge infestation by 2008.In addition, the Party states thattrials are underway to investigate lower MB/Pic formulations, such as50:50 MB/Pic, as there are no regulatory restrictions to the use of theseformulations. The Party states that LPF films are still not being widelyadopted on a commercial scale due tolack of availability, cost andtechnical problems with laying the films. Versions of metallised LPFfilms are being tested by several researchers and growers and showpromise. MBTOC believes that LPF films are technically andeconomically viable for this nomination. All of the technical problemsreported by the Party appear to havebeen solved in European countrieswhere the use of LPF film is mandatory. Grower scale trials haverepeatedly demonstrated the success of a 50% reduction in rate withLPF film (Gilreath and Santos, 2005). In fields with moderate to heavynutsedge pressure, Santos and Gilreath (2005) have shown that thestandard MB/Pic 67:33 at a rate of350 kg/Ha can be reduced by 25 -50% (to 175 kg/ha MB) under LPF filmwith equivalent yields andnutsedge control. In the past year, there has been substantialcommercial adoption of LPF film in the southeast (Bruno Rimini Ltd).MBTOC applied a reduction of 5% in the nomination for Florida,Georgia and the South East Region to account for decreased dosagerates of 175 kg/ha in anticipation of the likely increasedimplementation of emission controltechnologies, including adoption ofLPF barrier films by 2007.In remaining regionsyield losses significantlyreduce net revenues.October 2005 TEAP Report on 2005 CUNs:finalReport60Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Strawberryfruit – field2052.846 1523.180 397.597 1733.901 1476.019*MBTOC recommends a CUE of 1476.019 tonnes for this use,comprising 1077.88 tonnes for California, 147.531 tonnes for Easternstates, 248.231 tonnes for Florida and 2.377 tonnes for research. Aminority of MBTOC evaluated the parts of this CUN relating to theEastern states and Florida as ‘unable to assess’ (see Section 2.4.2).The nomination for California was reduced by 190 tonnes to accountfor uptake of the key alternatives. A further reduction of 11.405 and1.814 tonnes was applied to conform to MBTOC’s maximumguideline rates for strip of 260 kg/ha for high nutgrass. Quantitieswere adjusted for 175 kg/ha for 5% of the nomination for uptake ofLPF barrier film. In California, the nomination is based on thegrounds that township caps limit further adoption of 1,3-D, and hillyterrain prevents the use of drip-applied alternatives. In the case oftownship caps, alternatives that do not contain 1,3-D (such as Pic, PicEC and Pic + metham applied sequentially) are technically feasible inat least part of this area (Ajwa et al 2002, 2003, 2004, Haar et al.2001, Nelson et al. 2001a,b). As for the nomination in 2006, MBTOCapplied the same reduction of 190 tonnes to account for uptake ofthese alternatives. MBTOC acknowledges that there are regulatoryconstraints on use of VIF in California at present, so the nominationwas not adjusted for uptake of LPF films. In Eastern US, thenomination is based on moderateto severe pest pressure(Meloidogyne spp., Pythium, Rhizoctonia,Phytophthora cactorum,Cyperus escultentus,C. rotundus,Loliumspp.) affecting 30-40% ofthe crop area, and small farm buffer zones on 40% of the crop areawhich affects use of 1,3-D formulations. MBTOC considers thatalternatives are available for somepart of the buffer zones which arenot subject to heavy nutsedge pestpressure (e.g. Pic formulations,metham + Pic), and the Party says there is potential for adoption onabout 10% of the buffer zone area and this will be pursued by somegrowers and extensionpersonnel. MBTOC has accordingly reducedthe nomination by 6.629 tonnes for adoption of these alternatives anda further 10.057 tonnes to conformwith MBTOC’s standard guidelinerates of 200 kg/ha for use withstrip fumigation and low nutgrasspressures and 1.521 tonnes to allow for adoption of LPF barrier filmson 5% of the nominated area.CUN reports costs ofalternatives for three nextbest alternatives forCalifornia, Florida, andEastern United States.1,3-D with chloropicrinis reported to reduceyield by 14 percent.Resulting lowerproduction leads to lowernet revenue. Plantingand harvesting delayswith alternatives arereported to lead to loweraverage prices receivedin all regions, but is onlyshown in the revenueanalysis for California.October 2005 TEAP Report on 2005 CUNs: Final Report61Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Strawberryfruit – field(continued)For Florida, the Party states that at moderate to severe pest pressure(primarily nutsedge on 30-40% of area), protocols for commercialapplication of alternatives have notbeen sufficiently developed to beimplemented for the 2007 season. MBTOC considers that a transitionstrategy of using MB/Pic mixtures with lower MB (i.e.. MB/Pic50:50) can be used for karst areas with low nutgrass. MBTOCacknowledges the restriction imposed by karst topography onavailability of one alternative,1,3-D, but considers that otheralternatives (Pic EC, metham + Pic)are potentially suitable for use inkarst areas with low nutgrass pressure (Fennimore et al. 2003,Gilreath et al 2003a, Nelson et al 2002, USDA 2003, Ajwa et al 2003,2004) and urges the Party to consider further evaluation and adoptionof these alternatives, including incombination with low permeabilitybarrier films (Gilreath 2005a). No reduction was made for thesealternatives. MBTOC reduced thebalance of the nomination by45.745 tonnes to conform with MBTOC’s standard guideline rates of260 or 200 kg/ha for use with stripfumigation with or without highnutsedge pressure and 3.761tonnesto allow for adoption of LPFbarrier films on 5% of the nominated area.October 2005 TEAP Report on 2005 CUNs:finalReport62Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Strawberryrunners54.988 56.291 4.483 4.483 MBTOC recommends a CUE of 4.483 tonnes for this use, comprising2.654 tonnes for southeastern states, 1.375 tonnes for California, andan associated research amount of 0.454 tonnes for 2007. A highproportion, 94% of runner production covered by this CUN has beenexempted by the Party from critical use nomination under QPS. Infuture nominations, a copy of the certification requirements isrequested from the Party. In the Southeastern states the nomination isbased on the grounds that MB is needed to meet the strictrequirements for producing pest freenursery stock. For California,the nomination says that the state mandatory certification program hasstrict requirements for control ofdisease and nematodes, whichamount to near complete control of the key pests. MBTOCrecognizes the need to produce planting stock of high health status tominimise spread of diseases and pests. The Party states that keyalternatives are 1,3-D/Pic, 1,3-D/Pic + metham, and 1,3-D + metham,and that dazomet + Pic or 1,3-D isalso a possible alternative. TheParty notes that these chemicals, inaddition to other strategies, suchas use of high density tarps, may ultimately reduce or replace MB.Technical data provided with thesubmission indicates that severalalternatives (e.g. metham + Pic) provide effective disease control butfurther trials are required to validate disease tolerance. The CUNsection for California stated that research trials on metham sodiumincorporated with a tractor-mounted tillovator provides good resultsbut most growers do not have this equipment. Iodomethane is in theregistration process. Party states that substrates/plug plants arecurrently being produced and sold in the southeast and to a verylimited extent in California, but would require expensive retooling ofthe industry and additional pest control measures. Formulations of67:33 MB:Pic are applied broadacre under HDPE in many cases, at350 kg/ha in southeastern states and 263 kg/ha in California. Use ofVIF is restricted in California, butlow permeability barrier films (VIFor equivalent) could potentially be adopted in southeastern states withassociated reduction of dosage.CUN identifies 1,3-Dwith chloropicrin as thenext best alternative witha 10-percent yield loss inCalifornia and theSoutheastern States.Operating costs with 1,3-D plus chloropicrin aremarginally higher in theSoutheast and marginallylower in California. Inboth regions thealternative is predicted toresult in a 46-percentdecrease in net revenues.October 2005 TEAP Report on 2005 CUNs: Final Report63Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Tomato -field2876.046 2222.934 627.552 2334.047 2065.246*MBTOC recommends a reduced CUE of 2065.246 tonnes for 2007for this use, being 10.204 tonnes for Michigan and 2049.541 tonnesfor the Southeast, and 5.501 tonnes for research. The Californiannomination is not recommended. A minority of MBTOC evaluatedthe parts of this CUN relating to the Southeast as ‘unable to assess’(see Section 2.4.2). The Party’s nomination was reduced to accountfor the use of MBTOC’s standard dosage rates on the karst, lownutgrass portion of the Florida nomination and a further reduction(150 kg/ha for pathogensand 175kg/ha of MB for nutsedge) on 5% ofthe nomination for uptake of low permeability barrier films in Floridaand Michigan. MBTOC acknowledges the reduction by the Party onthe nomination to account for approx 8% uptake of alternatives by2007.In Michigan, the key pests are Phytophthora capsici andFusarium spp. The Party states that 1,3-D/chloropicrin may be aneffective alternative, but growers will miss the optimal marketwindow due to longer plant back times. According to the Party, thistreatment cannot be applied in autumn because of climatic conditionsand damage by deer and otheranimals to plastic mulches andirrigation tapes. In California the key pests are Fusarium, Verticillium,nematodes and Pythium. Township caps affect the adoption ofalternatives utilizing 1,3-dichloropropene (1,3-D). The Party statesthat 1,3-D is difficult to use on hillsides. According to 2003 data fromthe Californian Department of Pesticide Regulation, metham sodiumis used on nearly as many acres asmethyl bromide and therefore MSand its combinations with other treatments are considered a viablealternative for hillsides and in areas affected bytownship caps(CDPR 2003, Ajwa et al 2003, 2004, Gilreath et al 2005b, Johnsonand Webster 2001). In the southeast, the key pests are nutsedge,Fusarium, nematodes and Phytophthora. From the BUNI informationMBTOC has calculated that 4968 ha of tomato in karst areas have lowkey pest (nutsedge) pressure. In these circumstances, MBTOCconsiders a maximum dosage rate of 200kg/ha as sufficient to controlpathogens and adjusted the nomination accordingly. The Party statesthat metham sodium or metham potassium are promising alternatives,but still do not provide consistent control under the circumstances ofthe nomination and require further trials, which are underway. Otherstudies however, have demonstrated the efficacy of metham sodium +chloropicrin in areaswith low to moderate nutsedge pressure intomatoes and similar crops in the regions of the nomination (Locascioet al 2000, Nelson et al 2002, Gilreath et al 2005). MBTOCanticipates that there will be adoption of this alternative to replacemethyl bromide in karst areas with low nutsedge infestation by 2008.CUN reports yield losseswith alternatives rangingfrom 17 to 22 percent.Net revenue declinesreported for all regions.Missed market windowscited in Michigan andSoutheastern States.California estimate ofgross and net revenuelosses do not account fordistribution of yield lossacross individual growersand yield risk withalternatives.October 2005 TEAP Report on 2005 CUNs:finalReport64Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Tomato –field(continued)The Party states that LPF barrier films are still not being widelyadopted on a commercial scale due tolack of availability, cost andtechnical problems with laying the films. Recent trials however haveshown excellent results with new semipermeable barrier films(metallised films) and substantial commercial adoption on farms inFlorida (>3000acres) (Bruno Rimini Ltd). MBTOC believes that LPFbarrier films are technically and economically viable for thisnomination. All of the technicalproblems reported by the Party havebeen solved in European countrieswhere the use of LPF films ismandatory. Grower scale trials have repeatedly demonstrated thesuccess of a 50% reduction in rate with LPF films (Gilreath andSantos, 2004, 2005). In fields with moderate to heavy nutsedgepressure, Santos and Gilreath (2005)have shown that the standardMB/Pic 67:33 at a rate of 350 kg/ha can be reduced by at least 25 %(to 175 kg/ha MB) under LPF filmwith equivalent yields andnutsedge control. MBTOC recommends a reduction in thenomination to account for decreased dosage rates in areas withmoderate to severe nutgrass pressure at 175 kg/ha, and for lownutsedge and areas with pathogens at150 kg/ha, in anticipation of thelikely increased implementation of emission control technologies,including adoption of LPF barrier films by 2007.October 2005 TEAP Report on 2005 CUNs: Final Report65Party Industry TotalCUEs for2005 asapprovedby1EMOPand16MOPApproved for2006 by16MOPunderSect IIADec.XVI/2Approved(interim)for 2006by 16MOPunder Sect111 Dec.XVI/2Nominated in2005 for2006Nominated in2005 for2007Recommended byMBTOCfor 2006Recommended byMBTOCfor 2007MBTOC comments Economic reasoningprovided by the PartyUSA Turfgrass 206.827 131.6 78.04 78.04 MBTOC recommends a CUE of 78.040 tonnes in 2007 for this use,including 1.9 tonnes for associated research. The Party has reducedthe amount requested to 59% from that recommended by MBTOC in2006. All of this nomination is for production of certified propagativematerial. MBTOC recognises the importance of producing cleanpropagative material. Historically the industry has used a rate of 500kg/ha, but has recently reduced the rate to 300 kg/ha of 98:2 MB.Trials with mixtures of MB withchloropicrin indicate inconclusiveresults in pest and pathogen control. MBTOC suggests that furtherrate reductions can be achievedwith the use of low permeabilitybarrier films (VIF or equivalent) and the use of 67:33 or 50:50MB/Pic formulations. Further validation of their effectiveness issought in future nominations. Although dazomet is used effectively inother countries for this use, it has not yet proven effective in trials inUSA (Unruh et al. 2002). Trial use of this product with barrier filmsis suggested. New fumigant alternatives, sodium and potassium azide,iodomethane have shown excellentweed control (Unruh et al 2002).These chemicals at present lack registration.CUN is for turfproduction intended to besold as certified sod.CUN identifies dazometas next best alternative tomethyl bromide andstates quality losses withdazomet would excludemuch of production fromcertified market leadingto substantial losses ingross and net revenue.CUN states price fornon-certified sod is 75percent lower than pricefor certified sod.Footnotes:All quantities given in metric tonnes, unless otherwise stated.*Evaluation revised since TEAP May 2005 Report (TEAP 2005)(a) No specific CUE quantity approved for this use. Quantity approved included with other uses.(b) CUE includes exemptions for both Quebec and PEI growing regions(c) Categorised as 'unable-to-assess’ in the TEAP Report of October2004.

# October 2005 TEAP Report on 2005 CUNs: Final Report 

# 67 

# 3. Registration and Reregistration of Alternatives

3.1 Registration status of soil alternatives

This report on the registration and reregistration status of in-kind methyl bromide

alternatives is provided in conformity with Decisions Ex. I/4(9,i) and Ex. I/4(9,j). An

interim report on this topic was provided in TEAP (2005).

MBTOC has initiated a comprehensive Status of Methyl Bromide and its Alternatives

Report. The reporting format was drafted and piloted in one country. It was presented to

MBTOC at the Melbourne meeting and will be revised according to comments received

by MBTOC members. The report endeavours to provide for both soil fumigation and

post harvest uses the following information by country, by crop/site and by chemical:

• Active ingredient and trade name identification;

• Formulation specifications (% of active ingredient, % of inert ingredients, % of

other active ingredients in the product);

• Application rates, and

• Current label restrictions on the use of the product that could limit the extent to

which it could be used as an alternative to methyl bromide, where these

restrictions are significantly greater than restrictions for methyl bromide (e.g.

some labels state that some pesticides are required to have large buffers around

occupied structures, prohibition against greenhouses use, restrictions on use in

areas where groundwater could be contaminated, long plant back restrictions,

prohibition on use of the product in mixtures, personal protective equipment

requirements for mixers, loaders and applicators that are significantly greater than

restrictions for methyl bromide, etc.).

MBTOC intends to have these revised spread sheets sent out to Parties by November 2005

and could have a final report within one year depending on the responsiveness of the

Parties.

MBTOC recognizes that registration is a dynamic process. Thus, some information may

be out of date. MBTOC reports information as provided by the Parties or other reliable

sources. MBTOC does not speculate on dates registration action may be completed. In

the interim the following information that is currently available is provided here.

Table 5 presents available data on the registration status of leading chemical alternatives

for the control of soilborne pests and diseases. It indicates that metham sodium and

dazomet are widely registered, and 1,3-dichlor opropene (1,3-D) and chloropicrin are also

registered in a number of countries. Sodium tetrathiocarbonate (Enzone) is registered in

only a few countries. Registration of mixtures of fumigants (particularly 1,3-D + pic) is

increasing. In addition to the countries listed in Table 5, 1,3-D/Pic has been registered in

Article 5(1) countries such as Chile, Costa Rica, Cuba and Morocco, and registration is

being sought in countries such as Jordan, Argentina and China (Carrera et al. 2004). In

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 68 

# some countries fumigants must be registered as a mixture if they are to be applied

simultaneously; while in other countries fumigants can be simultaneously applied (coapplied) without the need for additional registration.

The US EPA has recently registered several products for the control of weeds, including

Cyperus spp. These include halosulfuron methyl (Sandea) for use in fruiting vegetables

and cucurbits, trifloxysulfuron sodium (Envoke) for tomato (Norton, 2004) and Smetolachlor for tomatoes. The US EPA also recently registered fosthiazate for tomatoes.

For the following soil fumigants registration applications have been submitted and are

currently under review: iodomethane in USA (for peppers, tomatoes, strawberries and

ornamentals) and dazomet in USA (for strawberries and tomatoes). Soil fumigants under

consideration are: furfural in USA (for gr eenhouse-grown cut flowers, greens, transplants

and propagative material), sodium azide in US A (for turf and golf courses), mixture of

1,3-D/chloropicrin in Italy, chloropicrin in France, dazomet in Hungary, cyanogen

(‘ethane dinitrile’) in Australia, and dimethyldisulphide (DMDS) in France. Japan

cancelled its methyl bromide registrations in 2004 while retaining its CUE registrations

for MB on melons, watermelons, cucumbers, green peppers, hot peppers, ginger and for

the control of the chestnut weevil.

Biological control products normally require registration but are not listed in Table 5

because they are not normally considered as MB alternatives due to their narrow

spectrum of activity, although they can play a useful role as adjuncts to alternatives such

as fumigants, steam or substrates. It should be noted that many non-chemical treatments

do not require registration under the European Union’s legislation on pesticide products;

this applies to treatments such as steam, heat, substrates, grafted plants, resistant varieties

and other cultural practices (Smeets, 2004). Many other countries also do not require

non-chemical treatments to be registered. However, non-chemical treatments may face

other difficulties such as requiring other regulatory approval and because commercial

companies have less incentive to market products that are not protected by patent-like

property rights.

Table 5. Registration status of chemical soil alternatives

This table is compiled from databases on registration and available alternatives submitted by Parties to

the Ozone Secretariat (European Commission, 2005a ), and information provided in critical use

nominations. Local conditions of use and requirement s may render a registered fumigant unavailable for

specific crops or locations, although registered in general.

. Fumigant products Non-fumigant products Country

13D Daz MIT

C Pic Enz 13D+

pic 13D+

MIT Nem Fun Her

Australia R R R R R R R R

Belgium R R R R R R R

Canada (a) R (b) R R R R

France R R R R R R R

Greece R R R R (d) R R R R

Ireland R R R R

Italy R R R R R R R

Japan R R R R R R R R R

# October 2005 TEAP Report on 2005 CUNs: Final Report 

# 69 Fumigant products Non-fumigant products Country

13D Daz MIT

C Pic Enz 13D+

pic 13D+

MIT Nem Fun Her

Poland R R R R R

Portugal R R R R (d) R R R

Spain R R R R R R (d) R R R

UK R R R R R R R

USA R (b) R (c) R R R R R R (e)



# NB. In some cases the fumigants are registered for sp ecific crops, while in other cases they are registered

for soil fumigation in general. (a) Registration inform ation relates to strawberry runners only. (b) not

permitted in some areas. (c) registered for non-food cr ops. (d) provisional at pres ent pending finalisation of

re-registration of fumigants in the EU. (e) for certain types of weeds only.



# R registered

13D 1,3-dichloropropene

Daz dazomet

Met metham sodium and/or metham potassium

Pic chloropicrin

Enz sodium tetrathiocarbonate (Enzone)

MITC methyl isothiocyanate

Nem various nematicide products, e.g. oxamyl

Fun various fungicide products – norma lly specific to certain groups of

fungi

Her various herbicides – normally specific to certain types of weeds.



# 3.2 Registration status of postharv est and structural alternatives

Table 6 (below) presents available data on the registration status of leading chemical

alternatives for the control of stored product pests in commodities and/or structures.

Phosphine (solid formulations) is registered in many countries. Registration of gaseous

forms of phosphine (cylinderised) and sulf uryl fluoride is increasing. The US EPA

recently registered a gaseous form of phosphine (Ecofume). Some countries registered

sulfuryl fluoride (SF) a number of years a go for non-food structures such as historic

buildings in some European countries, or domestic dwellings (replacing a large volume

of MB) in the USA. More recently sulfuryl fluoride formulations developed for certain

commodities or empty mills have been registered in USA and parts of Europe. The US

EPA recently registered sulfuryl fluorid e for food processing sites (July 2005). The

federal registration must now be reviewed by individual state authorities as part of the

registration process. Sulfuryl fluoride is reported to be in the registration process in

France, Benelux and Spain (Lange, 2004), and in Canada.

Apparently MITC is registered in Canada for flour mills, according to a list of registered

alternatives submitted by Canada to the Ozone Secretariat recently. Iodomethane has

recently been registered in Japan for broad-spectrum insect control on imported timber

(UNEP, 2004). Japan has also registered in 2004 a mixture of MITC and sulfuryl

fluoride dissolved in liquid carbon dioxide (Ecotwin).

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 70 

# Table 6. Registration status of postharvest alternatives

The table was compiled from databases on registration and available alternatives submitted by Parties to the

Ozone Secretariat (European Commission, 2005b), inform ation provided in critical use nominations, and

other sources.

Fumigant products Country

EF HCN IM MITC PH3

solid PH3

gas PPO SF

Australia R R R

Austria R (b) R R (a)

Belgium R

Canada R R R

Denmark R R

France R (id) R

Germany R R R (a b e)

Greece R

Ireland R

Italy R R (b)

Japan R R R R R

Poland R

Spain R R

Sweden R R (a)

Switzerland R R R (b)

UK R R (b)

USA R R R (f) R (a b c)



# (a) non-food structures, e.g. historic buildings. (b) empty food structures e.g. mills. (c) dried fruits, tree

nuts, cereal grains. (d) aircraft. . (e) dried fruit: (f) nutmeats, cocoa, spices; PPO mixed with CO2 is

registered for stored nuts



# R registered

EF ethyl formate

HCN hydrogen cyanide, calcium or sodium cyanides

IM iodomethane

MITC methyl isothiocyanate

PH3 solid phosphine (solid formulations)

PH3 gas gaseous phosphine in carbon dioxide or nitrogen

(cylinders)

PPO propylene oxide

SF sulfuryl fluoride

# October 2005 TEAP Report on 2005 CUNs: Final Report 

# 71 3.3 Reregistration of MB and alternatives

In the United States and European Union, a number of soil fumigants are undergoing

reregistration. Metham sodium and chloropicrin, as well as MB, are going through reregistration in the US at present, and decisions are scheduled to be completed in 2007.

To date, 1,3-D is the only soil fumigant that has completed the re-registration process in

the USA. The US EPA is utilizing a cluster approach in conducting its re-registration

assessments on soil fumigants (metham sodium, iodomethane, chloropicrin, 1,3-D,

dazomet and MB). This cluster approach aims (a) to ensure a level playing field by

evaluating the soil fumigant alternatives concurrently and consistently and (b) to ensure

that risk management decisions do not result in risk/benefit tradeoffs that neither improve

safety nor help agriculture.

In the European Union, MB is being evaluated for re-registration as part of the EC’s

general review of pesticides (active ingredients). The reviews include scientific

assessments of safety and environmental data submitted by applicants. Under the EC

Plant Protection Products Directive (91/414/EC) a dossier on MB is being reviewed and a

decision is due to be taken by the end of 2008 at the latest for pesticide uses that are

regulated under this Directive. Under the Biocides Directive (98/8/EC) MB has been

“identified” which means that biocidal products containing MB can only be placed on the

EU market until 1 September 2006 at the latest, according to Article 4(2) of Regulation

2032/2003 (Arash, pers. comm. 2005). A review of MB’s toxicity and environmental

effects is provided in IPCS/WHO (1995).

Most postharvest fumigants (active ingredients), except for sulfuryl fluoride, are

undergoing re-registration in the European Union and the US. Phosphine is the only post

harvest fumigant that has completed re-registration in the USA (1998).

# October 2005 TEAP Report on 2005 CUNs: Final Report 

# 73 

# 4. MBTOC Work plan for 2006

4.1 Introduction

The Parties, at their Sixteenth Meeting, decided to adopt the elements related to

procedures and terms of reference of the Methyl Bromide Technical Options Committee

(MBTOC) related to the evaluation of nominations for critical uses of methyl bromide as

set out in Annex I to the repor t of the Sixteenth Meeting of the Parties (16MOP) (decision

XVI/4).

Paragraph 15 of Annex I to the report of 16MOP states that annual work plan should be

drawn up by MBTOC (supported by the Ozone Secretariat) in consultation with TEAP

and that MBTOC should submit it to the Meeting of the Parties each year.

In accordance with paragraph 15 of Anne x I to the report of 16MOP, MBTOC has

prepared its 2006 work plan in consultation with TEAP and with support of the Ozone

Secretariat. The work plan is contained in Section 4.4 of the current document for

consideration by the Parties at their Sixteenth Meeting.

4.2 Summary report of the activities carried out in 2005

One of the elements specified in paragraph 15 of Annex I to the report of 16MOP is the

summary report of MBTOC activities over the previous year (paragraph 15(h)). In

accordance with this requirement, the summary report is provided in section III of the

current document.

4.3 Allocation of the Funds under Decision XVI/5

The Parties, at their Sixteenth Meeting, decided to provide additional financial support to

MBTOC in recognition of the heavy workload of the MBTOC in assessing nominations

for critical use exemptions (decision XVI/5). Section 4.6 of the current document

provides a detailed report on how the budget for implementing decision XVI/5 has been

allocated to MBTOC. The report on allocation of the funds was prepared in pursuance of

the fundamental principle adopted by the Parties of ensuring transparency in the process

of assessing critical use nominations.

4.4 MBTOC Workplan for 2006 - Details

Paragraph 1 of Annex I to the report of 16 MOP provides the schedule for the MBTOC

assessment of critical-use exemptions. In accordance with the schedule, MBTOC

envisages its activities as set out in Table 7 below. The elements of the work plan as

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 74 

# specified under paragraph 15 of Annex I to the report of 16MOP have been incorporated.

The schedule of the work to be carried out by the together with activities on the 2006

assessment and MBTOC composition is also included. The list of current membership of

MBTOC is contained in Annex II to the current document.

The work plan also includes an indicative budget which proposes to considerably

increase funding. Improved funding for non-A5 MBTOC members is strongly

recommended; most non-A5 members do not have funding to attend meetings. As the

workload and number of meetings resulting from the CUN process have increased, the

financial burden on individual members and/or their research institutions has become

unsustainable. In addition, the requirement for MBTOC reports to more clearly and

completely reference the reasons for decision making under the circumstances of

particular nominations strengthens the need for field trips to affected regions, for reports

summarizing particularly complex issues, and to cover the costs of obtaining reference

documents.

Table 7. MBTOC work plan and indicative budget

Tasks and actions Indicative budget needs

where applicable Indicative

completion date Dates of

meetings



# Assessment of the CUNs

1. Parties submit their nominations for critical-use

exemptions to the Secretariat - 24 January 2006

2. The nominations are forwarded to MBTOC cochairs for distribution to the subgroups of

appointed members - 7 February 2006

3. Initial summarization of the nominations US$ 30,000

4. Nominations in full are assessed by the

subgroups of appointed members. The initial

findings of the subgroups, and any requests for

additional information are forwarded to the

MBTOC co-chairs for clearance Funds for assistance in

technical analysis, report

preparation and reference

docs (throughout the process

as necessary):

US$ 20,000 28 February 2006

5. MBTOC co-chairs forward the cleared advice

on initial findings and may request additional

information on to the nominating Party

concerned and consult with the Party on the

possible presumption therein - 7 March 2006

6. Nominating Party deve lops and submits its

response to the MBTOC co-chairs - 28 March 2006

7. MBTOC Meeting No 1 to assess nominations,

including any additional information provided

by the nominating Party prior to the MBTOC

meeting under action 5 and any additional

information provided by nominating Party

through pre-arranged teleconference, or

through meetings with national experts, in

accordance with paragraph 3.4 of the terms of

reference of TEAP Funds for travel of 10 non-A5

members and co-chairs: US$

50,000. 11 April 2006 3 – 8 April 2006

Zagreb or

Dubrovnik,

Croatia

8. MBTOC advises the nominating Party of any

outstandin g information re g ardin g the 25 April 2006

# October 2005 TEAP Report on 2005 CUNs: Final Report 

# 75 Tasks and actions Indicative budget needs

where applicable Indicative

completion date Dates of

meetings

information requested under action 5 for those

critical-use nominations where it was unable

to assess the nomination

9. MBTOC provides its draft recommendations

on the CUNs to TEAP 3 May 2006

10. Field missions by selected MBTOC members

to some key sites where methyl bromide is used

as per nominations. Funds for travel:

US$ 2 0,000 Prior to May 2005

11. TEAP Meeting: To assess the MBTOC report

on critical-use nominati ons and submits the

finalised interim report on recommendations

and findings to the Secretariat. Funds for travel of 2 non-A5

co-chairs: US$ 10,000 [10] May 2006 April 24 – 28

2006 Beijing

12. The Secretariat posts the finalised report on its

web site and circulates it to the Parties - [31] May 2006

13. OEWG Bilateral Di scussions: Nominating

Party has the opportunity to consult with

MBTOC on a bilateral basis in conjunction

with the Open-ended Working Group meetings Funds for travel of 2 non-A5

co-chairs:

US$ 10,000 early July 2006 Likely late June

early July

14. The nominating Party submits further

clarification for the critical-use nomination in

the “unable to assess” category or if requested

to do so by the Open-ended Working Group,

and provides additional information should it

wish to appeal against a critical-use nomination

recommendation by MBTOC/TEAP - early August 2006

15. MBTOC Meeting No 2:

• reassess only those critical-use nominations in

the “unable to assess” category, those where

additional information has been submitted by

the nominating Party and any critical-use

nominations for which additional information

has been requested by the Open-ended Working

Group

• finalise the report, including notice of any

proposed new standard presumptions to be

applied by MBTOC

• conduct any bilateral consultations requested

by Parties

• draft work plan and budget for MBTOC for

2007 Funds for travel of 10 non-A5

members and co-chairs:

US$ 50,000. Meeting costs:

$US 6000. late August 2006 28 August – 2

September 2006,

Yokohama, Japan

16. MBTOC draft final report considered by

TEAP, finalised and made available to Parties

through the Secretariat - 10 October 2006

17. Eighteenth Meeting of the Parties Funds for travel of 2 non-A5

co-chairs: US$ 10,000 November 2006 Likely late

November to

early December

Total budget: US$206,000



# MBTOC 2006 assessment

18. Outline preparation and tasking of inputs (off

line). Identify chapter editors and member

contributors to chapters 15 November 2005

19. Preparation and review of the inputs to the

MBTOC assessment report:

• Methyl bromide production and consumption

• Emission control and transitional strategies for

MB phaseout Assessment will add an

additional 2 days to the

MBTOC meeting April 2006 3 – 11 April 2006

Zagreb or

Dubrovnik,

Croatia

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 76 Tasks and actions Indicative budget needs

where applicable Indicative

completion date Dates of

meetings

• Assessment of alternatives for soil treatment

• Assessment of alternatives for postharvest and

structural treatment

• QPS issues and alternatives

• Adoption of alternatives in A5 countries

• Discuss initial drafts of Assessment report,

identify areas where additional work is required

20. Compilation of the draft report and review of it

at the second MBTOC meeting Assessment will add an

additional 2 days to MBTOC

meeting late August 2006 28 August – 5

September 2006,

Yokohama, Japan

21. Comments and corrections to the draft and

circulation of the semi-final draft among the

MBTOC members 1 October 2006

22. Chapter authors meet to finalise draft

Assessment Report In conjunction with

18MOP

23. MBTOC to submit the final report to TEAP 15 December 2006

24. TEAP to submit the synthesis report of TEAP

and final reports of all its TOCs to the

Secretariat 31 December 2006

25. The Secretariat posts th e finalized reports on its

web site and circulates it to the Parties 31 January 2007



# Composition of MBTOC

26. At the MBTOC meeting on the assessment of

nominations, MBTOC will also update the list

of members and their expertise and decide on

missing expertise. The list and missing

expertise to be submitte d to the Secretariat. 3 April 2006

27. The Secretariat will pos t on its website the list

of members and their expertise and update the

webpage on ‘experts requi red for TEAP and its

TOCs’. 14 April 2006



# 4.5 Summary Report of the Activities Carried out by MBTOC in 2005

• Initial summarization of the CUNs (establishing the database by the Secretariat) –

split in two parts (i) the CUNs for ExMOP2 and (ii) CUNs for 25OEWG.

• Preparation of questions for Parties.

• First meeting of MBTOC on the assessment of the CUNs – Buenos Aires, 11-15

April 2005. Interim recommendations and report prepared for the Parties.

Welcomed new members from Brazil and USA and departure of two delegates

from USA.

• Site visits by 12 MBTOC members – 5 day tour of Florida and Georgia

horticulture (eg. strawberries, tomatoes, peppers, cucurbits) and forestry nurseries

to review alternatives research and industry issues with these alternatives.

Progress report drafting for four weeks after the April meeting.

• TEAP meeting – Lindau, 25-29 April 2005.

# October 2005 TEAP Report on 2005 CUNs: Final Report 

# 77 • Issuance of the interim report for consideration by the OEWG as part of TEAP

report and final report on the CUNs for decision by 2EMOP.

• 25OEWG (Montreal, 27-30 June 2005). Bilateral meetings with Australia, Japan,

Latvia, Spain, USA, US Food Processing and Agriculture Industry members, and

ExMOP2 (Montreal, 1 July 2005). Revised Handbook on Critical Use

Nominations tabled for discussion.

• Welcomed new MBTOC members as nominated by Brazil, China, Italy, Israel,

Japan, Lebanon and USA. Resignation of MBTOC members from Germany (1),

USA (2).

• Updated Matrix of MB alternatives for soils uses from recent MBTOC

documents.

• Second meeting of MBTOC, Melbourne, 29 August-2 Sept 2005. Bilaterals with

Australia (including Australian food pr ocessing industry members), and USA.

Site visits Australian field agriculture and grain processing. Presentation of the

preliminary data from the metaanalysis team.

• Drafted new suggested standard presumptions for in-field agriculture uses of MB

and concerning low permeability films.

• Drafted MB alternatives registration report and MB re-registration report for soils

and post-harvest uses. Reporting format prepared for distribution to Parties by

Secretariat.

• Short initial comments received from MBTOC member regarding MB treatment

of fresh dates. Full report incomplete; funds needed for travel and research from a

UN implementing agency.

• Preparation of standardized format for Parties to use when reporting back to

MBTOC.

4.6 Allocation of the Funds provided under Decision XVI/5

Under decision XVI/5, Parties decided to pr ovide MBTOC with financial assistance on

an exceptional basis for 2005, to cover the costs of expert assistance to MBTOC for the

maximum sum of $68,300, and travel for a non-Article 5(1) co-chair to three meetings

related to critical use nominations to the maximum sum of $15,000.

The funds were allocated as follows:

Decision XVI/5(1): $15,000: Travel costs for a non-Article 5(1) co-chair US$15,000.

Decision XVI/5(2): $68,300: Conducting the initial analysis and preparation of the

reports on the assessment of critical use nominations (US$2,500); reference data base,

metaanalysis database and model preparation for the metaanalysis of soils alternatives

US$ 54,000.

Balance of $14,300 applied to the combined MBTOC meeting in Buenos Aires and site

visit in Florida (decision XVI/5(5a)): Six non-Article 5 members funded at the cost of

$20,787.65.

Travel and DSA for non-Article 5(1) experts in the MBTOC meetings related to

assessment of critical use nominations (decision XVI/5(4)): Three non-Article 5(1)

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 78 

# members funded at the cost of US$9,281. Total travel costs for non-Article 5(1)

members: $30,068.65.

Shortfall: $15,768.75.

The actual certified expenditure against the allocations will only become available after

the closing of 2005 accounts in March 2006. This is a provisional report of information

that has already been recorded in the UN integrated management information system

(IMIS).

4.7 Management and Personnel Issues

It is a key need that MBTOC’s current transitional management status be completed

through the confirmation of an appropriate number of co-chairs, and that the co-chairs

designate and accept responsibility to achieve the functions and work plan milestones.

Co-chairs will need sufficient funding to ensure their attendance at meetings and to

ensure they can fairly share and accomplish MBTOC’s heavy workload in a timely

manner.

Annex II lists MBTOC members, country, work affiliation and expertise. MBTOC

members represent an impressive scope and depth of experience and ability; MBTOC has

members from twenty-seven countries. More than new members, MBTOC needs to have

its members funded to attend meetings, and able to commit to contributing to the work of

MBTOC outside of the meetings. Most members have been appointed by Parties, yet it is

a constant struggle for many members to obtain sufficient funding to attend all MBTOC

meetings, and even more so to be funded to spend the time necessary to accomplish the

heavy workload.

The response of the Parties to MBTOC’s indicative budget will, more than anything,

clarify MBTOC’s membership needs. Without funding to attend meetings this year, many

current non-A5 MBTOC members will be unable to attend. If there is to be no change in

the funding situation, MBTOC may need to replace up to 30% of its members; the loss of

that many experienced members would threaten both the best completion of CUN

decisions and the excellence of the Assessment report.

MBTOC continues to search for well-qualified members with expertise in:

Chemical and non-chemical control of weeds, nematodes and plant diseases,

Practical experience in alternatives fumigation and heat treatment of food processing

facilities,

Practical experience in chemical and non-chemical control of commodity pests,

quarantine and non-quarantine,

Agricultural economics, including in post-harvest applications,

Wood disinfection specialists,

Alternatives practitioners,

Technology cooperation,

Agricultural extension,

# October 2005 TEAP Report on 2005 CUNs: Final Report 

# 79 Recapture and recycling,

Regulatory processes and registration.

4.8 Proposed changes to standard presumptions

Standard presumptions used in the current (2005) and previous rounds of CUNs have

included a standard dosage of 200 kgMB/ha applied as a mixture with chloropicrin

(67:33). It is proposed that commencing with CUNs for 2007 use, this presumption be

altered to be a standard rate of 150 kgMB/ha for pathogen control and 175 kgMB/ha

where nutgrass must be controlled, both applied as 50:50 MB:Pic mixtures under LPF

films (e.g. VIF or equivalent).

Supporting data for the methyl bromide component and dosage is given in Section 2.3.6

above.

# October 2005 TEAP Report on 2005 CUNs: 

# final Report 80 ANNEX I

Annex I to the Report of the Sixteenth Meeting of the Parties to the Montreal Protocol (Prague, 22–

26 November 2004), paragraph 15.

(Decision XVI/4. Review of the working procedures and terms of reference of the Methyl Bromide

Technical Options Committee)

“15. An annual work plan will enhance the tran sparency of, and insight in, the operations of

MBTOC.

Such a plan should indicate, among other things:

(a) Key events for a given year;

(b) Envisaged meeting dates of MBTOC, including the stage in the

nomination and evaluation process to which the respective meetings relate;

(c) Tasks to be accomplished at each meeting, including appropriate

delegation of such tasks;

(d) Timing of interim and final reports;

(e) Clear references to the timelines relating to nominations;

(f) Information related to financial needs, while noting that financial

considerations would still be reviewed solely in the context of the review of the

Secretariat’s budget;

(g) Changes in the composition of MBTOC, pursuant to the criteria for

selection;

(h) Summary report of MBTOC activities over the previous year,

including matters that MBTOC did not manage to complete, the reasons for this

and plans to address these unfinished matters;

(i) Matrix with existing and needed skills and expertise; and

(j) Any new or revised standards or presumptions that MBTOC seeks

to apply in its future assessment of critical-use nominations, for approval by the

Meeting of the Parties. ”October 2005 TEAP Report on 2005 CUNs: Final Report81ANNEX IICurrent membership of the Methyl Bromide Technical Options CommitteeNames Gender Affiliation Expertise LengthofserviceCountry Article 5 statusCo-Chairs1. Jonathan Banks M Consultant Consultant, postharvest,particularly controlledatmospheres, phosphine,recapture (PhD)a Australia Non-A52. Nahum Marban Mendoza M Universidad Autonoma Chapingo(Academia)Researcher, soilsalternatives, particularlynematode problems (PhD,Prof.)c Mexico A5Members3. Alessandro Amadio M UNIDO International Agency,grafting technologies.(PhD)ItalyNon A54. Marten Barel M Consultant Fumigator, particularlysteam, MB andalternatives used Netherlands Non-A55. Chris Bell M Central Science Laboratory(Government research)Postharvest technologies,particularly phosphine(PhD)b UK Non-A56. Antonio Bello M Centrode Ciencias Medioambientales(Government research)Non-chemical alternatives(PhD, Prof)a Spain Non-A57. Mohamed Besri M InstitutAgronomique et VétérinaireHassan II (Acedemia)Researcher. PlantPathology, particularly.ecology of soilbornepathogens and MB andalts in A5s (PhD, Prof)b Morocco A58. Cao Aocheng M Chinese Academy of AgriculturalSciences (Government research)Researcher, soilalternatives, particularlyin China context (PhD)c China A5October 2005 TEAP Report on 2005 CUNs:finalReport829. Peter Caulkins M EnvironmentalProtection Agency Regulatory andregistration of methylbromide and alternatives.Soil disinfestation (PhD)d UnitedStatesNonA-510. Fabio Chaverri M IRET-Universidad Nacional(Academia)Researcher andconsultant, MB alts.,particularly soildisinfestation, incl.solarisation.c Costa Rica A511. Ricardo Deang M Consultant Regulatory andregistration (PhD)b Philippines A512. Patrick Ducom M Ministère de l’Agriculture(Government research)Postharvest alternatives b France Non-A513 Abraham Gamliel M ARO Volcani Centre Soils alternatives,solarisation, engineering,fumigant movementd Israel A514. Saad Hafez M University of Idaho (Academia) Soils alternatives,nematologist (PhD, Prof)c US Non-A515. Darka Hamel F Department of Environment Regulatory andregistration. Post-harvestfumigationd Croatia A516 George Lazarovits M Agriculture & Agri-food Canada(Government research)Researcher, Plantpathology particularlybeneficials and soilamendments (PhD)c Canada Non-A517. Michelle Marcotte F Consultant, Marcotte ConsultingLLCConsultant, particularlyfood safety, foodprocessing andirradiation. MBTOCConvenora Canada Non-A518. Carlos Medeiros M Embrapa (Government Research) Soils alternatives d Brazil A519. Cecilia Mercado F UNEP DTIE CAP (Internationalorganization)Implementing agencyissuesb ThailandPhillipinesA520. Melanie Miller F Consultant Consultant in MBalternatives use (PhD)a Belgium Non-A521. Andrea Minuto M Agroinnova Universita Torino(Academia)Researcher, MB alts,soilless culture andd Italy Non-A5October 2005 TEAP Report on 2005 CUNs: Final Report83alternatives in soils (PhD)22. Takashi Misumi M MAFF (Government research) QPS and stored productentomology, fumigationd Japan Non-A523. Mokhtarud-Din BinHusainM Department of Agriculture(Government research)Postharvest, includingtimber treatment andQPSc Malaysia A524. Kazufumi Nishi M Nat Institute of Vegetables and TeaScience (Government research)Nonchemical alts,particularly heat systemsfor soils (PhD)d Japan Non-A525. David Okioga M Ministry of Environment and NaturalResources (Government regulatory)Postharvest and QPS MBalts (PhD)a Kenya A526. Marta Pizano deMarquezF Hortitecnia Ltda (consultant) Consultant, MB alts,particularly cut flowerproductionb Colombia A527. Ian Porter M Department of Primary Industries(Government research)Researcher, soilsalternatives, IPM,particularly strawberryand ornamentals (PhD).MBTOC Convenorb Australia Non-A528. Christoph Reichmuth M BBAGermany (Governmentresearch)Researcher, MB alts inpostharvest/structures,artefacts, especially inertatmospheres (PhD, Prof)b Germany Non-A529. Ariane Saade F Ministry of Economy and Trade(Government regulatory)Trade and economics d Lebanon A530. John Sansone M SCC Products (Fumigator) Fumigator, trainer,particular expertise instructures and newprocessesa US Non-A531. Jim Schaub M United States Department ofAgriculture (Government regulatory)Agricultural economist(PhD)c US Non-A532 Sally Schneider F United States Department ofAgriculture (Government research)Researcher in soils alts,particularly replantproblems and propagativematerial (PhD)c US Non-A534. JL( Stappies) Staphorst MAgricultural Research CouncilPlant Protection Research InstituteSoil microbiologistparticularly root diseaseb SouthAfricaA5October 2005 TEAP Report on 2005 CUNs:finalReport84(Government research) biocontrol methods(PhD)35. Akio Tateya M Syngenta Japan KK Application of MB andalts, particularly in Japana Japan Non-A536. Robert Taylor M Associate - Natural ResourcesInstitute (Government research)Postharvest technology,specifically A5 usesa UK Non-A537. Alejandro Valeiro M Department of Agriculture(Government research)Introduction/use of soilsalts, including tobaccoc Argentina A538. Ken Vick M United States Department ofAgriculture (Government research)Research in MBalternatives, incl. QPS(PhD)a US Non-A539. Nick Vink M University of Stellenbosch(Academia)Agricultural economics(PhD, Prof)c SouthAfricaA540. Jim Wells M Consultant, Environmental SolutionsGroup LLCRegistration andregulatory - MB and alts.a US Non-A541. Chris Watson M IGROX Ltd (Fumigator) MB and alternatives,particularly structuresand commodities inc. bulkand container in transittreatments.b UK Non-A5Totals 41M =34F =7a = 11b = 10c = 11d = 9A5=16Non-A5=25a - >10 yearsb – 5-10 yearsc – 2-5 yearsd - <2 years

# October 2005 TEAP Report on 2005 CUNs: Final Report 

# 85 

# 5. References

5.1 

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