MONTREAL PROTOCOL 

ON SUBSTANCES THAT DEPLETE 

THE OZONE LAYER 

UNEP 

REPORT OF THE

TECHNOLOGY AND ECONOMIC ASSESSMENT PANEL

MAY 2010 

VOLUME 2 

PROGRESS REPORT

UNEP 

MAY 2010 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

VOLUME 2 

PROGRESS REPORT
iv May 2010 TEAP Progress Report 

Montreal Protocol 

On Substances that Deplete the Ozone Layer 

Report of the 

UNEP Technology and Economic Assessment Panel 

May 2010 

VOLUME 2 

PROGRESS REPORT

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

Co-ordination: Technology and Economic Assessment Panel 

Composition of the report: Lambert Kuijpers and Meg Seki (UNEP) 

Layout and formatting: Ozone Secretariat (UNEP) 

 Lambert Kuijpers (UNEP TEAP) 

Reproduction: UNON Nairobi 

Date: May 2010 

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

UNITED NATIONS ENVIRONMENT PROGRAMME 

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

This document is also available in portable document format from the UNEP Ozone 

Secretariat's website: 

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

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

acknowledgement of the source of the material. 

ISBN: 9966-7319-2-X
May 2010 TEAP Progress Report v

Disclaimer 

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

Assessment Panel (TEAP) Co-chairs and members, the Technical Options Committees Cochairs and members, the TEAP Task Forces Co-chairs 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 

operation requires consideration of worker safety and proper disposal of contaminants and 

waste products. Moreover, as work continues - including additional toxicity evaluation - 

more information on health, environmental and safety effects of alternatives and replacements 

will become available for use in selecting among the options discussed in this document. 

UNEP, the TEAP Co-chairs and members, the Technical Options Committees Co-chairs and 

members, and the Technology and Economic Assessment Panel Task Forces Co-chairs and 

members, in furnishing or distributing this information, do not make any warranty or 

representation, either express or implied, with respect to the accuracy, completeness, 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 

limited to any claims regarding health, safety, environmental effect or fate, efficacy, or 

performance, made by the source of information. 

Mention of any company, association, or product 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, the Technology and Economic Assessment Panel Cochairs or members, the Technical and Economic Options Committee Co-chairs or members, 

the TEAP Task Forces Co-chairs or members or the companies or organisations that employ 

them. 

Acknowledgements 

The Technology and Economic Assessment Panel, its Technical Options Committees and the 

Task Forces Co-chairs and members acknowledges with thanks the outstanding contributions 

from all of the individuals and organisations that provided support to Panel, Committees and 

Task Forces Co-chairs and members. The opinions expressed are those of the Panel, the 

Committees and Task Forces and do not necessarily reflect the reviews of any sponsoring or 

supporting organisation. 

The TEAP thanks the Ministry of Environment, Rural and Marine Affairs (Ministerio de 

Medio Ambiente y Medio Rural y Marino) in Madrid, Spain, for hosting the TEAP meeting, 

19-24 April 2010, where this report was composed and reviewed. Thanks are particularly 

indebted to Dolores Rollet and Albert Moral for making all necessary arrangements in a very 

forthcoming and outstanding way.

May 2010 TEAP Progress Report vii

Foreword 

The TEAP 2010 Progress Report 

The May 2010 TEAP Progress Report consists of two volumes: 

Volume 1 Decision XXI/9 Task Force Report, and 

 the “final” Decision XIX/8 Task Force Report 

Volume 2 TOC Progress Reports and Other Task Force Reports 

Volume 1 

Volume 1 contains: (1) the report of the Decision XXI/9 Task Force on the assessment of 

HCFCs and environmentally sound alternatives and (2) the final report of the Decision XIX/8 

Task Force dealing with the “scoping study on HCFC alternatives under high ambient 

temperature conditions”. 

Volume 2 

Volume 1 contains the essential use report, TOC progress reports, the QPS Task Force report 

(as requested in decision XXI/10), the MBTOC progress and preliminary CUN evaluation 

report, as well as TEAP organisation issues and TEAP-TOC membership lists 

This report is the Volume 2 report. 

The UNEP Technology and Economic Assessment Panel: 

Stephen O. Andersen, co-chair USA Marta Pizano COL 

José Pons-Pons, co-chair VEN Ian Porter AUS 

Lambert Kuijpers, co-chair NL Miguel Quintero COL 

Paul Ashford UK Ian Rae AUS 

Mohamed Besri MOR Helen Tope AUS 

David Catchpole UK Dan Verdonik USA 

Biao Jiang PRC Ashley Woodcock UK 

Michelle Marcotte CDN Masaaki Yamabe J 

Thomas Morehouse USA Shiqiu Zhang PRC 

Roberto Peixoto BRA 

May 2010 TEAP Progress Report ix

UNEP 

MAY 2010 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

VOLUME 2 

PROGRESS REPORT

TABLE OF CONTENTS ....................................................................................................................... PAGE 

1 ESSENTIAL USES....................................................................................................................1

1.1 EXECUTIVE SUMMARY OF ESSENTIAL USE NOMINATIONS FOR METERED DOSE 

INHALERS .....................................................................................................................................1

1.2 ESSENTIAL USE NOMINATIONS FOR METERED DOSE INHALERS .................................................4

1.2.1 Criteria for Review of Essential Use Nominations for MDIs.....................................................4

1.2.2 Review of Nominations ................................................................................................................4

1.2.3 Observations ................................................................................................................................4

1.2.4 Exported products........................................................................................................................7

1.2.5 Other Issues .................................................................................................................................8

1.2.6 Argentina......................................................................................................................................9

1.2.7 Bangladesh.................................................................................................................................11

1.2.8 People's Republic of China........................................................................................................12

1.2.9 India ...........................................................................................................................................15

1.2.10 Iran.............................................................................................................................................19

1.2.11 Pakistan......................................................................................................................................20

1.2.12 Russian Federation....................................................................................................................21

2 MEDICAL TECHNICAL OPTIONS COMMITTEE PROGRESS REPORT ...............23

2.1 EXECUTIVE SUMMARY ...............................................................................................................23

2.2 GLOBAL USE OF CFCS FOR MDIS ..............................................................................................24

2.3 TRANSITION AWAY FROM THE USE OF CFC MDIS.....................................................................27

2.4 TRANSITION STRATEGIES............................................................................................................29

2.4.1 Patient access and phase-out criteria .......................................................................................31

2.4.2 Timeline and final date for phase-out .......................................................................................32

2.4.3 Education ...................................................................................................................................33

2.4.4 Progress reports on transition strategies under Decision XII/2 ..............................................33

2.5 GLOBAL DATABASE IN RESPONSE TO DECISION XIV/5..............................................................33

2.6 EXPORT MANUFACTURING TRANSITION PLANS IN RESPONSE TO DECISION 

XVIII/16.....................................................................................................................................34

3 RESPONSE TO DECISION XXI/4(8): TECHNICAL, ECONOMIC AND 

ADMINISTRATIVE ISSUES AFFECTING THE TRANSITION FROM CFC 

METERED DOSE INHALERS TO CFC-FREE ALTERNATIVES IN THE 

RUSSIAN FEDERATION......................................................................................................35

3.1 BACKGROUND TO DECISION XXI/4(8).......................................................................................35

3.2 ORGANISATION...........................................................................................................................35

3.3 BACKGROUND TO THE TRANSITION FROM CFC TO CFC-FREE MDIS IN THE 

RUSSIAN FEDERATION................................................................................................................36

3.3.1 Asthma and COPD and healthcare in the Russian Federation................................................36

3.3.2 Salbutamol MDIs in the Russian Federation............................................................................36

3.3.3 Efforts to phase out CFCs in MDIs in the Russian Federation................................................40

3.3.4 Supply of CFCs for MDI manufacture in the Russian Federation...........................................41

3.4 STATUS OF TRANSITION IN THE RUSSIAN FEDERATION..............................................................41

3.4.1 Status of transition in the companies manufacturing CFC MDIs in the Russian 

Federation..................................................................................................................................41

3.5 BARRIERS TO TRANSITION ..........................................................................................................42
x May 2010 TEAP Progress Report 

3.5.1 Financial aspects to transition ..................................................................................................42

3.5.2 Technical aspects to transition..................................................................................................43

3.5.3 Regulatory and administrative aspects to transition ................................................................43

3.5.4 Logistical aspects to transition..................................................................................................44

3.6 RECOMMENDATIONS AND CONCLUSIONS...................................................................................44

4 CHEMICALS TECHNICAL OPTIONS COMMITTEE (CTOC) PROGRESS 

REPORT...................................................................................................................................47

4.1 EXECUTIVE SUMMARY ...............................................................................................................47

4.2 INTRODUCTION ...........................................................................................................................49

4.3 PROCESS AGENTS .......................................................................................................................50

4.3.1 Review of Table A of the decision X/14.....................................................................................51

4.3.2 Review of Table B of the decision X/14.....................................................................................52

4.3.3 Request of Switzerland...............................................................................................................53

4.4 LABORATORY AND ANALYTICAL USES OF ODS.........................................................................53

4.4.1 Uses already banned..................................................................................................................54

4.4.2 Methyl bromide exemptions.......................................................................................................54

4.4.3 Recommendations ......................................................................................................................55

4.4.4 Briefings by CTOC ....................................................................................................................56

4.4.5 Use of CTC in biomedical research ..........................................................................................56

4.5 ESSENTIAL USE EXEMPTIONS OF CFC-113 IN THE RUSSIAN FEDERATION ...............................57

4.5.1 Background of the nomination ..................................................................................................57

4.5.2 The CTOC comments on EUE of CFC-113 in 2011 by the Russian Federation .....................57

4.5.3 Conclusions................................................................................................................................58

4.6 N-PROPYL BROMIDE (N-PB) UPDATE ........................................................................................59

4.7 DESTRUCTION TECHNOLOGIES (RELATED TO DECISION XXI/2 (3)............................................60

4.7.1 Review of 2002 Task Force Report ...........................................................................................60

4.7.2 Emerging Destruction Technologies.........................................................................................61

4.8 FEEDSTOCKS...............................................................................................................................62

4.8.1 Where they are used...................................................................................................................62

4.8.2 Estimated emissions of ODS......................................................................................................64

APPENDIX: DETAILS OF LABORATORY AND ANALYTICAL USES OF ODS ...................................................65

5 FOAMS TECHNICAL OPTIONS COMMITTEE (FTOC) PROGRESS REPORT .....79

5.1 OVERVIEW PARAGRAPH ON FOAMS ...........................................................................................79

5.1.1 Transitional Status.....................................................................................................................79

5.1.2 Technology Update....................................................................................................................80

6 HALONS TECHNICAL OPTIONS COMMITTEE (HTOC) PROGRESS 

REPORT...................................................................................................................................83

6.1 UPDATE ON ALTERNATIVE AGENTS...........................................................................................83

6.2 UPDATE ON HALON USES...........................................................................................................83

6.3 UPDATE ON HALON 1301 USE AS A FEEDSTOCK .......................................................................83

6.4 HALON RECOVERY AND RECYCLING IN ARTICLE 5 COUNTRIES ...............................................83

6.5 CONTAMINATED RECYCLED HALONS ........................................................................................83

6.6 RESPONSE TO DECISION XXI/7 ..................................................................................................84

7 REFRIGERATION, AIR-CONDITIONING AND HEAT PUMPS TECHNICAL 

OPTIONS COMMITTEE (RTOC) PROGRESS REPORT..............................................87

7.1 PROGRESS REPORTS ...................................................................................................................87

7.2 RTOC 2010 ASSESSMENT REPORT ............................................................................................87

8 DECISION XXI/10 QUARANTINE AND PRE-SHIPMENT REPORT .........................89

8.1 EXECUTIVE SUMMARY ...............................................................................................................89

8.2 INTRODUCTION ...........................................................................................................................91

8.2.1 Mandate and scope....................................................................................................................91

8.2.2 Origin and intent of the QPS exemption ...................................................................................92

8.2.3 Quarantine and pre-shipment definitions and application.......................................................93

8.2.3.1 Definitions of quarantine and pre-shipment........................................................................................93

8.2.3.2 Alternatives for quarantine and pre-shipment.....................................................................................93
May 2010 TEAP Progress Report xi

8.2.3.3 Market penetration...............................................................................................................................93

8.2.4 Summary of response to Decision XX/6 ....................................................................................94

8.2.5 Organisation of work.................................................................................................................94

8.2.5.1 Membership of MBTOC-QPS ............................................................................................................94

8.2.5.2 Communications and meeting.............................................................................................................95

8.2.5.3 Structure of the report..........................................................................................................................95

8.3 FEASIBILITY, AVAILABILITY AND MARKET PENETRATION OF ALTERNATIVES TO 

METHYL BROMIDE FOR QUARANTINE AND PRE-SHIPMENT.....................................................96

8.3.1 Introduction and mandate .........................................................................................................96

8.3.2 Alternatives for sawn timber and wood packaging material....................................................96

8.3.2.1 Technical feasibility ............................................................................................................................96

8.3.2.2 Economic feasibility............................................................................................................................98

8.3.2.3 Market penetration of heat treatments compared to methyl bromide.................................................98

8.3.2.4 Regulatory requirements and other drivers.........................................................................................99

8.3.3 Alternatives for grains and similar foodstuffs.........................................................................100

8.3.3.1 Technical feasibility ..........................................................................................................................100

8.3.3.2 Economic feasibility..........................................................................................................................103

8.3.3.3 Market penetration.............................................................................................................................103

8.3.3.4 Regulatory requirements and other drivers.......................................................................................103

8.3.4 Alternatives for pre-plant soils use for propagative material and nursery uses....................103

8.3.4.1 Technical feasibility ..........................................................................................................................103

8.3.4.2 Economic feasibility..........................................................................................................................106

8.3.4.3 Market penetration.............................................................................................................................107

8.3.4.4 Regulatory requirements and other drivers.......................................................................................107

8.3.5 Alternatives for logs.................................................................................................................109

8.3.5.1 Technical feasibility ..........................................................................................................................109

8.3.5.2 Economic feasibility..........................................................................................................................113

8.3.5.3 Market penetration of alternatives.....................................................................................................114

8.3.5.4 Regulatory requirements and other drivers.......................................................................................114

8.3.6 Alternatives being investigated and under development ........................................................115

8.3.6.1 Sawn timber and wood packaging material ......................................................................................115

8.3.6.2 Grains and similar foodstuffs ............................................................................................................116

8.3.6.3 Pre-plant soils use..............................................................................................................................117

8.3.6.4 Logs ...................................................................................................................................................118

8.3.7 Summary of technical and economic feasibility and market penetration...............................120

8.4 FEASIBLE SCENARIO FOR THE GLOBAL REPLACEMENT OF METHYL BROMIDE 

USED FOR QUARANTINE AND PRE-SHIPMENT..........................................................................121

8.4.1 Introduction and mandate .......................................................................................................121

8.4.2 Feasible scenarios for quantities of methyl bromide..............................................................121

8.4.2.1 Article 5 Parties .................................................................................................................................121

8.4.2.2 Non-Article 5 Parties.........................................................................................................................121

8.4.2.3 Estimated amount of methyl bromide that could be replaced for QPS soil uses .............................122

8.4.2.4 Estimated replaceable quantities – summary....................................................................................122

8.4.3 Summary...................................................................................................................................128

8.5 DRAFT METHODOLOGY FOR ASSESSING THE FEASIBILITY OF ALTERNATIVES, THE 

IMPACT OF THEIR IMPLEMENTATION AND OF RESTRICTING METHYL BROMIDE 

FOR QUARANTINE AND PRE-SHIPMENT ...................................................................................128

8.5.1 Mandate and scope..................................................................................................................128

8.5.2 Description of the methodology that could be used to assess technically and 

economically feasible alternatives to methyl bromide for quarantine and preshipment uses ...........................................................................................................................129

8.5.2.1 Introduction........................................................................................................................................129

8.5.2.2 Uses of methyl bromide for soil that were categorised as QPS........................................................129

8.5.2.3 Definitions .........................................................................................................................................131

8.5.3 Technical feasibility of an alternative.....................................................................................131

8.5.4 Economic feasibility of alternatives ........................................................................................132

8.5.5 Description of the methodology for the assessment of the impact of the 

implementation of alternatives to methyl bromide for quarantine and preshipment uses ...........................................................................................................................133

8.5.5.1 Impact of an alternative on the atmosphere ......................................................................................133

8.5.5.2 Impact of the an invasive pest on agriculture, forests and ecosystems ............................................134
xii May 2010 TEAP Progress Report 

8.5.6 Description of the methodology for the assessment of the impact of restricting 

the quantities of methyl bromide production and consumption for quarantine 

and pre-shipment uses .............................................................................................................137

8.5.6.1 Consumption of methyl bromide for quarantine and pre-shipment .................................................137

8.5.6.2 Domestic use of methyl bromide for QPS treatments ......................................................................139

8.5.6.3 Methyl bromide reported as QPS consumption ................................................................................139

8.5.6.4 International Plant Protection Convention........................................................................................141

8.5.6.5 Trade that depends on the use of methyl bromide for QPS..............................................................141

8.5.6.6 Experiences of the phase out of methyl bromide for QPS in some countries..................................142

8.5.6.7 Other methods to reduce emissions of methyl bromide ...................................................................143

8.5.6.8 Design of the restriction influences TEAP’s proposed methodology ..............................................143

8.5.7 Discussion and conclusions.....................................................................................................145

8.6 REFERENCES.............................................................................................................................146

8.7 ANNEXES ..................................................................................................................................154

8.7.1 Annex 1: Decision XXI/10 Quarantine and pre-shipment uses of methyl bromide ...............154

8.7.2 Annex 2: Definitions of Quarantine and Pre-shipment .........................................................156

9 METHYL BROMIDE TECHNICAL OPTIONS COMMITTEE (MBTOC) 

PROGRESS REPORT..........................................................................................................157

9.1 MB PRODUCTION AND CONSUMPTION UPDATE ......................................................................157

9.1.1 Controlled uses ........................................................................................................................157

9.1.1.1 Production of MB for controlled uses...............................................................................................157

9.1.1.2 Global consumption for controlled uses ...........................................................................................158

9.1.1.3 Consumption trends in Non-Article 5 countries ...............................................................................159

9.1.1.4 Consumption trends in Article 5 and CEIT countries.......................................................................159

9.1.2 Exempted uses..........................................................................................................................161

9.1.2.1 Production for QPS purposes (exempted uses).................................................................................161

9.1.2.2 Consumption for QPS purposes (exempted uses).............................................................................162

9.2 ALTERNATIVES FOR SOIL TREATMENTS ..................................................................................163

9.2.1 Key alternatives .......................................................................................................................163

9.2.2 Update on registration of chemical alternatives: ...................................................................164

9.2.2.1 United States......................................................................................................................................164

9.2.2.2 Japan ..................................................................................................................................................165

9.2.2.3 Australia.............................................................................................................................................166

9.2.2.4 Canada ...............................................................................................................................................166

9.2.2.5 Israel...................................................................................................................................................166

9.2.2.6 Europe................................................................................................................................................167

9.2.3 Alternatives to methyl bromide for crops where a CUN is sought.........................................167

9.2.3.1 Vegetables..........................................................................................................................................167

9.2.3.2 Ornamental crops...............................................................................................................................169

9.2.3.3 Strawberry fruit..................................................................................................................................170

9.2.3.4 Nurseries and propagation material for strawberries and other crops..............................................171

9.2.3.5 Sweet potatoes ...................................................................................................................................171

9.2.3.6 Ginger ................................................................................................................................................171

9.2.3.7 Replant disease ..................................................................................................................................172

9.2.3.8 Weeds.................................................................................................................................................172

9.2.3.9 Virus diseases of cucurbits and peppers ...........................................................................................174

9.3 STRUCTURES AND COMMODITIES ............................................................................................174

9.3.1 Reulatory Update.....................................................................................................................174

9.3.1.1 Sulfuryl fluoride (SF) ........................................................................................................................174

9.3.1.2 Methyl Bromide.................................................................................................................................176

9.3.1.3 Methyl Iodide ....................................................................................................................................176

9.3.1.4 Phosphine...........................................................................................................................................176

9.3.1.5 Heat treatment....................................................................................................................................177

9.3.2 Environmental Concerns in Conflict with the Use of MB alternatives ..................................177

9.3.3 Personnel Issues ......................................................................................................................178

9.3.4 Update on Pest Control Methods in Mills and Food Processing in the United 

Kingdom...................................................................................................................................178

9.3.5 Special Report on Pest Control Issues of Fresh Dates...........................................................179

9.3.6 Research Update – Efficacy of Alternatives............................................................................180

9.4 QUARANTINE AND PRESHIPMENT.............................................................................................184

9.5 ECONOMIC ASPECTS OF METHYL BROMIDE ALTERNATIVES...................................................184

9.5.1 Background..............................................................................................................................184
May 2010 TEAP Progress Report xiii

9.5.2 Components of an assessment of financial feasibility.............................................................185

9.5.3 Estimating the components for assessing financial feasibility ...............................................186

9.6 REFERENCES.............................................................................................................................187

10 EVALUATIONS OF CRITICAL USE NOMINATIONS FOR METHYL 

BROMIDE AND RELATED MATTERS – INTERIM REPORT ..................................195

10.1 SCOPE OF THE REPORT .............................................................................................................195

10.2 CRITICAL USE NOMINATIONS FOR METHYL BROMIDE............................................................195

10.2.1 Mandate ...................................................................................................................................195

10.2.2 Fulfilment of Decision IX/6 .....................................................................................................196

10.2.3 Consideration of Stocks - Decision Ex.1/4 (9f).......................................................................196

10.2.3.1 Stocks.................................................................................................................................................199

10.2.4 Reporting of MB Consumption for Critical Use - Decision XVII/9 .......................................199

10.2.5 Trends in Methyl Bromide Use for CUEs since 2005.............................................................200

10.2.6 Evaluations of CUNs – 2010 round for 2011 and 2012 exemptions......................................204

10.2.7 Critical Use Nominations Review ...........................................................................................205

10.2.8 Disclosure of Interest...............................................................................................................205

10.3 MBTOC SOILS: FINAL EVALUATIONS OF 2010 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE ...................................................................................................................205

10.3.1 Summary of outcomes..............................................................................................................205

10.3.2 Issues related to CUN Assessment for Preplant Soil Use.......................................................207

10.3.2.1 Registration of alternatives for preplant uses - Decision Ex I/4 (9i) and (9j) ..................................208

10.3.2.2 Update on rates of adoption of alternatives for preplant uses - Decision XIX/9 .............................209

10.3.2.3 Sustainable alternatives for preplant uses .........................................................................................209

10.3.3 Standard presumptions used in assessment of nominated quantities.....................................210

10.3.4 Adjustments for standard dosage rates using MB/Pic formulations......................................212

10.3.5 Use/Emission reduction technologies - Low permeability barrier films and 

dosage reduction......................................................................................................................212

10.4 INTERIM CUN REPORT – ISSUES SPECIFIC TO MBTOC STRUCTURES AND 

COMMODITIES ..........................................................................................................................236

10.4.1 Standard Dosage Presumptions and Adjustments for standard dosage rates .......................238

10.4.2 Details of evaluations ..............................................................................................................238

10.5 REFERENCES.............................................................................................................................252

COMMON ACRONYMS.................................................................................................................................258

ANNEX 1 TO CHAPTER 10. DECISION IX/6..........................................................................................259

ANNEX II TO CHAPTER 10 DECISION XVI/4 .......................................................................................260

ANNEX III TO CHAPTER 10 - PART A: TREND IN PREPLANT SOIL APPLICATIONS .....................................261

ANNEX IV TO CHAPTER10 – PART B: POST-HARVEST STRUCTURAL AND COMMODITY 

APPLICATIONS ..........................................................................................................................268

11 TEAP AND TOC ORGANISATION ISSUES ...................................................................273

11.1 CURRENT TEAP/TOC MEMBERSHIP AND TEAP NOMINATION OF A 

REPLACEMENT TEAP CO-CHAIR .............................................................................................273

11.2 MEDICAL TECHNICAL OPTIONS COMMITTEE (MTOC)............................................................273

11.3 METHYL BROMIDE TECHNICAL OPTIONS COMMITTEE (MBTOC)..........................................273

11.4 REFRIGERATION, AC AND HEAT PUMPS TECHNICAL OPTIONS COMMITTEE 

(RTOC) ....................................................................................................................................273

11.5 VOLCANIC ASH COMPLICATES AND INCONVENIENCES TEAP AND TOC

OPERATIONS .............................................................................................................................273

11.6 FINANCIAL CONSTRAINTS AND CHALLENGES ENCOUNTERED BY TEAP AND TOC

MEMBERS..................................................................................................................................274

12 TEAP TOC MEMBERSHIP LIST STATUS APRIL 2010 ..............................................275

May 2010 TEAP Progress Report 1

1 Essential Uses 

1.1 Executive Summary of Essential Use Nominations for Metered Dose 

Inhalers 

MTOC received 7 essential use nominations requesting a total of 1,628.74 tonnes of CFCs for 

the manufacture of metered dose inhalers (MDIs) in 2011: 6 from Article 5 Parties 

(Argentina, Bangladesh, China, India, Iran, Pakistan); and 1 from a non-Article 5 Party 

(Russian Federation). 

Table 1-1 summarises the recommendations of the Technology and Economic Assessment 

Panel (TEAP) and its Medical Technical Options Committee (MTOC) on nominations for 

essential use production exemptions for chlorofluorocarbons (CFCs) for MDIs. 

Recommendations are made in accordance with Decision XV/5(3), which requests TEAP and 

its TOC to make recommendations on nominations for essential use exemptions for CFCs for 

MDIs with reference to the active ingredient of the metered-dose inhalers in which the CFCs 

will be used and the intended market for sale or distribution. Recommendations are for a total 

of 1,291.8 tonnes of CFCs for the manufacture of MDIs in 2011. 

Table 1-1: Recommendations for essential use nominations 

Party 2011 Active Ingredients Intended 

Markets 

106.7 tonnes Beclomethasone, budesonide, fenoterol, 

fluticasone, ipratropium, salbutamol, 

salbutamol/beclomethasone, 

salbutamol/ipratropium, salmeterol, 

salmeterol/fluticasone 

Argentina Argentina 

0.5 tonnes Salbutamol/ipratopium Chile, Paraguay 

and Peru 

Bangladesh 38.65 tonnes Ciclesonide, fluticasone/salmeterol, 

ipratropium, ipratropium/salbutamol, 

salmeterol and tiotropium 

Bangladesh 

China 741.15 tonnes Beclomethasone, 

beclomethasone/clenbuterol/ipratropium

, budesonide, datura metel 

extract/clenbuterol, dimethicone; 

ephedra, ginkgo, sophora favescens and 

radix scutellariae; ipratropium, 

ipratropium/salbutamol, isoprenaline, 

isoprenaline/guaifenesin, procaterol, 

salbutamol, salmeterol, cromoglycate 

China 

19.8 tonnes Ipratropium, ipratropium/salbutamol, 

tiotropium and tiotropium/formoterol 

India India 

28.4 tonnes Ipratropium, ipratropium/salbutamol, 

tiotropium and tiotropium/formoterol 

Colombia, 

Jamaica, 

Panama, Peru, 

Sri Lanka, 

Suriname, 

U.A.E., Uganda, 

Venezuela 
2 May 2010 TEAP Progress Report 

Party 2011 Active Ingredients Intended 

Markets 

Iran 105 tonnes Beclomethasone, salbutamol, 

salmeterol, cromoglycate 

Iran 

Pakistan 39.6 tonnes Beclomethasone, 

beclomethasone/salbutamol, 

fluticasone/salmeterol, ipratropium, 

salbutamol, salmeterol, triamcinolone 

Pakistan 

Russian 

Federation 

212 tonnes Salbutamol Russian 

Federation 

MTOC thanks the Shanghai Institute of Pharmaceutical Industry (SIPI) and the Ozone 

Secretariat for providing meeting venue sponsorship for the MTOC meeting held in Shanghai, 

China, 21-25 March 2010. SIPI provided a range of on-ground organisational assistance and 

in-kind support, such as printing. MTOC accepted hospitality including transportation, 

guides, meals and beverages. 

In 2009, MTOC reported that it found it difficult to assess the nominations due to a lack of 

data provided on availability and affordability of alternatives to CFC MDIs. In particular, it 

reported that it was difficult to assess accurately the essentiality of quantities of CFCs 

intended for export when country-specific information was not provided in nominations on 

the quantity of CFCs required for each active ingredient in each market and the availability 

and affordability of alternatives1

. MTOC concluded that in future years, in the absence of 

country-specific information, MTOC would consider the alternatives available in intended 

export markets and make recommendations for a quantity of essential use CFCs for the 

manufacture of MDIs which specifically excluded any countries considered to have an 

adequate range of alternatives. 

Based on the information provided this year in nominations for 2011, MTOC continued to 

find it difficult to assess the nominations from Article 5 Parties in accordance with the criteria 

set out in Decision IV/25. In particular there was again a shortage of data in nominations on 

the availability and affordability of alternatives to CFC MDIs for Article 5 Parties importing 

products from MDI manufacturing/nominating Parties. However, MTOC had more data 

accessible to it from publicly available sources in 2010 than in 2009 on the availability and 

affordability of alternatives to CFC MDIs, both for the MDI manufacturing/nominating 

Parties and for Article 5 Parties importing their products. There has been substantial progress 

in the development and marketing of affordable CFC-free MDIs, especially those 

manufactured by Article 5 Parties. 

MTOC considers that there is an adequate range of technically satisfactory and affordable 

CFC-free alternatives for CFC MDIs for beta-agonists (in particular, salbutamol) and inhaled 

corticosteroids (in particular, beclomethasone) available in many developing countries. 

Consequently, MTOC is unable to recommend any of the CFC quantities nominated to 

manufacture MDIs for beta-agonists and inhaled corticosteroids for intended export markets. 

Some importing countries may still consider salbutamol and/or beclomethasone CFC MDIs 

essential in 2011, including through concern for poorer patients, but MTOC was not provided 

evidence to support this. Parties may wish to request importing countries to demonstrate 

essentiality. 

 

1 Decisions XV/5, par. 2, and XX/3 par. 1(a) request nominating Parties to provide information on the intended market(s) for sale

or distribution for the use, the active ingredient(s) for the use in each market and the quantity of CFCs required for each active 

ingredient in each market. Decision XVI/12, par. 2 further states that when more specific data are not available, data aggregated 

by region and product group may be submitted for CFC MDIs intended for sale in Parties operating under paragraph 1 of Article 

5. 
May 2010 TEAP Progress Report 3

Beta-agonist and inhaled corticosteroid CFC MDIs can now be considered non-essential in 

many developing countries because the previous conditions for non-essentiality stated by 

MTOC in 2009 have been met: 

• There are several CFC-free therapeutically equivalent products; and 

• The price difference between CFC and CFC-free therapeutic equivalent alternatives is 

narrow. 

There are some Parties where beta-agonist and/or inhaled corticosteroid CFC MDIs may still 

be needed for use in their own countries in 2011: Argentina, China, Iran, Pakistan and the 

Russian Federation. CFCs for MDIs in these therapeutic categories are recommended for 

these markets for 2011 while the conversion to CFC-free alternatives is underway and HFC 

MDI capacity is increasing. 

It is technically difficult to formulate anti-cholinergic drugs, such as ipratropium bromide and 

tiotropium bromide, as HFC MDIs and only a limited range of CFC-free inhalers are currently 

available. New CFC-free inhalers (DPIs and HFC MDIs manufactured in both non-Article 5 

and Article 5 Parties) for tiotropium and ipratropium (and combinations with other moieties) 

are beginning to become available. However MTOC does not yet believe they provide an 

adequate range of CFC-free alternatives to consider the CFC MDIs for these drugs to be nonessential. MTOC has recommended the nominated quantities for ipratropium and tiotropium 

and their combinations to markets where they were considered essential for 2011 because of 

uncertainty about the range of available alternatives and the current capacity of the 

manufacture of these products. MTOC will revisit the developments in anti-cholinergic drug 

availability in 2011, as reformulation and marketing of CFC-free alternatives progress. 

There are increasing numbers of combination products becoming available in Article 5 Party 

markets. In previous years, MTOC had indicated that it does not consider combination 

products to be essential where there are the same active ingredients available in the separate 

CFC-free inhalers. However, recent evidence has suggested that the combination of active 

ingredients in a single inhaler is beneficial, with improved compliance and clinical benefit, 

sometimes combined with a decrease in cost for patients compared to the drugs delivered in 

separate inhalers. As a result of this evidence, in 2009 for 2010 nominations, MTOC 

considered the CFCs requested for combination products with anti-cholinergics to be essential 

for the nominations received from Article 5 Parties. MTOC reconsidered, and reaffirmed this 

conclusion for nominations for 2011. MTOC is aware of several CFC-free combination 

products containing anti-cholinergics that have become available in Article 5 Parties. 

However, MTOC does not have sufficient information on price, availability, and 

manufacturing capacity to know whether the CFC MDI formulations are essential for 2011. 

MTOC will continue to review the essentiality of combination products against the 

availability of alternatives, including the relevant moieties in separate inhalers, and in future 

may not recommend them as essential. 

MTOC is unable to recommend as essential any new CFC MDIs not in the marketplace in 

2009. A ciclesonide CFC MDI (an inhaled steroid) is proceeding through regulatory approval 

processes in China, for which CFCs are requested in China's essential use nomination for 

2011. All inhaled steroids have very similar characteristics. MTOC does not believe that 

ciclesonide provides substantial additional health benefits. A new product in the approval 

process in 2009 and 2010, without significant additional health benefits, cannot be considered 

essential in 2011 under Decision IV/25. 
4 May 2010 TEAP Progress Report 

1.2 Essential Use Nominations for Metered Dose Inhalers 

1.2.1 Criteria for Review of Essential Use Nominations for MDIs 

Decision IV/25 of the 4th Meeting and subsequent Decisions V/18, VII/28, VIII/9, VIII/10, 

XII/2, XIV/5, XV/5, XVI/12, XVIII/16, XX/3 and XXI/4 have set the criteria and the process 

for the assessment of essential use nominations for MDIs for Parties not operating under 

paragraph 1 of Article 5 and Parties operating under paragraph 1 of Article 5 of the Protocol. 

Other essential use decisions relevant to these Parties are Decisions XVII/5, XVIII/7 and 

XIX/13. 

1.2.2 Review of Nominations 

The review of essential use nominations by the MTOC was conducted as follows. 

Three members of the MTOC independently reviewed each nomination, each preparing an 

assessment. Further information was requested of nominating Parties where necessary. The 

MTOC considered the assessments, made recommendation decisions and prepared a 

consensus report at its meeting in Shanghai, China, 21-25 March 2010. Members disclosed 

any potential conflict of interests ahead of the discussion. Where necessary, members were 

recused from the decision-making process of the nomination relevant to any potential conflict 

of interest. Annually listed disclosures of members indicate specific interests and any 

relevant actions taken. 

Nominations were assessed according to the guidelines for essential use contained within the 

Handbook on Essential Use Nominations (TEAP, 2009) and subsequent Decisions of the 

Parties. Recommendations are made in accordance with Decision XV/5(3), which requests 

TEAP and its TOC to make recommendations on nominations for essential use exemptions 

for CFCs for MDIs with reference to the active ingredient of the metered-dose inhalers in 

which the CFCs will be used and the intended market for sale or distribution. 

Concurrent with the evaluation undertaken by the MTOC, copies of all nominations are 

provided to the Technology and Economic Assessment Panel (TEAP). The TEAP and its 

TOCs can consult with other individuals or organisations to assist in the review and to prepare 

TEAP recommendations for the Parties. 

1.2.3 Observations 

MTOC received 7 essential use nominations requesting a total of 1,628.74 tonnes of CFCs for 

the manufacture of metered dose inhalers (MDIs) in 2011: 6 from Article 5 Parties 

(Argentina, Bangladesh, China, India, Iran, Pakistan); and 1 from a non-Article 5 Party 

(Russian Federation). MTOC recommendations are for a total of 1,291.8 tonnes of CFCs for 

the manufacture of MDIs in 2011. 

For the first round of nominations from Article 5 Parties in 2009, MTOC reported that it 

found it difficult to assess the nominations due to a lack of data provided on availability and 

affordability of alternatives to CFC MDIs. In particular, it reported that it was difficult to 

assess accurately the essentiality of quantities of CFCs intended for export when country-
May 2010 TEAP Progress Report 5

specific information was not provided in nominations on the quantity of CFCs required for 

each active ingredient in each market and the availability and affordability of alternatives2

. 

MTOC concluded that in future years, in the absence of country-specific information, MTOC 

would consider the alternatives available in intended export markets and make 

recommendations for a quantity of essential use CFCs for the manufacture of MDIs which 

specifically excluded any countries considered to have an adequate range of alternatives. 

Based on the information provided this year in nominations for 2011, MTOC continued to 

find it difficult to assess the nominations from Article 5 Parties in accordance with the criteria 

set out in Decision IV/25. In particular there was again a shortage of data in nominations on 

the availability and affordability of alternatives to CFC MDIs for Article 5 Parties importing 

products from MDI manufacturing/nominating Parties. 

The substantive criteria for essential use exemptions are detailed in Decision IV/25 of the 

Parties. Paragraph 1 (a) of Decision IV/25 states that: 

"Use of a controlled substance should qualify as essential only if: 

i. it is necessary for health, safety or is critical for the functioning of society 

(encompassing cultural and intellectual aspects); and 

ii. there are no available technically and economically feasible alternatives or 

substitutes that are acceptable from the standpoint of environment and health." 

There were also substantial inconsistencies in some nominations, with some nominating 

Parties listing exports to Parties that have already declared CFC MDIs as non-essential. 

However, MTOC had more data accessible to it from publicly available sources in 2010 than 

in 2009 on the availability and affordability of alternatives to CFC MDIs, both for the MDI 

manufacturing/nominating Parties and for Article 5 Parties importing their products. There 

has been substantial progress in the development and marketing of affordable CFC-free 

MDIs, especially those manufactured by Article 5 Parties. With economies of scale, and a 

range of different brands from local manufacturers, HFC MDIs are now becoming more 

competitively priced compared to CFC MDIs. 

MTOC considers that there is an adequate range of technically satisfactory and affordable 

CFC-free alternatives for CFC MDIs for beta-agonists (in particular, salbutamol) and inhaled 

corticosteroids (in particular, beclomethasone) available in many developing countries. 

Consequently, MTOC is unable to recommend any of the CFC quantities nominated to 

manufacture MDIs for beta-agonists and inhaled corticosteroids for intended export markets. 

Economic aspects, in particular those related to affordability, are important criteria for the 

assessment of essential uses under Decision IV/25. In their nominations, most Article 5 

Parties have previously reported price differences between inhalers made in Article 5 Parties 

compared to imported inhalers from non-Article 5 Parties. The major change in 2010 has 

been the new widespread availability of CFC-free alternatives manufactured in Article 5 

Parties. Some manufacturers have completed MLF funded projects (e.g. Cuba, Uruguay), 

while others are completing manufacturing conversion independently (e.g. Algeria, Croatia, 

 

2 Decisions XV/5, par. 2, and XX/3 par. 1(a) request nominating Parties to provide information on the intended market(s) for sale

or distribution for the use, the active ingredient(s) for the use in each market and the quantity of CFCs required for each active 

ingredient in each market. Decision XVI/12, par. 2 further states that when more specific data are not available, data aggregated 

by region and product group may be submitted for CFC MDIs intended for sale in Parties operating under paragraph 1 of Article 

5. 
6 May 2010 TEAP Progress Report 

Syria, Venezuela). The largest manufacturer in India, Cipla, has 51 different CFC-free 

products available. In Bangladesh, three manufacturers will have HFC MDIs for both 

salbutamol and beclomethasone on sale in 2010, with combined installed capacity to 

manufacture 25 million inhalers per year. Since domestic MDI use is currently 5 million 

inhalers per year, companies in Bangladesh will be competing with those from other Article 5 

Parties to supply affordable HFC MDIs to many markets previously reliant on CFC MDIs 

manufactured and exported by Article 5 Parties. This new HFC MDI manufacturing capacity 

has the potential to reduce the prices of CFC-free inhalers. Finally, any importing Parties 

with difficulty in sourcing affordable CFC-free inhalers could potentially access them through 

the Asthma Drug Facility (an independent non-profit organisation managed by the 

International Union against Tuberculosis and Lung Disease www.globaladf.org). 

Taking these issues into consideration, beta-agonist and inhaled corticosteroid CFC MDIs can 

now be considered non-essential in many developing countries because the previous 

conditions for non-essentiality stated by MTOC in 2009 have been met: 

• There are several CFC-free therapeutically equivalent products; and 

• The price difference between CFC and CFC-free therapeutic equivalent alternatives is 

narrow. 

There are some Parties where beta-agonist and/or inhaled corticosteroid CFC MDIs may still 

be needed for use in their own countries in 2011: Argentina, China, Iran, Pakistan and the 

Russian Federation. CFCs for MDIs in these therapeutic categories are recommended for 

these markets for 2011 while the conversion to CFC-free alternatives is underway and HFC 

MDI capacity is increasing. 

It is technically difficult to formulate anti-cholinergic drugs, such as ipratropium bromide and 

tiotropium bromide, as HFC MDIs and only a limited range of CFC-free inhalers are currently 

available. New CFC-free inhalers (DPIs and HFC MDIs manufactured in both non-Article 5 

and Article 5 Parties) for tiotropium and ipratropium (and combinations with other moieties) 

are beginning to become available. However MTOC does not yet believe they provide an 

adequate range of CFC-free alternatives to consider the CFC MDIs for these drugs to be nonessential. MTOC has recommended the nominated quantities for ipratropium and tiotropium 

and their combinations to markets where they were considered essential for 2011 because of 

uncertainty about the range of available alternatives and the current capacity of the 

manufacture of these products. MTOC will revisit the developments in anti-cholinergic drug 

availability in 2011, as reformulation and marketing of CFC-free alternatives progress. 

In those countries where the MLF is funding phase-out projects for different companies, it is 

likely that the previously stated conditions for non-essentiality could be met before all the 

projects have been completed. Therefore essentiality should not be linked necessarily to the 

completion of all phase-out projects, but rather to the satisfaction of essential use criteria. 

Some companies have been successful in transition. Market leaders in HFC MDIs ought not 

be penalised for fast transition by competing against lower priced CFC MDIs in the same 

markets. These circumstances also arose in non-Article 5 Parties, and this was an important 

factor in delaying salbutamol CFC MDI transition in some countries. 

Furthermore, the concept of therapeutic equivalence (such as within the group of inhaled 

corticosteroids where one corticosteroid has similar therapeutic benefits to another) implies 

that not all moieties that were formulated as CFC MDIs need to be reformulated as HFC 

MDIs to complete the CFC phase-out. The experience with phase-out in non-Article 5 Parties 

shows that in some cases reformulation may not be commercially viable or technically 

possible, while in other cases it was possible to reformulate a moiety as a DPI, but not as an 

MDI. 
May 2010 TEAP Progress Report 7

Pricing policies, tariffs, import taxes and restrictions have been implemented by some Parties 

to protect local industry. These policies favour locally made pharmaceuticals, including CFC 

MDIs, and discourage use of imported pharmaceuticals, including CFC-free alternatives. 

Parties may wish to consider pricing policies that will expedite the rapid transition to CFCfree inhalers, with the priority of protecting the health of patients. 

Slow regulatory approvals processes have been cited as one reason for delays in the 

introduction of CFC-free alternatives. Given the phase-out of CFCs, Parties are encouraged 

to fast-track approvals of CFC-free alternatives. 

1.2.4 Exported products 

MTOC has noted previously the wide availability in Article 5 Parties of technically suitable 

alternatives to CFC MDIs from multinational companies. However, this has not prompted 

transition largely due to lack of affordability of these alternatives. Inhaler products sourced 

from manufacturers in Article 5 Parties are now substantially increasing the range of 

affordable alternatives. For example, Cipla, an Indian multinational pharmaceutical company, 

now markets 51 different CFC-free inhalers and has previously reported its commitment to 

phase out domestic supply of CFC MDIs by the end of 2009. 

Several of the nominations included significant CFC quantities to manufacture MDIs intended 

for export to other Article 5 Parties. None of the nominations adequately demonstrated that 

these CFC MDIs were essential in the intended export markets or demonstrated that importing 

Parties had provided their prior informed consent for the import of the CFC MDIs in 2011. 

MTOC does not have the information from importing Parties to substantiate that these uses 

are essential. Furthermore, it is not clear whether importing Parties are specifically requesting 

the continued import of CFC MDIs despite the alternatives available, whether they simply 

import the cheapest available product even if it contains CFCs, or whether they are unable to 

switch to alternatives because of a lack of regulatory approval of the alternatives. There is an 

opportunity for importing Parties to help to drive the global phase-out of CFCs through 

judicious sourcing of CFC-free alternatives. 

MTOC considers that there is an adequate range of technically satisfactory and affordable 

CFC-free alternatives for CFC MDIs for beta-agonists (in particular, salbutamol) and inhaled 

corticosteroids (in particular, beclomethasone) available in many developing countries. 

Argentina, China, Iran, Pakistan and the Russian Federation may need salbutamol and/or 

beclomethasone CFC MDIs in 2011 while the conversion to CFC-free alternatives is 

underway and HFC MDI capacity is increasing. However, MTOC is unable to recommend 

any of the CFC quantities nominated to manufacture MDIs for beta-agonists and inhaled 

corticosteroids intended for export. Some importing countries may still consider salbutamol 

and/or beclomethasone CFC MDIs essential in 2011, including through concern for poorer 

patients, but MTOC was not provided evidence to support this. Parties may wish to request 

importing countries to demonstrate essentiality. 

MTOC reviewed the available data about alternatives from the nominations and other sources, 

including a dataset supplied by IPAC. Decision XIV/5 requests each Party to submit 

available information on CFC and CFC-free MDIs and DPIs in their markets to the Ozone 

Secretariat by 28 February 2003 with annual updates thereafter, and requires TEAP to review 

this information in making its annual assessments. Some Parties have submitted data 

pursuant to Decision XIV/5 since its inception, but much of the data is up to 10 years old and 

no longer relevant to today’s market. It is important that Article 5 Parties collect their own 

data on CFC and CFC-free inhalers and provide it annually to the Secretariat by February 

each year to be posted on its website, in accordance with Decision XIV/5. The Ozone 
8 May 2010 TEAP Progress Report 

Secretariat will send a letter later this year to remind Parties of their obligation to report under 

Decision XIV/5. 

Decision XII/2(3) also requests Parties, including Article 5 Parties, to notify the Ozone 

Secretariat of any CFC MDI products determined to be non-essential, and for nominating 

Parties to take this information into consideration. The Ozone Secretariat website only has 

information pursuant to Decision XII/2(3) from the European Community. Parties may wish 

to consider the decision reminding all Parties to notify the Ozone Secretariat of any MDI 

products determined to be non-essential. Information posted on the Ozone Secretariat website 

can then be used by nominating Parties and MTOC in the essential use nomination process. 

Parties may wish to consider requesting nominating Parties to demonstrate that they have 

received informed consent of the government of any importing country for imports of CFC 

MDIs in any future nomination. 

1.2.5 Other Issues 

Decision XX/3 requests Parties to prepare preliminary plans of action by mid-2009 for the 

phase-out of salbutamol CFC MDIs. By March 2010, Argentina had not yet submitted its 

national strategy or preliminary plan of action. 

There are increasing numbers of combination products becoming available in Article 5 Party 

markets. In previous years, MTOC had indicated that it does not consider combination 

products to be essential where there are the same active ingredients available in the separate 

CFC-free inhalers. However, recent evidence has suggested that the combination of active 

ingredients in a single inhaler is beneficial, with improved compliance and clinical benefit, 

sometimes combined with a decrease in cost for patients compared to the drugs delivered in 

separate inhalers. As a result of this evidence, in 2009 for 2010 nominations, MTOC 

considered the CFCs requested for combination products with anti-cholinergics to be essential 

for the nominations received from Article 5 Parties. MTOC reconsidered, and reaffirmed this 

conclusion for nominations for 2011. MTOC is aware of several CFC-free combination 

products containing anti-cholinergics that have become available in Article 5 Parties. 

However, MTOC does not have sufficient information on price, availability, and 

manufacturing capacity to know whether the CFC MDI formulations are essential for 2011. 

MTOC will continue to review the essentiality of combination products against the 

availability of alternatives, including the relevant moieties in separate inhalers, and in future 

may not recommend them as essential. 

MTOC is unable to recommend as essential any new CFC MDIs not in the marketplace in 

2009. A ciclesonide CFC MDI (an inhaled steroid) is proceeding through regulatory approval 

processes in China, for which CFCs are requested in China's essential use nomination for 

2011. All inhaled steroids have very similar characteristics. MTOC does not believe that 

ciclesonide provides substantial additional health benefits. A new product in the approval 

process in 2009 and 2010, without significant additional health benefits, cannot be considered 

essential in 2011 under Decision IV/25. 

China is still in the early stages of transition from CFC MDIs. Research and development of 

HFC MDIs by local companies started in China in 2002. Salbutamol HFC MDI files were 

submitted in 2004 but production has not yet started. Imported HFC MDIs and DPIs are more 

expensive than locally manufactured CFC MDIs, which could explain the lack of market 

penetration of CFC-free MDIs. No inhalers from other Article 5 Parties have yet been 

approved for use in China. China’s transition strategy plans phase-out of salbutamol CFC 

MDI by the end of 2016 and of beclomethasone CFC MDIs and all other active ingredients by 

the end of 2017. During the MTOC meeting in Shanghai, presentations were made by the 

Chinese pharmaceutical-grade CFC propellant manufacturer, Juhua, and two major MDI 
May 2010 TEAP Progress Report 9

manufacturers, Jinweim and Nuokang. Jinweim and Nuokang indicated that they might be 

able to phase out salbutamol CFC MDIs earlier than scheduled in the national strategy, 

provided there is a favourable fast-track regulatory approval process. The marketing date for 

the first salbutamol HFC MDI product is likely to be achieved by the end of 2011. MTOC 

recommends that consideration be given to implementing fast track regulatory processes to 

expedite approvals of CFC-free alternatives. Juhua manufactures pharmaceutical-grade CFCs 

and HFCs for all Chinese MDI manufacturers. CFC batches are made in a swing plant 

operating for 20-30 days per year, and the company has capacity to store about 500 tonnes of 

CFCs. As the phase-out of CFC MDIs nears completion, the quantities of CFCs needed to 

supply MDIs in China may be small. In the last years of the phase-out, China may need a 

final campaign production to supply remaining CFC MDI manufacture, since it may not be 

cost-effective to make small CFC batches of less than 200 tonnes. Chinese MDI 

manufacturers should consider an accelerated phase-out, and this could protect the health of 

Chinese patients if CFC supplies become uncertain. 

1.2.6 Argentina 

Year Quantity nominated 

2011 120.2 tonnes 

Specific Use: MDIs for asthma and COPD 

Active ingredients and intended markets for which the nomination applies: 

Active Ingredients Intended markets 

Beclomethasone 

Fenoterol 

Ipratropium 

Salmeterol 

Argentina 

Budesonide 

Fluticasone 

Salbutamol 

Salbutamol/Beclomethasone 

Salbutamol/Ipratropium 

Salmeterol/Fluticasone 

Argentina, Chile, Paraguay, Peru 

Recommendation: 

Recommend 106.7 tonnes CFCs for MDIs for use in Argentina in 2011 for the active 

ingredients beclomethasone, budesonide, fenoterol, fluticasone, ipratropium, salbutamol, 

salbutamol/beclomethasone, salbutamol/ipratropium, salmeterol, salmeterol/fluticasone, and 

0.5 tonnes for intended use in Chile, Paraguay and Peru for salbutamol/ipratopium. 

Unable to recommend CFCs for MDIs for intended use in Chile, Paraguay and Peru for the 

active ingredients budesonide, fluticasone, salbutamol, salbutamol/beclomethasone, 

salmeterol/fluticasone. 

Comments 

The nomination from Argentina requests 120.2 tonnes of CFCs for MDIs. This is a 33 

percent reduction compared to the 2010 nomination. The nomination for the domestic market 

is 106.7 tonnes (15 percent reduction) and for intended export markets is 13.5 tonnes (74 
10 May 2010 TEAP Progress Report 

percent reduction). Almost 80 percent of the nomination is for salbutamol CFC MDIs (95.9 

tonnes). 

The quantities of CFCs requested appear to be consistent with historical trends for CFC MDI 

production in Argentina. The export of CFC MDIs is limited to three Latin American 

countries (Chile, Paraguay and Peru). Argentina contacted 13 export markets to ask whether 

there were any bans on the import of CFC MDIs, and was able to reduce the intended export 

markets to these 3 countries. However, no information was provided in the nomination on the 

alternatives available in those markets or their affordability. MTOC is aware of a range of 

affordable alternative CFC-free MDIs in these countries for budesonide, fluticasone, 

salbutamol, salbutamol/beclomethasone, salmeterol/fluticasone. MTOC is unable to 

recommend 13.0 tonnes for export to Chile, Paraguay and Peru for these active ingredients 

and combination products. MTOC has recommended approval of the nominated quantities 

intended for export of salbutamol/ipratropium CFC MDIs because anti-cholinergic drugs are 

technically more difficult to reformulate and only a limited range of CFC-free inhalers are 

currently available for this type of products. 

Active Ingredients Intended markets and nominated quantities 

Argentina Export Total 

Beclomethasone 0.5 0 0.5 

Budesonide 11.0 2.0 13.0 

Fenoterol 1.0 0 1.0 

Fluticasone 0.3 0.2 0.5 

Fluticasone/Salmeterol 1.2 0.3 1.5 

Ipratropium 1.0 0 1.0 

Salbutamol 85.9 10.0 95.9 

Salbutamol/Beclomethasone 2.3 0.5 2.8 

Salbutamol/Ipratropium 1.5 0.5 2.0 

Salmeterol 2.0 0 2.0 

Total 106.7 13.5 120.2 

MTOC understands that a national transition strategy is being developed through funding 

from the MLF, although it has not yet been submitted to the Ozone Secretariat. Neither has a 

preliminary plan of action for salbutamol CFC MDIs yet been submitted, which is contrary to 

Decision XV/5(4bis). An MLF-funded project has been approved for the conversion of the 

domestic inhaler manufacturers. The objectives of the project are: to eliminate the use of 

CFC at Pablo Cassara for the production of salbutamol CFC MDI; to eliminate the use of 

CFCs at Denver Farma for the production of salbutamol and budesonide; and to provide 

technical support for alternative formulations for four locally owned companies filling their 

own MDIs through third parties. Four MDI companies have signed preliminary agreements, 

but there is some delay for two other manufacturers. Pablo Cassara, which supplies 60-70 

percent of the market, are included in the MLF project that plans to phase out salbutamol CFC 

MDI by 2014 using isobutane as a propellant. Phoenix, Raffo, Roux-Ocefa and Dallas have 

established HFC projects and seven other companies have research underway. Two of the 

multinational companies committed to stop manufacturing CFC MDIs at the end of 2009. 

Current total installed capacity for salbutamol HFC MDIs is more than sufficient to meet 

demand. 

The MTOC considered the isobutane reformulation project. While an MDI formulated with 

isobutane propellant could be potentially beneficial in reducing greenhouse gas emissions due 

to HFC propelled MDIs, there has been no successful isobutane reformulation worldwide. 
May 2010 TEAP Progress Report 11

MTOC has identified toxicological concerns for isobutane in combination with a beta-agonist 

(Final report of the Safety Assessment of isobutane, isopentane, n-butane, and propane. Int. J. 

Toxicology, 1; 4: 127-142, 1982.). A safety study for an entirely novel MDI propellant in 

asthma COPD may require at least 12 months clinical trial experience in thousands of 

patients. This may be prohibitively expensive for this volume of production. Therefore 

MTOC has major concerns about the viability of this project, and its ability to provide a safe 

CFC MDI alternative in a timely fashion. In addition, a secure supply of pharmaceuticalgrade CFCs is increasingly unlikely in 2012 and beyond, which may not provide protection 

for Argentine patient health if conversion does not occur well before 2014. The company 

already has HFC reformulation expertise since it has marketed a combination 

salbutamol/beclomethasone (“Butocort”) product since July 2006. There would appear to be 

no technical barriers for this company to reformulate its salbutamol CFC MDIs with HFCs. 

Pablo Cassara should urgently consider a faster and already proven HFC reformulation route 

for salbutamol CFC-free MDIs. Next year, if progress in Pablo Cassara’s isobutane 

reformulation is not demonstrated or a switch to HFC reformulation had not commenced, 

MTOC may be unable to recommend CFCs for its salbutamol MDIs in any future nomination. 

MTOC has recommended the nomination for domestic use in 2011. While there is an 

adequate choice of CFC-free inhalers available in the domestic market, MTOC observes that 

the salbutamol HFC MDIs are more expensive than the salbutamol CFC MDIs made by Pablo 

Cassara. MTOC believes that adequate capacity to manufacture HFC MDIs will exist in 

Argentina but that post-marketing studies may yet be needed, meaning that the supply of CFC 

MDIs in 2011 will still be required. MTOC may be unable to recommend CFCs for use in 

salbutamol MDIs in 2012, in view of the availability of alternatives. Argentine patients 

would be best served by a rapid, safe transition to HFC MDIs. 

1.2.7 Bangladesh 

Year Quantity nominated 

2011 113.73 tonnes 

Specific Use: MDIs for asthma and COPD 

Active ingredients and intended markets for which the nomination applies: 

Active Ingredient Intended market Quantity (Tonnes)

Beclomethasone Bangladesh 8.89 

Ciclesonide Bangladesh 0.48 

Fluticasone/Salmeterol Bangladesh 9.78 

Ipratropium Bangladesh 1.34 

Ipratropium/ Salbutamol Bangladesh 25.32 

Levosalbutamol Bangladesh 0.87 

Salbutamol Bangladesh 65.32 

Salmeterol Bangladesh 1.10 

Tiotropium Bangladesh 0.63 

Total 113.73 

Recommendation: 

Recommend 38.65 tonnes of CFCs for MDIs for use in Bangladesh for ciclesonide, 

fluticasone/salmeterol, ipratropium, ipratropium/salbutamol, salmeterol and tiotropium. 
12 May 2010 TEAP Progress Report 

Unable to recommend CFCs for MDIs for active ingredients beclomethasone, levosalbutamol 

and salbutamol. 

Comments 

Bangladesh nominated a total of 113.73 tonnes of CFC for use in MDIs in 2011. The CFCs 

are for the manufacture of MDIs for domestic consumption only, as Bangladesh does not 

export CFC MDIs. There are multiple HFC alternatives on the market in Bangladesh for 

salbutamol and beclomethasone and there are single HFC or DPI alternatives for budesonide, 

fluticasone/salmeterol, ipratropium, ipratropium/salbutamol and salmeterol. There are as at 

yet no CFC-free alternatives for ciclesonide and tiotropium. Many of the CFC-free products 

are manufactured locally. 

Bangladesh developed a national transition strategy for phasing out the use of CFCs in MDI 

manufacture in Bangladesh in 2007. CFC-free MDIs have been introduced starting in 2006 

and it appears their adoption has continued to grow. Currently, three companies commenced 

manufacturing HFC-MDIs while two companies manufacture DPI inhalers. In general, the 

pricing of these alternatives is comparable to their CFC counterparts and this fact should help 

with continued uptake. 

In a 2010 update to its transition strategy, Bangladesh states that it will phase out CFC use 

completely by 2012, four years earlier than was originally proposed in last year’s nomination. 

This development has been aided by the UNDP funding of plant conversion projects which 

appears to have progressed well and accounted for availability of multiple HFC products (for 

salbutamol and beclomethasone) to meet domestic needs. Bangladesh is to be commended 

for being proactive and diligent in pursuing its transition strategy from CFC MDI products. 

In light of the availability of a number of alternatives for salbutamol and beclomethasone 

CFC MDIs, MTOC is unable to recommend CFC quantities for these products. Also, MTOC 

does not regard levosalbutamol (an isomer of salbutamol) as essential given the availability of 

multiple salbutamol products. Therefore MTOC recommends 38.65 tonnes of CFC needed 

for the manufacture of MDIs only for the active ingredients ciclesonide, 

fluticasone/salmeterol, ipratropium, ipratropium/salbutamol, salmeterol and tiotropium. 

MTOC believes that continued manufacture of CFC products beyond 2010 for products for 

which multiple HFC or DPI alternatives already exist will compete with the CFC-free 

alternatives and slow down the transition. Bangladesh is encouraged to continue to pursue its 

transition to CFC-free alternatives for all its asthma and COPD products so that no further 

nomination for CFCs beyond 2011 will be necessary. 

1.2.8 People's Republic of China 

Year Quantity nominated 

2011 809.91 tonnes 

Specific Use: MDIs for asthma and COPD, and acute pulmonary oedema. 
May 2010 TEAP Progress Report 13

Active ingredients and intended markets for which the nomination applies: 

Active Ingredients Intended markets 

Beclomethasone Burma, Cambodia, Chile, China, Dominica, 

Ethiopia, Fiji, Kenya, Mali, Mexico, 

Moldova, Mozambique, New Guinea, 

Nigeria, Pakistan, Peru, Sierra Leone, Sri 

Lanka, Sudan, Suriname, Turkmenistan, 

Uzbekistan, Vietnam and Yemen. 

Beclomethasone/clenbuterol/ 

ipratropium 

China 

Budesonide China 

Ciclesonide China 

Cromoglycate China 

Datura metel extract/clenbuterol China 

Dimethicone China 

Ephedra, Ginkgo, Sophora 

Favescens and Radix Scutellariae 

China 

Ipratropium China 

Ipratropium/Salbutamol China 

Isoprenaline China 

Isoprenaline/Guaifenesin China 

Procaterol China 

Salbutamol Burma, Cambodia, Chile, China, Dominica, 

Ethiopia, Fiji, Kenya, Mali, Mexico, 

Moldova, Mozambique, New Guinea, 

Nigeria, Pakistan, Peru, Sierra Leone, Sri 

Lanka, Sudan, Suriname, Turkmenistan, 

Uzbekistan, Vietnam and Yemen. 

Salmeterol China 

Recommendation: 

Recommend 741.15 tonnes CFCs for MDIs intended for China for the active ingredients 

beclomethasone, beclomethasone/clenbuterol/ipratropium, budesonide, datura metel 

extract/clenbuterol, dimethicone; ephedra, ginkgo, sophora favescens and radix scutellariae; 

ipratropium, ipratropium/salbutamol, isoprenaline, isoprenaline/guaifenesin, procaterol, 

salbutamol, salmeterol, cromoglycate. 

Unable to recommend 62.71 tonnes CFCs for MDIs intended for export to Burma, Cambodia, 

Chile, Dominica, Ethiopia, Fiji, Kenya, Mali, Mexico, Moldova, Mozambique, New Guinea, 

Nigeria, Pakistan, Peru, Sierra Leone, Sudan, Suriname, Turkmenistan, Uzbekistan, Vietnam, 

Yemen for the active ingredients salbutamol and beclomethasone, and 6.051 tonnes CFCs for 

MDIs intended for China for the active ingredient ciclesonide. 
14 May 2010 TEAP Progress Report 

Comments 

The People’s Republic of China nominates 747.20 tonnes for domestic market use and 62.71 

tonnes for export to a number of countries. The nomination states that of the 809.91 tonnes 

requested, 686.19 tonnes are for two active ingredients, salbutamol (589.38 tonnes) and 

beclomethasone (96.81 tonnes). The estimated consumption of CFCs during 2010 is reported 

to be about 300 tonnes less than the quantity of 972.2 tonnes that was approved for 2010. 

About 8 percent of the requested CFC quantity is for the manufacture of MDIs intended for 

export, only for salbutamol and beclomethasone. 

The transition strategy has been formulated and submitted to the Ozone Secretariat. There is 

an approved MLF project for CFC phase-out in China’s MDI sector, which is due for 

completion in 2015. The first product planned for phase out is salbutamol, which will 

officially begin on December 31, 2013 and be completed by December 31, 2015. The 

strategy anticipates that CFC MDIs will co-exist on the market with HFC MDIs for a period 

of one year. Consequently, phase-out of salbutamol CFC MDIs will be completed by 

December 31, 2016. Consumption of CFCs for salbutamol MDIs represents about 73 percent 

of the total CFC quantity requested. The second largest quantity requested (accounting for 

another 12 percent) is for beclomethasone, which will no longer be essential when two CFCfree alternatives are available from two different producers. Phase-out of beclomethasone 

will officially begin on December 31, 2014 and be completed by December 31, 2017. The 

remaining active ingredients will be phased out during this period. 

MTOC notes that research and development of HFC MDIs by local companies started in 

China in 2002. Salbutamol HFC MDI files were submitted in 2004 but production has not yet 

started. The nomination states that drug regulatory approvals can take many years. The 

marketing date for the first salbutamol HFC MDI product is likely to be achieved by the end 

of 2011. MTOC recommends that consideration be given to implementing fast track 

regulatory processes to expedite approvals. At least one imported salbutamol HFC MDI 

manufactured by a multinational is already on sale in China, which could provide clinical 

experience that might allow an expedited process for those drug products. 

There are imported HFC MDIs (e.g. salbutamol) and DPIs (e.g. formoterol and budesonide) 

available. The current retail prices of locally produced CFC MDIs are considerably cheaper 

than the prices of imported CFC-free inhalers (MDIs or DPIs). Therefore pricing is an 

important reason for the lack of market penetration of imported CFC-free inhalers in China, 

and therefore, government pricing policies could be reviewed to consider pricing for local and 

imported inhalers that do not discourage CFC-free inhalers. 

Between 2004 and 2009, CFC consumption for MDI manufacture had an annual growth rate 

of up to 24 percent. Because of the impact of the recent international financial crisis, the 

nomination for 2011 (taking into consideration that CFC consumption is estimated to be about 

300 tonnes less than the approved amount for 2010) reflects the predicted same growth rate 

per year from 2009. This is justified by China as an increasing number of patients are treated 

with CFC MDI therapy. It reflects the reform and enlargement of medical insurance, basic 

medicine and the special support for chronic diseases including asthma and COPD. 

No specific data were provided in the nomination on pre- and post- 2010 stocks of CFCs held 

by companies. These data would be included in the accounting framework next year. 

According to the submission from China, there will be a license management process in place 

for the Government to control production and consumption of CFCs on an annual basis, and 

manage surplus CFCs. MTOC understands that currently there may be significant stocks of 

bulk CFC in China. Paragraph 3 of Decision XVI/12 calls on nominating Parties to take into 

consideration existing stocks of banked controlled substances, when preparing essential use 

nominations, with the objective of maintaining no more than one year's operational supply. 
May 2010 TEAP Progress Report 15

MTOC will consider this when reviewing accounting frameworks received in 2012. With 

diminishing demand for CFCs in the future, careful management of the stockpile will be 

needed to keep it within the one-year level and to avoid CFC destruction at the completion of 

phase-out. 

For traditional Chinese medicines, the Chinese Government will organize re-evaluation and 

substitution studies. If re-evaluation considers these as non-essential or ready for complete 

substitution, they will not be included in future EUN applications. MTOC requests 

information from the outcomes of this re-evaluation to be provided in any nomination 

submitted for 2012. 

As with the nomination for 2010, the CFC quantity to manufacture ciclesonide MDIs cannot 

be recommended for 2011 because the product has not been launched and is still under 

regulatory review in 2010. 

The nominated quantities of CFCs for essential uses in domestic and export markets for the 

nominated active ingredients in 2011 (metric tonnes) are: 

Active Ingredients China Export Total 

Beclomethasone 82.06 14.75 96.81 

Beclomethasone/clenbuterol/ipratropium 0.8 0 0.8 

Budesonide 5.996 0 5.996 

Ciclesonide 6.051 0 6.051 

Cromoglycate 14.01 0 14.01 

Datura metel extract/clenbuterol 2.5 0 2.5 

Dimethicone 0.21 0 0.21 

Ephedra, ginkgo, sophora flavescens, radix 

scutellariae 

15 0 15 

Ipratropium 9.3 0 9.3 

Ipratropium /salbutamol 1.3 0 1.3 

Isoprenaline 61.5 0 61.5 

Isoprenaline/guaifenesin 3.3 0 3.3 

Procaterol 3.5 0 3.5 

Salbutamol 541.42 47.96 589.38 

Salmeterol 0.25 0 0.25 

Total 747.2 62.71 809.91 

MTOC believes that continued manufacture and export by China of CFC-containing 

salbutamol and beclomethasone MDIs to countries that already have a number of suitable 

CFC-free alternatives may not be essential. Therefore, MTOC is unable to recommend 62.71 

tonnes of CFCs for MDIs intended for export to Burma, Cambodia, Chile, Dominica, 

Ethiopia, Fiji, Kenya, Mali, Mexico, Moldova, Mozambique, New Guinea, Nigeria, Pakistan, 

Peru, Sierra Leone, Sudan, Suriname, Turkmenistan, Uzbekistan, Vietnam, Yemen for the 

active ingredients salbutamol and beclomethasone. 

1.2.9 India 

Year Quantity nominated

2011 192.3 tonnes 
16 May 2010 TEAP Progress Report 

Specific Use: MDIs for asthma and COPD 

Active ingredients and intended markets for which the nomination applies: 

Active Ingredients Intended Markets 

Beclomethasone Algeria, Bahrain, Bolivia, Brazil, Brunei, Colombia, Ethiopia, 

Guatemala, Guyana, Hong Kong, India, Iran, Iraq, Jamaica, 

Kenya, Libya, Madagascar, Malaysia, Maldives, Mexico, Oman, 

Palestine, Puerto Rico, Peru, Sri Lanka, Suriname, U.A.E., 

Uganda, Venezuela, West Indies, Yemen, Zaire 

Beclomethasone/ 

Formoterol 

India 

Beclomethasone/ 

Salbutamol 

Benin, Bolivia, Brazil, Chile, Colombia, India, Jamaica, Libya, 

Peru, Singapore, Somaliland, Venezuela, West Indies, Yemen, 

Zambia 

Budesonide Algeria, Benin, Chile, Colombia, India, Kenya, Mauritius, Peru, 

Sri Lanka, Tanzania, Thailand, U.A.E., Yemen 

Budesonide/ 

Formoterol 

Bolivia, India, Kenya, Libya, Mauritius, Sri Lanka, U.A.E. 

Fluticasone Chile, Colombia, Guatemala, India, Iran, Libya, Oman, Peru, Sri 

Lanka, U.A.E 

Formoterol Guatemala, India, Jordan, Puerto Rico, U.A.E., Venezuela 

Formoterol/ 

Fluticasone 

India 

Ipratropium Colombia, India, Iran, Jamaica, Panama, Peru, Singapore, South 

Africa, Sri Lanka, Suriname, U.A.E., Uganda 

Ipratropium/ 

Salbutamol 

Colombia, India, Iran, Peru, Philippines, U.A.E., Venezuela 

Levasalbutamol India, Peru 

Salbutamol Algeria, Benin, Bolivia, Brazil, Burkina Faso, Burundi, 

Cameroon, Chile, Colombia, Costa Rica, Ethiopia, Guatemala, 

Guyana, India, Jamaica, Jordan, Kenya, Liberia, Libya, Macau, 

Madagascar, Malaysia, Malawi, Mali, Mauritius, Mexico, 

Mozambique, Myanmar, Nigeria, Oman, Peru, Puerto Rico, 

Republic of Congo, Sri Lanka, Singapore, U.A.E., Venezuela, 

West Indies, Yemen, Zambia 

Salmeterol India, Oman, Sri Lanka, U.A.E., Yemen 

Salmeterol/ 

Fluticasone 

Chile, Guatemala, India, Kenya, Mauritius, Morocco, Peru, Sri 

Lanka, U.A.E. 

Tiotropium Colombia, India, Panama, Peru, Puerto Rico, Sri Lanka 

Tiotropium/ 

Formoterol 

Colombia, India, Panama, Peru, Puerto Rico, Sri Lanka 

Recommendation: 

Recommend 19.8 tonnes CFCs for MDIs for intended use in India for the active ingredients 

ipratropium, ipratropium/salbutamol, tiotropium bromide and tiotropium/formoterol. 
May 2010 TEAP Progress Report 17

Recommend 28.4 tonnes for intended use in Colombia, Jamaica, Panama, Peru, Sri Lanka, 

Suriname, U.A.E., Uganda, Venezuela for the active ingredients ipratropium, 

ipratropium/salbutamol, tiotropium bromide and tiotropium/formoterol. 

Unable to recommend CFCs for MDIs for intended use in India and for intended use in export 

markets for the active ingredients beclomethasone, beclomethasone/salbutamol, 

beclomethasone/formoterol, budesonide, budesonide/formoterol, fluticasone, formoterol, 

formoterol fumarate/fluticasone, levasalbutamol, salbutamol, salmeterol, 

salmeterol/fluticasone. 

Unable to recommend CFCs for MDIs for intended use in Iran, Philippines, Puerto Rico, 

Singapore, South Africa for ipratropium, ipratropium/salbutamol, tiotropium bromide and 

tiotropium/formoterol. 

Comments 

The Indian nomination requests 192.3 tonnes of CFCs for MDIs. Of this, 58.5 tonnes are for 

domestic use and 133.9 tonnes are for CFC MDI products intended for export to other Article 

5 Parties. The nomination states that remaining stocks of bulk CFC will be exhausted by the 

end of 2010. The total nominated amount was for eight active ingredients in a total of sixteen 

products (alone or in combination). The nomination for 2011 represents a 33 percent 

reduction in domestic use and a 48 percent reduction in exports compared with the 

nomination for 2010. 

The date for complete transition of all CFC products is now stated by India to be 2013, rather 

than 2012 as indicated in the National Transition Strategy submitted to the 56th Executive 

Committee. MTOC notes that the strategy aims to reformulate all existing CFC MDIs. 

However, some CFC MDIs may not be considered essential due to the available range of 

alternative CFC-free inhalers within each therapeutic category, and some may have ongoing 

technical difficulty in formulation. 

The nomination notes that the use of MDIs in India continues to grow at 15 percent per 

annum. MTOC notes that one company (Cipla) produces 51 different CFC-free inhalers and 

has previously reported its commitment to phase out domestic supply of CFC MDIs by the 

end of 2009. There are also at least two other manufacturers of HFC MDIs in India. In 

addition, there is a wide range of available single- and multi-dose DPIs. The nomination 

claims that DPIs have a number of drawbacks and affordability of HFC MDIs and multi-dose 

DPIs remains an issue. However, a recent market research study by Bhome in 20093

suggested that both HFC MDIs and DPIs were considered affordable and equally effective by 

a sample of 150 patients in India. 

Last year, MTOC expressed the view that the recommended and subsequently exempted 

amount of CFCs for India for 2010 would be sufficient to support Indian CFC MDI 

manufacturers that had not yet launched CFC-free alternatives. Taken together with the 

market research, and the wide range of CFC-free alternatives available for beta-agonists and 

inhaled corticosteroids, MTOC is unable to recommend the nominated CFCs for MDIs 

intended for India for the active ingredients listed above. However, MTOC considers that 

anti-cholinergics, ipratropium, ipratropium/salbutamol and tiotropium, either alone or in 

combination with formoterol, are the only products for which there could be insufficient CFCfree alternatives and does not yet consider the CFC MDIs for these drugs to be non-essential. 

 

3 “Drug delivery systems and customer perceptions; an Indian viewpoint”, in Drug Delivery to the Lungs 20, The 

Aerosol Society, Portishead, United Kingdom, pp 30-33 (not peer-reviewed). 
18 May 2010 TEAP Progress Report 

Therefore, this is the only part of the nomination for domestic use that MTOC recommends 

(19.8 tonnes). New CFC-free inhalers (manufactured in both non-Article 5 and Article 5 

Parties) for tiotropium and ipratropium (and combinations with other moieties) are beginning 

to become available. MTOC will revisit the developments in anti-cholinergic drug 

availability in 2011. Without adequate information in any future nominations to demonstrate 

essentiality, MTOC may not be able to recommend CFCs for these drugs. 

Although the nominated quantity for export is substantially less than for 2010, the nomination 

contains no information on the essentiality of the products intended for export to those 

specific markets. Furthermore, there are several inconsistencies in the nomination: 

Several countries identified as intended export markets (Iran, Philippines, Puerto Rico, 

Singapore, South Africa and Thailand) have prohibited the import of CFC MDIs. 

A volume was nominated for export of CFC-based sodium cromoglycate without identifying 

the intended market(s). 

For formoterol and salmeterol, intended export markets were identified but without any 

nominated CFC quantity. 

The West Indies is identified as an Article 5 Party, which it is not. 

MTOC is concerned about the proposed export of CFC MDIs to Parties that have a number of 

technically suitable and affordable CFC-free alternatives. Some Indian companies with HFC 

MDIs and/or DPIs for salbutamol or beclomethasone launched on the domestic market are 

simultaneously planning to export the equivalent CFC MDI to importing countries. However, 

MTOC recognises that for ipratropium, ipratropium/salbutamol and tiotropium, some CFCfree alternatives have only recently introduced in India, and may not yet be registered with 

importing Parties. 

In light of the above, MTOC is unable to recommend CFCs for MDIs to be exported from 

India, for all but the anti-cholinergics, ipratropium, ipratropium/salbutamol and tiotropium, 

alone and in combination with formoterol to Colombia, Jamaica, Panama, Peru, Sri Lanka, 

Suriname, U.A.E., Uganda, Venezuela. However, for these anti-cholinergics, MTOC was 

unable to recommend CFCs for MDIs intended for export markets known to prohibit the 

import of CFC MDIs, specifically Iran, Philippines, Puerto Rico, Singapore and South Africa. 

India did not provide a breakdown of nominated quantities for each intended export market so 

it was not possible for MTOC to deduct the quantities of CFCs for these countries for these 

active ingredients. In 2009, MTOC concluded that in future years, in the absence of countryspecific information, it would consider the alternatives available in intended export markets 

and make recommendations for a quantity of essential use CFCs for the manufacture of MDIs 

which specifically excluded any countries considered to have an adequate range of 

alternatives. In the absence of country-specific information from India, MTOC has therefore 

made its recommendation for 28.4 tonnes, which specifically excludes Iran, Philippines, 

Puerto Rico, Singapore and South Africa. Therefore India will not need the entire 28.4 

tonnes, which was requested by India for anti-cholinergics for all intended export countries: 

the quantity is only recommended as an upper limit in the absence of better information. 

Parties may wish to request that additional information be provided by India in time for the 

22nd MOP when considering essential use authorisations to adjust the quantities to meet the 

needs of only Colombia, Jamaica, Panama, Peru, Sri Lanka, Suriname, U.A.E., Uganda, 

Venezuela, assuming these Parties indeed require anti-cholinergic CFC MDIs. 
May 2010 TEAP Progress Report 19

MTOC would expect progress in registration of CFC-free alternatives during 2010, and would 

require evidence of essentiality in importing countries to recommend as essential uses any 

CFCs intended for anti-cholinergics, and their combinations, next year. 

Intended markets and nominated 

quantities 

Active Ingredients 

India Export Total 

Beclomethasone 3.3 33.0 36.3 

Beclomethasone/Formoterol 1.6 0 1.6 

Beclomethasone/Salbutamol 6.4 9.0 15.4 

Budesonide 4.0 4.6 8.6 

Budesonide/Formoterol 5.8 1.6 7.4 

Fluticasone 0 3.0 3.0 

Fluticasone/Salmeterol 5.7 9.0 14.7 

Formoterol 1.0 0 1.0 

Formoterol/Tiotropium 2.0 0 2.0 

Ipratropium 6.5 22.0 28.5 

Ipratropium/Salbutamol 7.3 5.6 12.9 

Levosalbutamol 3.0 0 3.0 

Salbutamol 7.2 45.2 52.4 

Salmeterol 0.7 0 0.7 

Tiotropium 4.0 0.8 4.8 

Total 58.5 133.9 192.3 

1.2.10 Iran 

Year Quantity nominated 

2011 105 tonnes 

Specific Use: MDIs for asthma and COPD 

Active ingredients and nominated quantities for which the nomination applies: 

Active Ingredients Intended market Quantity (Tonnes) 

Beclomethasone Iran 14 

Cromoglycate Iran 5 

Salbutamol Iran 75.5 

Salmeterol Iran 10.5 

Total 105 

Recommendation: 

Recommend 105 tonnes CFCs for MDIs for intended use in Iran for active ingredients 

beclomethasone, salbutamol, salmeterol, cromoglycate. 
20 May 2010 TEAP Progress Report 

Comments 

Iran’s nominated quantities for 2011 are identical to that exempted for 2010. Iran is awaiting 

regulatory approval for HFC inhalers for salbutamol and beclomethasone. Salmeterol HFC 

MDI is due for submission to regulatory authorities in late April 2010. MTOC recommends 

the nomination to allow Iran to procure CFCs should there be any unforeseen delays in HFC 

MDI launch. MTOC notes that Iran may not need to acquire any CFCs approved by Parties 

under an exemption for 2011, or may not need to acquire the entire amount, if the production 

of HFC inhalers proceeds as scheduled. 

1.2.11 Pakistan 

Year Quantity nominated 

2011 39.6 tonnes 

Specific Use: MDIs for asthma and COPD 

Active ingredients and intended markets for which the nomination applies: 

Active Ingredient Intended Market Quantity (Tonnes) 

Beclomethasone Pakistan 4.5 

Beclomethasone/Salbutamol Pakistan 19.3 

Fluticasone/Salmeterol Pakistan 6.2 

Ipratropium Pakistan 0.5 

Salbutamol Pakistan 8.8 

Salmeterol Pakistan 0.2 

Triamcinolone Pakistan 0.1 

Total 39.6 

Recommendation: Recommend 39.6 tonnes CFCs for MDIs for intended use in Pakistan for 

the active ingredients beclomethasone, beclomethasone/salbutamol, fluticasone/salmeterol, 

ipratropium, salbutamol, salmeterol, triamcinolone. 

Comments 

Ipratropium, salmeterol and triamcinolone are included in the 2011 nomination when they 

were not included in the nomination for 2010. While the nomination made no explanation for 

this, MTOC notes that the Annex to Executive Committee document 

UNEP/OzL.Pro/ExCom/54/19 refers to these active ingredients being produced as CFC MDIs 

in Pakistan in 2008. All of the products are for domestic use and not for export. 

In Pakistan there are three local CFC MDI manufacturers: Macter, Zafa and GSK Pakistan. 

The majority of CFC MDIs manufactured in Pakistan was by GSK Pakistan as salbutamol 

until the company committed to stop all CFC MDI manufacture at the end of 2009. GSK 

Pakistan also imports HFC MDIs. The halt in manufacturing at GSK Pakistan has resulted in 

a substantial drop in Pakistan’s nomination for 2011. GSK Pakistan launched an imported 

salbutamol HFC inhaler (Aerolin) in 2007. A range of other CFC-free products is also 

available in Pakistan. 
May 2010 TEAP Progress Report 21

Macter, now the major user of CFCs for MDIs in Pakistan, continues to manufacture a range 

of CFC MDIs products including salmeterol and fluticasone. MTOC notes that Macter has 

more than doubled its CFC consumption for salbutamol MDIs since 2008. 

A national transition strategy for the phase-out of CFCs in MDIs for Pakistan was submitted 

in July 2008. It describes the baseline data of current manufacturing capability and outlines 

plans for the conversion of MDI production, the projected costs and planned timelines. The 

investment in the MLF project is for education and awareness as well as legislative and 

regulatory measures. The 2008 national phase-out strategy anticipates complete transition by 

the end of 2012. 

If the GSK Pakistan conversion is delayed, there could be insufficient capacity from the other 

two companies to supply the Pakistan market with affordable salbutamol CFC MDIs. The 

2011 nomination states that in case of any delay in the GSK Pakistan conversion project, the 

only substitute for the locally manufactured CFC MDIs will be imported HFC MDIs. The 

prices of these imported products are currently considerably higher than locally produced 

CFC MDIs. For example, the price of locally made CFC MDI has remained close to Pakistan 

Rupees 85 (almost US$1) per inhaler. Imported HFC MDIs range between Rupees 600 –

1000 (about US$7–10) per inhaler. The high price of imported salbutamol HFC MDIs may 

significantly limit patient access to this therapy. The Government of Pakistan may need to 

carefully manage the price of imported salbutamol HFC MDIs to ensure affordability and 

accessibility of these products. 

Furthermore, as the world’s pharmaceutical-grade CFC supply is decreasing and becoming 

more uncertain, the price of CFCs has increased. Before the Pakistan conversion process 

started, CFCs were available at the rate of $4-4.5 per kilogram. Recent information from the 

Government of Pakistan indicates that the price of CFCs has increased 3-4 fold. This would 

significantly increase the cost of CFC MDI production and may narrow the price gap between 

imported HFC MDI and domestic CFC MDI products. 

Due to the uncertainty in the short-term supply of affordable MDIs in Pakistan while GSK 

Pakistan completes conversion, MTOC recommends the nomination for 2011. 

1.2.12 Russian Federation 

Year Quantity nominated 

2011 248.0 tonnes 

Specific Use: MDIs for asthma and COPD 

Active ingredients and intended markets for which the nomination applies: 

Active Ingredient Intended market Quantity (Tonnes) 

Salbutamol Russian Federation 248.0 

Recommendation: 

Recommend 212 tonnes CFCs for MDIs for intended use in the Russian Federation for the 

active ingredient salbutamol. 

Comments 

The Russian Federation nomination requests 248 tonnes for domestic use only for the 

manufacture of salbutamol CFC MDIs by two manufacturers. This nomination represents a 
22 May 2010 TEAP Progress Report 

17 percent increase over the exempted quantity for 2010. The Russian Federation does not 

expect to have any domestic manufacture of CFC-free salbutamol inhalers in 2011; the 

majority of patients will continue to use domestically made CFC MDIs. 

The manufacturing conversion from salbutamol CFC MDIs has been repeatedly delayed in 

the Russian Federation due mainly to a lack of finance. The TEAP/MTOC mission on “Issues 

affecting the Transition from CFC metered dose inhalers in the Russian Federation” has 

reported on these issues in more detail under its response to DecisionXXI/4(8) in Chapter 3. 

GEF funding is currently being investigated and the Russian Federation has stated that if this 

funding becomes available phase-out could be achieved by the end of 2012. 

MTOC requests evidence of substantial progress with the conversion projects for its 

consideration of any future essential use nomination. This includes demonstration of funding 

commitment, installation of filling lines, and HFC product registration with the health 

authorities. During the recent TEAP/MTOC mission, the Russian Federation authorities 

recognized the necessity of accelerating the conversion process. They proposed the 

establishment of a Working Group, chaired by the Ministry of Health, with members from 

government and industry, to facilitate progress and provide MTOC with quarterly updates on 

the progress of the conversion to CFC-free alternatives. MTOC understands that the first 

meeting of this Working Group took place prior to this report. MTOC welcomes this new 

development, and the urgency with which the Russian Federation is meeting this challenge. 

However, there is a range of imported CFC-free short-acting beta-agonists (SABAs), 

predominantly salbutamol HFC MDIs, on the market. According to IMS data4

, some of these 

are available at inhaler prices comparable to the domestically manufactured CFC MDIs. The 

average price per inhaler for the salbutamol HFC MDI from Cipla, India, is 3.04 USD (200 

doses) compared with the average price per inhaler for the Russian-made salbutamol CFC 

MDIs of 2.89 USD (90 doses). However, these affordable CFC-free MDIs do not appear to 

be widely available in pharmacies. The price per dose for imported SABA HFC MDIs ranges 

from 0.015 to 0.051 USD, while the price per dose for domestically manufactured salbutamol 

CFC MDI is 0.032 USD. A more detailed account of inhaler prices is given in Chapter 3. 

Consumption of CFCs to manufacture salbutamol MDIs in the Russian Federation has 

remained steady at about 240 tonnes for 2007-2009. Parties approved an exemption for 212 

tonnes for the Russian Federation for the year 2010. For 2011, MTOC again recommends 

212 tonnes of CFCs, instead of the nominated 248 tonnes requested to supply an anticipated 

increase in demand for salbutamol MDIs. MTOC believes that available imported HFC MDIs 

could meet any increased demand for salbutamol MDIs in 2011. If Parties approve an 

essential use exemption for 2011, this would give time for the proposed manufacturing 

transition to be achieved or, if funding is not approved during 2010, there would be time for 

imported CFC-free inhalers to increase their market share by the necessary factor of 4 (from 

25 to 100 percent of the market) to provide adequate CFC-free alternatives by the start of 

2012. Without demonstrated progress in manufacturing transition, MTOC may not be able to 

recommend any future essential use nomination. 

 

4 IMS Health is an international company that supplies the pharmaceutical industry with sales data.
May 2010 TEAP Progress Report 23

2 Medical Technical Options Committee Progress Report 

2.1 Executive Summary 

The Medical Technical Options Committee (MTOC) thanks the Shanghai Institute of 

Pharmaceutical Industry (SIPI) and the Ozone Secretariat for providing meeting venue 

sponsorship for the MTOC meeting held in Shanghai, China, 21-25 March 2010. SIPI 

provided a range of on-ground organisational assistance and in-kind support, such as printing. 

MTOC accepted hospitality including transportation, guides, meals and beverages. 

The global use of CFCs to manufacture MDIs in 2009 is estimated to be about 2,300 tonnes. 

Article 5 Parties used about 1,700 tonnes and the Russian Federation and the United States 

used about 580 tonnes of CFCs for the manufacture of MDIs in 2009. 

Parties reported that there are about 1,017 tonnes of pharmaceutical-grade CFCs available in 

stockpiles in the United States and Venezuela (total of about 951 tonnes of CFC-11 and -12, 

with 367 tonnes of CFC-114 that may not be consumed since it is less commonly used in 

MDI formulations). Stockpiles are available for export under commercial agreement with 

holders of those stocks. 

Production of pharmaceutical-grade CFCs is now limited to a few sources. Honeywell, in the 

United States, has a swing plant producing HCFC-22 that can also produce CFCs. However, 

regulatory processes to allow export of newly produced CFCs would likely take more than a 

year to complete. The 60th Executive Committee Meeting, April 12-15, 2010, decided to 

modify the production sector agreements for China and India to allow the production for 

export of pharmaceutical-grade CFCs for 2010, with an annual review, for purposes of 

meeting essential use requirements of other countries provided that the exporting countries 

had specified reporting and verification systems in place. Any new source of supply of CFCs 

will require that CFC MDI producers validate the suitability of the newly sourced propellant 

in each specific MDI product. 

CFC stockpiles available in Venezuela and the United States may or may not be enough to 

cover estimated CFC requirements for MDIs for 2010, 2011 and 2012 (about 1,397 tonnes) 

excluding China, the Russian Federation and the United States. This depends on, inter alia, 

Parties’ decisions regarding essential use exemptions for 2011, whether stockpile is acquired 

under commercial arrangements, and also whether the CFC mix and specifications of the 

stockpile meets the needs of the MDI manufacturers. However, it could be possible to 

complete the phase-out of CFC MDIs with careful management of existing global CFC 

stockpiles, provided manufacture of pharmaceutical-grade CFCs in China continues to supply 

its own needs and those of the Russian Federation. 

A cautious approach to CFC production is advisable since transition is moving quickly and 

Parties may wish to avoid CFC production that is surplus to actual needs, which subsequently 

would require costly destruction. The welfare of patients with asthma and COPD and of the 

environment would be best served by a rapid transition to CFC-free inhalers. 

Technically satisfactory alternatives to CFC MDIs to treat asthma and COPD are available in 

almost all countries worldwide. MTOC has noted previously the wide availability in Article 5 

Parties of technically suitable CFC-free alternatives to CFC MDIs manufactured by 

multinational companies in developed countries. CFC-free inhalers manufactured in 

developing countries are now substantially increasing the range of affordable alternatives. 
24 May 2010 TEAP Progress Report 

2.2 Global use of CFCs for MDIs 

The global use of CFCs to manufacture MDIs in 2009 is estimated to be about 2,300 tonnes. 

Article 5 Parties used about 1,700 tonnes and the Russian Federation and the United States 

used about 580 tonnes of CFCs for the manufacture of MDIs in 2009. The total use of CFCs 

by Article 5 Parties reduced by about 200 tonnes between 2008 and 2009, with some 

countries increasing (e.g. China) and others decreasing (e.g. India) consumption. There has 

been significant global progress in the transition of CFC MDIs to CFC-free inhalers, with 

substantial capacity to manufacture CFC-free inhalers expected by 2011-2012. 

Decision XXI/4 encouraged Parties with stockpiles of pharmaceutical-grade CFCs potentially 

available for export to notify the Ozone Secretariat by 31st December 2009. As a result of this 

request, Parties reported that there are about 1,017 tonnes of pharmaceutical-grade CFCs 

(about 225 tonnes CFC-11, 425 tonnes CFC-12, 367 tonnes CFC-114) available in stockpiles 

in the United States and 301.4 tonnes of pharmaceutical-grade CFC-12 available in 

Venezuela. CFC-114 may not be fully consumed since it is less commonly used in MDI 

formulations. Stockpiles are available for export under commercial agreement with holders 

of those stocks. Regulatory processes for exporting CFCs from the United States’ stockpiles 

for essential uses are not complicated. The cost of CFCs available from stockpiles has 

increased the price of pharmaceutical-grade CFCs from about $4-5/kg to $12-16/kg, which 

may help to encourage transition. Any remaining stockpiles in the European Union are not 

available for export due to regulations prohibiting the production and export of CFCs from 1st

January 2010. 

Production of pharmaceutical-grade CFCs is now limited to a few sources. Honeywell, in the 

United States, has a swing plant producing HCFC-22 that can also produce CFCs. However, 

regulatory processes to allow export of newly produced CFCs would likely take more than a 

year to complete. China and India both have production facilities capable of manufacturing 

pharmaceutical-grade CFCs but they are subject to MLF production phase-out agreements. 

Under its existing CFC production phase-out agreement, China is allowed to manufacture 

pharmaceutical-grade CFCs for authorised essential uses for itself and for export to the 

Russian Federation only. Decision XXI/4 requested the Executive Committee to consider 

reviewing both of the CFC production phase-out agreements with China and India with a 

view to allowing production of pharmaceutical-grade CFCs to meet authorised levels of CFC 

production for essential uses. The 60th Executive Committee Meeting, April 12-15, 2010, 

decided to modify the production sector agreements for China and India to allow the 

production for export of pharmaceutical-grade CFCs for 2010, with an annual review, for 

purposes of meeting essential use requirements of other countries provided that the exporting 

countries had specified reporting and verification systems in place. 

Any new source of supply of CFCs will require that CFC MDI producers validate the 

suitability of the newly sourced propellant in each specific MDI product. Validation takes 

time to complete, and in some cases would require the approval of health authorities. Total 

time to register a new source could be up to 6 months. 

MTOC estimates that less than about 1,100 tonnes of pharmaceutical-grade CFCs might be 

required in 2010 to supply CFCs for essential MDI uses excluding China, the Russian 

Federation and the United States (see Table 2-1)1

. If India supplies its own essential use 

requirements for 2010, this is estimated to be about 344 tonnes, and could be less given the 

 

1 Decisions taken at the 60th Executive Committee meeting allow CFC production for export in 2010 for the 

purposes of meeting essential use requirements under modified production sector agreements with China and India. 

Conclusions for 2011 and onwards do not assume continued production for export by China (other than to the 

Russian Federation) or by India since this would be the subject of annual review by the Executive Committee.
May 2010 TEAP Progress Report 25

pace of transition in that country. Estimates of CFC requirements for 2010 are based mainly 

on quantities exempted by Parties, although not all of this quantity may be needed given the 

rate of transition in some countries. If Parties approve MTOC’s recommendations for 

essential use quantities of CFCs at the 22nd Meeting of the Parties, less than 250 tonnes of 

pharmaceutical-grade CFCs might be required in 2011 to supply CFCs for essential MDI uses 

excluding China, the Russian Federation and the United States. For 2012 onwards, estimated 

CFC consumption for essential MDI uses might be about 55 tonnes in countries excluding 

China, the Russian Federation and the United States. 

CFC stockpiles available in Venezuela and the United States (total of about 951 tonnes of 

CFC-11 and -12, with 367 tonnes of CFC-114 that may not be consumed) may or may not be 

enough to cover estimated CFC requirements for MDIs for 2010, 2011 and 2012 (about 1,397 

tonnes) excluding China, the Russian Federation and the United States. This depends on, 

inter alia, Parties’ decisions regarding essential use exemptions for 2011, whether stockpile is 

acquired under commercial arrangements, and also whether the CFC mix and specifications 

of the stockpile meets the needs of the MDI manufacturers. However, it could be possible to 

complete the phase-out of CFC MDIs with careful management of existing global CFC 

stockpiles, provided manufacture of pharmaceutical-grade CFCs in China continues to supply 

its own needs and those of the Russian Federation. For example, India may not need to 

produce any CFCs to meet its own requirements for 2010 onwards and could potentially 

supply its needs from available global stockpile, especially given the capacity of HFC MDI 

and DPI production and speed of transition in that country. 

A cautious approach to CFC production is advisable since transition is moving quickly and 

Parties may wish to avoid CFC production that is surplus to actual needs, which subsequently 

would require costly destruction. The welfare of patients with asthma and COPD and of the 

environment would be best served by a rapid transition to CFC-free inhalers. 
26 May 2010 TEAP Progress Report 

Table 2-1: Estimated CFC usage2

 for nominating Parties, 2010-2014+ 

 

2 For 2010, usage data is based on exempted quantities or estimates provided by countries in 2011 essential use 

nominations. For 2011, MTOC estimates are based on essential use quantities recommended by MTOC and does 

not pre-judge decisions taken by Parties. For Iran, MTOC recommended 105 tonnes for 2011 to allow CFCs to be 

available if there are unforeseen delays in HFC MDI launch. In this table, MTOC has assumed consumption of 

zero for Iran for the purposes of estimating global consumption for 2011. For 2012 onwards, estimated usage does 

not take into account whether use meets the essential use criteria. 

Country 2010 2011 2012 2013 2014 + Total 

Algeria 11 8 0 0 0 19.0 

Argentina 178 107 3 0 0 287.7 

Bangladesh 156.7 38.7 27 0 0 222.4 

China 652.0 741.2 650 400 345 2,788.2 

Colombia - - - - - 0.0 

Cuba - - - - - 0.0 

Egypt 227.4 0 0 0 0 227.4 

India 344 48.2 15.0 0 0 406.8 

Indonesia - - - - - 0.0 

Iran 105 0 0 0 0 105.0 

Mexico - - - - - 0.0 

Pakistan 35 39.6 10 0 0 84.5 

Russian Federation 212 212 30 0 0 454.0 

Syria 44.7 0 0 0 0 44.7 

United States 92.0 - - - - 92.0 

Uruguay - - - - - 0.0 

Venezuela - - - - - 0.0 

Total, excluding 

China, Russian 

Federation and the 

United States 

1,101.3 241.2 55.0 0.0 0.0 1,397.4 

Total 2,057.3 1,194.3 735.0 400.0 345.0 4,731.6 
May 2010 TEAP Progress Report 27

Figure 2-1: Estimated CFC usage3

 for MDIs for nominating Parties, 2010-2014+

0

100

200

300

400

500

600

700

800

900

2007 2008 2009 2010 2011 2012 2013 2014 +

Year

Algeria

Argentina

Bangladesh

China

Egypt

India

Iran

Pakistan

Russia

Syria

United States

2.3 Transition away from the use of CFC MDIs 

Technically satisfactory alternatives to CFC MDIs to treat asthma and COPD are available in 

almost all countries worldwide. Since 1994, the propellant in MDIs has been gradually 

replaced with HFCs, and there are now sufficient HFC MDI alternatives available to cover all 

key classes of drugs used in the treatment of asthma and COPD. It is estimated that 

approximately 250 million HFC MDIs are currently manufactured annually worldwide, using 

approximately 4,000 tonnes of HFCs. A barrier for transition from CFC to CFC-free MDIs in 

developing countries has been that replacement HFC MDIs manufactured by multinational 

companies in developed countries can be more expensive than CFC MDIs manufactured in 

developing countries, meaning that poor patients cannot afford them. The MLF has funded 

projects in developing countries mainly focussed on technology transfer and institutional 

strengthening to convert CFC MDI manufacture to HFC MDIs, which may in some cases take 

a few more years to complete. 

Dry powder inhalers, which do not require a propellant, provide a not-in-kind alternative to 

MDIs. DPIs fall into two categories; single-dose and multi-dose. Single-dose DPIs, which 

have been in use for more than 60 years, utilise a single capsule inserted into the device. 

They are inexpensive but may be more susceptible to humidity than some more recent multidose DPIs. Multi-dose DPIs, which have been in use for more than 20 years, typically 

contain enough doses for at least 1 month’s treatment. Multi-dose DPIs made by 

multinational companies in developed countries generally have a similar price to the 

equivalent dose of drug in an MDI produced by multinational companies in developed 

countries, except for salbutamol, which is more expensive in multi-dose DPIs. However DPIs 

remain more expensive than MDIs manufactured in developing countries. Single-dose DPIs 

 

3 For 2010, usage data is based on exempted quantities or estimates provided by countries in 2011 essential use 

nominations. For 2011, MTOC estimates are based on essential use quantities recommended by MTOC and does 

not pre-judge decisions taken by Parties. For 2012 onwards, estimated usage does not take into account whether 

use meets the essential use criteria. 
28 May 2010 TEAP Progress Report 

have the advantage in developing countries that they permit low-income patients to avoid the 

expense of buying one month’s therapy at a time. 

There are two types of multi-dose DPI, one with individual doses pre-metered during 

manufacture, and the second that loads a measured amount for inhalation from a reservoir in 

the device. Older reservoir multi-dose DPIs can suffer from water ingress in high humidity 

environments that leads to clumping of the powder formulation. Some HFC MDIs are also 

affected by high humidity. Both can be partially addressed by supplying the device in a foil 

pouch opened on first use. Newer multi-dose DPIs function equally well in areas of high 

humidity, such as experienced in many developing countries. DPIs can be easier for the 

patient to use because the drug delivery is achieved by the patient’s inhalation, and they do 

not require as much patient co-ordination as MDIs. Studies4

 have shown that for many 

patients single- and multi-dose DPIs are easier to use correctly than MDIs. In some studies as 

many as 50 percent of patients cannot use an MDI efficiently, although issues of coordination may be overcome through use of a spacer or breath-activated inhaler. Indeed, the 

MDI used with a spacer may be the only device suited for treating the very young or the 

elderly and for treating acute asthma attacks; it has been estimated that up to 30 percent of 

elderly COPD patients could not achieve satisfactory inspiratory flows through common 

DPIs5

. 

CFC-free product launches continue to occur around the world. Comparison between 2008 

and 2009 of marketed products available from companies in the International Pharmaceutical 

Aerosol Consortium (IPAC)6

 shows a net increase of 127 CFC-free products, 80 of which 

were in Article 5(1) Parties. In addition to CFC-free products manufactured in and/or 

exported from Article 5(1) Parties, there are a total of 168 salbutamol CFC-free products 

launched by IPAC member companies across 92 Article 5(1) Party markets. Furthermore, 

there are 235 corticosteroid CFC-free products (beclomethasone, budesonide or fluticasone) 

available in a total of 65 Article 5(1) Parties. By contrast, there are only 30 CFC-free 

products from IPAC member companies containing ipratropium bromide available in 29 

Article 5 Parties. 

IPAC has also analysed progress in the transition to CFC-free alternatives based on available 

prescribing data. Although not wholly accurate for information from some developing 

countries, IMS7

 data show an encouraging global trend towards CFC-free therapy. CFC 

MDIs in 2009 form only 30 percent of all MDI sales, compared to 47 percent in 2007. This is 

against a background of an 8 percent increase in global MDI usage over the same period. 

Assuming that MDIs require 2 puffs for 1 dose, whereas DPIs only require 1 puff, then CFC 

MDIs now represent only 19 percent of the total number of doses taken. 

 

4 Atkins, P.J., Dry powder inhalers: an overview, Respir. Care. 2005; 50; 1304-12; Timsina MP, Martin SP et al., 

Drug delivery to the respiratory tract using dry powder inhalers, Int. J. of Pharmaceutics. 1994, Vol 101, pp 1-13; 

Singh M and Kumar L., Randomized Comparison of a Dry Powder Inhaler and Metered Dose Inhaler with Spacer 

in Management of Children with Asthma, Indian Paediatrics. 2001; 38: 24-28; Zeng X Macritchie H B Marriott C 

Martin G P., Humidity-induced changes of the aerodynamic properties of dry powder aerosol formulations 

containing different carriers. Int. J. of Pharmaceutics. 2007; 333: 45-55. 

5

 W. Janssens, P. VandenBrande, E. Hardeman, E. De Langhe, T. Philps,T. Troosters and M. Decramer Inspiratory 

flow rates at different levels of resistance in elderly COPD patients, Eur. Respir. J., 2008; 31: 78–83. 

6

 The International Pharmaceutical Aerosol Consortium is a group of companies (Abbott, Astrazeneca, Boehringer 

Ingelheim, Chiesi Farmaceutici, Glaxosmithkline, Teva. and Sepracor.) that manufacture medicines for the 

treatment of respiratory illnesses, such as asthma and COPD. 

7

 IMS Health is a company that gathers and analyses pharmaceutical market data. IMS Health granted IPAC 

permission to submit this data to MTOC/TEAP. 
May 2010 TEAP Progress Report 29

Unfortunately, this global picture can be contrasted with the trends in developing markets. 

Generally in Latin America, Africa and Asia CFC MDI usage has not declined but remained 

constant or slightly increased over the last 3 years. The reduction in CFC usage has, as might 

have been expected, been driven by a reduction in developed country markets, excepting 

Russia. MTOC believes that there could be difficulties in some markets with IMS data 

collection. For instance, CFC usage in India appeared to increase by 18 percent over 2007-

2009 in contrast to the decline demonstrated in information provided in the nomination for 

India. The difficulty in obtaining accurate data is further illustrated with China, where the use 

of MDIs appeared to remain constant over the last 3 years despite historic consumption data 

in China’s nomination showing an almost doubling in the quantity of CFCs used in MDI 

manufacture. 

MTOC has noted previously the wide availability in Article 5 Parties of technically suitable 

CFC-free alternatives to CFC MDIs manufactured by multinational companies in developed 

countries. However, this has not prompted transition, largely due to the lack of affordability 

of these alternatives. CFC-free inhalers manufactured in developing countries are now 

substantially increasing the range of alternatives. For example, Cipla, an Indian multinational 

pharmaceutical company, now markets 51 different CFC-free inhalers and has previously 

reported its commitment to phase out domestic supply of CFC MDIs by the end of 2009. 

Several of the nominations included significant CFC quantities to manufacture MDIs intended 

for export to other Article 5 Parties. None of the nominations demonstrated that these CFC 

MDIs were essential in the intended export markets or demonstrated that importing Parties 

had provided their prior informed consent for the import of the CFC MDIs in 2011. MTOC 

does not have the information from importing Parties to substantiate that these uses are 

essential. Furthermore, it is not clear whether importing Parties are specifically requesting the 

continued import of CFC MDIs despite the alternatives available, whether they simply import 

the cheapest available product even if it contains CFCs, or whether they are unable to switch 

to alternatives because of a lack of regulatory approval of these alternatives. There is a clear 

opportunity for importing Parties to help to drive the global phase-out of CFCs through 

judicious sourcing of alternatives. 

2.4 Transition strategies 

In response to Decision XII/2, transition strategies developed by seven Parties are listed on 

the Ozone Secretariat’s web site. Pursuant to Decision XV/5(4), plans of action regarding the 

phase-out of the domestic use of salbutamol CFC MDIs from the European Community, the 

Russian Federation and the United States are also listed on the Ozone Secretariat’s web site8

. 

On April 14, 2010, the US FDA published in the Federal Register its final rule to remove the 

essential-use designations for CFC MDIs where the active ingredients are flunisolide, 

triamcinolone, metaproterenol, pirbuterol, salbutamol and ipratropium in combination, 

cromolyn, and nedocromil. For triamcinolone and cromolyn, the effective date of removal of 

essential use designation is December 31, 2010; for metaproterenol and nedocromil, the 

effective date is 60 days after publication in the Federal Register on April 14, 2010; for 

flunisolide, the effective date is June 30, 2011; for pirbuterol and for salbutamol and 

ipratropium in combination, the effective date is December 31, 2013. 

The publication also notes that after the effective date of this rule there will remain only three 

designated essential uses of ODSs in the United States: anaesthetic drugs for topical use on 

accessible mucous membranes of humans where a cannula is used for application; metered 

dose atropine sulfate aerosol human drugs administered by oral inhalation; and sterile aerosol 

 

8

 http://ozone.unep.org/Exemption_Information/Essential_Use_Nominations/index.shtml 
30 May 2010 TEAP Progress Report 

talc administered intrapleurally by thoracoscopy for human use. MTOC was previously 

unaware that these applications were designated as essential ODS uses under United States’ 

regulation. MTOC notes that there are suitable, commonly used CFC-free alternatives for all 

of these applications, including common methods of anaesthesia without the use of ODS, 

anti-cholinergic drugs as a superior medical alternative to atropine, and an aqueous 

suspension of sterile talc used for pleurodesis. As these are not essential uses approved under 

the Montreal Protocol, MTOC supposes that either the applications are no longer produced 

with CFCs but retain regulatory status in the United States as designated essential uses, or the 

applications are manufactured with CFCs produced prior to 1996. 

For Article 5 Parties, Decisions IX/19(5bis) and XV/5(4bis) set out requirements for the 

development of national transition strategies and preliminary plans of action for the phase-out 

of salbutamol CFC MDIs respectively. 

Decision IX/19(5bis) states: 

“To require Parties operating under paragraph 1 of Article 5 submitting essential-use 

nominations for chlorofluorocarbons for metered-dose inhalers for the treatment of 

asthma and chronic obstructive pulmonary disease to present to the Ozone Secretariat 

an initial national or regional transition strategy by 31 January 2010 for circulation to 

all Parties. Where possible, Parties operating under paragraph 1 of Article 5 are 

encouraged to develop and submit to the Secretariat an initial transition strategy by 31 

January 2009. In preparing a transition strategy, Parties operating under paragraph 1 

of Article 5 should take into consideration the availability and price of treatments for 

asthma and chronic obstructive pulmonary disease in countries currently importing 

chlorofluorocarbon-containing metered-dose inhalers;” 

Decision XV/5(4bis) states: 

“That no quantity of chlorofluorocarbons for essential uses shall be authorized after 

the commencement of the Twenty-First Meeting of the Parties if the nominating Party 

operating under paragraph 1 of Article 5 has not submitted to the Ozone Secretariat, in 

time for consideration by the Parties at the twenty-ninth meeting of the Open-ended 

Working Group, a preliminary plan of action regarding the phase-out of the domestic 

use of chlorofluorocarbon containing metered-dose inhalers where the sole active 

ingredient is salbutamol;” 

Decision XVII/5(3bis) requests nominating Article 5 Parties to submit a date to the Ozone 

Secretariat prior to the Twenty-Second Meeting of the Parties, by which time a regulation or 

regulations to determine the non-essentiality of the vast majority of chlorofluorocarbons for 

metered-dose inhalers where the active ingredient is not solely salbutamol will have been 

proposed. Decision XV/5(6) requests Parties to submit to the Ozone Secretariat specific dates 

by which time they will cease making nominations for essential use nominations for CFCs for 

MDI where the active ingredient is not solely salbutamol. 

For Article 5 Parties, according to Executive Committee Decision 45/54, Low Volume 

Countries (LVCs) submitting Terminal Phase-Out Management Plans (TPMPs) can obtain up 

to US$30,000 to develop and implement a transition strategy. Some transition strategies have 

been approved under national ODS/CFC phase-out plans, others have been approved as part 

of MLF-funded MDI investment projects; and yet others as stand alone projects. 

This report provides an overview of the national strategies submitted to the MTOC for its 

review at its 2010 meeting. MTOC has noted, from its experience reviewing Essential Use 

Nominations, that Parties engaged in transition from CFC MDI to CFC-free alternatives 

encounter challenges and struggles of various kinds that could result in changes to dates, 

alteration in project timelines and product availability. Notwithstanding, MTOC believes that 
May 2010 TEAP Progress Report 31

a well-articulated national transition strategy can provide the necessary road map for a 

country to accomplish the transition. 

In 2010, transition strategies were received as part of the Essential Use Nominations from five 

Parties (Bangladesh, China, India, Iran and Pakistan), and from one other country, Egypt. 

These strategies are not yet posted on the Ozone Secretariat website. Argentina has not yet 

submitted its national transition strategy. In the submitted strategies, each Party provides a 

status update on the transition to CFC-free alternatives in its country. Progress reported 

includes the increased availability of CFC-free salbutamol and beclomethasone MDIs in most 

countries. In all these countries – Bangladesh, China, Egypt, India, Iran, and Pakistan – MDI 

products are mostly manufactured locally. In addition, Egypt imports CFC-free inhalers from 

either Article 5 or non-Article 5 countries. In 2009, about 10 percent of the CFC-free inhalers 

consumed in China were from imports. 

The national strategies highlight challenges that have been faced in the transition by each of 

the Article 5 Parties manufacturing MDIs. These challenges have included financial 

limitations, lack of local expertise, lack of access to technology, intellectual property issues, 

equipment conversion timelines, cost, and regulatory processes for approval of CFC-free 

alternatives. 

2.4.1 Patient access and phase-out criteria 

The submitted national transition strategies all include key elements for protecting patient 

access to products needed for the treatment of asthma and COPD. The Parties express a 

desire to balance withdrawal of CFC MDIs with the introduction of alternatives so that 

management of asthma and COPD is not compromised. 

However, while some of the submitted strategies include a patient focussed approach for the 

safe withdrawal of CFC MDIs from the market, others do not. 

China provides a strategy that is based on CFC MDI phase-out moiety-by-moiety as well as 

category-by-category. A systematic withdrawal of each product category from the market is 

planned to occur only when alternatives ranging from one to five (depending on the number 

of CFC products in the category) become available on the market in adequate quantities. In 

the case of salbutamol, China has indicated that it will require at least five CFC-free MDIs on 

the market, and four different products for beclomethasone. 

Egypt and Iran have developed broad criteria for phase-out of a CFC MDI. These criteria do 

not follow a moiety-by-moiety or category-by-category approach. Instead they include the 

following requirements: 

• Any new CFC-free inhaler is at least as safe as the corresponding CFC inhaler; 

• Any new CFC-free inhaler is as effective as the CFC inhaler it is intended to replace; 

• There should be sufficient quantities of the alternative(s) available to assure an 

uninterrupted supply of medication; 

• Post-marketing surveillance data must confirm the safety of the alternative product(s); 

and 

• There should be sufficient types of alternatives available to meet the needs of 

different patient sub-groups. 
32 May 2010 TEAP Progress Report 

Bangladesh has developed a strategy that is not driven by the substitution of specific 

asthma/COPD drugs, but rather by a general assessment of adequacy of manufacturing 

facilities to produce the alternatives. Its national strategy mentions the need for available 

alternatives by the time CFC products are to be phased out. Bangladesh has a number of 

HFC/DPI alternatives for salbutamol and beclomethasone for instance, and single alternatives 

for most of the other asthma/COPD drugs including combinations. These CFC-free 

alternatives are being manufactured locally. On this basis, Bangladesh has decided that it 

could phase out CFC MDI by 2012 when domestic manufacturing of the alternatives will be 

adequate to meet the needs of its asthma/COPD population. Bangladesh states that it will 

maintain a stockpile of CFC MDIs for products other than salbutamol and becomethasone for 

2010-2012, to ensure COPD patients are protected. 

India will ensure continued availability of affordable MDIs for patients by having 

simultaneous availability of CFC MDI and CFC-free alternatives for a stipulated period. 

Pakistan recognises the need for expeditious transition so as not to put patients at risk. 

The submitted transition strategies also highlight additional steps to be taken by the Parties to 

ensure success of the HFC alternatives in the market place. These include pricing and 

differentiated labelling initiatives as well as use of policies and regulations. For example, in 

order to support the transition to CFC-free inhalers, India proposes partial licensing of CFC 

MDI manufacturing beyond 2009; bans on licensing of any new formulations or MDI 

products with CFC, and bans on the import of new CFC MDIs. Additionally, India is 

considering fiscal incentives for adopting CFC-free alternatives and fast track regulatory 

procedures, to reduce product approval times from the standard two years to nine months for 

the approval of CFC-free alternatives. Similarly, Egypt plans to reduce its regulatory 

approval time for the CFC-free alternatives from two years to nine months. China plans to 

fast track regulatory approval processes for the CFC-free products supported by a 

‘strengthened’ post-marketing surveillance system to ensure safety of the new products. 

Most of the submitted national strategies mention that differential pricing between CFC MDI 

and CFC-free alternatives is a factor in the on-going transition. For example, China states 

that the price of domestic made CFC MDIs is one third to one tenth of imported CFC-free 

MDIs and DPIs. In contrast, in Bangladesh CFC-free MDIs and CFC MDIs are now similarly 

priced. 

2.4.2 Timeline and final date for phase-out 

In the national strategies submitted, each Party has described the processes involved in the 

product development, manufacturing facility installation or conversion and regulatory 

procedures in the transition to CFC-free alternatives. These steps are pre-requisites for 

availability of the alternatives and thus withdrawal of the CFC MDIs from the market. While 

acknowledging current and potential challenges in the transition process, each of the five 

Parties provided a target date for complete phase-out of CFC use in MDIs. 

Egypt anticipates phase-out of CFC MDIs in early 2010. Iran has banned imports of CFC 

MDIs since 2008 and expects to phase out CFC MDIs completely by the end of 2010 or early 

2011. Bangladesh plans to complete its phase-out by 2012. Pakistan expects to complete 

phase-out of CFC MDIs by the end of 2012. India states that it will complete CFC MDI 

phase-out in 2013, rather than 2012 as previously indicated in the national transition strategy 

submitted to the 56th ExCom. China is planning to phase out salbutamol CFC MDIs by the 

end of 2016 and remaining asthma/COPD CFC MDI products by the end of 2017, at least 4 

years later than any other Party. China’s strategy also addresses the use of relatively small 

volumes of CFCs used in Chinese Traditional Medicines and dimethicone aerosol, both of 

which are unique to China. Re-evaluation and substitution studies are planned for Chinese 
May 2010 TEAP Progress Report 33

Traditional Medicines. CFC use in these products will only cease if the studies suggest they 

are non-essential or if substitution is feasible. China states that it will continue to request 

essential use CFCs for dimethicone each year, but did not state an end-date for use of CFCs in 

the product. 

2.4.3 Education 

The national strategies submitted to MTOC include plans for the education of the 

stakeholders on the phase-out process. The Parties outlined the educational steps that have 

occurred so far as well as future strategies. In general, the submitted strategies include plans 

to develop educational training packages, arrange symposia and clinics, and organize training 

and awareness campaigns, involving media, schools and written materials. These programs 

are aimed at healthcare providers, the pharmaceutical industry, policy developers and patients. 

The objectives include raising awareness of the environmental reasons for the CFC phase-out, 

efforts that have been made to develop alternatives and the timelines for the phase-out. In 

many of the countries, these campaigns plan to utilize a variety of media including posters, 

leaflets, advertising, conferences, interviews, symposia etc. 

As an example, in its transition strategy, Iran states that it strongly believes that an education 

campaign will be the core of its strategy. As a result, Iran’s educational campaign will 

include cooperation between the professionals involved on a local or regional basis to discuss 

how the transition is to be implemented. It proposes to involve all healthcare professionals, 

patient associations, and the pharmaceutical industry to ensure that all patients receive 

adequate information, both orally and in writing. Other Parties provided similar details of 

their plans to educate the stakeholders in the transition process. 

2.4.4 Progress reports on transition strategies under Decision XII/2 

Under Decision XII/2, Parties are required to report to the Secretariat by 31 January each year 

on progress made in transition to CFC-free MDIs. In 2010, progress reports about progress 

made with implementation of national transition strategies were received within essential use 

nominations. Argentina has not yet developed its national transition strategy. 

It is critical that all Article 5 Parties develop their own national transition strategy and provide 

it to the Secretariat, to be posted on its website, and then to report each year on progress in 

transition, in accordance with Decisions XX/3 and XII/2. This provides the background 

information against which TEAP and MTOC can prepare technical assessments of future CFC 

essential use nominations. For example, Thailand is an importing country whose transition 

strategy states that it has phased out CFC MDIs. However it remains on the list of countries 

to which India requests CFCs for intended export of CFC MDIs in its essential use 

nomination for 2011. MTOC was unable to recommend CFCs for intended export to 

Thailand. 

2.5 Global database in response to Decision XIV/5 

Under Decision XIV/5, all Parties are requested to submit information on CFC and CFC-free 

alternatives to the Secretariat by 28 February each year. In 2010, a report was received from 

Canada9

. Twenty-two Article 5 Parties have submitted data pursuant to Decision XIV/5 since 

its inception, but much of the data is up to 10 years old and no longer relevant to today’s 

markets. These Parties are Argentina, Belize, Bosnia and Herzegovina, Brazil, China, Costa 

Rica, Croatia, Cuba, Eritrea, Georgia, Guyana, India, Indonesia, Jamaica, Malaysia, 

 

9 http://ozone.unep.org/Exemption_Information/Essential_Use_Nominations/index.shtml 
34 May 2010 TEAP Progress Report 

Mauritius, Namibia, Oman, Singapore, South Africa, Sri Lanka, and Uruguay. The Ozone 

Secretariat has agreed to send a letter later this year to remind Parties of their obligation to 

report under Decision XIV/5. 

It is important that Article 5 Parties collect their own data on CFC and CFC-free inhaler use 

annually and provide it to the Secretariat by 28 February each year, to be posted on its 

website, in accordance with Decision XIV/5. Decision XII/2(3) also requests Parties, 

including Article 5 Parties, to notify the Ozone Secretariat of any MDI products determined to 

be non-essential, and for nominating Parties to take this information into consideration. The 

Ozone Secretariat website only has information for the European Community. Collection of 

such data would aid in the development of effective transition plans within each country and 

in the determination of any essential use nominations for Article 5 Parties beyond 2010. 

Parties may wish to remind all Parties of Decision XII/2(3) to notify the Ozone Secretariat of 

any MDI products determined to be non-essential. 

Given the complexity and fluidity of export markets, Parties may wish to consider requesting 

nominating Parties to demonstrate that they have received informed consent of the 

government of any importing country for imports of CFC MDIs in any future nomination. 

2.6 Export Manufacturing Transition Plans in response to Decision 

XVIII/16 

Decision XVIII/16(7) requests: 

“...each Party receiving essential-use exemptions for the production or import of 

chlorofluorocarbons to manufacture metered-dose inhalers for export to Parties 

operating under paragraph 1 of Article 5 to submit to each importing Party a 

detailed export manufacturing transition plan for each manufacturer where the 

exports of an active ingredient to that Party exceed 10 metric tonnes, specifying 

the actions that each manufacturer is taking and will take to transition its exports 

to chlorofluorocarbon-free metered-dose inhalers as expeditiously as possible in 

a manner that does not put patients at risk;” 

Paragraph 10 of that Decision requests each Party to submit a report summarising the export 

manufacturing transition plans as part of the Party’s essential use nomination, and paragraph 

11 requests the TEAP to consider such reports in its assessments of essential use nominations. 

No export manufacturing transition plan has been submitted under this Decision because the 

threshold has not been exceeded (10 metric tonnes of CFCs for an active ingredient for 

exports to a Party). 
May 2010 TEAP Progress Report 35

3 Response to Decision XXI/4(8): Technical, Economic and 

Administrative issues affecting the Transition from CFC 

Metered Dose Inhalers to CFC-free Alternatives in the 

Russian Federation 

3.1 Background to Decision XXI/4(8) 

Decision XXI/4(8) requested the Technology and Economic Assessment Panel and its 

Medical Technical Options Committee to “organize and undertake a mission of experts to 

examine the technical, economic and administrative issues affecting the transition from CFC 

metered-dose inhalers to CFC-free alternatives in the Russian Federation, and to report the 

results of this mission to the meeting of the thirtieth Open-Ended Working Group. The 

Technology and Economic Assessment Panel is requested to examine: 

(a) The status of transition in the enterprises manufacturing CFC MDIs; 

(b) Technical, financial, logistical, administrative or other barriers to transition; 

(c) Possible options to overcome any barriers and facilitate the transition”. 

3.2 Organisation 

Experts in the team that went on the mission to the Russian Federation were selected by the 

co-chairs of the Medical Technical Options Committee (MTOC) in consultation with the 

Technology and Economic Assessment Panel (TEAP). The selected experts were: Dr Tom 

Batchelor, Belgium; Dr Olga Blinova, Russian Federation; Mr Christer Carling, Sweden; and 

Dr Helen Tope, Australia (MTOC co-chair). 

Funding for the mission was provided through the Ozone Secretariat by grants from the 

Governments of Sweden and Finland, and from the two companies in the Russian Federation 

that manufacture CFC MDIs. 

The TEAP/MTOC team visited the Russian Federation from 8 to 12 February at the invitation 

of the Ministry of Health and Social Development, which coordinated a number of meetings. 

The team met with a range of experts from the Russian Federation including: the Ministry of 

Health and Social Development; the Federal Service for Health Supervision (FSHS; also 

known in the Russian Federation as Roszdravnadzor); the Ministry of Natural Resources and 

Environment; the State Federal Unitary Enterprise “Federal Centre of Geo-ecological 

Systems”; the Ministry of Industry and Trade; the two Russian Federation companies 

manufacturing CFC MDIs (JSC Moschimpharmpreparaty and JSC Altayvitaminy); the 

Russian Federation company that imports pharmaceutical-grade CFCs (JSC Phyton); 

Academicien Alexandre Chuchalin, Russian Academy of Medical Science; and importers of 

HFC MDIs and DPIs (Chiesi and TEVA). 

During the mission, the team accepted hospitality including transportation, lunch and 

beverages, from JSC Moschimpharmpreparaty, as the host. 
36 May 2010 TEAP Progress Report 

3.3 Background to the transition from CFC to CFC-free MDIs in the 

Russian Federation 

3.3.1 Asthma and COPD and healthcare in the Russian Federation 

Data from Global Initiative on Asthma and from the Ministry of Health and Social 

Development show the incidence of asthma in the Russian Federation to be approximately 9 

percent or 13 million people; and the incidence of chronic obstructive pulmonary diseases 

(COPD) is estimated to be about 1-2 percent or 1-3 million people, although some estimates 

are as high as 8 million people. 

The Russian Government determines the priorities for health care where one of the main 

goals is the treatment of diseases categorised as socially important, which includes lung 

diseases. The Ministry of Health determines a list of life-saving drugs that provides the basis 

for government reimbursed medicines, which makes affordability of medicines very 

important to the Government. The list is updated annually and includes medicines for treating 

asthma including some, but not all, MDI products. About 5 million asthma patients classified 

as “disabled” are eligible for free medicines from regional authorities. 

The Federal Service of Health Supervision is the government authority responsible for the 

control of medical products, including their registration and market authorisation. This 

Service also regulates the maximum wholesale prices for medicines on the government list of 

life-saving drugs. Retail mark-up of drugs included on this list is determined by the regional 

authorities and limited to 30 percent of the wholesale price. Price regulation does not apply to 

all asthma drugs, only those that are included on the government list of life-saving drugs. 

In August 2008, the Russian Ministry of Industry and Trade announced a new draft strategy 

for the development of the Russian pharmaceutical industry, called “Industry Development to 

2020”, which focuses on increasing the capacity of the domestic industry in the Russian 

Federation to produce medicines according to international quality standards and increasing 

patient access to innovative drugs. By 2020, the government aims to increase the market 

share of domestically produced pharmaceuticals to 50 percent. The Russian Federation 

currently manufactures about 70 percent of the MDIs sold on the market, and therefore this 

national strategy aims to ensure that domestically produced pharmaceuticals include future 

MDI production. 

3.3.2 Salbutamol MDIs in the Russian Federation 

In 1984, the manufacture of CFC MDIs began in the Russian Federation, and currently there 

are two domestic manufacturers of salbutamol CFC MDIs. Another manufacturer of MDIs 

(JSC St. Petersburg Pharmaceutical Factory) entered the market in June 2009 with a 

beclomethasone HFC MDI, having not previously manufactured the corresponding CFC 

MDI. Multinational companies also import a variety of inhalation products, as HFC MDIs 

and DPIs. Therefore there is a range of domestically produced and imported MDI products 

that currently meet patient demand. 

Data available from IMS Health1

 show that direct pharmacy sales2 of salbutamol MDIs 

(where patients pay the full retail price) dominate the market, compared to MDIs available 

 

1 IMS Health is an international company that supplies the pharmaceutical industry with sales data. 

2 In this report, direct pharmacy sales are used to describe pharmacy sales of MDIs where patients pay the full 

retail price. 
May 2010 TEAP Progress Report 37

through hospital and government reimbursement sectors. In 2009, direct pharmacy MDI sales 

were 92 percent of the salbutamol MDI market in units (of a total of about 8 million units) 

and 83 percent in sales value. Full retail price MDI sales were increasing in units in 2006-

2008, while hospital and reimbursement purchases were declining in 2006-2009. This means 

that the cost to the government for MDIs has been reducing in recent years, as more patients 

are directly buying MDIs themselves at the full retail price. This recent trend means that the 

affordability of medicines has become important to more patients. All purchases of MDIs 

declined in 2009, probably because of the global economic crisis. 

Salbutamol is a short-acting beta-agonist (SABA) that accounts for the majority of 

asthma/COPD treatments. Other drugs in this category are therapeutically equivalent 

treatments to salbutamol, and because salbutamol CFC MDIs are still being produced in the 

Russian Federation, the SABA category warrants specific attention in this report. SABA 

products available on the Russian market include salbutamol inhalers (CFC MDIs from the 

Russian manufacturers; HFC MDIs from Cipla, GlaxoSmithKline (GSK) and TEVA; dry 

powder inhalers (DPIs) from TEVA) and fenoterol HFC MDIs (from Boehringer Ingelheim 

(BI)) (Table 3-1). In 2009, Russian-made salbutamol CFC MDIs accounted for 73 percent of 

the total market in numbers of units, 56 percent of the total wholesale sales, and 70 percent 

(or about 5 million units) of the market share for direct pharmacy sales. Russian-made 

salbutamol CFC MDIs therefore dominate the Russian Federation market. 

Table 3-1: Imported CFC-free inhalers which are alternatives to salbutamol CFC MDI in 

the Russian Federation 

Drug Manufacturer Inhaler type Launch date in Russian 

Federation 

Astalin (salbutamol) Cipla HFC MDI Launched date (N/A) 

Berotec N (fenoterol) Boehringer Ingelheim HFC MDI April 2000 

Berodual N (fenoterol) Boehringer Ingelheim HFC MDI July 2002 

Cybutol (salbutamol) TEVA DPI N/A 

Salamol Eco (salbutamol) TEVA HFC MDI August 2001 

Salamol Eco Easi-Breathe TEVA HFC MDI June 2002 

Ventolin (salbutamol) GSK HFC MDI Launched (date N/A) 

The average price in the retail sector of all SABA CFC and HFC MDIs is $3.13 per unit 

(inhaler)3

. In this report, a “unit” means an inhaler containing 90 or 200 doses. The average 

retail price of Russian-made salbutamol CFC MDIs (90 doses) is $2.89. The average retail 

prices of imported SABA HFC MDIs range from $3.04 (Astalin, Cipla, 200 doses, 1 percent 

market share) to $19.07 (Berodual, BI, 200 doses, combination product 

fenoterol/ipratropium). The average price of the major imported salbutamol HFC MDI on the 

Russian market is $5.24 (Ventolin, 200 doses, 14 percent market share), which is 45 percent 

more expensive per unit than the Russian-made CFC MDIs (90 doses at $3.13 per unit), but 

similar in price on a per dose basis. The TEAP/MTOC team visited a Moscow pharmacy to 

make its own small sample comparison of SABA inhalers to find a similar pattern in prices 

(Table 3-2). 

 

3

 Data is for the 2nd quarter of 2009. The rouble was valued at 32.2 roubles to the US dollar on 15 May 2009.
38 May 2010 TEAP Progress Report 

Table 3-2: MTOC sample of retail sector pharmacy prices of SABA CFC and HFC MDIs 

Drug Doses Price per unit 

(Roubles4

) 

Price per dose 

(Roubles) 

Altayvitaminy 

salbutamol CFC 

MDI 

90 65 0.72 

Ventolin 

(salbutamol) HFC 

MDI 

200 145 0.73 

Berotec (fenoterol) 

HFC MDI 

200 386 1.93 

IMS data show that the price per unit of Russian-made CFC MDIs is cheaper than the average 

price per unit of all SABA inhalers, and the cheapest SABA inhalers, but their average price 

per dose is higher than some imported HFC MDIs (Table 3-3). 

Table 3-3: Sample of average unit retail price and price per dose for SABA inhalers 

(IMS data) 

Drug Doses Price per unit ($) Price per dose ($) 

Salbutamol CFC MDI 

(Russian-made) 

90 doses 2.89 0.03 

Astalin HFC MDI (Cipla 

imported) 

200 doses 3.04 0.02 

Salamol Eco HFC MDI 

(Teva imported) 

200 doses 4.67 0.02 

Ventolin HFC MDI (GSK 

imported) 

200 doses 5.24 0.03 

Berotec N (fenoterol) HFC 

MDI (BI imported) 

200 doses 10.29 0.05 

Pharmacies supply Russian-made salbutamol CFC MDIs more often than imported SABA 

HFC MDIs because they have the lowest unit price. Imported MDIs are reportedly not 

always as readily available in pharmacies as Russian-made MDIs, except for Ventolin that is 

widely distributed. Russian manufacturers, multinational importers and government told the 

mission that patients are very conscious of their out-of-pocket purchase expenses. So the unit 

price becomes a threshold for whether a purchase is made or not. The majority of patients 

seek the lowest unit price, which is the main driver in purchasing decisions. It was not clear 

why Cipla’s Astalin, which is almost the same unit price and half the price per dose, is not 

widely available to patients. If the product were more readily available in pharmacies, it 

would present a highly affordable alternative. 

In the government reimbursement sector, imported SABA HFC MDIs have 98 percent and 

Russian-made salbutamol CFC MDIs have 2 percent market share. The average price for 

reimbursed products in this sector is $6.43 per unit. The implications of these data are that 

 

4 The rouble was valued at 32.262 roubles to the US dollar on 10 February 2010. 
May 2010 TEAP Progress Report 39

most sales on the Russian market of MDIs are without government reimbursement and paid at 

full retail cost by the consumer at a pharmacy. 

Originally three producers, the JSC “Moschimpharmpreparaty” named after N.A., Semahko”, 

Moscow, JSC “Altaivitaminy” Biysk, Altay Region and JSC “Octyabr” (now ICN Ltd.), St 

Petersburg, consumed CFC-11 and -12 for the manufacture of medical aerosols in the Russian 

Federation. However, JSC “Octyabr” was later purchased by ICN Ltd. (USA). ICN ceased 

production of CFC aerosols before 2000. According to accounting framework reports 

submitted by the Russian Federation in relation to its essential use exemptions, CFC 

consumption for MDI manufacture ranged from 330 tonnes in 2003 to 396 tonnes in 2006, 

declining to and remaining stable at about 240 tonnes from 2007 to 2009 (Figure 3-1). The 

Russian Federation was approved an essential use exemption of 212 tonnes for 2010 and has 

submitted a nomination for 248 tonnes of CFCs for MDI use in 2011. 

The objective of the two companies, Altayvitaminy and Moschimpharmpreparaty, is to 

manufacture affordable MDIs for the regional markets within the Russian Federation. 

Altayvitaminy supplies mostly Siberia, the Far East, Altay and Ural regions of the Russian 

Federation. Moschimpharmpreparaty supplies mostly the European part of the Russian 

Federation. They have stated that they “...work as colleagues and not as competitors on the 

national market, both trying to provide affordable products to patients”. They have informal 

agreements on market split across Russia and on the price of products to make them 

competitive with imported products. These companies have good distribution channels that 

reach even the more remote regions of the Russian Federation. They each produce about 50 

percent of the Russian-made salbutamol CFC MDIs. 

Figure 3-1: CFCs exempted, used and on stock for the Russian Federation 1997-2009 

0

200

400

600

800

1000

1200

1400

1996 1998 2000 2002 2004 2006 2008 2010

Year

Exempted

Used

On stock

Altayvitaminy is a 60-year old private company with 150 shareholders that had its beginnings 

in vitamin manufacture. Its early vitamin manufacture included the use of natural raw 

materials, such as sea buckthorn oil, which remains the signature product line of this 

company. It is one of the ten most significant pharmaceutical companies in the Russian 

Federation. Aerosol products are the most significant income source for Altayvitaminy, 

which produces a range of medical aerosols. Production of salbutamol CFC MDIs started in 
40 May 2010 TEAP Progress Report 

2000. It produces about 6 million salbutamol MDI units per year, which makes up about 25 

percent of the company’s total revenue and was reported by the company to be “the most 

important factor” for the company’s financial survival. According to the company, demand 

for Altayvitaminy’s salbutamol MDI is determined by the remoteness of the regions it 

supplies and its strategic location for supplying those regions, the argued difficulty for 

importers to supply MDIs to those regions, and established channels for its other product 

lines. Altayvitaminy is also registered to supply CFC MDIs to 6 other countries of the former 

USSR, including Kazakhstan, Uzbekistan and Belarus but has not supplied these countries for 

a number of years. 

Moschimpharmpreparaty is a 125-year old state-owned company with about 100 

pharmaceutical products. Its salbutamol MDI plant produces about 6-7 million units per year. 

According to the company, MDIs are very important to Moschimpharmpreparaty’s revenue 

although not as significant to overall revenue as for Altayvitaminy. Because 

Moschimpharmpreparaty is a state-owned enterprise, with Board members including the 

Ministry of Industry, the continued manufacture of MDIs is also seen as an important social 

issue for the lower income patients supplied by Russian-made MDIs. 

3.3.3 Efforts to phase out CFCs in MDIs in the Russian Federation 

In the early 1990s, the international community recognised the difficulty that Countries with 

Economies in Transition (CEITs) in Eastern Europe and the former Soviet Union would have 

in meeting their obligations under the 1990 London Amendment to the Montreal Protocol, 

namely the elimination of Annex A and B Ozone Depleting Substances (ODS) consumption 

and production by 31 December 2000. In 1996 a project entitled “Russia Ozone Depleting 

Substance Consumption Phase-out Project” was established with a total budget estimated at 

$104 million, comprising $60 million grant from the Global Environmental Facility (GEF) 

and co-financed by $44.3 million by Russian Federation companies. As non-Article 5 Parties 

under the Montreal Protocol, the Russian Federation was not eligible for international 

assistance available under the Multilateral Fund. As a consequence, the GEF formally opened 

an Ozone Focal Area in 1995 for CEITs that had country programmes endorsed by the 

Montreal Protocol and had ratified the London Amendment. The World Bank was a key 

participant in the development of the Ozone Focal Area in the early 1990s. 

Unlike GEF initiatives in other CEITs, this Project was initially limited to phase out 

investment in only two high consumption sectors (non-medical aerosol and refrigeration 

equipment). It became evident that the CFC Phase out Programme in the Russian Federation 

did not include technical assistance for phasing out CFCs in the production of Metered Dose 

Inhalers (MDIs) because this was considered a lower priority while there was provision for 

essential use exemptions for CFCs under the Montreal Protocol. 

During 2006-2007, two investment projects, one for Altayvitaminy and one for 

Moschimpharm-preparaty were prepared by the World Bank with the participation of a local 

bank within the “Russia Programme for Organization of Investments for Environment 

Protection”. These two investment projects dealt with the provision of financial assistance to 

both companies in making the conversion from CFC-based MDI production to CFC-free 

MDIs. However, both companies were unable to accept the associated credit terms of the 

local bank because the terms of the loan were too short with prohibitively high interest rates 

(1.5-2 years at 18-20 percent where 3-3.5 year loans were needed at lower rates) and 

unacceptable loan terms (real estate required as security which is not feasible with the stateowned Moschimpharmpreparaty). Consequently, the World Bank returned the unspent GEF 

funds to the GEF. 
May 2010 TEAP Progress Report 41

In 2004, the Ministry of Natural Resources and Environment submitted to the Montreal 

Protocol Ozone Secretariat a National Plan of Action to phase out the use of CFCs in the 

manufacture of MDIs in the Russian Federation by 2008. The Plan included a series of 

activities to be implemented by the two CFC MDI manufacturers. In addition to this plan, the 

Russian Government implemented an overarching Plan of Action for phase-out of remaining 

ODS consumption and fulfilment of commitments for protection of Ozone layer over 2005-

2008. Item 5 of this Plan stated that CFC-free MDIs would be developed and launched by the 

end 2008 and CFCs would no longer be required in 2008. The phase-out was not achieved in 

the MDI sector for the reasons outlined above. 

In 2008, the Ministry of Health and Social Development through FSHS requested UNIDO to 

render technical assistance in developing an MDI project to phase out the use of CFCs in 

MDI manufacture in the Russian Federation. On 20 September 2009, the Ministry of Natural 

Resources and Environment officially requested UNIDO to formulate an MDI project. 

UNIDO plans to submit the project identification form (PIF) to the GEF in April 2010 under 

the GEF5 programme. Funding for the project has yet to be committed. The Russian 

Federation brought the issue of difficulties in its transition from CFC to CFC-free MDIs to the 

attention of the 21st Meeting of the Parties in late 2009, which was the basis for Decision 

XXI/4(8) and the TEAP/MTOC mission. 

3.3.4 Supply of CFCs for MDI manufacture in the Russian Federation 

As a result of the implementation of the ODS phase out programme, CFC production ceased 

in 2000 in the Russian Federation. Import of CFCs for MDI production is regulated by an 

annual quota from the Ministry of Natural Resources and Environment or supplied from the 

stockpile. Russia has been importing pharmaceutical-grade CFCs from China, and on one 

occasion from India, since 2002. A local company, Phyton, is the importer and supplier of 

pharmaceutical-grade CFCs in the Russian Federation primarily from one CFC producer, 

Zhejiang Juhua Group, located in Shanghai, China. The China CFC production phase-out 

agreement under the MLF allows for the production and export of CFCs to meet essential use 

exemptions of non-Article 5 Parties such as the Russian Federation after 2009. 

Imported CFCs must meet Russian specifications and indicators of quality. Pharmaceuticalgrade CFC prices were reported to be increasing before the economic crisis but the price 

remained stable from 2008-2009. Phyton has also had discussions with a US CFC producer 

but did not consider the potential arrangements to be practical. CFCs are imported in multiple 

monthly deliveries by sea and then transferred into smaller containers before delivery to the 

MDI manufacturers. Phyton stockpiles will support CFC-MDI production in the Russian 

Federation for a maximum of 3 months. MDI manufacturers also carry small stockpiles of 

CFCs for MDIs and have very limited stockpiling capacity. At the end of 2009, only 1.6 

tonnes of stockpile was carried in the Russian Federation. Phyton is also working towards 

supplying pharmaceutical-grade HFC-134a to Russian MDI manufacturers in due course. 

3.4 Status of transition in the Russian Federation 

3.4.1 Status of transition in the companies manufacturing CFC MDIs in the 

Russian Federation 

With the realisation that the original GEF funding was unavailable to the Russian MDI 

manufacturers, in 2004 Altayvitaminy and Moschimpharmpreparaty started research and 

development of new HFC formulations for salbutamol to replace the salbutamol CFC MDIs. 

Altayvitaminy and Moschimpharmpreparaty have funded all reformulation work to date 

without government support. From information contained in previous essential use 
42 May 2010 TEAP Progress Report 

nominations, HFC-227ea was initially investigated as a potential MDI propellant for the new 

formulation. HFC-134a is now the preferred MDI propellant in the Russian Federation. 

Formulation of new salbutamol HFC MDIs has been completed and initial dossiers including 

pre-clinical tests have been submitted to the FSHS by Altayvitaminy, and also more recently 

by Moschimpharmpreparaty. Clinical trials (phase III), for which FSHS would specify the 

test criteria and review the results, are yet to be finalised by the companies. FSHS will also 

perform certain laboratory studies of the formulation. If not given special priority, this entire 

“subject examination” might take 18-24 months. Following delivery, installation and 

validation of production lines (estimated to take about 18 months after order), stability tests 

on product from three full-scale commercial batches have to be produced and analysed (6 

months) before approval by FSHS (3 months) and grant of license for commercialisation. 

This would, with some prioritisation, bring the total time to obtain the product certificates 

necessary to market the product up to about 2 years. 

Altayvitaminy and Moschimpharmpreparaty will both source all MDI components from 

outside Russia. Quality certificates, required by the FSHS, are yet to be obtained for active 

ingredient, excipients and components. For the active ingredient, salbutamol, sources are 

known but contracts are yet to be agreed, and sourced material is yet to be assessed against 

international quality standards. For HFC-134a, the potential suppler has been identified in 

China, but contracts are yet to be agreed. For excipients such as ethanol, sources are known 

(European producers) but contracts have yet to be agreed. For valves and canisters, sources 

are known but contracts have yet to be agreed. 

By comparison, JSC St. Petersburg Pharmaceutical Factory produced its first beclomethasone 

HFC MDI in June 2009. This company’s experience was that product registration took about 

two years to complete, and there were many difficulties with equipment commissioning. 

Equipment commissioning is critical for the timeline of the project. Upon financing, 

companies will need to order the equipment and follow its delivery and installation with high 

priority. 

Both companies need additional financial and some technical assistance to replace their 

present filling lines to allow for production of CFC-free MDIs. Funds required to complete 

the conversion of the local companies are estimated to be in the order of $4-6 million. Both 

companies have been and are ready to continue to co-finance the project with previous and 

future commitments of up to $10 million. Some technical assistance will be needed to 

complete documentation and other requirements to meet with the licensing requirements 

required by the FSHS and the requirements of Good Manufacturing Practice. 

The Ministry of Natural Resources and Environment has officially requested UNIDO to 

formulate an MDI project to provide the financial and technical assistance necessary to 

achieve transition of CFC to HFC MDI manufacturing. UNIDO is preparing a project for 

submission to the GEF to request funding to implement the project. 

3.5 Barriers to transition 

3.5.1 Financial aspects to transition 

Financing for technology conversion and equipment investment is needed urgently to 

complete the conversion. Company investment is limited due to a range of factors including 

the global financial crisis, devaluation of the rouble, falling company revenue, rising raw 

material costs and competing company investment priorities. Local bank loans have been 

investigated but the interest is too high and the term too short. Government assistance 
May 2010 TEAP Progress Report 43

through the Ministry of Finance to access local bank loans with favourable terms requires 

more time than is available, and would be difficult to negotiate. 

GEF funding with co-financing from the MDI manufacturing companies is being explored as 

an option. However further urgent work is required to determine the viability of this option as 

a source of finance, given the competing demands on GEF funding in other sectors not related 

to ozone layer protection. Bilateral funding between the Russian Federation and one or more 

donor countries also remains an option to be explored. Since the time to complete the 

transition commences when the finance is secured, securing finance as soon as possible is by 

far the most important governing factor if the transition to CFC-free MDI production in the 

Russian Federation is to be completed by the end of 2012. 

The Government controls wholesale prices of essential drugs on a list of life-saving 

medicines, which currently includes some salbutamol MDIs, but the prices of drugs not on the 

list can increase. The unit price of Russian-made salbutamol CFC MDIs is cheaper than 

average price for drugs in this therapeutic category, and the cheapest in this category. 

However the average price per dose for Russian-made salbutamol CFC MDIs is higher than 

some imported HFC MDIs. 

Pharmacies supply Russian-made salbutamol CFC MDIs more often than imported SABA 

HFC MDIs. Imported SABA HFC MDIs are not always as readily available in pharmacies as 

Russian-made salbutamol CFC MDIs. These findings indicate that the patient’s ability to 

purchase is governed by how much they are willing to pay or can afford to pay at one time. 

Affordability and accessibility of asthma inhalers are important for Russian patients, and price 

affects both. Therefore replacement of Russian-made salbutamol CFC MDIs with more 

expensive inhalers could have potential adverse financial and health impacts, especially for 

low-income patients. The average price per inhaler for the Russian-made salbutamol CFC 

MDIs is 2.89 USD (90 doses). The Russian reformulated salbutamol HFC MDIs might be 

more expensive than their own CFC MDIs if they contain 200 doses per unit. Although, 

Russian manufacturers have said that they aim to provide competitively priced MDIs. 

3.5.2 Technical aspects to transition 

As well as financial assistance, some technical assistance is also needed to complete the 

conversion of CFC MDI to HFC MDI manufacture. In particular, technical assistance with 

equipment installation and commissioning is required, as well as facilitation of equipment and 

component procurement. This technical assistance is likely to come from the manufacturer of 

the equipment supplied to the companies to manufacture HFC MDIs. 

The overall total time for conversion of the 2 companies is estimated to be about 24 months 

once finance becomes available. If finance becomes available by the 3rd quarter of 2010, then 

projected CFC MDI phase-out could be by about mid-2012. This assumes that remaining 

steps of the product documentation, licensing approval and production equipment 

commissioning proceed smoothly. In response to questions regarding its essential use 

nomination for 2011, the Russian Federation stated, “If the GEF funds are available the 

phase-out is going to be achieved by the end 2012”. 

3.5.3 Regulatory and administrative aspects to transition 

Government ministries and agencies with crucial roles in the transition of the Russian CFC 

MDIs to HFC MDIs include the Ministry of Health, Federal Service of Health Supervision, 

Ministry of Natural Resources and Environment, the State Federal Unitary Enterprise 

“Federal Centre of Geoecological Systems”, Ministry of Trade and Industry, Ministry of 

Finance, and Ministry of Economy. The first two have the largest influence on a successful 
44 May 2010 TEAP Progress Report 

transition. Other Ministries have important supportive roles, which will be even more 

essential if GEF funding is not available e.g. Ministry of Finance. All discussions during the 

TEAP/MTOC mission showed strong cooperation and willingness between the parties to 

facilitate the transition to CFC-free MDIs. 

Information for healthcare providers and patients is necessary for the final stages of the 

transition, and needs to be planned well in advance of HFC MDI product launch. 

3.5.4 Logistical aspects to transition 

The overall time for conversion of the 2 companies is estimated to be about 24 months once 

finance becomes available. To meet this schedule, the regulatory authorities and the 

companies agreed that most of the activities associated with the transition must be carried out 

in parallel. . 

Delays in the transition to Russian-made CFC-free MDIs could threaten patient health 

because imported CFC-free inhalers may be less affordable or available for poor patients. 

Imports of sufficient quantities of HFC MDIs are technically feasible for the Russian market, 

but the individual unit purchase price may be higher. Two multinational importers, with 

whom the team consulted, stated that HFC MDI imports could be increased within a year to 

meet demand for patient care in the Russian Federation, if domestically produced MDIs 

cannot be produced. Salbutamol HFC MDIs from multinational companies in Article 5 

Parties might provide a cost-effective alternative. The average price per inhaler for the 

salbutamol HFC MDI from Cipla, India, is 3.04 USD (200 doses) compared with the average 

price per inhaler for the Russian-made salbutamol CFC MDIs of 2.89 USD (90 doses), and 

the price per dose of the Cipla product is considerably less than the Russian-made product. 

However, these affordable CFC-free MDIs do not appear to be widely available in 

pharmacies. If these products were more readily available, they would present highly 

affordable alternatives. 

3.6 Recommendations and conclusions 

Financial support is critical for successful transition in the Russian Federation. The potential 

for GEF funding should be investigated urgently. National commercial loans with better 

terms should be investigated as another option, but this would take much longer. Bilateral 

funding between the Russian Federation and one or more donor countries also remains a 

possible option to be explored. Once funding is secured, about 24 months will be needed for 

overall conversion of the two companies. Since the time to complete the transition 

commences when the finance is secured, securing finance as soon as possible is by far the 

most important governing factor if the transition to CFC-free MDI manufacture in the Russian 

Federation is to be completed by the end of 2012. 

Accelerated processes by FSHS could further facilitate approvals – give the ‘green light’ as 

soon as possible to the key regulatory steps. Regulatory approvals and company activities 

should be carried out in parallel as much as possible to reduce time. Government, companies 

and suppliers should continue the established co-operative approach. This includes the 

preparation and delivery of information for healthcare providers and patients, which will be 

needed in time for the launch of any domestically produced HFC MDI. 

Russian-made salbutamol CFC MDIs have the cheapest unit price and dominate the market. 

Russian patients are price-sensitive to pharmaceutical expenses and increases in the price of 

their inhalers may exceed the threshold price that they can afford to pay. Some imported 

products are competitively priced based on price per dose, and one imported product (Cipla) 

is competitively priced based on price per unit. Market transition to imported CFC-free 
May 2010 TEAP Progress Report 45

inhalers is technically feasible but patient perceptions of price and/or sensitivity to unit price 

could be a barrier. If CFCs become unavailable before the Russian Federation companies 

complete the transition to HFC MDIs, or transition is delayed by lack of finance, HFC MDI 

imports will need to be increased to protect patient health. 

The TEAP/MTOC mission requested Russian Government Ministries, including the Ministry 

of Health and the Ministry of Natural Resources and the Environment, and the two Russian 

companies to keep MTOC informed of any developments during 2010. In this way, MTOC 

can also keep the Parties informed. The TEAP/MTOC mission recommended quarterly 

updates from the Ministry of Health on progress in the transition, covering for example 

progress with finance, regulatory approvals and dates for market launch. This suggestion was 

favourably received. In response, at the final meeting with the TEAP/MTOC team on 12 

February, the Ministry of Health proposed the formation of an inter-Ministerial Working 

Group chaired by the Ministry of Health with representatives from the Ministry of Natural 

Resources and the Environment, the Federal Service of Health Supervision, the Ministry of 

Trade and Industry, and from industry, to develop and coordinate Plans of Action, to 

exchange information and provide updates to MTOC. This Working Group first met in 

March 2010. MTOC recommends that a representative from the Working Group provide an 

update to MTOC at the end of each quarter. 

As soon as funding is approved, the two companies and the Government will need to work 

quickly to achieve transition in the anticipated 24 months. The proposed inter-Ministerial 

Working Group would be crucial to maintaining momentum and facilitating transition once 

finance is approved. 

Provided funding becomes available, the period of the Russian Federation’s most recent 

essential use nomination for 2011 overlaps with the period of transition to HFC MDI 

manufacturing, with possible conclusion by the end of 2012. The 6th MOP in 1994 agreed 

the first essential uses in 1996. It is now 13 years since the Russian Federation was first 

approved an essential use exemption for CFCs in 1997. The National Plan of Action 

submitted in 2004 by the Russian Federation stated that the two companies would phase out 

their use of CFCs for MDIs by 2008, but this was not achieved due to lack of funds. 

Nonetheless the Parties have continued to approve CFCs past the time that the Russian 

Federation said it would complete the transition. 

Consumption of CFCs to manufacture salbutamol MDIs in the Russian Federation has 

remained steady at about 240 tonnes for 2007-2009. Parties approved an exemption for 212 

tonnes for the Russian Federation for the year 2010. For 2011, MTOC has again 

recommended 212 tonnes of CFCs, instead of the nominated 248 tonnes requested to supply 

an anticipated increase in demand for salbutamol MDIs. MTOC believes that available 

imported HFC MDIs could meet any increased demand for salbutamol MDIs in 2011. If 

Parties approve an essential use exemption for 2011, this would give time for the proposed 

manufacturing transition to be achieved or, if funding is not approved during 2010, there 

would be time for imported CFC-free inhalers to increase their market share by the necessary 

factor of 4 (from 25 to 100 percent of the market) to provide adequate CFC-free alternatives 

by the start of 2012. Without demonstrated progress in manufacturing transition, MTOC may 

not be able to recommend any future essential use nomination. 

May 2010 TEAP Progress Report 47

4 Chemicals Technical Options Committee (CTOC) Progress 

Report 

4.1 Executive Summary 

This report responds to decisions XVII/6, XXI/6 and XIII/7 on process agents, laboratory and 

analytical uses, and n-PB, respectively; assesses a new essential use nomination of CFC-113 

from Russian Federation; updates destruction technologies identified in the 2002 TEAP Task 

Force Report under the decision XXI/2 (3), and presents new information on several emerging 

destruction technologies submitted to the Ozone Secretariat. Also the CTOC updated the list 

of ODS feedstock application and the estimated emission from those feedstock uses. 

Process Agents 

The USA and the EC submitted data on their process agent uses in 2008 to the Ozone 

Secretariat. Six process agent applications (No.1, 2, 6, 8, 24 and 28 in table A of decision 

XIX/15) are still in use in the USA, but the EC reported the phase out of three process agent 

uses: 

- No.5 CTC in the manufacture of isobutyl acetophenone 

- No.11 CFC-113 in the production of perfluoropolyether-peroxide intermediate for the 

production of perfluoropolyether diester 

- No.27 CTC for the production of radio-labelled cyanocobalamin 

Therefore, the CTOC recommends deleting process agent uses No.5, 11 and 27 in table A of 

decision XIX/15). 

Table B of decision X/14 was updated by adding reported data in 2008 (submitted in 2009) as 

shown in Table 4-1 . The make-up limit for EC was slightly exceeded in 2008, and 

countermeasures are taken in EC to comply with the make-up quantities specified in table B. 

As of 4 May 2010, Armenia, Australia, Canada, Cyprus, Hungary, Jamaica, Macedonia, 

Panama, Poland, Saint Lucia and Sweden have reported that no process agent applications are 

in use in those Parties. The CTOC recommends that countries phasing out process agent uses 

be removed from table B and that submission of annual data to the Ozone Secretariat is 

required only for the Parties using ODS process agents. The CTOC notes that the EC may 

wish to investigate the 54 facilities with considerable quantities of CTC emissions to water 

and the 17 facilities with significant quantities of CTC emissions to air and to clarify whether 

these emissions arise from process agent, feedstock, inadvertent production, or other uses. 

http://prtr.ec.europa.eu/PollutantReleases.aspx

The Swiss government asked the CTOC to consider a confidential process agent application 

for a new manufacturing process utilizing CTC. The CTOC requested, but did not receive, 

necessary information on the process, amounts of CTC to be used and its expected emissions. 

Further discussion revealed that the proposed use was as feedstock. 

Although a joint report by TEAP and the Executive Committee of the Multilateral Fund as 

requested by decision XXI/3 (5) could not be prepared in time for the current progress report, 

TEAP and its CTOC would like to bring to the attention of the Parties that the quadrennial 

assessment report of CTOC due to be completed later in the year will contain some relevant 

information on the subject. The CTOC will cooperate with the MLF Secretariat to produce a 

joint report on progress with phasing out process agent applications in 2011. 
48 May 2010 TEAP Progress Report 

Laboratory and Analytical Uses of ODS 

According to the requests of Decision XXI/6, the TEAP and its CTOC will report 

comprehensive studies of laboratory analytical uses of ODSs in the 30th OEWG meeting. 

CTOC's work on decision XXI/6 paragraphs 5 and 6 is still ongoing. CTOC will endeavour 

to provide some further information at MOP-22. TEAP and its CTOC would appreciate 

having information from the Article 5Parties if they have any laboratory and analytical uses 

that are already banned from the exemption. The information would enable TEAP and its 

CTOC to carry out the task under decision XXI/6 paragraph 6 

Recommendations are made for removal of a range of laboratory and analytical uses, mainly 

of carbon tetrachloride (CTC), from the general exemption of laboratory and analytical uses 

because suitable alternatives are available (Table 4-2). It is recommended that the general 

exemption be maintained for a small number of uses (Table 4-3). Full details of the 

investigation of the reasons for use of ODS and of suitable alternatives are presented in the 

Appendix to this report. 

Briefings by CTOC members under decision XXI/6 (10) have already commenced with a 

presentation at the regional meeting of South Asia and South East Asia Pacific ozone officers 

in Chiang Mai, Thailand, in October 2009, and at the meeting of Europe and Central Asia and 

South Asia ozone officers in Istanbul, Turkey, in April 2010. 

The CTOC recently determined that CTC uses have been widespread in biochemical research 

for inducing liver fibrosis in the research of the role of oxidative and classical reductive 

metabolism related to liver toxicity. The quantities of CTC used in each research project are 

likely small but, worldwide consumption is unknown. This use resembles an approved use for 

another ODS, methyl bromide, in ‘laboratory toxicological studies’ (decision XVII/10). 

Essential Use Exemptions of CFC-113 in the Russian Federation 

The CTOC reviewed this nomination and acknowledged the reductions with the projected use 

reaching 35 metric tonnes in 2014. Accordingly the CTOC recommends the Essential Use 

Exemptions for 100 metric tonnes of CFC-113 in 2011 for manufacturing the missile and 

space equipments for the Russian Federation, but also recommends greater efforts for the 

introduction of appropriate alternatives, of materials compatible with non-ODS alternative 

solvents, and adoption of newly designed equipment to complete phase-out of CFC-113 

within an accelerated time schedule. 

n-Propyl Bromide (n-PB) Update 

Obtaining more complete and accurate information continues to be difficult. No governmental 

records are available on emission or uses since n-PB is not a controlled chemical substance 

like CFCs, and HCFCs (ODS class I and II) nor designated as a hazardous air pollutant in the 

Clean Air Act in the USA or reportable compound for pollution release (emission) and 

transfer (PRTR) in Europe and Japan. The US EPA is proposing to allow n-PB in some, but 

not all, end uses as a solvent, with a TLV (Threshold Limit Value) of 10ppm as an 8-hour 

time-weighted average of exposure (TWA) through its SNAP (Significant New Alternatives 

Policy) Program. Although n-PB has a finite ODP range of 0.02-0.1 similar to those of 

HCFCs and some chlorinated carbons, its use cannot be monitored and the growth of its use is 

unchecked. Thus, Parties may wish to establish a reporting system so accurate data for n-PB 

can be considered by the TEAP and CTOC. 
May 2010 TEAP Progress Report 49

Destruction Technologies 

The interest of the Montreal Protocol is to quantify the ODS destroyed and eligible for 

remanufacture and to assure environmental, occupational, health and safety. There is an 

additional interest to quantify the carbon value of ODS destroyed for possible consideration 

under national and private emissions trading schemes designed to protect climate. 

The CTOC identified at least 176 destruction facilities in 27 countries operated by a variety of 

technologies far wider than those reported in the 2002 TEAP Task Force Report. Current 

destruction technologies other than the twelve TEAP recommended technologies have been 

evaluated by the performance criteria of their own countries, as well as by those of the Task 

Force Report. 

The CTOC also observes that technology transfer to Article 5 countries has begun. This is 

likely to increase since ODS destruction can be expected to become more important in Article 

5 countries. 

The TEAP/CTOC has received information on four kinds of emerging destruction 

technologies for evaluation. Although these technologies are still confidential, the CTOC 

expects to be able to give advice on their acceptability through further communications. A US 

patent revealed a new technology to convert halons and CFCs to unsaturated fluoromonomers 

like vinylidene fluoride, which is useful for the production of poly vinylidene fluoride. 

Another proposal concerns the applicability of current destruction technologies to methyl 

bromide, which is very difficult to destroy by incineration. An emerging destruction 

technology is attempted by contacting methyl bromide with a thiosulphate solution in a liquid 

scrubber to yield methyl thiosulphate ions. 

In the revision of destruction technologies, technical guidelines for methyl bromide as well as 

authorized methods for newly developed destruction technologies might be required. 

Feedstocks 

The CTOC has updated the list of common feedstock applications and the estimated 

emissions from those feedstock uses. The list includes 16 feedstock applications and the total 

emissions from feedstock uses are estimated on the order of 4,000 metric tonnes (1,600 ODP 

tonnes). 

4.2 Introduction 

The CTOC met on March 10-12, 2010 in Beijing, China. The meeting was held on the 

campus of the Beijing University hosted by CTOC member, Professor Jianxin Hu, and his 

students. Fourteen of the 17 CTOC members were attended from China, India, Japan, Kuwait, 

Mauritius, Netherlands, Russia and USA. 

The primary purpose of the meeting was to discuss the response for the requests of the Parties 

in decisions XVII/6, XXI/6 and XIII/7 on process agents, laboratory and analytical uses, and 

n-PB, respectively. Furthermore, the CTOC reviewed a new essential use nomination of CFC113 from the Russian Federation under decisions IV/25 and VIII/9, and also reviewed those 

destruction technologies identified in the 2002 TEAP Task Force Report under the decision 

XXI/2 (3) and new information on several emerging destruction technologies submitted to the 

Ozone Secretariat for their recognition. Also the CTOC updated the list of common feedstock 

applications and the estimated emissions from those feedstock uses. 
50 May 2010 TEAP Progress Report 

4.3 Process Agents 

The CTOC reported in its 2009 Progress Report, a revision of table A of decisions X/14 and 

XIX/15 and of table B of decision X/14. 

The CTOC is reporting again the revision of table A and table B according to the decisions 

XVII/6 (7) and XVII/6 (8), respectively for consideration at the 22nd MOP in 2010. 

Decision XVII/6 regarding process agents was taken at the Dakar MOP in 2005and included 

the following paragraphs: 

6. To request the Technology and Economic Assessment Panel and the Executive 

Committee to report to the Open-ended Working Group at its twenty-seventh 

meeting in 2007, and every other year thereafter unless the Parties decide 

otherwise, on the progress made in reducing emissions of controlled substances 

from process-agent uses; the associated make-up quantity of controlled 

substances; on the implementation and development of emissions-reduction 

techniques and alternative processes and products not using ozone-depleting 

substances; 

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

information submitted in accordance with the present decision and to report and 

make recommendations to the Parties at their Twentieth Meeting in 2008, and 

every other year thereafter, on process-agent use exemptions; on insignificant 

emission associated with a use, and process-agent uses that could be added to or 

deleted from table A of decision X/14; 

8. To request Parties with process-agent uses to submit data to the Technology 

and Economic Assessment Panel by 31 December 2007 and 31 December of each 

subsequent year on opportunities to reduce emissions listed in table B and for the 

Technology and Economic Assessment Panel to review in 2008, and every other 

year thereafter, emissions in table B of decision X/14, taking into account 

information and data reported by the Parties in accordance with that decision, 

and to recommend any reductions to the make-up and maximum emission on the 

basis of that review. On the basis of these recommendations, the Parties shall 

decide on reductions to the make-up and maximum emissions with respect to 

table B; 

The implications are that the following reports would be required: 2007, 2009, 2011 ... 

progress made in reducing emissions, make-up quantities and implementation and 

development of emissions-reduction techniques and alternative processes and products. 

2008, 2010, 2012 ... process-agent use exemptions, insignificant emissions and uses that could 

be added to or deleted from table A of decision X/14; 

However, decision XXI/3 taken at Port Ghalib in 2009 included the following paragraphs: 

5. To request the Technology and Economic Assessment Panel and the Executive 

Committee of the Multilateral Fund to prepare a joint report for future meetings, 

reporting on progress with phasing out process-agent applications, as sought by 

Decision XVII/6 (paragraph 6); 

6. To revisit this issue at the 30th Meeting of the Open-ended Working Group; 
May 2010 TEAP Progress Report 51

The reference in paragraph 5 of decision XXI/3 to paragraph 6 of decision XVII/6 means that 

the joint report is required in 2011, that is, at OEWG 31. However, the succeeding paragraph 

6 of decision XXI/3, stating that parties will ‘revisit the issue’, implies that some report is 

required in 2010 at OEWG 30. Although a joint report by TEAP and the Executive 

Committee of the Multilateral Fund could not be prepared in time for the current progress 

report, TEAP and its CTOC would like to bring to the attention of the Parties that the 

quadrennial assessment report of CTOC due to be completed later in the year will contain 

some relevant information on the subject. 

New process agent uses, mostly in Article 5 countries, have been added to Table A of 

decision X/14 in recent years as parties learned more about the activities in the chemical 

industry sectors. The cut-off date, before which a process must have commenced in order to 

qualify the use of ODS as process agent, 30 June 1999, means that the number of such 

‘discoveries’ should soon reduce to zero. 

On the other hand, some process agent uses have ceased when the production is discontinued 

or alternatives to ODS have been introduced, and are removed from Table A of decision 

X/14. The MLF has been active in providing financial and technical assistance for such 

changes, and more cessations can be anticipated. The small number of uses that might remain 

on Table A of decision X/14, say in five years’ time, will be those that for economic or 

technical reasons are unlikely to be phased out or replaced by the use of alternatives. 

Emissions from process agent uses have not been well reported, and so it has not been 

possible for the CTOC to identify cases with excessive emissions for which remedial financial 

and technical assistance might be required. For the same reasons, it has not been possible to 

make creditable estimates of total emissions and to point to systematic reduction in emissions. 

4.3.1 Review of Table A of the decision X/14 

Data submitted by USA 

The US has reported the following process agent uses in the US 

1. Elimination of NCl3 in the production of Cl2/NaOH (1)* 

2. Recovery of chlorine in tail gas from production of Cl2 (2)* 

3. Manufacture of chlorosulphonated polyolefin (CSM) (6)* 

4. Manufacture of synthetic fiber sheet (8)* 

5. Bromination of a styrenic polymer (24)* 

6. Production of high modulus PE fiber (28)* 

* Reference number in table A 

Data submitted by EC 

The EC has reported that the following process agent uses have ceased in the EC: 

1. CTC in the manufacture of isobutyl acetophenone (5)* 

2. CTC for the production of radio-labelled cyanocobalamin (27)* 

3. CFC-113 in the production of perfluoropolyether-peroxide intermediate for the 

production of perfluoropolyether diester (11)* 

*Reference number in table A 

The CTOC recommends deleting the three mentioned process agent uses reported by EC from 

table A, if no other countries than EC have these applications. 
52 May 2010 TEAP Progress Report 

4.3.2 Review of Table B of the decision X/14 

Table 4-1 shows table B of decision X/14 with reported data in 2008 (submitted in 2009). 

Not all the data have been available, but the reported data by USA are in line with table B of 

decision X/14. The make-up limit for EC was slightly exceeded in 2008; countermeasures are 

being taken in the EC to be in compliance with the make-up quantities as mentioned in table 

BAs of 4 May 2010, Armenia, Australia, Canada, Cyprus, Hungary, Jamaica, Macedonia, 

Panama, Poland, Saint Lucia and Sweden have reported that no process agent applications are 

in use in those Parties. Due to the fact that not all the data are available, the CTOC cannot 

make any recommendation on reductions to the make-up and maximum emission regarding 

table B of decision X/14. The CTOC recommends that countries having no process agent uses 

be removed from table B.

Remark: The make-up quantities for the EC were mainly based on the quantities brought 

forwards in 1998 and no significant changes have been made, even not when new process 

agent applications with significant make-up quantities were added to table B in later years. 

Table 4-1: Updated table B of decision X/14 (Expressed by metric tonnes per year) 

Countries/Regions 

Maximum 

make-up or 

consumption 

Reported make-up 

or consumption 

(2008) 

Maximum 

emissions 

Reported 

emissions 

(2008) 

European 

Community 1083 1159* 17 1.6 

United States of 

America 2300 No data? 181 82 

Canada 13 No data 0 No data 

Japan 0 No data 0 No data 

Russian Federation 800 No data 17 No data 

Australia 0 No data 0 No data 

New Zealand 0 No data 0 No data 

Norway 0 No data 0 No data 

Iceland 0 No data 0 No data 

Switzerland 5 No data 0.4 No data 

TOTAL 4201 ? 215.4 83.6 

In view of the reporting of process agent uses and emissions required by the decision of the 

21st MOP, the CTOC expects to be able to provide a more comprehensive report in 2011 

when this reporting is completed by Parties in 2010. Parties were sent a reminder from the 

Ozone Secretariat in April. 

CTC Emissions 

In the EC the emission to air in 2007 (excluding incidents 1.2 tonnes) was 63 metric tonnes, 

references: http://prtr.ec.europa.eu/PollutantReleases.aspx. These emissions were from 17 

facilities in the EC. The threshold for reporting was 100 kg. Besides the emission to air there 

are 54 facilities in the EC that have emissions to water from more than 1 kg per year in 2007. 

It seems likely that the use of CTC in these facilities is not all feedstock use or process agent 

use. In some cases CTC might be formed during the process and afterwards emitted. This 

emission level is significantly higher than the reported process agent emissions of 5 metric 

tonnes in 2006 from the EC. The CTOC recommends that the EC investigates these processes 

and their emissions and clarifies whether they arise from process agent, feedstock, inadvertent 

production or other uses. 
May 2010 TEAP Progress Report 53

4.3.3 Request of Switzerland 

The Swiss government asked the CTOC to consider an application for process agent 

exemption for a new manufacturing process utilizing carbon tetrachloride (CTC). The CTOC 

notes that this process was not in operation prior to 1999 and therefore would not qualify for a 

process agent exemption. However, further discussion revealed that the proposed use was as 

feedstock. 

4.4 Laboratory and analytical uses of ODS 

Decision XXI/6 included the following points that are addressed in this report. 

5. To request the TEAP and its Chemicals Technical Options Committee to complete 

the report as requested under Decision XIX/18 and to provide for the 30th Open Ended 

Working Group 

(a) A list of laboratory and analytical uses of ODS, including those uses where no 

alternatives exist. 

(b) To identify the international and national standards that require the use of ODS 

and to indicate the corresponding alternative standard methods not mandating the use 

of ODS. 

(c) To consider the technical and economical availability of those alternatives in 

Article 5 and non-Article 5 parties as well as to ensure that the alternative methods 

show similar or better statistical properties (for example accuracy or detection limits). 

6. To request TEAP while continuing its work as described in paragraph 5, to 

evaluate the availability of alternatives for those uses already banned under the global 

exemption in Parties operating under Article 5(1), considering technical and 

economical aspects. By the 30th meeting of the Open Ended Working Group TEAP 

should present its findings and recommendations whether exemptions would be 

required for parties operating under paragraph 1 of Article 5 for any of the uses 

already banned. 

The CTOC reminds that the following conditions apply to the exemption for laboratory and 

analytical uses and are listed in Annex II of the report of the 6th MOP: 

1. Laboratory purposes are identified at this time to include equipment 

calibration; use as extraction solvents, diluents, or carriers for chemical analysis; 

biochemical research; inert solvents for chemical reactions, as a carrier or laboratory 

chemical and other critical analytical and laboratory purposes. Production for 

laboratory and analytical purposes is authorized provided that these laboratory and 

analytical chemicals shall contain only controlled substances manufactured to the 

following purities: 

CTC (reagent grade) 99.5 % 

1,1,1-trichloroethane 99.0 % 

CFC-11 99.5 % 

CFC-13 99.5 % 

CFC-12 99.5 % 

CFC-113 99.5 % 

CFC-114 99.5 % 

Other w/Boiling P>20o C 99.5 % 

Other w/Boiling P<20o C 99.0 % 
54 May 2010 TEAP Progress Report 

2. These pure controlled substances can be subsequently mixed by 

manufacturers, agents, or distributors with other chemicals controlled or not 

controlled by the Montreal Protocol as is customary for laboratory and analytical 

uses. 

3. These high purity substances and mixtures containing controlled substances 

shall be supplied only in re-closable containers or high pressure cylinders smaller than 

three litres or in 10 millilitre or smaller glass ampoules, marked clearly as substances 

that deplete the ozone layer, restricted to laboratory use and analytical purposes and 

specifying that used or surplus substances should be collected and recycled, if 

practical. The material should be destroyed if recycling is not practical. 

4. Parties shall annually report for each controlled substance produced: the 

purity; the quantity; the application, specific test standard, or procedure requiring its 

uses; and the status of efforts to eliminate its use in each application. Parties shall also 

submit copies of published instructions, standards, specifications, and regulations 

requiring the use of the controlled substance. 

CTOC's work on decision XXI/6 paragraphs 5 and 6 is still ongoing. CTOC will endeavour 

to provide some further information at MOP22. TEAP and its CTOC would appreciate 

having information from the Article 5Parties if they have any laboratory and analytical uses 

that are already banned from the exemption. The information would enable TEAP and its 

CTOC to carry out the task under decision XXI/6 paragraph 6. 

4.4.1 Uses already banned 

Recalling Decisions VII/11, XI/15, XVIII/15 and XIX/18 that already eliminated the 

following uses from the global exemption for laboratory and analytical uses: 

(a) Refrigeration and air conditioning equipment used in laboratories, including 

refrigerated laboratory equipment such as ultra-centrifuges; 

(b) Cleaning, reworking, repair, or rebuilding of electronic components or 

assemblies; 

(c) Preservation of publications and archives; 

(d) Sterilization of materials in a laboratory; 

(e) Testing of oil, grease and total petroleum hydrocarbons in water; 

(f) Testing of tar in road-paving materials; 

(g) Forensic finger-printing; 

(i) Testing of organic matter in coal 

4.4.2 Methyl bromide exemptions 

In 2006 the Parties decided (Decision XVII/10) that ‘subject to the conditions applied to the 

exemption for laboratory and analytical uses contained in Annex H to the report of the Sixth 

meeting of the Parties, to adopt a category of laboratory and analytical critical use to allow 

methyl bromide to be used: 
May 2010 TEAP Progress Report 55

(i) As a reference or standard: 

- To calibrate equipment which uses methyl bromide; 

- To monitor methyl bromide emission levels; 

- To determine methyl bromide residue levels in goods, plants and commodities; 

(ii) In laboratory toxicological studies; 

(iii)To compare the efficacy of methyl bromide and its alternatives inside a laboratory; 

(iv)As a laboratory agent which is destroyed in a chemical reaction; 

4.4.3 Recommendations 

The methods presented in the 2009 Progress Report have been further investigated and in 

almost all cases suitable alternative procedures have been identified, confirming the advice 

provided in 2009. The Appendix to this report contains details of the uses and analyses, 

including the reasons why ODS were used. 

Based on this investigation, TEAP/CTOC recommends that the following procedures (Table 

4-2) be removed from the global exemption for laboratory and analytical uses of ODS. 

Table 4-2: Recommendation of procedures to be removed 

Kinds of ODS Procedures 

Methyl Bromide Laboratory uses as a methylating agent 

Carbon tetrachloride 

(CTC) 

Reaction solvents except reactions involving N-bromosuccinimide 

 (see below) 

CTC A solvent for IR, Raman and NMR spectroscopy 

CTC Grease removal and washing of NMR tubes 

CTC Iodine partition and equilibrium experiments 

CTC Analysis of hydrocarbon oils and greases in water, soil or oil mist in air 

CTC Analysis of polydimetylsiloxane and medicinal products such as simethicone 

that contain this substance 

CTC A solvent for assay of cyanocobalamin (Vitamin B12) 

1,1,1-trichloroethane 

(TCA) 

Determination of bromine index 

CTC and other 

ODSs 

Analysis involving selective solubility, including analyses of cascarosides, 

thyroid extracts and polymers, and in formation of picrates 

CTC Preconcentration of analytes in liquid chromatography (HPLC) gas 

chromatography, adsorption chromatography of organic substances, atomic 

absorption spectroscopy and X-ray fluorescence analysis 

CTC Detection of the end point in titrations involving iodine and thiosulphate 

(iodometry) for analysis of iodine, copper, arsenic, hypochlorite, chrorate, 

bromate or sulfur 

CTC Determination of iodine index 
56 May 2010 TEAP Progress Report 

Kinds of ODS Procedures 

CTC Determination of jellification point of agar, cement analysis and gas-mask 

cartridge breakthrough 

CTC Determination of porosity of activated carbon, 

TEAP/CTOC recommends that the general exemption for laboratory and analytical uses of 

ODS should be retained for the following procedures in Table 4-3. 

Table 4-3 Recommendation of procedures to be retained 

Kind of ODS Procedures 

CTC A solvent for reactions involving N-bromosuccineimide 

CTC A chain transfer agent in free-radical polymerization reactions 

CTC Biomedical research (see Section 3.5, below) 

TEAP/CTOC note that the earlier information about the use of CTC in determining stiffness 

of leather was in error and so this procedure (ASTM D2821) is not of concern. 

4.4.4 Briefings by CTOC 

Decision XXI/6 also included the following clause: 

10. To encourage UNEP to invite representatives of the Chemicals Technical Options 

Committee to regional network meetings to raise awareness of ODS alternatives for 

laboratory and analytical uses where problems have been specifically identified by 

members of that network. Where considered necessary other representatives from 

competent authorities of Parties could be invited to participate in the meeting. 

This work has already commenced, with a presentation by a CTOC co-chair at the regional 

meeting of South Asia and South East Asia Pacific ozone officers in Chiang Mai, Thailand, in 

October 2009. In April 2010 a CTOC member made a presentation at the meeting of Europe 

and Central Asia and South Asia ozone officers in Istanbul, Turkey. UNDP has also 

supported the provision of advice to laboratory users in Chile, Paraguay and Bolivia. 

4.4.5 Use of CTC in biomedical research 

This use is widespread in biomedical research but has only recently come to the attention of 

the CTOC. 

Damage to liver cells can lead to their replacement by scar tissue and development of fibrous 

tissue (fibrosis), a condition that is often identified under the heading of ‘cirrhosis’. Alcoholic 

poisoning is a well-known cause of this condition but there are other causes and congenital 

hepatic (liver) fibrosis may be present. In order to study the condition, its effect on other 

body functions and progression and recovery of the condition, liver fibrosis is induced in 

experimental animals by dosing with chemical substances, among which is CTC. A typical 

experiment would involve intraparenteral injection of CTC (1 ml/kg) twice weekly for 4-12 

weeks. Oral gavages may also be used for CTC administration. 

Because CTC has been used in this way for many years, there is a large body of research on 

biochemical modes of action, the role of oxidative and classical reductive metabolism related 
May 2010 TEAP Progress Report 57

to liver toxicity. These are benchmarks against which new results can be assessed. Modern 

studies frequently use CTC in conjunction with ethanol or paracetamol (other classical liver 

toxins) to investigate genetic responses to liver damage. The research is directed at 

improvements to human health. A review that describes the research field, including the use 

of CTC and other hepatic toxins, was published in 2008 (K. Wallace, A.D. Burt and M.C. 

Wright, ‘Liver fibrosis’, Biochemical Journal, 411 (1), 1-18 (2008)). Further detail is 

available in the journal Methods in Molecular Medicine, 117 2005, in particular in C. 

Constandinou, N. Henderson and J.P. Iredale, ‘Modeling Liver Fibrosis in Rodents’, Methods 

in Molecular Medicine, 117, 237-250 (2005). 

Other substances can be used to induce fibrosis – dimethylnitrosamine, thioacetamide, pig 

serum – and it may also be induced by feeding a diet deficient in two essential substances 

(methionine and choline). Each of these alternatives produces its own particular type of liver 

damage but for certain research directions the use of CTC is essential. Also, CTC is by far 

the most widely used hepatotoxin. A Google search identified over 3000 articles using and 

referencing the use of CTC in liver fibrosis research on mice over the five year period 2005-

2010. 

In any one institution, the quantities of CTC used are small but world-wide consumption is 

unknown. Because of the method of administration to experimental animals (mice) there are 

no emissions to air. Some of the CTC may be converted in vivo to non-ozone depleting 

substances. Any residual material is disposed of in bio-hazardous waste for which the 

disposal technology involves incineration. 

This resembles an approved use for another ODS, methyl bromide, in ‘laboratory 

toxicological studies’ (Decision XVII/10). 

4.5 Essential Use Exemptions of CFC-113 in the Russian Federation 

The Ministry of National Resources and Ecology of the Russian Federation has sent a new 

request for Essential Use Exemptions of 100 metric tonnes of CFC-113 for manufacturing the 

missile and space equipments in the year 2011, to the Ozone Secretariat on January 14, 2010. 

The TEAP/CTOC has reviewed this nomination and recommends the EUE for 100 metric 

tonnes of CFC-113 in 2011 for the Russian Federation. 

4.5.1 Background of the nomination 

Decision XXI/5 in MOP-21 approved an essential use exemption of 120 metric tonnes of 

CFC-113 in 2010 for applications in the missile and aerospace industries in the Russian 

Federation, taking into consideration the TEAP/CTOC findings that no appropriate 

alternatives to CFC-113 currently exist for some uses in the aerospace industries in the 

Russian Federation and that the search for alternatives continues, as confirmed in the TEAP 

May 2009 Progress Report Vol.1 (p60-79) 

4.5.2 The CTOC comments on EUE of CFC-113 in 2011 by the Russian 

Federation 

The Russian Federation has been successful in reducing the annual consumption of CFC-113 

in the missile and space industry from 241 metric tonnes in 2001 to 120 metric tonnes in 2009 

as shown in the Illustration 2 (TEAP May 2009 Progress Report Vol.1, p79). However, the 

Russian industry has found no solvents comparable to CFC-113 from viewpoints of cleaning 

efficiency, versatility and compatibility with structural materials. 
58 May 2010 TEAP Progress Report 

The new request by the Russian Federation for an Essential Use Exemption for 100 metric 

tonnes of CFC-113 in the year 2011 describes and explains in detail, why this application is 

urgent for health and safety or vital for the society, what efforts are made to investigate 

currently available alternatives, why they are insufficient or unsuitable, and also efforts for 

minimizing emission of CFC-113. 

Unique physicochemical properties, and high processing and operational characteristics of 

CFC-113 ensure the required cleanliness levels of parts and assembly units, and high tightness 

levels of the missile and space equipment. Faultless and reliable operation in those 

applications, and consequently, the life and health of spacecraft crews, personnel and 

communities in launching area depend on proper selection of the cleaning solvent for those 

parts and equipment. In particular failures of gyro instruments of the launch vehicle or space 

vehicle control system can lead to fatal situations and faulty liquid-propellant rocket systems, 

which use liquid oxygen as an oxidizer, can result explosions during launching. 

So far, solvents tested to replace CFC-113 have included ozone-safe organic solvents, 

chlorocarbon solvents, aqueous detergents, transitional HCFC solvents (HCFC-122, HCFC122a, HCFC-141b and HCFC-225), fluorocarbons and n-PB. 

But none of those candidates could meet the requirements for the replacement of CFC-113. 

In order to minimize emissions of CFC-113, recirculation and stock accumulation have been 

attempted, but recycled and accumulated stock of CFC-113 is not available in sufficient 

quality for the expected application. 

The Russian new nomination satisfies the following criteria to qualify as “Essential” under 

the decision IV/25. 

1. It is necessary for the health, safety or critical for the functioning of the society. 

2. There are no available technically and economically feasible alternatives or 

substitutes that are acceptable from the standpoint of environment and health. 

3. An action has been attempted to minimize emission of CFC-113. 

4.5.3 Conclusions 

The TEAP/CTOC recommends the Essential Use Exemptions for 100 metric tonnes of CFC113 in 2011 for the Russian Federation. 

Taking into account the reductions achieved so far and assuming the timely conversion of the 

missile and space industry to technologies that avoid or restrict application of CFC-113, the 

Russian Federation has forecasted the future reduction plan as follows: ~80 metric tonnes in 

2012, ~50 metric tonnes in 2013 and ~35 metric tonnes in 2014. 

The TEAP/CTOC acknowledges the projected reduction, but recommends greater efforts for 

the introduction of appropriate alternatives, of materials compatible with non-ODS alternative 

solvents, and adoption of newly designed equipment to complete phase-out of CFC-113 

within an accelerated time schedule. 
May 2010 TEAP Progress Report 59

4.6 n-Propyl Bromide (n-PB) Update 

Under Decision XIII/7, the TEAP has been requested to report annually on n-PB use and 

emissions. 

The properties of n-PB including its ODP remain the same and its field of application has not 

significantly changed from what has been reported in the 2008 CTOC Progress Report except 

that there were some recommendations from the manufacturers that it could be used as 

replacement for hydrocarbons or chlorinated solvents for paint application. 

The global production level is still estimated to be around 20,000-30,000 metric tonnes (2007) 

as reported in the 2008 Progress Report. It is assumed to be produced in China, France, India, 

Israel, Japan, Jordan and the USA. China is estimated to have produced around 20,000 metric 

tonnes in 2008, of which approximately 40% were exported. Solvent use in Japan was 1,100-

1,200 metric tonnes in 2009 showing that the use is leveling off in Japan as mentioned in the 

2008 progress report. No information is available for other regions. 

Obtaining more complete and accurate data on production and uses of n-PB, as well as its 

emissions, continues to be difficult. No governmental records are available on emission or 

uses since n-PB is not classified or registered as a controlled chemical substance like CFCs, 

and HCFCs (ODS class I and II) nor designated as a hazardous air pollutant in the Clean Air 

Act in the USA or reportable compound for pollution release (emission) and transfer (PRTR) 

in Europe and Japan. Although n-PB has a finite ODP range of 0.02-0.1 similar to those of 

HCFCs and organo-halogens, its use cannot be monitored and its use growth is kept 

unchecked. Thus, Parties may wish to establish a reporting system so accurate data for n-PB 

can be considered by the CTOC and TEAP. 

The situation of n-PB toxicity study remains the same as described in the 2006 and 2008 

CTOC Progress Report. It has low acute toxicity but its complete toxicological profile 
60 May 2010 TEAP Progress Report 

necessitates a low exposure guideline. ACGIH and Israel have set an exposure guideline of 

10ppm, with Europe setting the lowest 8-hour occupational exposure limit (OEL) value in 

humans and enforcing the tightest labeling classification. The US EPA is proposing to allow 

n-PB in some, but not all, end uses as a solvent, with a TLV (Threshold Limit Value) of 

10ppm as an 8-hour time-weighted average of exposure (TWA) through its SNAP 

(Significant New Alternatives Policy) Program, although OSHA has not yet issued a 

Permissible Exposure Limit (PEL) for n-PB. (2007 Final and Proposed Regulations for n-PB 

by US EPA)

4.7 Destruction Technologies (related to decision XXI/2 (3) 

4.7.1 Review of 2002 Task Force Report 

The 2002 TEAP Task Force on Destruction Technologies considered 45 technologies 

candidates and sixteen destruction technologies were screened-in. In addition the Task Force 

reported suggested minimum standards of DRE (destruction and removal efficiencies (99.99 

% for concentrated sources and 95% for ODS in foams) and criteria for atmospheric 

emissions such as PCDDs/PCDFs, HF, and so on. The “screened-in” technologies were 

evaluated further with emphasis on actual data about ODS destruction performance. Of these, 

twelve technologies met the recommended criteria. 

From the documents distributed by the Ozone Secretariat until October 2009, the CTOC 

identified at least 176 destruction facilities in 27 countries which are being operated. Present 

destruction facilities are operated by a variety of technologies far wider than those listed in 

the 2002 Task Force technologies. The technologies applied are classified into four 

categories, i.e. high temperature incineration, furnaces dedicated to manufacturing, plasma, 

and other non-incineration. Furnaces dedicated to manufacturing include cement kilns, lime 

rotary kilns, electric furnace, sulfuric acid recovery furnace and lightweight aggregate kilns. 

Other non-incineration technologies include catalytic destruction, chemical treatment and 

solid-phase alkaline reactor. As indicated in the 2002 Task Force report, the suggested 

minimum standards of technical performance are guidelines for selecting the destruction 

technologies. 

Current destruction technologies other than the twelve TEAP recommended technologies 

were evaluated against the performance criteria of their own countries, as well as by those of 

the 2002 Task Force report. The United States of America, for instance, has established their 

domestic technologies permitted by RCRA requirements and ODS has been destroyed under 

MACT (Maximum Achievable Control Technology) standards for destruction efficiency (DE) 

and atmospheric emissions. In European countries, ODSs are destroyed by the technologies 

recommended by the 2002 Task Force report and by a variety of incinerators that are used for 

PCB/POPs destruction. Japan has permitted the destruction technologies based on the Law of 

Fluorocarbon Recovery and Destruction. 

The CTOC also observes that technology transfer to Article 5 countries has begun. The ODS 

destruction project in Indonesia using cement kiln project was supported by the Japanese 

government and a private company. Such assistance to Article 5 countries is likely to increase 

since ODS destruction can be expected to be more important in such countries. 

Owing to the existence of above-mentioned facilities, since 1993 the EU and US have 

destroyed 114,603 and 38,278 tonnes of ODS, respectively. Japan has destroyed 25,925 

tonnes of CFCs, HCFCs and HFCs. Recently, Korea, China, Brazil and some Article 5 

countries have started destruction of ODS. 
May 2010 TEAP Progress Report 61

4.7.2 Emerging Destruction Technologies 

The CTOC has received information on four kinds of emerging destruction technologies for 

evaluation (Table 6.2.1). Although these technologies are still confidential, the CTOC expects 

to be able to give advice on their acceptability. Appropriate advice has been sent to the 

developers regarding technical performance of these technologies and suitable substances to 

be destroyed under destruction conditions. Since details of the technical information are not 

available presently, these technologies will be evaluated by further communication. 

One technology, Newcastle process, is covered by a US patent 0036719 (2009) to Kennedy, 

et al. Halons or CFCs have been processed on a pilot scale, 25 kg/hour, with 99.8% 

conversion and vinylidene fluoride as a major product. At higher temperatures, the conversion 

efficiency is over 99.99% for halons and CFCs. No dioxins have been detected. 

Another proposal concerns the applicability of current destruction technologies to methyl 

bromide (MB). Although MB among ODS is the most difficult to destroy by incineration1), 

annual amounts of MB destruction ranging from year of 1991 to 2003 were reported by US 

(May 2009). Amount destroyed in 2002 was 4,713 metric tonnes (Table 4-5). 

Commercial recapture systems for MB have been developed based on adsorption of MB from 

treatment containers and chambers on activated carbon. An emerging destruction technology 

was attempted by contacting MB released from activated carbon with a thiosulphate solution 

in a liquid scrubber to yield methyl thiosulphate ions. 

Table 4-4: Proposed Emerging Destruction Technologies 

Organisation Nation Fluorocarbons 

Destroyed 

Evaluation 

Lesni A/S Denmark CFCs, HFCs Destruction of dilute fluorocarbons by 

catalytic cracking 

Midwest 

Refrigerants, LLC 

United States of 

America 

CFCs, HCFCs, HFCs, 

PFCs, Halons 

Transformation of fluorocarbons by 

pyrolytic conversion 

SGL Carbon 

GmbH 

Germany HCFCs, HFCs, CCl4 Destruction of concentrated sources by a 

porous reactor 

University of 

Newcastle 

Australia Halons, CFCs Transformation of fluorocarbons to 

fluorinated vinyl monomers 

SRL Plasma Pty 

Ltd 

Australia Methyl bromide Applicability of present destruction 

technologies to methyl bromide 
62 May 2010 TEAP Progress Report 

Table 4-5: Destruction of Methyl Bromide in the United States of America2)

Year 1991 1992 1993 1994 1995 1996 1997 

Methyl 

bromide 

destroyed 

264,227 53,953 47,20 84,956 2,257,735 300,431 562,872

Year 1998 1999 2000 2001 2002 2003 

Methyl 

bromide 

destroyed 

323,943 634,830 611,938 1,145,955 4,713,595 2,237,757 

References 

1) B. Dellinger and P. H. Taylor, “Handbook: Guidance on setting permit conditions and reporting trial 

burn results, Appendix D” US EPA/625/6-89/019, (1989). 

2) UNEP/OzL.Pro/Workshop.3/INF/1, 26 June 2009, “ODS Destruction in the United States of 

America and Abroad (May 2009), Prepared by ICF International for U.S. EPA’s Stratospheric 

Protection Division”: Table 10: Reported Kilograms of ODS Destroyed by Type, as Reported in TRI 

(1991 – 2003) 

4.8 Feedstocks 

The CTOC has updated the list of common feedstock applications and the estimated 

emissions from feedstock uses of ODSs since the CTOC reported them in 2008. 

Carbon tetrachloride (CTC), trichloroethane, halons, chlorofluorocarbons (CFCs) and 

hydrochlorofluorocarbons (HCFCs) serve as chemical building blocks in the preparation of 

other chemicals. In their use as a raw material, they are fully converted to other products 

except for de minimus residues. As a result, their environmental impact is avoided with the 

exception of very small amounts. These could be residual levels in the ultimate product 

(which are typically miniscule) or by fugitive leaks in the production, storage and/or transport 

processes. 

Montreal Protocol definitions 

The Montreal Protocol defines “Production” as: “Production means the amount of controlled 

substances produced, minus the amount destroyed by technologies to be approved by the 

Parties and minus the amount entirely used as feedstock in the manufacture of other 

chemicals. The amount recycled and reused is not to be considered as Production.” Based on 

this definition, continuing use of feedstocks is allowed. 

4.8.1 Where they are used 

CTC, halons, CFCs and HCFCs can be feedstocks either by being fed directly into the process 

as a raw material stream or as an intermediate created during the synthesis of another product. 

Losses can occur during production, storage, transport, if necessary, and transfers. 

Intermediates are normally used at the same site and so fugitive leaks are somewhat lower in 

this case. 
May 2010 TEAP Progress Report 63

Common feedstock applications include, but are not limited to the following: 

- Conversion of Halon-1301 in manufacture of pesticides and pharmacueticals 

- Conversion of HCFC-21 in the synthesis of HCFC-225 which finds application as a 

solvent 

- Conversion of CFC-113 to chlorotrifluoroethylene. The latter is subsequently 

polymerized to polychlorotrifluoroethylene, a barrier resin used in moisture-resistant 

packaging. 

- Conversion of CFC-113 and CFC-113a to HFC-134a and HFC-125. As this is the 

route to much of the HFC volumes, it is a high volume use. 

- Conversion of HCFC-22 to tetrafluoroethylene (TFE). TFE forms the building block 

of many fluoropolymers both by homopolymerization and copolymerization. This is 

a very high volume use. 

- Conversion of 1,1,1- trichloroethane (TCA) as a feedstock in the production of 

HCFC-141b and HCFC-142b. This can continue until 2040 at high volume for 

emissive uses of these products and can continue long-term for uses related to 

conversion to polymers as noted below. Note that the cap and subsequent reduction 

of HCFC volumes globally will eventually reduce this use. 

- Conversion of HCFC-142b to vinylidene fluoride which is polymerized to 

polyvinylidene fluoride or to copolymers. These are specialty elastomers. This use of 

HCFC-142b is not subject to phase-out 

- Conversion of carbon tetrachloride (CTC) to CFC-11, CFC-12, etc. This has 

historically been a very high volume application. However, as the phase-out of CFC 

production progressed and production became limited to essential uses, the volume of 

CTC for this application has diminished significantly. 

- Conversion of CTC to chlorocarbons which, in turn, are used as feedstocks in 

production of HFC-245fa and other fluorochemicals. 

- Reaction of CTC with 2-chloropropene to eventually lead to production of HFC365mfc. 

- CTC is used in reaction with vinylidene chloride for preparation of HFC-236fa with 

production volumes under 1 million pounds annually. 

- CTC is converted to DV acid chloride in the manufacture of synthetic pyrethroids 

- Conversion of HCFC-123, HFC-123a and HFC-133a in manufacture of 

pharmaceuticals which are not subject to phase-out. 

- Conversion of HCFC-123 in the production of HFC-125. While this usually occurs 

as an intermediate, it is possible that this could be done using HCFC-123 as a starting 

material. We are not aware of using HCFC-123 as a starting material at this time. 

- HCFC-124 can be used as a feedstock to prepare HFC-125. 
64 May 2010 TEAP Progress Report 

4.8.2 Estimated emissions of ODS 

The IPCC recommends that emissions can be estimated from production facilities at 0.5% for 

HFCs and 0.2% for SF6. This includes fugitive and transport emissions. If one accepts that 

0.5% is an appropriate guidance level for products transported and used as raw materials, 

calculations from 2008 production data suggest that: 

CFC-113 used in production of HFCs = 351,000 tonnes 

Emission volume of ODS = 1758 tonnes 

ODP impact of emissions = 1406 ODP tonnes 

HCFC-22 used in production of fluoropolymers = 307,000 tonnes 

Emission of ODS = 1364 tonnes 

ODP impact of emissions = 68 ODP tonnes 

TCA used in production of HFCs = 175,000 tonnes (2008) 

Emission volume of ODS = 870 tonnes 

ODP impact of emissions = 87 ODP tonnes 

CTC used in production of CFCs = 2859 tonnes (yr. 2008) 

Emission of ODS = 14 tonnes 

ODP impact of emissions =17 ODP tonnes 

These data are only for emissions associated with manufacture and do not include any 

emissions related to uses. Therefore, total emissions from feedstock use are on the order of 

4,000 metric tonnes and contribute about 1600 ODP tonnes. Numbers could be higher if 

actual emissions were higher than the 0.5% guideline. 
May 2010 TEAP Progress Report 65

Appendix to Chapter 4: Details of Laboratory and Analytical Uses of 

ODS 

A1 Laboratory uses of ODS

The laboratory and analytical uses of methyl bromide and other ODS were discussed in the 

2006 Progress Report of the TEAP. The 2008 TEAP Progress report contained details of a 

number of these procedures and the non-ODS alternatives, and the 2009 TEAP progress 

report contained an extensive tabulation of methods using ODS and approved or 

recommended non-ODS alternatives. 

Whether the ODS is recovered, consigned for destruction (together with other laboratory 

wastes) or released to the environment, the quantities involved are trivial when compared to 

those involved in chemical industry, although there is no accounting of them by Parties. 

A1.1 Laboratory preparative uses 

(i) methyl bromide Methyl bromide has often been the reagent of choice for reactions in 

which the methyl group, CH3-, is transferred from bromine to an atom such as oxygen, 

nitrogen, phosphorus or magnesium. The most common case is that of formation of 

quaternary ammonium salts:

R3N + CH3-Br → R3N-CH3

+

 + BrHere, R represents other groups attached to the nitrogen. Ether linkages are established by 

reaction with oxygen, for example CH3-O-R, but in the case of phosphorus the initial salt is 

reacted further (by reaction with base, to remove HBr) to an ylid containing the =CH2

function: 

R3P + CH3-Br → R3P-CH3

+

 + Br- → R3P=CH2

The ylid may be reacted further to transfer the =CH2 moiety to another molecule. Sulfurbased ylids are also known: they are prepared and used in ways analogous to the phosphorus 

ylids. 

Methyl bromide reacts with magnesium to form methyl magnesium bromide, CH3-Mg-Br, 

from which the methyl group may be transferred to another molecule, and a new carboncarbon bond established. 

For all of these reactions there are alternatives to the use of methyl bromide, such as methyl 

chloride (chloromethane), methyl iodide, trimethyl phosphate and various methyl sulfonate 

esters. Cost and availability are not barriers to uptake of the alternatives, but long-term users 

of methyl bromide in these applications may need to experiment so as to adapt their practice 

to the alternative methylating agents. 

A critical use exemption for ‘preparative’ uses of methyl bromide, in which the ODS is 

destroyed, was included in decision XVII/10. 

(ii) carbon tetrachloride (CTC) As with methyl bromide, these uses involve transfer of all 

or part of the CTC molecule to another molecule. A common reaction is the addition of CTC, 

via a free radical mechanism (involving and initiator radical and radical fragments Cl.

 And 

Cl3C.

), to a carbon-carbon double bond:

CCl4 + -CH=CH- → Cl3C –CH-CH-Cl 
66 May 2010 TEAP Progress Report 

Except that a more complicated alternative synthesis pathway be adopted, possibly more 

complex and expensive, there are no alternatives to the use of CTC in such reactions. 

In the Appel reaction, CTC reacts with triphenyl phosphine in a complicated way to replace 

the –OH group in an alcohol with chlorine while the CTC is converted to chloroform 

(trichloromethane): 

PPh3 + CCl4 + RCH2OH → OPPh3 + RCH2Cl + CHCl3

There is an analogous reaction with carbon tetrabromide, with bromine replacing chlorine in 

the above reaction scheme. 

(iii) difluoromethylation with HCFC-22 HCFC-22, CHClF2, may be used to transfer a –

CF2 group to another molecule, for example, an alkoxide formed from an alcohol:

RO-

 + CHClF2 → RO-CHF2 + ClThis reaction can also be performed with halon 22B1, CHBrF2, by displacement of bromine. 

(iv) reactions with bromochloromethane (BCM) Reactions in which a halogen such as 

chlorine or bromine is displaced from the molecule of a controlled substance, with formation 

of a new bond between the carbon atom and a carbon, sulfur, oxygen or nitrogen atom, can be 

performed with BCM. It is even possible to perform stepwise reactions, with the bromine 

being displaced first, and the chlorine next (under more vigorous conditions):

R(1) + CH2BrCl → R(1)-CH2-Cl 

R(2) + R(1)-CH2-Cl → R(1)-CH2-R(2) 

There is an example in the industrial production of the antibiotic sultamicillin, for which the 

use BCM is used in large excess in the first step. 

A1.2 Laboratory solvent uses 

(i) CTC in chemical reactions CTC has been widely used as a solvent in synthetic organic 

chemistry for reactions in which two or more components are dissolved in the solvent and 

heated to form new substances. These are recovered by cooling followed by appropriate 

‘work up’ often involving evaporation (and potential recovery) of the CTC. CTC is used in 

the chemical industry for one or more of the following reasons: reasonably good solvency, 

does not attack common materials including many elastomers used in reaction vessels, nonflammable and not easily degraded under conditions of use, easily removed by evaporation or 

distillation without excessive energy consumption, readily available at affordable prices. 

Many of the industrial uses of CTC stem from patented procedures that were developed in 

laboratories. Where such laboratory work is destined to become an industrial process, 

consideration needs to be given to finding an alternative solvent at the outset. 

Trichloroethylene, which is not a controlled substance, meets many of the above criteria but 

must be handled with care because of toxicity concerns that also apply to CTC. 

The one chemical reaction that the CTOC has been able to discover in which no alternative 

has been found for CTC is its use as a solvent in bromination reactions using Nbromosuccinimide (depicted below as succ-N-Br): 

Succ-N-Br + CH3-C=C- → Succ-N-H + BrCH2-C=C- 
May 2010 TEAP Progress Report 67

The reaction, conducted under mild conditions (with boiling CTC), is specific for conversion 

of –CH groups to –CBr when the CH is in an allylic position (one carbon away from a double 

bond or aromatic ring) as shown. During the reaction, the soluble Succ-N-Br is replaced by 

insoluble Succ-N-H as the reaction proceeds, and it is thought that this differential solubility 

in CTC is important to the success of the reaction. Some experiments have been conducted to 

identify a suitable alternative solvent, but so far without success. 

(ii) chain transfer during polymerization Small quantities of CTC are included in reaction 

mixtures for free-radical-induced polymerization of methyl methacrylate to polymethyl 

methacrylate. The CTC functions as a chain-transfer reagent, stopping the growth of polymer 

chains with concomitant initiation of a new polymer chain. The overall effect is to limit chain 

size and so influence the properties of the resulting polymer. 

Other chain transfer agents are available, and newer methods of polymerization are available 

that obviate the need for this technology. However, conservatism in the laboratory is likely to 

see only slow movement away from the use of CTC. 

(iii) CTC in spectroscopy The use of CTC in analytical spectroscopy is detailed in section 

3.2.1 below. However, there are non-analytical uses of this type that find a place in teaching 

and research laboratories. When an infrared spectrum of the C-H stretching region, say 2800-

3200 cm-1, is required, CTC has commonly been used as a solvent for the substance under 

investigation. Alternatives are tetrachloroethylene, as outlined below, fluorocarbons such as 

S-316, or for specialist applications, carbon disulfide (although the low boiling point, 46o

, and 

unpleasant odour of carbon disulfide act to limit its use).

For recording nuclear magnetic resonance (NMR) spectra arising from hydrogen (1H) nuclei 

in the sample under investigation, CTC has been used a solvent since its molecules have no 

hydrogen atoms and consequently do not contribute a background spectrum. However, CTC 

does not have sufficient solvent power to dissolve many substances, and so the use of 

deuteron-chloroform – CDCl3, chloroform in which the hydrogen has been replaced by 

deuterium – has become more frequent although it is somewhat more expensive. Given the 

widespread availability and use of deuteron-chloroform, and its counterparts such as 

deuteron-acetone, the use of CTC in this application is easily replaced by alternatives. 

CTC is also used as solvent for the recording of Raman spectra, a technique in which the 

sample is irradiated with ultraviolet light, and comparison is made between the light emerging 

and that of the incident beam. Differences in the two are due to characteristic vibrational 

spectrum of the sample being investigated, and in order to visualize the spectrum, a solvent 

that has no Raman spectrum is required. CTC meets this need, since its molecules are 

symmetrical and have no dipole moment, thus rendering its Raman spectrum as zero. It is 

often the case that infrared and Raman spectra are recorded for the same sample, and where 

C-H vibrations give rise to the bands of interest the solvent employed must not interfere. 

Carbon disulfide, and deuterated solvents are recommended as alternatives to CTC (B. 

Schrader, ed., Infrared and Raman Spectroscopy. Methods and Applications, VCH, 

Weinheim, 1995, pages 146-7 and 220-222). 

(iv) grease removal and washing of NMR tubes Removing grease from glassware, 

especially the smooth surfaces of standard taper joints, may be done with paper or fabric 

wetted with a solvent, and CTC is one solvent that has been used in this way. Numerous 

alternatives are available, depending on the type of grease encountered, paraffin or synthetic, 

for example. Readily available solvents such as hexane or other petroleum hydrocarbons, 

chloroform and aromatic solvents such as benzene may be used at similar cost and under the 

same occupational health and safety conditions. 
68 May 2010 TEAP Progress Report 

The sample tubes used in nuclear magnetic resonance (NMR) experiments are long (15 cm) 

and narrow (5 or 10 mm diameter), and they need to be washed to remove the last sample 

before they reused. In the case of 1

H NMR there is an advantage in using CTC because any 

traces of the washing solvent remaining in the tube will not affect the subsequent use, since 

CTC has no hydrogen atoms in its molecule. When 13C spectra are being recorded, all traces 

of carbon-containing solvents – and that includes all organic solvents – must be removed. 

The best method involves rinsing the tubes with acetone, and then drying them (upside down 

to allow the escape of heavy vapors) in a ventilated oven at temperatures near 100o

C. 

(v) iodine partition and equilibrium experiments One of the traditional experiments in 

undergraduate physical chemistry laboratories concerns the distribution of iodine between an 

organic solvent, immiscible with water, and water or a solution containing other species that 

can react with iodine, and CTC was commonly prescribed as the organic solvent in this 

experiment. Two sets of measurements are made: (i) concentration of iodine in solvent and 

water after the two have been shaken to enable equilibrium distribution of the iodine; (ii) 

concentration of iodine in the solvent and of iodine and the complex ion I3

-

 in the water phase. 

The calculation from the measured data gives the distribution coefficient for iodine in the 

solvent/water pair, and the equilibrium constant for the reaction

I2 + I-

 ⇆ I3

-

While older laboratory manuals prescribe the use of CTC as the organic solvent for this 

experiment, subsequent writers (for example, www.practicalchemistry.org/experiments) have 

used cyclohexane, the only significant difference being that, in the latter case, the solvent is 

less dense than water and forms the upper layer, whereas CTC is more dense and forms the 

lower layer. Clearly, other solvents such as chloroform or trichloroethylene (both denser than 

water) or hexane (less dense) could be used in this experiment. 

A2 Analytical Uses of ODS

A2.1 ODS used as a solvent for spectroscopic measurements

(i) recording infrared and nuclear magnetic resonance spectra 

The most common uses in this category are of CTC or CFC-113 which are used as solvents 

when measurements are being made by nuclear magnetic resonance or infrared spectroscopy. 

In the spectroscopic regions of interest, the solvent makes no contribution and so the 

contributions of the solute molecules are clearly visible and their intensities can be directly 

related to the concentrations of the solutes. The analyses may concentrate on the presence in 

the solute ( sometimes called the analyte) of certain atoms or bonds that are not present in the 

solvent, and may be used to measure quantities of single substances, of mixtures, or of certain 

functional groups in molecules, as is the case with the hydroxyl index (OH groups measured). 

Two specific analyses are discussed in (ii) and (iii) below, but this general exclusion may 

apply to other analytical methods, not all of which would be acknowledged standard methods, 

so analysts should be aware that alternatives to the use of ODS can be found in all cases. 

(ii) hydrocarbons (oil and grease) in water or soil or oil mists in air 

The molecules of these solvents have no carbon-hydrogen bonds, and so the infrared spectra 

are clear in the region where such bonds absorb, approximately 2900-3300 cm-1. The 

molecules of oils and greases are rich in C-H bonds and vibrations of these bonds give rise to 

absorption peaks in this region of the infrared spectrum. The intensities of these absorption 

peaks are directly related to the concentration of oil or grease in the solution, and can be 

prepared with the intensities of peaks from solutions prepared with known concentrations that 

are used to calibrate this instrumental analysis. 
May 2010 TEAP Progress Report 69

The standard methods of analysis based on the use of CTC or CFC-113 as solvent are elegant 

in their simplicity. The sample is prepared for analysis by shaking the contaminate water with 

the solvent, or (in the case of soils and absorbent materials on which oil mists have been 

deposited) extracting with the solvent. The resulting solution of oil or grease in CTC or CFC113 is dried and an infrared spectrum is recorded. Peak intensities are compared with 

standards. CTC is used as solvent in method ASTM D-3921 (total hydrocarbons extracted 

from water, wastewater and sediments), and in method APHA AWWA-WPCF 5520C (IR 

method) for hydrocarbon extraction from water and soils. Despite the fact that CFC-113 was 

already a controlled substance, ASTM method D3921-96, proposing its use, was introduced 

in 1996, and revised in 2003 (ASTM D3921-96(2003)e1). 

The analysis may also be performed with tetrachloroethylene (perchloroethylene) as solvent, 

because this substance meets the necessary criteria of molecular structure and physical 

properties (solvent power and water-immiscibility) and is available in spectroscopic grades of 

high purity. Industrial grades of this solvent have been widely used in the dry cleaning 

industry. Health and safety aspects are about the same as those with CTC, and both of these 

chlorinated solvents need to be used with appropriate laboratory care. Although there is no 

standard method that describes the use of tetrachloroethylene, its use has been reported in the 

scientific literature and it has been introduced successfully as a replacement for CTC in the 

petroleum refining industry of Chile. Literature details may be found in: Farmaki, E., 

Kaloudis, T., Dimitrou, K., Thanasoulias, N., Kousouris, L and Tzoumerkas, F.,'Validation of 

an FT-IR method for the Determination of Oils & Greases in Water, with the use of 

tetrachloroethylene as the extraction Solvent', Proceedings of the 9th International Conference 

on Environmental Science and Technology, Rhodes Island, Greece, 1-3 September 2005. 

Farmaki, E., Kaloudis, T., Dimitrou, K., Thanasoulias, N., Kousouris, L and Tzoumerkas, F., 

'Validation of an FT-IR method for the Determination of Oils & Greases in Water, with the 

use of tetrachloroethylene as the extraction Solvent', Desalination, 2007, 210 (1-3), 52-60. 

The proprietary solvent S-316 (the dimer/trimer of chlorotrifluoroethylene) produced by 

Horiba has also been used successfully in a number of laboratories for the spectroscopic 

analysis of oil and grease. It is more expensive than other solvents but has very low toxicity 

and may be preferred on those grounds. A new standard method ASTM D 7066-04 (Test 

Method for Dimer/Trimer of Chlorotrifluoroethylene S-316 Recoverable Oil and Grease and 

Nonpolar Material by Infrared Determination) (Rintoul, S. (2005)) describes the use of this 

solvent. 

There are several alternative, non-spectroscopic methods for analysis of oils and greases in 

these contexts. The most rudimentary, for which standard analysis exist, is a gravimetric 

method (Standard Methods for the Examination of Water and Wastewater, American Public 

Health Association, 20th edition, Washington, DC. Method 5520C (Partition-infrared. 

Method 5520B gravimetric method. US EPA (1978). US EPA (1978), Method 418.1: 

Petroleum Hydrocarbons, Total Recoverable, Storet No. 45501. ASTM (2003). ASRM 

(2003), Method D 3921-96: Standard Test Method for Oil and Grease and Petroleum 

Hydrocarbons in Water, ASTM International.) which involves the extraction of the oil or 

grease into a volatile hydrocarbon solvent (most often hexane), evaporation of the solvent and 

weighing of the residual non-volatile oily material. Volatile hydrocarbon fractions may be 

lost during this procedure, whereas they would be included in the spectroscopic analysis 

described above. However, the gravimetric method is cheaper – not having to rely on a 

spectroscopic instrument – and in the case of environmental samples there volatile material is 

likely to have been lost before the sample is collected for analysis, so the gravimetric method 

gives a true account of the quantity being analysed. 

The most sophisticated method available for these analysis similarly collects the oil into an 

organic solvent and then analyses the mixture by GC-MS, a combination of gas 

chromatography (in which hydrocarbon components of the mixture are separated and 
70 May 2010 TEAP Progress Report 

quantified) and mass spectroscopy (in which their molecular nature is revealed). The USEPA 

Method 8260B ‘Volatile organic Compounds by Gas Chromatography/Mass Spectrometry 

(GC/MS)’ is a suitable method. 

The use of ODS for ‘testing of oil, grease and total petroleum hydrocarbons in water’ was 

eliminated from the global exemption by Decision XI/15 (clause (a)) from 2002, but such 

uses have persisted, especially in developing countries. The availability of alternatives to 

ODS was further recognized in the TEAP Progress report 2009 and in Decision XXI/6. 

(iii) Simethicone (polydimethylsiloxane) 

Polydimethylsiloxane is used as an internal medicine, marketed as Dimethicone (or 

Dimeticone) or, when mixed with silica, as Simethicone or Simeticone. The active ingredient 

can be identified and its concentration may be measured by infrared spectroscopic analysis. 

However, instead of monitoring peaks due to absorption by C-H vibrations, as in the case of 

the oil and hydrocarbon analyses discussed above, the analysis of the polydimethylsiloxane 

uses the intensity of the peak for vibration of the CH3-Si group near 1260 cm1. Various 

references give the peak position 1254, 1259 and 1260 and 1261 cm-1, and 7.9 μm = 1266 

cm-1, but the spectrometer resolution is usually on the order of 4 cm-1 so these figures are 

essentially the same. The solvent originally prescribed for this analysis in a number of 

standard reference works and in a research paper (G. Torrado, A. Garcia-Arieta, F. de los Rio, 

J.C. Menéndez and S. Torrado, ‘Quantitative determination of dimethicone in commercial 

tablets and capsules by Fourier transform infrared spectroscopy and antifoaming activity test’, 

J. Pharmaceutical and Biomedical Analysis, 1999, 19, 285-292) was CTC, which has no 

absorption peaks close to 1260 cm-1. Many other solvents in which the polydimethylsiloxane 

would be soluble would also have no absorptions near the peak to be measured, and both 

toluene and chloroform have been used in this analysis. Both the US Pharmacopeia 2009 

(Vol 2, page 3555) and the British Pharmacopoeia 2010 (Vol 2, pages 1892-3), which also 

incorporates the requirements of the European Pharmacopoeia 6th edition, describe the use of 

toluene for the assay, and the latter reference also includes the spectrum of Dimeticone (Vol 

4, page S41). 

The availability of alternatives to ODS in this analysis was reported in the 2009 TEAP 

Progress report and recognized in Decision XXI/6. 

A2.2 ODS used as a solvent for electrochemical methods of analysis

(i) cyanocobalamin For the assay of cyanocobalamin, the British Pharmacopoeia 2010 

(pages 607-608) recommends ultraviolet and visible absorption spectrophotometry of an 

aqueous solution (peak at 361 nm); thin layer chromatography using a mixed solvent (dilute 

ammonia, methanol and dichloromethane) after application of an aqueous ethanol solution of 

cyanocobalamin; and liquid chromatography using as mobile phase a mixture of methanol and 

aqueous disodium hydrogen phosphate. Similar conditions for liquid chromatography of 

radio-labelled cyanocobalamin[57Co] and [58Co] are given on pages 3383-3384. 

The same conditions for liquid chromatography of radio-labelled cyanocobalamin are 

prescribed the US Pharmacopeia 2009 (pages 2008-2009) but the cobalamin radiotracer assay 

described on page 145 employs mixtures of cresol-carbon tetrachloride and butanol-carbon 

tetrachloride, followed by elution from an alumina column and measurement of the 

absorbance at 361 nm. In view of the later information contained in the British 

Pharmacopoeia, the use of organic solvents could be avoided. 

(ii) bromine index In a procedure used to measure the degree of unsaturation of hydrocarbon 

fractions by determining the uptake of bromine, the chemical reaction being represented by 

the equation: 
May 2010 TEAP Progress Report 71

-CH=CH- + Br2 → -CHBr-CHBrThe bromine is generated electrolytically in situ from bromide and bromate ions and its 

disappearance is monitored electronically, in a mixed solvent containing methanol and acetic 

acid (the components that hold inorganic salts in solution and promote conductivity) and 

1,1,1-trichloroethane (the component that holds the hydrocarbon in solution). There are 

several standard methods for this assay, including ASTM D2710-99 ‘Standard Test Method 

for Bromine Index of Petroleum Hydrocarbons by Electrometric Titration’ and ASTM 

Method D1159 ‘Test Method for Bromine Number of Petroleum Distillates and Commercial 

Aliphatic Olefins by Electrometric Titration’, which describes the solvent as a mixture of 

glacial acetic acid, methanol, sulfuric acid and 1,1,1-trichloroethane. The procedure for 

determination of bromine Index closely resembles that used for Karl Fischer determination of 

traces of water, and the same apparatus may be used for both determinations, an example 

being the 796 Titroprocessor marketed by Metrohm. 

The need to replace1,1,1-trichloroethane, an ozone depleting substance, had already been 

identified by the companies that market the analytical equipment for this specialised 

measurement. Methylene chloride, diethyl carbonate and 1-methyl-2-pyrrolidone were 

suggested as suitable alternatives. One bulletin (Metrohm method 9) describes a mixture of 

glacial acetic acid, 1-methylpyrrolidone, methanol and sulfuric acid. A bulletin from another 

branch of the company (Metrohm, Application Bulletin 177/4e) describes the use of 1,1,1-

trichloromethane but also comments that ‘if possible one should refrain from using 

chlorinated solvents. Our investigations have shown that carbon tetrachloride and 1,1,1,-

trichloroethane can be replaced by diethyl carbonate’. Further information may be found in 

Metrohm Application Bulletin 177/4e. Automatic determination of the bromine index and/or 

bromine number in petroleum products. (www.metrohm.co.uk/bulletins/177_e.pdf, accessed 

January 2008. 

Metrohm. Method 9 – Bromine index of heptane. 

www.metrohm.com/products/01/pac/oilpac/e/oilpac_method9_e.pdf, accessed January 2008. 

The petroleum refining industry in Chile tested the alternatives and concluded that methylene 

chloride was the best alternative to 1,1,1-trichloromethane. 

A2.3 Analyses involving selective solubility in the ODS 

(i) cascarosides A number of medicines consist of, or are prepared from, natural material, 

and analytical procedures have been developed for measuring the amount of the active 

constituents in the natural materials. Cascarosides are bright yellow substances found in the 

bark of the tree Rhamnus pushiana DC (cascara bark, cascara sagrada) and they possess 

laxative properties. Cascarosides are listed in many pharmacopeias and the content of active 

constituents is prescribed (for example, European Pharmacopeia (Vol. 2), Council of Europe, 

Maisonneuve S.A., Sainte-Ruffine, France, 1971. p. 355, and USP 25 I NF 20 - The United 

States Pharmacopeia; The National Formulary. 2002. Rockville, MD: The United States 

Pharmacopeial Convention, Inc.). 

A common assay involves extraction of the active constituents with an organic solvent, 

followed by thin layer chromatography. The yellow spots on the chromatogram are compared 

for size with those of a standard solution of the active constituents. A solvent commonly used 

for this procedure is CTC but many other solvents can be used instead. For example, alcohols 

such as ethanol or iso-propanol, and solvents such as dichloromethane or ethyl acetate. A 

more advanced chromatographic method for this analysis has also been described (De Witte, 

P., Cuveele, J. and Lemli, J. ‘Determination of bicascarosides in cascara fluid by highperformance liquid chromatography’, Journal of Liquid Chromatography, 1991, 14, 2201-

2206) 
72 May 2010 TEAP Progress Report 

There is also an instrumental method in which the intensity of absorption of visible light in a 

spectrophotometer, by a solution of the active constituents in ethyl acetate, is used. So, in 

summary, many common organic solvents can replace CTC and a number of analytical 

methods are available. 

(ii) thyroid extracts A further example of the use of CTC in extraction of active constituents 

from natural materials is an application to thyroid glands removed from animals. This is an 

assay for the thyroid hormones which is based on the work of L.W. Riggs one hundred years 

ago (‘The Determination of Iodine in Protein Combinations’, Journal of the American 

Chemical Society, 1910, 32(5), 692-698). 

Extraction of particular components from natural materials is not confined to medicinal 

products but also plays a part in research projects, and this is covered in the ‘laboratory’ 

section, above. 

(iii) polymers An ODS, typically CTC, could have found application as a solvent for 

selectively removing a polymer from a mixture, so that proportion of that component in the 

mixture could be measured, or so that the infrared of 1

H nuclear magnetic resonance (NMR) 

spectrum of the polymer could be recorded for assay or identification purposes. However, 

very few polymers are soluble in such solvents and, in any case, other solvents can be found 

for these purposes. For recording NMR spectra, solutions of polymers in trifluoroacetic acid 

or hot o-dichlorobenzene have been used. Another kind of solvent use would be to remove 

some soluble impurity or additive (a plasticizer or flame retardant, for example) from a 

commercial polymer, for identification or assay purposes, but many other solvents are 

available for such purposes. 

(iv) formation of picrates Older methods for the identification of unknown organic 

substances are still practiced in some teaching laboratories in developing countries, whereas 

in developed countries and in the chemical industry these methods have been displaced by 

modern spectroscopic methods. These are more expensive and hence the survival of the old 

methods in developing countries. The identification of the unknown substance can involve its 

reaction with another chemical substance to form a ‘derivative’. The melting point of this 

derivative can be used, by referenced to standard tables and in conjunction with other 

properties of the unknown substance, to identify the unknown substance. 

Under this procedure, polycyclic aromatic hydrocarbons such as naphthalene, anthracene, 

phenanthrene and other aromatic hydrocarbons can be reacted with picric acid to form 1:1 

adducts known as picrates. Picric acid and the unknown substance are dissolved in a suitable 

solvent by warming, and upon cooling the picrate is recovered as crystals. CTC has often 

been used as the solvent, but most textbooks (for example, F.J. Smith and E. Jones, A Scheme 

of Qualitative Organic Analysis (1951); W.J. Hickinbotham, Reactions of Organic 

Compounds (1942); A.I. Vogel, A Textbook of Practical Organic Chemistry (several editions) 

prescribe the use of benzene, acetone, ethanol or acetic acid and so alternatives to the use of 

CTC are readily available, cheap and safe to use. Similar procedures can be adopted for the 

formation of analogous derivates of hydrocarbons with picrolonic acid or 1,3,5-

trinitrobenzene. 

A2.4 ODS used to preconcentrate the analyte

A further development of the solvent extraction procedure described above is the dissolution, 

often involving pre-concentration, of a soluble or volatile substance prior to its introduction 

into the analytical instrument. Four examples are considered below. 

(i) liquid chromatography (HPLC) of drugs and pesticides The concentrated solution of 

the substance or mixture (the analyte = material to be analyzed) to be analyzed, is dissolved in 
May 2010 TEAP Progress Report 73

a suitable solvent and injected into the chromatography column. The flow of solvent to 

develop the chromatogaphy – commonly a methanol-water or an acetonitrile-water mixture – 

is then passed through the column, eluting the components of the analyte and separating them. 

They may be identified in or recovered from the emerging solution. While CTC has been 

used in this application, many other solvents can replace it and CTC is not listed as a suitable 

solvent in the major texts and laboratory manuals (W.J. Lough and I.W. Wainer, eds., High 

Performance Liquid Chromatography. Fundamental principles and Practice, Blackie 

Academic & Professional, London, 1996, pages 168-169; M.C, McMaster, HPLC. A 

Practical User’s Guide, VCH, New York, 1994, page 137; S. Kromidas, ed., HPLC Made to 

Measure. A Practical Handbook for Optimization, Wiley-VCH, 2006, pages 350-351). 

According to Lough and Wainer, the sample should be ‘dissolved in the mobile phase’, or if 

this is not feasible, ‘in a liquid that is chemically very similar to the mobile phase’, and this 

makes CTC an unlikely choice. For pre-c0ncentration of the sample, polar solvents such as 

dichloromethane or the Folsch mixture (2:1 chloroform:methanol) are recommended. 

(ii) gas chromatography of organic chemicals such as steroids Similar techniques are used 

in this analysis, the difference being that the chromatogram is developed, and components 

thus separated, by a stream of inert gas (nitrogen or argon). The separated components may 

be trapped as they are eluted from the column. Again, many solvents are available for use in 

transferring the analyte to the chromatography column. 

(iii) adsorption chromatography of organic chemicals Once again the aim of the analyst is 

to transfer the analyte to the chromatography column in the minimum volume of solvent and 

then to develop the chromatogram by successive elution with solvents. As in the two 

examples above, a range of suitable solvents is available for transferring the analyte to the 

column. 

(iv) atomic absorption spectroscopy The aim of this analysis is to identify metals by 

subjecting them to intense heat in a flame or plasma and examining the light emitted at 

particular frequencies, characteristic of each element. The light intensity can also be used to 

make a quantitative analysis (= assay). Metal salts are typically soluble in water (or dilute 

acid) and so can be introduced into the hot zone in the form of aqueous solutions. A 

technique for pre-concentration of dilute samples, or when trace quantities are involved, is to 

make a solvent-soluble complex of the metal ion, dissolve the complex in a suitable organic 

solvent, and begin the analysis with this. While CTC has been used in this application, 

together with the complexing agents dithizone, a dithiocarbamate or 8-hydroxyquinoline, it is 

more common to use chloroform, methyl isobutyl ketone, xylene, or a phosphate ester (G.F. 

Kirkbright and M. Sargent, Atomic Absorption and Fluorescence Spectroscopy, Academic 

press, London, 1974, pp 49-497. Preconcentration Techniques for Trace Elements, CRC 

Press, 1992, p 124). 

(v) X-ray fluorescence Sample preparation is the same for a related technique for metal 

analysis, in which the sample is irradiated with high energy X-rays or gamma rays, and the 

emitted (secondary) X-rays are recorded and analyzed for the presence of frequencies 

characteristic of the various metals. 

A2.5 Titration of iodine with thiosulfate (iodometric analyses) 

Volumetric analysis or titration, in which a reagent of known concentration is added from a 

burette, to a sample to be analyzed, has been the backbone of laboratory analysis for well over 

a century and still finds a place in many laboratories despite the availability and sophistication 

of modern instrumental methods of analysis. Of course the old technique is inexpensive, 

except for the time of the analyst, and that is one reason why it has persisted. The most 

common applications of the technique involve acid-base reactions, the acid normally in the 

burette and the base, together with an indicator substance that will change colour at the 
74 May 2010 TEAP Progress Report 

equivalence point (‘end point’ of the titration), in the receiving flask. Electrometric methods 

can also be used to detect the end point. 

In the titrations under consideration here, the reagent in the burette is sodium thiosulfate, 

Na2S2O3, and the solution in the flask contains iodine I2, the quantity of which is to be 

measured in the volumetric analysis. Because the iodine has limited solubility in water, it is 

normally held in solution as the more soluble I3

-

 ion, which releases iodine as the titration 

progresses. During the titration the iodine is converted (reduced) to iodide ion, I-

, and the 

brown colour of the iodine fades gradually to yellow and disappears at the end point. 

The final change from pale yellow to colourless can be hard to detect by eye and so two 

methods have been developed for visualizing it. In the first of these, as the end point 

approaches and iodine concentration is already low, a solution of starch is added so that a 

deep blue starch-iodine complex forms in solution. When the last traces of iodine are gone, 

the blue colour disappears. The second visualization method is based on the intense violet 

colour of iodine solutions in organic solvents that have no oxygen in their molecules. CTC 

has been used in this method. A few mL are added to the titration solution in the flask, 

forming a globule at the bottom (since CTC is much denser than water) and dissolving the 

iodine. As the iodine is removed from the solution during the titration, the violet colour fades 

and the end point – colourless – is easily detected. 

In this second visualization method, CTC (relative density 1.59) can be replaced with another 

solvent that has no oxygen and also meets the requirements of water immiscibility and 

density. Chloroform (CHCl3, relative density 1.48), dichloromethane (CH2Cl2, 1.33 ) and 

trichloroethylene (C2HCl3, 1.46) all meet these criteria, and chloroform has been found to be 

quite successful. Like CTC, these solvents can be recovered and reused, and this is often 

done if a laboratory has many such titrations to perform. The use of chloroform as an 

alternative to CTC is described in standard texts such as Vogel’s Quantitative Inorganic 

Analysis. 

There are many applications that rely on the generation of iodine in solution, in equivalent to 

the amount of the substance being analyzed. Some representative examples are given below. 

(i) iodine Titrations of the kind described above are performed in a number of situations 

where iodine is handled. One example is the monitoring of iodine content in medicinal 

preparations containing iodine as disinfectant or antiseptic. Another is the assay of residual 

iodine in water from which solid iodine has been removed in the commercial production of 

iodine from mineral deposits. Chloroform, has been shown to serve well in this application. 

(ii) copper In the volumetric method for determination of copper in solution, the copper is 

reacted with iodide ion, oxidizing it so that a quantity of iodine, equivalent to the amount of 

copper, is generated in the solution. The copper is concomitantly reduced, changing its 

oxidation state from Cu(II) to Cu(I). The quantity of iodine is determined by means of the 

titration described above and thus the quantity of copper can be calculated. As before, the 

iodine may be titrated with sodium thiosulfate to the end point that can be detected with starch 

or an organic solvent such as chloroform. There is no necessity for the use of CTC since 

alternatives are available. 

(iii) arsenic Arsenic, in its pentavalent As(V) state – that is, the form of arsenate ion, 

As3O4

3-, or arsenic pentoxide, As2O5 - can be determined in more or less the same way, since 

its reaction with iodide ion converts an equivalent amount of iodide to iodine, the arsenic 

being reduced to the trivalent (+3) state. As before, the iodine may be titrated with sodium 

thiosulfate to the end point that can be detected with starch or an organic solvent such as 

chloroform. There is no necessity for the use of CTC since alternatives are available. 
May 2010 TEAP Progress Report 75

(iv) hypochlorite, chlorate and bromate Each of these species is a powerful oxidizing 

agent, capable of converting iodide ion to iodine in amount equivalent to the quantity of 

oxidizing agent. The quantity of iodine, and therefore of the oxidizing agent, can be 

determined as above by titration with thiosulfate. 

(v) Sulfur Sulfur can be determined by means of a related volumetric method that involves 

converting the sulfur to sulfur dioxide or sulfite ion, SO3

2-, and titration with iodine, which 

oxidizes the sulfite to sulfate, SO4

2-. The procedure is the converse of the above titrations, 

and is properly termed iodimetry (a term frequently misused in the literature). The end point, 

the first appearance of unconsumed iodine in solution, may be detected by the methods 

described above for monitoring the disappearance of iodine in the process of iodometry – that 

is, blue colour with starch, or violet colour in an organic solvent. An excellent example is 

provided in a recent article (M. Gros, J-P. Morand and A. Bezos, ‘Determination of Total 

Sulfur Contents in the International Rock reference Material SY-2 and other Mafic and 

Ultramafic Rocks Using an Improved Scheme of Combustion/Iodometric Titration’, 

Geostandards and Geoanalytical Research, 2007, 29(1), 123-130) where starch indicator is 

used. Determinations of this type are sometimes performed by ‘back titration’ with 

thiosulfate following the addition of a known excess of iodine to the sulfur-containing 

solution, but the approximate amount of sulfur must be known in order for the excess to be 

calculated. Sulfur may also be determined by instrumental methods such as X-ray 

fluorescence (XRF), pyrohydrolysis/ion chromatography, inductively coupled plasma mass 

spectrometry (ICP-MS), and electron microprobe analysis (EMPA). 

A2.6 Iodine Index (iodine value, iodine number) 

The Iodine Index is an indicator of the extent to which the molecules being studied possess –

C=C- linkages (double bonds or unsaturation). Such unsaturation may be in hydrocarbons, 

but the petroleum industry generally uses the closely related Bromine Index, rather than the 

Iodine Index, to express the degree of unsaturation in their products. The Iodine Index is 

commonly used when the unsaturation is in the components of natural fats and oils, and so 

edible oils and fatty foods such as butter are studied in this way, and products such as 

biodiesel that are derived from fats and oils. 

The methodology involves the addition of a solution of iodine chloride (ICl) in acetic acid – 

named after the inventor of the technique as ‘Wijs Solution’ – to a solution of a weighed 

amount of the oil or fat in an organic solvent. Since a wide range of sample may need to be 

analysed, with differing solubilities, the mixed solvent ensures that the whole sample is in 

solution. CTC was for many years the organic solvent used in the Wijs method but a number 

of other solvents can be used as alternatives. 

An excess of Wijs solution is used in the determination. The rate of the chemical reaction - 

addition of the ICl to the double bonds - is slow, and so a waiting time of at least an hour is 

necessary. After this time, an aqueous solution of potassium iodine is added and this reacts 

with the excess ICl to form iodine. The amount of iodine is measured in the usual way, by 

titration with sodium thiosulfate and visualization of the end point (when all of the iodine has 

been consumed by the thiosulfate) by starch, which forms a deep blue colour with iodine. 

The end point is the disappearance of the blue colour. Since the amount of Wijs reagent was 

known, and the excess was measured (as iodine) the quantity of ICl consumed can be 

calculated. The amount of sample is known, so the Iodine Index may be calculated. 

The Association of Official Analytical Chemists has published a standard procure for 

determination of the Iodine Value using CTC (AOCS method Cd 1-25, (1989) but even at the 

time the method was being developed by the American Oil Chemists’ Society (AOCS) it was 

acknowledged that CTC would have to be replaced and (later) that CFC-113 was not 

recommended as a replacement ‘because of environmental concerns’. Subsequently, AOCS 
76 May 2010 TEAP Progress Report 

Recommended Practice Cd 1b-87 gave cyclohexane as the best replacement for CTC but 

acknowledged that ‘erratic results may be obtained for oils with iodine values’ in the range 

100-120. 

ASTM D5768-02 (2006) is another standard methods for performing this analysis. The 

ASTM ‘method was developed in order to replace the hazardous solvent, carbon tetrachloride, 

used in Test Method D 1959 with the less hazardous and more available solvents, iso-octane 

and cyclohexane. As data on the satisfactory use of other solvents becomes available, this test 

method will be amended to include those solvents’. The German organization Deutsches 

Institut fur Normung E.V. has developed method DIN 53241-1: 1995 Determination of iodine 

value - Part 1: Methods using Wijs solution, but details are not available. 

A recent publication describes a method in which the unsaturated material being tested is 

reacted with iodine in a water-alcohol mixture at 50o

C, with excess iodine being measured by 

thiosulfate titration as in the standard method. The method revives a procedure first described 

in 1924, and compares the results favourably with those achieved with the standard method 

described above. The new method is not (yet) a standard method although it was published in 

the AIST journal and so has been brought to the attention of the standard-setting organization 

(J.A. Aricetti, A.J. da S. maciel, O.C. Lopes and M. Tubino, ‘A Simple Green method for 

Biodiesel Iodine Number Determination’, Journal of ASTM International 7 (1), 1-8 (2010). 

A2.7 Miscellaneous analyses

(i) stiffness of leather Earlier indications that ODS were used in this standard method were 

in error and so this procedure (ASTM D2821) is not of concern. 

(ii) jellification point CTC is used in small quantities in the measurement of the jellification 

point of the seaweed-derived product, agar. As far as can be ascertained, this use is confined 

to a single company, where CTC is used because it is heavy (relative density 1.59) and 

immiscible with water. Following discussion with a CTOC co-chair, the company is seeking 

and should be able to find an alternative (non-ODS) that meets its requirements. 

(iii) cement analysis This analysis was described in the 2008 TEAP Progress Report, in 

which it was observed that the original standard method using CTC had been replaced by 

another (ASTM C 243-95 Standard test method for Bleeding of Cement Pastes and Mortars) 

using 1,1,1-trichloroethane (TCA), but since this was also a controlled substance the method 

was withdrawn in 2001. There has been available for many years the standard test ASTM C 

188-44, revised in 1967, in benzene is used as solvent and CTOC has received information 

that this method is acceptable to the industry. Hence, there is no justification for the 

continued use of CTC or TCA. 

(iv) gas mask cartridge breakthrough As noted in the 2009 TEAP Progress Report, 

Japanese researchers have found that cyclohexane is a suitable alternative to CTC in the 

standard test of breakthrough time of a gas mask cartridge (M. Furuse, S. Kanno, T. Takano 

and Y. Matsu, ‘Cyclohexane as an Alternative Vapor to Carbon Tetrachloride for the 

Assessment of Gas Removing Capacities of Gas masks’, Industrial Health, 39, 1-7 (2001). 

‘Carbon tetrachloride (CCl4) vapor has long been used’, the authors observe, ‘ as a 

representative organic vapor for testing breakthrough times of gas mask cartridges and 

canisters in the National Approval Test of Respirators as well as in respirator tests in 

manufactures’. However, a suitable alternative, cyclohexane, is available. 

(v) porosity of activated carbon Impurities in gases or liquids can be removed by 

adsorption onto the surface of ‘activated carbon’, a kind of char that is produced by heating 

woody material in the absence of oxygen. Some of the best grades are made from coconut 

husks. The activated carbon has very high porosity, and therefore very high surface area, and 
May 2010 TEAP Progress Report 77

this important property can be measured by measuring the uptake (g/100 g) of an organic 

chemical substance by grains of the activated carbon. The ASTM Method of long standing, 

D3467-04 (2009), Standard Test Method for Carbon Tetrachloride Activity of Activated 

Carbon, describes how this can be done using CTC. However, some years earlier, following 

criticism of the use of CTC, a new method using butane was developed (ASTM D5228-92 

(2005)) Standard test method for Determination of Butane Working Capacity of Activated 

Carbon. When an analyst changes to a new standard test method, the question always arises 

about the relationship of the new result to those obtained with the older method, and so, 

foreseeing such concern, ASTM has published a correlation graph that enables the old and 

new results to be viewed on a common scale: CTC activity = 2.55 x butane activity (R2

 = 

0.935). This is included in ASTM D5742-95 (2005) Standard Test Method for Determination 

of Butane Activity of Activated Carbon. 

May 2010 TEAP Progress Report 79

5 Foams Technical Options Committee (FTOC) Progress 

Report 

5.1 Overview Paragraph on Foams 

• The primary challenge for the foams sector continues to be the phase-out of HCFCs in 

developing countries under Decision XIX/6. Alternatives such as methyl formate and 

methylal are being evaluated as specific alternatives to meet these challenges, even 

though experience of these alternatives has been limited in developed countries. 

• The blowing agent usage patterns in developed countries are now relatively mature, 

although there is still some limited migration from saturated HFCs to hydrocarbons in 

the polyurethane sector for cost reasons where performance characteristics can be met. 

There is also an interest in the potential role of unsaturated HFCs in the domestic 

refrigeration sector, particularly in North America, where saturated HFCs have a 

significant market, and in PU Spray foam both in Europe and North America. One of 

these (HFC-1234ze) has found some initial use in Europe as a replacement for HFC-134a 

in PU One Component Foams. 

• The extruded polystyrene sector has successfully made its transition out of HCFCs in 

North America, although, for the most part, this has been to solutions involving various 

combinations of saturated HFCs. There is interest in Europe, primarily driven by market 

pressure to move to low GWP alternatives. Those evaluated include Dimethyl Ether and 

unsaturated HFCs. 

• Meanwhile the management of ODS banks in the foam sector offers both challenges and 

opportunities to limit the emissions of these greenhouse gases. The evaluation conducted 

by the TEAP Task Force responding to Decision XX/7 indicated that costs of recovery 

and destruction of blowing agents were substantially higher than those relating to 

refrigerants. Although significant progress has been made in establishing ODS protocols 

to facilitate carbon finance, the inclusion of foam blowing agents has been limited by the 

lack of a solid understanding of the business-as-usual baseline in many developing 

countries. 

5.1.1 Transitional Status 

Decision XIX/6 still remains a key focus of the Foams TOC as it seeks to identify and 

document relevant technology options – particularly for developing countries. The following 

sections list key conclusions from this process as follows: 

Transition Status - Developing Countries 

• Pilot projects have been approved and, in some cases, are close to completion on a 

number of key technology options. A recent workshop in Brazil has confirmed that the 

use of methyl formate is becoming established in Australia, Brazil and the USA in 

integral skin, specialty flexible and most rigid foam applications, while some use in 

China, New Zealand and South Africa has been noted. 

• Pre-blended or directly injected hydrocarbons may have a significant role to play for 

medium-sized enterprises but safety concerns persist. A pilot project has been approved 

for Egypt and another has been prepared for China. 

• A further project is being progressed in the polyurethane sector on methylal (Brazil) 

while projects with HFC-1234ze (Turkey) for the XPS sector and super-critical CO2

(Colombia) for the PU Spray foam have been approved. 
80 May 2010 TEAP Progress Report 

• The TEAP Report responding to Decision XXI/9 provides a review of options that might 

avoid saturated HFCs in the foam sector and offers a current commentary on minimising 

the climate impact of transitions 

• There is growing concern in the foam sector that a provision for quantifying climate 

impacts of technology transitions is not yet available 

• Pilot projects on the end-of-life management of domestic refrigerators have been 

identified and are in the process of development. 

• Various stakeholders in the carbon market (e.g. the Climate Action Reserve (CAR) and 

the Voluntary Carbon Standard (VCS)) have developed ODS destruction protocols, but 

these are unlikely to be operable in developing countries for foam blowing agents 

because of concerns over the definition of baselines. 

Transition Status - Developed Countries 

• Transitions out of HCFCs has been completed in the North American XPS sector, with 

the primary choice of blowing agent being various combinations of saturated HFCs 

• Market pressures in Europe are encouraging some XPS manufacturers to investigate 

alternatives to saturated HFCs. 

• HFC use is continuing to decline in the polyurethane sector as hydrocarbon technologies 

continue to mature. Increasing interest in climate mitigation strategies might add further 

impetus to this process. 

• Further optimisation of hydrocarbon technologies has largely closed the gap in thermal 

performance with HFC technologies. This has been partially achieved by improvements 

in cell morphology (size and orientation). 

• Although the construction sector is depressed as a result of the current economic crisis, 

the insulation industry continues to grow in most regions based on higher insulation 

requirements in new buildings and a number of efforts to stimulate building 

refurbishment. 

• Unsaturated HFCs are being investigated in a number of foam applications and HFC1234ze is already in commercial use within some polyurethane (PU) One Component 

Foam (OCF) products in the niche market for larger cans. 

• The cost-effectiveness of bank management in the foam sector has been the subject of 

much study in non-Article 5 countries. In many regions, end-of-life management of foam 

in refrigerators is mandated. In others, it is the subject of wider producer responsibility 

requirements. In still others, such activities may attract credits under carbon financing 

initiatives. However, it is still unclear whether the end-of-life management of foams in 

buildings will be technically and/or economically viable in many cases. 

5.1.2 Technology Update 

The following table illustrates the main substitute technologies currently considered or 

already used in the polyurethane, extruded polystyrene/polyolefin and phenolic foam sectors. 

Recognising that the technology choices across the world are likely to become more 

homogeneous with time, the future technology choices are now listed as ‘global’. 

 
May 2010 TEAP Progress Report 

Foams TOC Update Report 2010 - Technical Options Table 

SECTOR DEVELOPED 

COUNTRIES 

DEVELOPING 

COUNTRIES 

GLOBAL 

 CURRENT CURRENT FUTURE 

POLYURETHANE RIGID 

Domestic refrigerators and freezers 

c-pentane, cyclo/iso pentane blends, HFC- 245fa, HFC-134a 

c-pentane, cyclo/iso pentane blends, HCFC-141b or HCFC141b/22 c-pentane, cyclo/iso pentane blends, unsaturated HFCs 

Other appliances 

c-pentane, cyclo/iso pentane blends, HFC- 245fa, HFC-365mfc/227ea blends, Methyl Formate 

HCFC-141b, c-pentane, cyclo/iso pentane blends, Methyl Formate 

c-pentane, cyclo/iso pentane blends, unsaturated HFCs, Methyl Formate 

Transport & reefers c-pentane, cyclo/iso pentane blends, HFC- 245fa, HFC-365mfc/227ea blends HCFC-141b, HCFC-141b/22 c-pentane, cyclo/iso pentane blends, unsaturated HFCs, Methyl Formate Potentially H

use 

Boardstock 

c-pentane, n-pentane, cyclo/iso pentane blends, HFC- 245fa, HFC365mfc/227ea blends Limited commercial production in Art 5.1 but HCFC-22 in use c-pentane, n-pentane, unsaturated HFCs HFC for strin

standards. 

Panels – continuous c-pentane, n-pentane, HFC- 245fa, HFC-365mfc/227ea blends HCFC-141b & minor use of C- pentane, n-pentane, HCFC-22 c-pentane, n-pentane, unsaturated HFCs HFC for strin

standards 

Panels discontinuous HFC- 245fa, HFC-365mfc/227ea blends, c-pentane, n-pentane n-Pentane, HCFC-141b, Methyl Formate c-pentane, n-pentane, unsaturated HFCs, Methyl Formate HFCs, not HCSpray HFC- 245fa, Supercritical CO2 CO2 (water), HCFC-141b, Methyl Formate HFC- 245fa, Supercritical CO2, CO2 (water), Blocks c-pentane, n-pentane, HFC- 245fa, HFC-365mfc/227ea blends HCFC-141b c-pentane, n-pentane, unsaturated HFCs, Methyl Formate HC use increPipe-in-pipe c-pentane, n-pentane, HFC- 245fa, HFC-365mfc/227ea blends HCFC-141b c-pentane, n-pentane, unsaturated HFCs, Methyl Formate One Component Foam Mixtures of propane, butane and dimethyl ether, HFC-134a, HFC-1234ze HCFC-22, HFC-134a Mixtures of propane, butane and dimethyl ether, HFC-1234ze HC use drive

legislation 

POLYURETHANE FLEXIBLE Integral Skin CO2 (water), HFC-134a, HFC- 245fa, HFC-365mfc/227ea blends, n-pentane CO2 (water), HCFC-141b, Methyl Formate CO2 (water), n-pentane, Methyl Formate, unsaturated HFCs HFC-134a is Shoe Soles CO2 (water), HFC-134a CO2 (water), HFC-134a CO2 (water), Methyl Formate, unsaturated HFCs HFC-134a is PHENOLIC Board & block Isopentane, n-pentane, minor use of HFC-365mfc/227ea blends HCFC-141b HCs HFCs are use

performance 

EXTRUDED POLYSTYRENE Boardstock 

HFC-134a, HFC-152a, CO2, 

CO2/ethanol, (HCs in Japan), blends of 

CO2/hydrocarbons 

Mainly HCFC-142b/22 but growing HCFC-22. Some minor use of HCs 

 CO2, blends of CO2/ ethanol or 

CO2/hydrocarbons, unsaturated 

HFCs, dimethylether 

HCFC-142b uAmerica until is end-produc

NOT-IN-KIND INSULATIONDomestic Buildings Glass fibre, rock fibre, cellulose Limited NIK insulation types Awaiting new technology Non-domestic Buildings Glass fibre, rock fibre Limited NIK insulation types Awaiting new technology 

Fibre insulation cost Market share efficiency gro

Industrial applications Mostly rock fibre, calcium silicate Limited NIK insulation types Awaiting new technology Choice driven 

temperature 

May 2010 TEAP Progress Report 83

6 Halons Technical Options Committee (HTOC) Progress 

Report 

The Halons Technical Options Committee (HTOC) met in Montpellier, France on March 9 -

11, 2010. HTOC members in attendance were from Article 5 countries: India, Jordan, 

Kuwait, South Africa, and Venezuela; CEIT: Russian Federation; and the non-Article 5 

countries: Canada, Japan, United States, and three member states of the European Union. The 

following is the update for 2010. 

6.1 Update on Alternative Agents 

Four new alternative agents are not yet commercialized but are in the advanced stages of 

development. These agents will be described in the 2010 Assessment Report. 

6.2 Update on Halon Uses 

It was previously reported that halon 2402 is being commercialized in a new specialty flame 

retardant paint, where the halon is encapsulated and only released when it gets hot, 

presumably from exposure to a fire. Other extinguishing agents are now being similarly 

encapsulated and the flame retardant paint has been commercialized in Russia. Ukraine also 

has an interest in commercialization of this paint for local markets. 

6.3 Update on Halon 1301 Use as a Feedstock 

Halon 1301 (CF3Br) continues to be produced in China and France for use as a feedstock in 

the manufacture of the pesticide Fipronil. The total halon production quantities in these 

countries are unknown to the Committee but have been increasing annually in China since 

2005. 

6.4 Halon Recovery and Recycling in Article 5 Countries 

Recent information indicates that there has been a further decline in recovery and recycling 

operations on Article 5 countries since the HTOC’s last report. Operational costs have been 

increasing and technological skills have been found to be in short supply in many cases. For 

example, in India the civil recycling and storage facility is not working effectively so each of 

the armed forces is setting up its own facility. This is resulting in little or no reclaimed stock 

availability, particularly for halon 1211. In some other cases, halons contaminated with other 

fluorocarbons cannot be purified without a reclamation process based on distillation. The 

necessary equipment is expensive and unavailable in Article 5 countries, and thus stocks of 

contaminated but unrecyclable halons are accumulating. This is imposing a financial and 

operational burden on some recycling facilities. 

Parties may wish to consider strategies and propositions that will help non-functioning halon 

recovery and recycling operations become functional, to ensure the long-term sustainability of 

these halon banking operations. These will be needed to provide for regional forecasted 

critical halon use requirements. 

6.5 Contaminated Recycled Halons 

The UK Civil Aviation Authority (CAA) reported to the European Aviation Safety Agency 

(EASA) that contaminated halons had made their way into the civil aviation industry. It is 

alleged that a UK halon recycler falsified third party laboratory test reports that indicated 
84 May 2010 TEAP Progress Report 

contamination to show that the halon met specification. The halon was then sold on to 

aviation fire protection equipment suppliers, thus compromising the effectiveness of on-board 

aircraft fire protection. The concern is primarily halon 1211, but contaminated halon 1301 has 

also been found - details are still being consolidated. 

Contaminants found in halon 1211 include R-11, R-12, Halon 2402, R-134a, R-141b, R-22, 

R-152a (flammable), R-125, carbon tetrachloride, and isobutane (flammable). These have 

been found in varying quantities, and in some cases the total contaminant content is in excess 

of 30%. It has been estimated that over 30,000 extinguishers could be affected. EASA and the 

US Federal Aviation Administration (FAA) have issued airworthiness directives as the 

affected extinguishers have also been found outside of Europe. Testing of suspect 

extinguishers continues and the HTOC has recommended that analysis of the halon purity be 

done using a gas chromatography/mass spectroscopy (GC/MS) method. The HTOC is also 

working closely with ASTM International to fast track a halon 1211 Standard that utilizes this 

analysis method so that halon recyclers and purchasers can refer to it for purity determination. 

The existing ASTM halon 1301 Standard will have its analysis test method updated in 

accordance with the new halon 1211 Standard. The HTOC recommends strict adherence to 

these standards to avoid potential risks from reduced fire extinguishing performance or 

increased agent toxicity. 

6.6 Response to Decision XXI/7 

At the request of the International Civil Aviation Organization (ICAO) Secretariat, one coChair and one member of the Technology and Economic Assessment Panel’s Halons 

Technical Options Committee (HTOC) participated in a three day meeting, 1-3 December 

2009, to discuss progress on eliminating halons in civil aviation. This meeting was a follow 

up to the ICAO General Assembly Resolution (equivalent to a Montreal Protocol decision of 

the Parties) A36-12 that requested the ICAO Council to consider a mandate to require halon 

alternatives for lavatory, handheld extinguisher and engine/auxiliary power unit fire 

protection systems. In addition to HTOC, the Deputy Executive Director of the Ozone 

Secretariat also attended the meeting. Attendees from civil aviation included the ICAO 

Secretariat, International Coordinating Council of the Aerospace Industries Associations 

(ICCAIA), Boeing, Airbus, the International Air Transport Association (IATA), US Federal 

Aviation Authority (FAA), Air Transport Canada, European Aviation Safety Agency 

(EASA), and commercial industry suppliers of aviation fire protection equipment. 

The working group developed the following draft text for consideration as a Resolution for 

the 37th General Assembly in September of 2010. 

• Requests that the Council consider a mandate to be applicable in the: 

o 2011 timeframe for the replacement of halon in lavatories for new production 

aircraft. 

o 2014 timeframe for the replacement of halon in hand-held extinguishers for new 

production aircraft. 

o 2014 timeframe for the replacement of halon in engines and auxiliary power 

units for aircraft for which a new application for type certification (sometimes 

referred to as new designs) has been submitted. 

• Urges States to issue guidance material for halon alternatives and fire detection 

systems in cargo compartments for new production aircraft. 

• Encourages States to promote aircraft and engine manufacturers research on halon 

alternative fire suppression systems. 
May 2010 TEAP Progress Report 85

• Urges States to take note of its halon reserves and report back at the next regular 

assembly meeting. 

The Ozone Secretariat and the HTOC note that the dates in the new draft Resolution are up to 

three years delayed from those originally agreed upon in Resolution A36-12. ICAO had not 

yet adopted any changes to their Annexes, which would need to be made in order to require 

implementation of halon alternatives. The reason for the proposed changes is that the 

Chicago Convention requires a minimum of three years, from the date of a change to required 

aircraft design criteria, called Annex 8, to implement the change. The earliest that the ICAO 

Secretariat could make the change and get the Annex approved through their system would be 

2011. Therefore, the earliest date that we could require halon alternatives to be implemented 

would be 2014. This same three year implementation requirement does not apply to changes 

to their Annex 6, which covers provisioning. Therefore it was agreed to keep the original 

2011 date for implementation of halon alternatives in lavatory waste bin fire protection. 

Subsequent to the meeting, ICCAIA, Boeing and Airbus requested that ICAO consider a two 

year delay in the installation of halon alternative handheld fire extinguishers for new 

production aircraft. The reason for the delay is to allow for the further development of a “low 

GWP” unsaturated HBFC, known as 2-bromo,1,1,1-trifluoropropene or 2-BTP. This was the 

agent mentioned in the fire protection section of the TEAP response to Decision XX-8 that 

could be commercialized in the short term as a significant part of the required testing had 

already taken place. In their request to ICAO to consider a two year delay, ICCAIA, Boeing 

and Airbus agreed that even should 2-BTP prove unsuitable, they would meet the 2016 date to 

implement non-halon handheld extinguishers using existing alternatives. These are the two 

high GWP HFCs already approved and the HCFC-123 blend also approved but subject to 

Montreal Protocol production and consumption phase-out. HTOC was concerned with 

granting another two year delay. ICAO recommended a compromise to accept the two year 

delay in exchange for strengthening the requirement from “consider a mandate” to “establish 

a mandate.” ICCAIA, Airbus and Boeing agreed to the compromise. Attendees of the 1-3 

December Meeting are being consulted on the following proposed change to the draft 

resolution: 

• Requests that the Council establish a mandate to be applicable in the: 

o 2011 timeframe for the replacement of halon in lavatories for new production 

aircraft. 

o 2016 timeframe for the replacement of halon in hand-held extinguishers for 

new production aircraft. 

o 2014 timeframe for the replacement of halon in engines and auxiliary power 

units for aircraft for which a new application for type certification (sometimes 

referred to as new designs) has been submitted. 

May 2010 TEAP Progress Report 87

7 Refrigeration, Air-conditioning and Heat Pumps Technical 

Options Committee (RTOC) Progress Report 

7.1 Progress Reports 

In recent years the Refrigeration Technical Options Committee (RTOC) has normally drafted 

Progress Reports for the annual TEAP Progress Report. In the 2008 TEAP Progress Report one can 

find an overview of the latest developments in the various sub-sectors of refrigeration and air 

conditioning; the trends described there are still valid today. 

In the year 2009, the TEAP installed a Task Force to address Decision XX/8. The majority of the 

chapters of this XX/8 report describing the newest developments were contributed by members from 

the RTOC. The XX/8 Task Force report had chapters on domestic, commercial and industrial 

refrigeration, unitary and chiller air conditioning and mobile air conditioning, with Chapter Lead 

Authors that also fulfil this role in the 2010 RTOC Assessment Report. Considering that all relevant 

material was going to be published in the XX/8 Task Force report, it was the opinion of the RTOC 

that the drafting of a separate progress report for the TEAP 2009 Progress Report would be redundant. 

In the year 2010, something similar happened. The TEAP installed a Task Force to address Decision 

XXI/9. The Decision requests a description of HCFCs and environmentally sound alternatives, as well 

as a comparison of low-GWP with high-GWP alternatives, and requests the publishing of a 

reorganised and restructured version of the XX/8 report. The majority of the chapters of this 2010 

XXI/9 Task Force report, describing newest developments, were again contributed by members from 

the RTOC. As for the XX/8 Task Force report, the XXI/9 Task Force report had chapters on domestic, 

commercial and industrial refrigeration, unitary and chiller air conditioning and mobile air 

conditioning, as well as transport refrigeration. The Chapter Lead Authors for the refrigeration and air 

conditioning chapters were again those that fulfil this role for the 2010 RTOC Assessment Report. 

The RTOC therefore took an approach consistent with the one of 2009 and decided that the drafting of 

a separate progress report for the TEAP 2010 Progress Report would be redundant as the relevant 

material is provided in the XXI/9 Task Force report. 

A second issue that needs to be mentioned here is the following. In 2009 the RTOC, via a 

Subcommittee, published a draft report version responding to Decision XIX/8, “HCFC alternatives for 

high ambient temperatures”. In 2010, this draft report has been made final, has been extended with a 

section on air conditioning of deep mines, and will be part of the TEAP 2010 Progress Report. The 

developments described in this RTOC Subcommittee report can also be seen as new material, which, 

under normal circumstances, could have been part of a progress report. 

7.2 RTOC 2010 Assessment Report 

In 2008 the RTOC organised a first meeting in Copenhagen to determine the outline and topics for the 

2010 Assessment Report, as well as the membership that would be involved. It was decided that a 

large part of the membership for the 2006 RTOC Assessment would continue; a number of nonArticle 5 and Article 5 members were dismissed, and others were taken on board. A second meeting 

of the RTOC was organised in March 2009 in Montreal at the offices of the Multilateral Fund 

Secretariat. The RTOC discussed the outline again as well as first conceptual drafts for the chapters. 

Since the long-standing RTOC co-chair Agarwal (India) had indicated that he wanted to resign, the 

Committee endorsed RTOC member Roberto Peixoto (Brazil) as its new co-chair. 

During the period March-August 2009 drafts for the several chapters were updated and were 

discussed in a meeting in Sao Paulo, hosted by the new RTOC co-chair Peixoto. The major issue in 

this meeting was the investigation of the consistency of the approaches in the various chapters. The 
88 May 2010 TEAP Progress Report 

RTOC agreed on the timelines into the year 2010, particularly when new drafts would be circulated 

for review. 

The current status is that a complete draft report will be circulated to all RTOC members for review 

and the results will be discussed in the next RTOC meeting, which was originally planned for 

Bangkok, back to back with the Montreal Protocol OEWG meeting. The move of the OEWG meeting 

to Geneva has caused a rescheduling of the RTOC meetings for 2010. 

The first RTOC meeting will now be held in Prague, August 2010, hosted by a RTOC member; this 

meeting will discuss and amend the semi-final draft that will have to be circulated between May and 

August 2010. This meeting in Prague will then also agree on the draft that will be sent out for peer 

review to a large number of experts and expert institutions in the course of September 2010 (with a 

deadline for submission of comments of mid-November 2010). The RTOC plans to discuss the peer 

review comments received in a meeting hosted by a RTOC member in Hangzhou, China, in 

December 2010; it is confident that it can comply with the deadline of 31 December 2010 for the 

submission of the RTOC 2010 Assessment Report to UNEP. 
May 2010 TEAP Progress Report 89

8 Decision XXI/10 Quarantine and Pre-shipment Report 

8.1 Executive Summary 

As requested by Decision XXI/10, the availability and market penetration of technically and 

economically feasible alternatives were estimated for the four largest consuming categories of methyl 

bromide for QPS: sawn timber and wood packaging material (ISPM-15); grains and similar 

foodstuffs; pre-plant soils use; and logs. MBTOC-QPS estimated that about 1,995-2,571 tonnes of 

methyl bromide used for QPS were immediately replaceable globally for the four main categories of 

QPS, which represents 32-42% of total consumption for these major categories of use. 

For sawn timber and wood packaging material, heat is a technically and economically feasible 

alternative that has a good market penetration in most countries including many Article 5 Parties. For 

at least 28 countries, methyl bromide is not an option and heat is the main alternative used to meet the 

phytosanitary requirements of the FAO-IPPC international standard ISPM-15. Not in kind 

alternatives such as plastic pallets are used in some countries and avoid the need for methyl bromide 

or heat. In some countries, heat was reported to be less expensive than methyl bromide. Six 

additional treatments to methyl bromide and heat are under evaluation by the IPPC for possible 

inclusion as treatment options for wood packaging material in ISPM-15. 

For grains and similar foodstuffs, many treatments target non-quarantine pests and are therefore preshipment treatments. Phosphine is the most commonly used alternative. Controlled atmospheres 

were in usage where this technology was available. Where permitted, dichlorvos and sulfuryl fluoride 

were also used. Several countries specified methyl bromide as the only acceptable treatment which 

limited the use of alternatives even when available. Heat disinfestation is technically but not 

economically feasible. For quarantine pests, phosphine is the most widely used treatment. 

For pre-plant soils use, the United States was the only country that categorised consumption of 

methyl bromide for this purpose as QPS. As a category within QPS, it was the second largest 

consumer of methyl bromide in 2007. Plants for propagation in the US are not eligible for 

certification if nematodes are detected in a sample of the propagation material, and methyl bromide or 

an alternative (1,3-D) are applied to the soil in which the plants are grown is used is used to meet this 

nematode-free requirement. As the treatment targets nematodes that are not quarantine pests 

according to the definition used in the Montreal Protocol, TEAP considered this use of methyl 

bromide in soil inconsistent with this definition. TEAP encourages Parties to require the uses of 

methyl bromide to be fully consistent with the definitions of QPS agreed by the Parties as this would 

reduce the amount of methyl bromide used for QPS. Technically and economically feasible 

alternatives (1,3-D/Pic and methyl iodide/Pic) are available for controlling pests in soils to meet the 

required standard, and MBTOC estimated that about 50-95%% of the methyl bromide used for this 

purpose was replaceable after consideration of the regulatory and other conditions that limit its use. 

TEAP notes that the United States has requested methyl bromide for the same end uses under the 

Critical Use Exemption and the QPS Exemption. According to the Critical Use Nomination 

submitted by the United States, the requirement for plant health is similar and specifies that the plants 

are essentially free from pests and diseases. TEAP notes that use of methyl bromide can be replaced 

in both exemption categories by technically and economically feasible alternatives that have already 

been implemented by many Parties. 

For logs, methyl bromide is the most widely used fumigant for logs and the largest single commodity 

treated using methyl bromide. The quantities of methyl bromide used vary according to the 

requirements of the importing country. In-transit fumigation with phosphine when logs are being 

shipped from one country to another is a technically feasible alternative and less expensive than 

methyl bromide for certain pests and between certain countries. In-transit fumigation with phosphine 

has partially replaced methyl bromide in some countries, but it currently has a small market 
90 May 2010 TEAP Progress Report 

penetration globally. The more widespread application of this alternative is limited by the acceptance 

of bilateral agreements between countries usually due to a lack of efficacy data on specific quarantine 

pests of concern. Other fumigants and mixtures of them are technically and economically feasible 

alternatives in some cases and have been registered, but none have been implemented as quarantine 

treatments for use on logs. Heat applied to logs is a technically and economically feasible alternative 

in some circumstances where sawn timber is acceptable to the end user, but this treatment may render 

the logs unsuitable for the end user which limits its use for the control of quarantine pests. Debarking 

of logs is expensive and sometimes must be combined with another treatment for acceptance as a 

quarantine treatment, which limits its application as a quarantine treatment to mainly high value logs 

in countries where debarked logs are acceptable to the customer. 

In accordance with Decision XXI/10 that required further elaboration of the information provided in a 

previous report, MBTOC-QPS estimated that in Article 5 Parties that more than 60% of the methyl 

bromide used in sawn timber and wood packaging material could be replaced by heat or alternative 

fumigants; less than 10% of the methyl bromide used as a quarantine treatment in grains and similar 

foodstuffs could be replaced by alternative fumigants and controlled atmospheres, and 30-70% for 

pre-shipment treatments in grains and similar foodstuffs could be replaced by fumigants, protectants, 

controlled atmospheres and integrated systems; and 10-20% of the methyl bromide used in logs could 

be replaced by alternative fumigants, conversion to sawn timber (lumber), immersion, debarking and 

heat. There was no categorisation of methyl bromide as QPS used on soil in Article 5 Parties. 

MBTOC-QPS estimated that in Non-Article 5 Parties that more than 60-80% of the methyl bromide 

used in sawn timber and wood packaging material could be replaced by heat or non-wooden pallets; 

less than 10% of the methyl bromide used as a quarantine treatment in grains and similar foodstuffs

could be replaced by alternative fumigants and controlled atmospheres, and more than 80% for preshipment treatments in grains and similar foodstuffs could be replaced by fumigants, protectants, 

controlled atmospheres and integrated systems; about 50-95% of the methyl bromide used in soil 

could be replaced by alternative fumigants, provided the alternatives meet certification standards and 

a key alternative (methyl iodide/Pic) was available; and 10-20% of the methyl bromide used in logs 

could be replaced by alternative fumigants, conversion to sawn timber (lumber), immersion, 

debarking and heat. 

The technical and economic feasibility of alternatives to methyl bromide used for QPS in all countries 

depended mainly on the efficacy against quarantine pests of concern, the infrastructural capacity of 

the country, end-use customer requirements, phytosanitary agreements where relevant, and logistical 

requirements and regulatory approval for the use of the alternative. 

Decision XXI/10 also asked TEAP to describe methodology for the assessment of the impact of 

restricting the quantities of methyl bromide production and consumption for quarantine and preshipment uses. Methyl bromide is important to many countries for facilitating trade while at the same 

time protecting forestry, food production, human health and the indigenous environment from exotic 

pest incursions. The use of methyl bromide or an alternative treatment for quarantine pests before 

departure or on arrival in a country are much less expensive strategies than containment or eradication 

(where possible) which generally involve significant costs. 

MBTOC-QPS suggested that the methodology should focus on the quantities of methyl bromide used 

to facilitate trade for the major QPS categories of methyl bromide use (by quantity) that were reported 

by Parties for QPS, and in particular methyl bromide that was used for QPS on entry to facilitate trade 

by one Party with many different countries. The consumption by category and use in Asian countries 

in future could be examined further since this was the only region where methyl bromide for QPS was 

increasing significantly, according to the 2008 consumption data which was the most complete 

dataset. 

In the case where an exporting country bans the use of methyl bromide for QPS, and the importing 

country had not changed its requirement to allow an alternative to methyl bromide to be used by the 
May 2010 TEAP Progress Report 91

exporting country, the importing country may require fumigation with methyl bromide in another 

country en route, or on arrival. The ability of governments to detect such uses of methyl bromide 

depends on fumigators maintaining good fumigation records, and in governments collecting and 

analysing the records to determine uses for which alternatives are available and could be used. 

Using MBTOC-QPS’s working definition of an available alternative for QPS, which required it to be 

registered and operating to an appropriate level of protection, TEAP in the future could examine the 

constraints and opportunities for methyl bromide replacement in key categories where methyl 

bromide is currently used. Countries that had phased out methyl bromide for QPS could be examined 

in order to understand more completely the necessary timeframe to phase out, the usefulness of 

policies and measures that encouraged alternatives, and the extent and funding of research on 

alternatives that collectively contributed to the successful substitution of the use of methyl bromide 

for QPS. Equally important, areas where substitution was not successful could also be examined. 

The uses of methyl bromide for pre-shipment could also be quantified as much as possible, since it 

appears from the latest information provided by Parties that most of the pre-shipment use in the past 

has been replaced by alternatives. 

The methodology that could be used to assess an alternative as economically feasible could include 

the requirement that its net returns are determined relative to a methyl bromide treatment. An 

alternative should be implemented without significant market disruption and the sectors that benefit as 

a result of the adoption of the alternative should be identifiable. 

The design of any QPS restriction could have an impact on the feasibility of the transition from 

methyl bromide to alternatives for QPS, and the methodology that TEAP could put in place to assess 

the impact of restricting the quantities of methyl bromide production and consumption for quarantine 

and pre-shipment uses. In regard to the design, and without any presumption of such a restriction 

being put in place, TEAP considers a number of factors as important which the Parties may wish 

consider, among them being: the timeframe for Party compliance, the flexibility of Party choice in 

how to maintain compliance, the usefulness of an appropriate exemption pathway that was 

administratively feasible and expedient to take account of trade flow decisions, and whether or not 

pre-shipment or pre-plant soil uses should be included in the methodology. Feedback from the Parties 

on their views of these factors would assist TEAP in the design of appropriate methodology to meet 

the requirements of the Parties. 

TEAP would be pleased to receive any comments from the Parties that they may wish to make that 

would contribute to the further development of this methodology on data accumulation, analysis and 

reporting that could assist the Parties with the assessment of the impact of restricting the quantities of 

methyl bromide production and consumption for quarantine and pre-shipment uses. 

8.2 Introduction 

8.2.1 Mandate and scope 

Decision XXI/10 requests the Technology and Economic Assessment Panel (TEAP) and its Methyl 

Bromide Technical Options Committee (MBTOC), in consultation with other relevant experts and the 

International Plant Protection Convention (IPPC) Secretariat, to provide a report to be considered by 

the 30th Meeting of the Open-Ended Working Group covering the following: 

A review of available information on the technical and economical feasibility of alternatives, and the 

estimated availability, for the following categories of quarantine and pre-shipment uses: 

a. Sawn timber and wood packaging material (ISPM-15); 

b. Grains and similar foodstuffs; 
92 May 2010 TEAP Progress Report 

c. Pre-plant soils use; 

d. Logs; 

The current availability and market penetration rate of quarantine and pre-shipment alternatives to 

the uses listed in paragraph (1) above, and their relation with regulatory requirements and other 

drivers for the implementation of alternatives;

An update of Table 9-1 of the 2009 Task Force report to include economic aspects, and to take 

account of the information compiled under this paragraph, distinguishing between Article 5 and nonArticle 5 Parties and between quarantine and pre-shipment uses separately; 

A description of a draft methodology, including assumptions, limitations, objective parameters, the 

variations within and between countries and how to take account of them, that the Technology and 

Economic Assessment Panel would use, if requested by the Parties, for the assessment of the technical 

and economical feasibility of alternatives, of the impact of their implementation and of the impacts of 

restricting the quantities of methyl bromide production and consumption for quarantine and preshipment uses. 

The full text of Decision XXI/10 is shown in Annex 1. 

8.2.2 Origin and intent of the QPS exemption 

At the 1992 Meeting of the Parties in Copenhagen that established methyl bromide as a controlled 

Ozone Depleting Substance, Article 2H of the Protocol specifically excluded QPS from control 

measures when it stated, inter alia: 

 ‘The calculated levels of consumption and production ...shall not include the amounts used by the 

Party for quarantine and pre-shipment applications’. This was the first time that QPS was mentioned 

in the Protocol documentation. It is notable that in the report of this Meeting of the Parties at that 

time offered no definition of ‘quarantine’ or ‘pre-shipment’ (UNEP/Ozl.Pro.4/15), and the terms were 

defined two years later (UNEP.OzL.Pro.6). 

At the time that Article 2H was documented in Copenhagen in 1992, the Parties were aware that there 

were no alternatives to methyl bromide for a diverse range of treatments carried out with methyl 

bromide. The Parties recognised that although QPS consumption was about 10% of global methyl 

bromide consumption at that time, this relatively small volume was nevertheless sufficiently 

important to merit a specific exemption in the absence of alternatives. Later in 1997, many Parties 

expressed support for retaining the exemption for methyl bromide used for quarantine and preshipment applications, but some expressed concern that exemptions should not overly weaken 

controls on methyl bromide1

. Therefore, unlike other ozone-depleting substances where a process 

was established for essential uses, quarantine and pre-shipment uses of methyl bromide were excluded 

from control. 

Methyl bromide used for QPS performs a dual role of facilitating trade as well as protecting the 

environment against the accidental import of exotic pests that can incur substantial costs for control 

and if possible eradication. The importance of excluding such pests, and the costs of their control and 

eradication if exclusion is unsuccessful, are discussed on page 134 in Section 8.5.5.2. 

 

1 UNEP. 1997. Report of the Meeting of the Parties. UNEP/OzL.Pro.9/12; page 16 
May 2010 TEAP Progress Report 93

8.2.3 Quarantine and pre-shipment definitions and application 

8.2.3.1 Definitions of quarantine and pre-shipment 

The scope of the QPS exemption set out in paragraph 6 of Article 2H has been clarified in Decisions 

VII/5 and XI/12 of the Protocol relating to the terms 'Quarantine' and 'Pre-shipment'. The definitions 

of QPS that follow these Decisions, and that are used in this report, are contained in Annex 2. 

TEAP (2002) provided some discussion and examples of cases that might or might not fall within the 

QPS exemption. There is also discussion of the scope of the exemption from control under the 

Protocol for QPS uses of methyl bromide in TEAP (1999) and the UNEP/IPPC (2008) publication 

‘Methyl Bromide: Quarantine and Pre-shipment Uses’. 

TEAP and its QPS Task Force have provided (TEAP, 2009) an in-depth analysis of the definitions of 

QPS and Decisions of the Montreal Protocol dealing with methyl bromide uses for QPS purposes. 

In response to Decision XX/6(7), TEAP listed methyl bromide uses that had been classified as 

QPS by some Parties but not by others. Parties with use listed by TEAP provided explanatory 

responses that were annexed to the TEAP (2009) report. TEAP notes that the use of methyl 

bromide as a QPS treatment for soil fumigation against endemic pests and diseases for production 

of propagation material of high plant health status is not consistent with the definition of 

‘quarantine’ agreed by the Parties. This is further discussed in the context of alternatives to 

methyl bromide for soil uses (Section 8.3.4.1) and the methodology that could be used by TEAP 

to assess the impact of restricting the quantities of methyl bromide production and consumption 

on QPS (Chapter 8.5, on page 129 in Section 8.5.2.2).

8.2.3.2 Alternatives for quarantine and pre-shipment 

The Sixteenth Meeting of the Parties to the Montreal Protocol resulted in the definition of an 

“alternative” to methyl bromide as “any practice or treatment that can be used in place of methyl 

bromide2

”. In the assessment of the US critical use nomination submissions reviewed annually by 

MBTOC since 2003, a technically feasible alternative to methyl bromide has been defined for many 

years as “an alternative that provides sufficient pest and/or weed control for continued production of 

that crop to existing market standards” (TEAP 2007). 

These definitions focused on non-QPS treatments and did not consider other elements that would be 

required in the definition of an alternative to methyl bromide for QPS. Therefore, for the purposes of 

this report, a working definition of an alternative to methyl bromide for QPS is shown within the 

context of the discussions in Chapter 8.5, which describes draft methodology for assessing the 

technical and economic feasibility of an alternative to methyl bromide for QPS (see page 131 in 

Section 8.5.2.3). 

8.2.3.3 Market penetration 

The Sixteenth Meeting of the Parties also resulted in the definition of “market penetration” as “the 

case-by-case determination of the extent to which an alternative is distributed in the market to users, 

according to information supplied by the supplier, distributer or manufacturer3

. The extent of the 

market penetration of an alternative is dependent on the number of enterprises that need to transition, 

 

2 Handbook. 2009. Annex I of the Report of the Sixteenth Meeting of the Parties. Handbook for the Montreal Protocol on Substances that Deplete the Ozone Layer. 

Eight Edition. Page 502. 

3

 Handbook. 2009. Annex I of the Report of the Sixteenth Meeting of the Parties. Handbook for the Montreal Protocol on Substances that Deplete the Ozone Layer. 

Eight Edition. Page 504.
94 May 2010 TEAP Progress Report 

the estimated training time for the alternative assuming full effort, the opportunities for importing 

alternative equipment, and the cost”. 

In view of the limited time available to provide information in response to the request from the 

Parties, the market penetration of an alternative to methyl bromide for QPS was based mainly on the 

experiences of the members of the MBTOC-QPS sub-committee. 

8.2.4 Summary of response to Decision XX/6 

TEAP responded to technical aspects of Decision XX/6 in its report of October 2009. This report 

responds to Decision XXI/10 and builds on this previous report submitted to the Parties by TEAP in 

2009 in response to Decision XX/6. The report in 2009 by the QPS Task Force in response to 

Decision XX/6 considered the: 

• Volumes of methyl bromide used for QPS, by major uses and target pests; 

• Technical and economic availability of alternatives for the main methyl bromide uses, by 

volume, and of methyl bromide recovery, containment and recycling; 

• QPS applications for which no alternatives are available and an assessment of why 

alternatives are not technically or economically feasible or cannot be adopted; 

• Regulations that directly affect the use of methyl bromide for QPS treatment, using 

illustrative examples; 

• Barriers preventing the adoption of alternatives to methyl bromide; 

• Opportunities for reducing methyl bromide use or emissions for QPS, including technologies 

for recapture and destruction of methyl bromide from QPS applications. 

The report in response to Decision XX/6 also provided: 

• An analysis of the information available and an indication of areas where the information was 

insufficient (and the reasons for this insufficiency), together with a proposal on how best to 

obtain the information as a basis for a satisfactory analysis; 

• A list of categories of use that had been classified as QPS by some Parties but not by others. 

The Parties mentioned in this classification submitted a rationale for their use of methyl 

bromide for QPS, and their responses were included in the Final Report. 

The Final Report of the TEAP QPS Task Force can be found at: 

http://ozone.unep.org/Assessment_Panels/TEAP/Reports/TEAP_Reports/teap-qpstf-october2009.pdf 

8.2.5 Organisation of work 

8.2.5.1 Membership of MBTOC-QPS 

In response to Decision XXI/10 on QPS uses of methyl bromide, TEAP requested a newly formed 

QPS subcommittee within MBTOC to prepare a report on those parts of Decision XXI/10 requiring a 

response by TEAP. 

The QPS sub-committee was comprised of nine members: Six non-Article 5 Parties and three from 

Article 5 Parties. Members came from diverse regions: Africa, Australasia, Europe, North America, 

South America and Asia. In accordance with the Decision, TEAP and the MBTOC QPS subcommittee consulted with the IPPC Secretariat and other relevant experts in the collation and 

assessment of information in support of this report. Further details on the members of the MBTOC 

QPS sub-committee that contributed to this report, together with their disclosures of interest, are 
May 2010 TEAP Progress Report 95

included in the MBTOC membership list at http://ozone.unep.org/Assessment_Panels/TEAP/tocmembers-disclosures.shtml. 

8.2.5.2 Communications and meeting 

MBTOC-QPS work was conducted initially by electronic communication. The website created by the 

Ozone Secretariat was used for storing documents and making them available to for the work of the 

MBTOC-QPS subcommittee in this report. MBTOC-QPS conducted extensive reviews of published 

literature, conference proceedings, QPS regulations from different countries, and undertook 

consultation with experts, and reviewed other relevant information to the best extent possible. 

MBTOC economists assisted with economic aspects of this report. 

MBTOC-QPS met the IFAPA Research and Education Centre in Chipiona, Spain, from 12 through 

16 April 2010 to finalise the report to be presented during the 30th OEWG. This meeting was held 

concurrently with committee meetings of MBTOC-Soils and MBTOC-Structures. 

As with other MBTOC reports from MBTOC-Soils and MBTOC-Structures, MBTOC-QPS had 

limited time at the meeting to share reports that would allow comment and comprehensive input and 

review. The reports from the three sub-committees in MBTOC were not finalised at the meeting in 

Chipiona. A plenary meeting was held on the last day of the MBTOC meeting in Chipiona to present 

summaries of each of the MBTOC sub-committee reports to the MBTOC for discussion and 

comment. In addition, all reports were circulated to members electronically for their comment and 

review after the Chipiona meeting and during the TEAP meeting in Madrid. 

8.2.5.3 Structure of the report 

The responses by MBTOC-QPS to the tasks assigned by the Parties to TEAP and its MBTOC in 

Decision XXI/10 are contained in the following four chapters: 

Chapter 2 – Provides a summary of the QPS exemption, background information on uses of methyl 

bromide for QPS purposes and a summary of the reports written in response to Decision XX/6; 

Chapter 3 – Describes the main alternatives for major uses of methyl bromide for QPS purposes and 

addresses their registration status, technical and economic feasibility plus their estimated market 

penetration. The relation with regulatory requirements and other drivers for the implementation of 

alternatives is also discussed; 

Chapter 4 – Describes a feasible scenario for replacing some QPS uses of methyl bromide globally, 

distinguishing between Non-Article 5and Article 5 Parties and between quarantine and pre-shipment 

uses; 

Chapter 5 – Presents a draft methodology for the assessment of the feasibility of alternatives, and of 

the impact of their implementation and of restricting methyl bromide use for QPS purposes. 

Two Annexes are included: 

Annex 1: Decision XXI/10 Quarantine and pre-shipment uses of methyl bromide

Annex 2: Definitions of Quarantine and Pre-shipment
96 May 2010 TEAP Progress Report 

8.3 Feasibility, Availability And Market Penetration Of Alternatives To Methyl 

Bromide For Quarantine And Pre-Shipment 

8.3.1 Introduction and mandate 

Paragraph 3(1) of Decision XXI/10 requests: 

A review of available information on the technical and economical feasibility of alternatives, and 

the estimated availability, for the following categories of quarantine and pre-shipment uses: 

a. Sawn timber and wood packaging material (ISPM-15); 

b. Grains and similar foodstuffs; 

c. Pre-plant soils use; 

d. Logs; 

The current availability and market penetration rate of quarantine and pre-shipment alternatives 

to the uses listed in paragraph (1) above, and their relation with regulatory requirements and 

other drivers for the implementation of alternatives. 

Previous MBTOC and TEAP reports have provided details of existing alternatives for various QPS 

uses (e.g. MBTOC 1995, 1998 2002 2007; TEAP 1999 2006 2009ab). The 2002 MBTOC 

Assessment (MBTOC 2002) provided detailed discussion of alternatives to QPS methyl bromide use 

on commodities in specific circumstances. A comprehensive discussion on alternatives was included 

in the 2006 MBTOC Assessment Report (MBTOC 2007). A detailed report on QPS and alternatives 

is given in TEAP (2003), produced in response to Decision XI/13(4). More information can be found 

in the QPSTF interim and final reports (TEAP 2009). 

8.3.2 Alternatives for sawn timber and wood packaging material 

This section excludes logs and covers only quarantine treatments of wood that has been sawn into 

lumber and wooden packaging material derived from sawn timber. This material is free of bark, but 

may include sapwood as well as heartwood. Sapwood is often present in lumber and can contain 

insects even in logs that have been debarked. For exports of lumber from New Zealand, some 

countries such as China and Korea do not require fumigation but inspect on arrival and fumigate if 

pests are detected; and other countries such as India require fumigation of lumber containing 

sapwood; and in Japan sapwood is categorized as logs and it is inspected and treated in import 

quarantine. 

Sawn timber may be in trade or made into pallets, dunnage and other packing material associated with 

either international or domestic trade. 

8.3.2.1 Technical feasibility 

8.3.2.1.1 Heat treatment 

The only alternative treatment to methyl bromide treatment approved and accepted internationally 

under ISPM-15 for treatment of wood packaging materials (wood packaging material) is heat 

treatment, including kiln drying. A temperature of at least 56°C, core temperature, must be 

maintained for at least 30 minutes (IPPC 2006). The current (2009) version of the ISPM-15 standard 

(IPPC 2009) specifically encourages the use of heat where feasible in preference to methyl bromide, 

because of the ozone-depleting properties of methyl bromide. 
May 2010 TEAP Progress Report 97

There is substantial use of the heat treatment in many countries to meet ISPM-15. Many countries use 

heat exclusively to meet ISPM-15. Canada does not include methyl bromide as an alternative to heat 

in ISPM-15 treatments carried out in Canada. In general, heat treatment requires a somewhat higher 

level of infrastructural support compared with methyl bromide fumigation, but has the advantage that 

a toxic gas is not used. 

ISPM-15 requires that the wood packaging material be treated to the required standard before it is 

stamped with the logo as evidence of the pallet having complied with the ISPM-15 standard. Where 

packing material such as pallets have not yet been certified, they may be treated to ISPM-15 standard 

in a heated enclosure of some kind. However, some countries may stamp pallets prior to treatment, 

which does not comply with the requirements of ISPM-15. Pre-treatment stamping of pallets was 

understood to have occurred in situations where it may be expedient to treat the packaging material 

and the goods on the pallets together, such as in a loaded shipping container. This may preclude the 

use of heat, where heat-sensitive and dense goods are present, leaving methyl bromide as the only 

available alternative. 

Kiln drying of sawn timber (lumber) exceeds the temperature thresholds and duration criteria defined 

in ISPM-15, thereby providing an alternative quarantine treatment to methyl bromide where insect 

and nematodes are pests of quarantine concern. Higher temperatures are required for control of fungi, 

but some timber (especially hardwoods) can be damaged by the high temperature treatment. 

Canada (CFIA 2007) describes procedures for measuring and achieving ISPM-15 heat conditions with 

both green and dried wood. The Australian (AQIS) standard for heat treatment (AQIS 2009) provides 

procedures for measuring heat dosages to meet ISPM-15 and for the treatment of other commodities 

too. 

8.3.2.1.2 Chemical alternatives 

A chemical treatment is preferred when goods on wood packaging material need to be disinfested to 

meet the requirements of ISPM-15, and the goods are likely to be damaged by heat. The only 

officially-recognised chemical option at present is methyl bromide. Alternative chemicals are being 

evaluated (Section 8.3.2) and non-timber pallets are being used (Section 8.3.2.1.3) 

A new ISPM is being drafted for the international movement of wood that will include two categories 

of treatments. The first category plans to include those that are already in use in bilateral trade and 

that have proven efficacy against specific pests. The second category will be for classes of wood 

(round wood, sawn wood and mechanically processed wood) and will be based on the draft criteria for 

future ISPM-15 treatment submissions and that will use the same decision-tree approach. 

8.3.2.1.3 Not in-kind alternatives for wood packaging material 

Not-in-kind alternatives exist for wood pallets and other wooden packaging materials. These avoid 

the need for methyl bromide fumigation or heat treatment. Plastic pallets (often made from recycled 

plastic) are commercially available and are used by many companies in the EC, the US and many 

other regions of the world. Cardboard pallets can be suitable for loads of about 3,000 kg, for 

example, and are available commercially in Australia, the EC, Kenya, New Zealand, the US and 

others. A detailed description of the environmental and economic benefits of using pallets 

manufactured from different materials is not a topic for inclusion in this report. 

Plastic, cardboard, plywood and particle board can also be used, instead of wood packing materials, 

for boxes, containers and staves which prevent goods moving within packed shipping containers. 

These materials are exempt from the requirements for methyl bromide or heat treatments under the 

ISPM-15, which refers only to solid wood packaging materials. ISPM-15 excludes non-wood 
98 May 2010 TEAP Progress Report 

packaging (plastic, cardboard) and plywood, particle board, oriented strand board and similar 

processed wood that have been glued or pressed during processing (IPPC 2009). 

As a side benefit, a reduction in the volume of new timber used for wood pallets would benefit 

countries where forest resources are under pressure. Kenya, for example, is estimated to use about 

250,000 to 300,000 wood pallets per annum for tea exports alone. This volume of pallets comprises 

about 5,500-6,600 tonnes of cut timber, which require the felling or importation of about 8,330 - 

10,000 tonnes of raw timber per annum (Rodwell 2007). This demand for timber causes problems in 

Kenya where the tree cover is rapidly dwindling due to other pressures such as the need for firewood 

(Rodwell 2007). However, in many Parties especially those that are Article 5 Parties, the added 

expense of using alternative materials to wood as well as in some cases lack of raw materials with 

which to make such pallets, places constraints on access to pallets that are not made of wood. 

8.3.2.2 Economic feasibility 

APHIS (2003) suggests that in the US the use of heat treatment for meeting ISPM-15 is more cost 

effective than methyl bromide fumigation. The cost of treatments in the United States using methyl 

bromide without gas recapture was estimated to range between $1.82 (2003) and $2.34 per pallet 

(including cost of chemical and construction of fixed fumigation structure). The cost to fumigate 

using a tarpaulin structure ranged from $1.79 and $2.70 per pallet. 

Gas recapture is required in some parts of California and Texas where fumigation facilities are sited 

near schools and other vulnerable facilities. In those places, the cost of a methyl bromide treatment 

with recapture was reported to be 2-3 times more expensive than in other locations were recapture 

was not required, when the cost of disposal of the contaminated carbon was also taken into 

consideration (Ken Vick pers. comm. 2010). By comparison heat treatment was estimated to add 

$2.00 per pallet (Jabara et al. 2008). Estimates of the cost of plastic pallets vary widely from 3 to 6% 

more than wooden pallets (Mokhlesi and Lohrabesi 2009) to double the cost. 

The economic impact in the US of using heat treatment to meet ISPM-15 have been assessed, using 

the economic model from the Global Trade Analysis Project (GTAP) (Jabara et al. 2007) for the case 

of two heat treatments. The authors found that ISPM-15 would have only a minor impact on US 

imports, and generally less than 1% change in import value. 

Methyl iodide is registered in some countries. It is also under consideration as a potential alternative 

to methyl bromide in ISPM-15. Methyl iodide is more costly than methyl bromide on a weight-forweight basis, plus the preferred delivery for space fumigation is to mix with CO2 which is likely to 

add further cost. It can be expected that materials cost for the MI/CO2 system will be more expensive 

than methyl bromide. However, as the cost of chemical applied is usually less than 20-30% of the 

cost of fumigation, a significant increase in chemical cost does not translate directly to the same 

level of increase for the whole fumigation. 

As sulfuryl fluoride has not been approved as a treatment under ISPM-15 there is no information on 

the economics of this specific use on wood packaging material. 

8.3.2.3 Market penetration of heat treatments compared to methyl bromide 

There is a trend of compliance with ISPM-15 to entirely using heat rather than methyl bromide. 

A variety of facilities are in use to achieve the specified heat dosage for ISPM-15. They include 

timber kilns (present in many countries), hot water dipping e.g. Bangladesh (Kabir 2005), modified 

freight containers or similar enclosures with either hot water heating (China) or electrical or gas 

heating (Australia, Jamaica). Heat has been used in many Article 5 countries for many years (e.g. 
May 2010 TEAP Progress Report 99

Morocco, Costa Rica, Colombia and Ecuador) and is made easier due to the fact that it can be 

integrated with kiln drying. 

Heat treatment of wood packaging material to comply with ISPM-15 is well established in Article 5 

countries. In Colombia for example, 156 heat treatment companies around the country are presently 

certified to provide this treatment and can treat on the average four million pallets per year. The 

technique has become widely available in just five years since the inception of ISPM-15 in the 

country. Even though the Colombian Institute of Agriculture certified two fumigation chambers for 

complying with ISPM-15 with methyl bromide treatment in 2009, these have not been used so far 

(Arévalo and Cárdenas 2010). 

Of the 626 companies registered in Mexico for treating wood packaging material for compliance with 

ISPM-15, 578 (92.3%) provide heat treatment and only 48 (7.7%) treat with methyl bromide. These 

are located throughout the country but 50% (309) are located in states that border the US and in 

combination can treat 4.8 million packaging units per month, the national total being 9.9 million units 

(García 2007). 

Of the 183 companies registered in New Zealand for ISPM-15 only 19 (10.4%) of them continue to 

treat with methyl bromide (Ken Glassey pers. comm. 2010). As of March 2010, almost 300 

companies in Japan conduct ISPM-15 treatments. Ninety-one percent of them use heat and 9% use 

methyl bromide to meet ISPM-15 requirements (Takashi Misumi, pers. comm. 2010). 

In Argentina, only one facility is registered and authorised for methyl bromide treatment, but it has 

not been used for the past five years since costs and difficulty of operation do not make it a feasible 

option. Heat treatment is the preferred method of complying with ISPM-15, and at least 200 

companies throughout the country are now authorised for heat treatment. Since an important 

consideration is transferring packaging materials to and from the treatment site at least cost, the 

availability in different regions of heat treatment facilities is most important. Owners of such 

facilities quoted costs, health and environmental hazards and others as factors that discourage them 

from using methyl bromide instead of heat. 

Because methyl bromide for QPS was restricted in the past in the EU, and to encourage the use of as 

many alternatives to methyl bromide as possible for the treatment of wood packaging material, the EU 

published a Manual of options and alternatives to achieve the objectives of ISPM-15 without using 

methyl bromide (Vermeulen and Kool 2006). The Manual includes a description of the use of 

controlled atmospheres and sulfuryl fluoride as two possible alternatives to the use of methyl bromide. 

8.3.2.4 Regulatory requirements and other drivers 

If sulfuryl fluoride is approved by the IPPC for use in ISPM-15 in 2011, a revised draft standard 

would go to all countries for consultation in 2012 and could be promulgated in 2013 providing it is 

agreed by the Parties to the IPPC. This would allow those countries where sulfuryl fluoride is 

registered such as Europe, Australia and the USA to use sulfuryl fluoride for the disinfestation of 

wood packaging material. A government could also approve sulfuryl fluoride for domestic quarantine 

prior to this if they so wish. 

Many countries have not registered sulfuryl fluoride for any use. The high global warming potential 

may prevent further registrations of sulfuryl fluoride in some countries. Companies are under pressure 

to reduce their carbon footprint. 
100 May 2010 TEAP Progress Report 

8.3.3 Alternatives for grains and similar foodstuffs 

8.3.3.1 Technical feasibility 

Methyl bromide fumigation continues to be used for pre-shipment treatment of cereal grains where 

logistical constraints at point of export, or importing country specifications, preclude the use of 

phosphine. Phosphine is the principal accepted fumigant alternative to methyl bromide. Methyl 

bromide is also applied when it is specified by regulation, and/or for treatments against certain 

specific regulated quarantine pests. Methyl bromide fumigation may be the treatment of choice or the 

only approved and available treatment for the situations where a quarantine treatment is required. 

There are different alternative treatments of choice for grains to meet appropriate QPS standards, 

depending on whether the treatment is officially required by national authorities for common and 

cosmopolitan insects that attack or are associated with grain in storage and transport (i.e., preshipment), or they are for control and elimination of specific regulated quarantine pests. 

Export cereal grains, such as rice and wheat, are prone to infestation by a number of cosmopolitan 

grain pests that cause damage when in storage and are unacceptable to modern market standards. 

Most of the methyl bromide fumigations are pre-shipment treatments that target non-quarantine pests. 

These pre-shipment treatments are officially required by official regulations of some exporting 

countries or by official requirements of some importing countries. Examples of pre-shipment 

treatments have been reported previously (TEAP 1999, 2002; MBTOC 2002). Export cereal grains, 

similar products and associated packaging from some locations may also be subject to quarantine 

treatments against specific insect pests, notably Khapra beetle (Trogoderma granarium), 

Prostephanus species or contaminants such as specific snails (e.g. Cochlicella spp.) or seed-borne 

diseases such as Karnal bunt (Tilletia indica). 

Many countries have strict quarantine regulations on grain and other durables originating from 

countries where Khapra beetle occurs. Typically, only methyl bromide treatment is specified against 

this quarantine pest, using double normal dosages for stored product disinfestation often with 

extended exposure period. For instance, cereal products from Khapra beetle areas for import into 

Australia require 80 gm-3 of methyl bromide for 48 hours at 21°C with an end point concentration at 

48 hours of 20 gm-3 (ICON 2009). 

8.3.3.1.1 Alternatives for pre-shipment treatments 

There are well known, standard processes for protection and disinfestation of stored grain in storage 

and transport. Grain and similar dry foodstuffs, either bagged or in bulk, can be delivered to an export 

point in a ‘pest-free’ condition without recourse to methyl bromide fumigation (e.g. see MBTOC 

2007). The choice of alternative is dependent on the commodity or structure to be treated, the 

situation in which the treatment is required, the accepted level of efficacy and the cost and the time 

available for treatment. Some alternatives (e.g. some fumigants, heat treatment) may be implemented 

as ‘stand alone’ treatments to replace methyl bromide in certain situations. Others may be used in 

combination to achieve an acceptable level of control. 

These processes, theoretically, can avoid the need for any further treatment against infestation at the 

export port. In practice, consignments may be brought to the export point in infested condition. Also, 

particularly in humid, tropical situations, there is often a high invasion pressure from pests at the 

export point. As a result, an insecticidal process (usually fumigation) must be used to ensure the grain 

meets the exporter’s or importer’s official regulations for lack of infestation. 

In some cases, the pre-shipment treatment is used to disinfest ship holds or other conveyances before 

placing grain or similar commodities in the ship hold, in order to prevent infestation from 

contaminated holds during shipment. Alternatives to methyl bromide for pre-shipment fumigation of 
May 2010 TEAP Progress Report 101

shipholds using phosphine were proposed on the basis of work undertaken in Canada (Field and Jones 

1999). 

Pre-shipment treatments in general are aimed at a lower standard of pest control than quarantine. 

While quarantine treatments lead to a commodity free of regulated quarantine pests, pre-shipment 

only requires the consignment to be “practically free” of pests. This lower level of security gives 

some wider choice of alternatives, with reduced requirements for efficacy testing. 

Alternatives to methyl bromide fumigation for pre-shipment of cereal grains, including rice, vary with 

situation, particularly the required speed of action. In some export situations, there is sufficient 

capacity at the port, to allow slower acting alternative treatments to be used easily, with treatment 

times of 7 days or more for full effectiveness. Phosphine fumigation is in widespread use for this 

purpose, for both bagged and bulk consignments. Controlled atmosphere technologies have some 

usage at present (e.g. Clamp and Moore 2000), but have potential for much more widespread 

adoption. Direct application of pesticide to the grain will also will give pest-free grain to inspection 

standards, sometimes with a holding period before inspection to allow for action of the pesticide on 

the pests. Rapid acting pesticides for direct application include dichlorvos and cypermethrin. The use 

as methyl bromide alternatives is limited by various registration issues and also by market and end 

user requirements, some of which require ‘residue-free’ grain. 

In many export situations, a high throughput is required, where there is limited space at the port for 

treatments and as demurrage costs on waiting vessels is high. Typical turnaround times for methyl 

bromide for a shipment can be 24-48 hours, a time that has to be accommodated in the organisation of 

the export consignment under pre-shipment treatment. 

Sulfuryl fluoride fumigation was restricted by the availability and registration of the fumigant to only 

a few countries at this time. However, it is now used routinely as an alternative to methyl bromide for 

pre-shipment treatment of grain e.g., in Australia. 

Irradiation has been used as a pre-shipment disinfestation of grain (Zakladnoi et al. 1982) and heat 

treatments have been demonstrated at moderate rates of throughput (150 tonnes per hour (Thorpe et 

al. 1984)). Both systems require very substantial infrastructure if they are to match treatment speeds 

provided by fumigants, including methyl bromide. 

Some importing countries may specify fumigation at point of export as a pre-shipment treatment, with 

indications as to what treatments are acceptable. In cases where methyl bromide is specified as one 

treatment, phosphine fumigation may be specified as an alternative. However, several countries 

specify use of methyl bromide as the only acceptable QPS treatment of imported grain from specified 

exporters. 

Treatment of bulk or bagged grain in ships with phosphine after loading may potentially replace some 

current pre-shipment uses of methyl bromide. However, this may be interpreted as falling outside 

‘pre-shipment’ and may not meet regulatory requirements of some exporters and importers who 

require grain to be practically pest-free before loading. Phosphine treatments may be conducted at the 

dockside, in lighters or barges prior to loading a ship, or in the ship after loading and before sailing. 

In suitable ships, in-transit phosphine treatment gives an effective post-export treatment. 

The International Maritime Organisation recommendations on safe use of pesticides in ships and 

shipping containers describe the safe use of both phosphine and methyl bromide at port and in-transit 

(IMO 2008ab). The Organisation specifically recommended that cargoes should not be fumigated in 

ships with methyl bromide prior to sailing due to the risks resulting from the difficulty in ventilating 

the cargo effectively (IMO 1996). As an alternative to methyl bromide, for safety and efficacy 

reasons, in-transit treatment with phosphine is restricted to specially-designed bulk carriers, tankertype vessels and other ships where the holds are gastight or can be made so (Semple and Kirenga 

1997). In addition, equipment must be installed to circulate the phosphine through the cargo mass 
102 May 2010 TEAP Progress Report 

(Watson et al. 1999). The circulation equipment ensures that the gas penetrates throughout the load 

and can be aired from the load prior to unloading. 

In-transit treatment of bulk grain is in widespread use, potentially avoiding the need for methyl 

bromide treatment prior to shipment where import and export regulations permit. USDA APHIS 

estimates that of the 95 million tonnes of wheat and corn that the U.S. exported in 2009, 66.9 million 

tonnes were transported under in-transit fumigation with phosphine. 

8.3.3.1.2 Alternatives for quarantine treatments 

The USDA PPQ Treatment Manual (USDA 2009) contains many treatment schedules specific to 

Khapra beetle and most involve fumigation with methyl bromide. Schedule T307a refers to various 

treatment schedules for commodities and transport vehicles found infested with Khapra beetle for 

post-entry quarantine treatment. Heat treatment at a high temperature and prolonged exposure (7 

minutes at 65.5°C) is given as the only approved alternative to methyl bromide and can only to be 

used when specifically authorised by the APHIS. 

Heat treatment is a good alternative to methyl bromide for controlling many stored product pests, 

including Khapra beetle. Despite its tolerance to temperatures of about 41°C, Khapra beetle is quite 

susceptible at higher temperatures, more so than some common storage pests such as Rhyzoperta 

dominica. There are old but good quality data to substantiate heat susceptibility of stored product 

pests in general. For instance, Husain (1923) studied heat disinfestation of wheat from Khapra larvae. 

Pupae of T. granarium were found to be the most heat tolerant stage, requiring 16 hours at 50°C or 2 

hours at 55°C for ‘100%’ kill, while other stages were eliminated in less than 2 hours (Mookherjee et 

al.1968). R. dominica requires in excess of 24 hours for complete kill at 50°C, 5 hours at 51°C and 10 

minutes at 55°C. Battu et al. (1975) found LT95 for diapausing and non-diapausing larvae to be 7.4h 

and 3h respectively at 50°C. Lindgren et al. (1955) noted a slight dependence of time to complete kill 

at an ambient relative humidity. Treatment at high humidities extended the time. At 55°C, 75% RH, 

95% mortality was obtained after 8 and 15 minutes with 4th instar larvae and pupae respectively. 

Wright et al. (2007) investigated heat treatment of Trogoderma variabile, showing it to have similar 

response to heat as T. granarium. The economic feasibility of heat treatments for grain and similar 

foodstuffs are discussed further in Section 8.3.3.2. 

In the past, T. granarium was quite susceptible to phosphine e.g. Hole et al. (1976), which made 

phosphine a potential alternative to methyl bromide against this pest. However, with the development 

of high levels of phosphine resistance by T. granarium in the Indian subcontinent, phosphine is not 

currently an option for controlling this pest. 

Some winter wheat fields in Texas were infected with Karnal bunt disease, Tilletia indica, in 2001. 

Karnal bunt was detected in Arizona in March 1996 and in Texas in 1997. The 2001 detection in 

Texas was significant because it occurred outside the quarantine area in Texas (J. Schaub pers. comm. 

2010). When infected grain was harvested and transferred to storage bins, the bins and grain handling 

equipment became infected. Methyl bromide fumigation of emptied contaminated storage bins 

requires a high dosage (240 gm-3) for 96 hours to meet quarantine standards. Steam heating to a point 

of runoff in bins also is an effective alternative to methyl bromide providing surface temperatures 

reach 77°C (Dowdy 2002). 

Japan imports about 30 million tonnes of grain including wheat, maize and soybean. Methyl bromide 

is the fumigant of preference for treatment of these imports. There is no approved treatment schedule 

other than methyl bromide where granary weevil (Sitophilus granarius) is detected in the grain. This 

flightless pest, widespread in most countries, is a listed object of quarantine in Japan. The quantity of 

methyl bromide used for grains in Japan is larger than for any other category except whole logs (PPS 

2007). Phosphine fumigation using aluminum phosphide tablets has been included in the plant 

quarantine treatment schedule in Japan (MAFF, 1971). The treatment with phosphine takes many 
May 2010 TEAP Progress Report 103

days and is thus unsuitable where there is insufficient capacity at import ports to allow long holding 

periods. Methyl bromide treatments typically take less than 48h. 

8.3.3.2 Economic feasibility 

Methyl bromide fumigation was used widely in the past to fulfill requirements for pre-shipment 

treatment of grain. In general, other processes are cheaper and more convenient and methyl bromide 

use for this purpose has decreased to the stage where it is typically used only in situations where the 

rapid action of methyl bromide confers technical and economic benefits. 

Use in 1992 for QPS treatment of grains and similar foodstuffs was estimated to be about 7,000 

metric tonnes (TEAP 1997). In 2005, this annual consumption for this purpose was estimated to be 

about 1,700 tonnes (TEAP 2009). This significant reduction, brought about largely by the 

replacement of methyl bromide by phosphine, is indicative of cost competitive nature of phosphine 

compared with methyl bromide. 

Although heat is technically feasible, its use is limited by the high cost of heat treatment facilities that 

are able to heat grain moving at fast handling speeds, such as when loading or discharging, compared 

to the costs of facilities to implement other alternatives. Small scale heat disinfestation facilities for 

bulk grain, operating at a relatively slow speed of tens of tonnes per hour throughput, are 

commercially available. 

8.3.3.3 Market penetration 

See Section 8.3.3.2. 

8.3.3.4 Regulatory requirements and other drivers 

Transition to phosphine for the pre-shipment of grains has been driven largely by economic 

consideration. Increasing health regulations associated with avoiding worker exposure to methyl 

bromide are likely to further encourage use of alternatives. 

Methyl bromide treatment of grains for quarantine purposes continues to be often the only accepted 

and convenient treatment in many cases. There appears to be no drivers away from this situation, in 

the absence of measures to curtail methyl bromide use for QPS purposes. 

8.3.4 Alternatives for pre-plant soils use for propagative material and nursery uses 

8.3.4.1 Technical feasibility 

A very large amount of research has been conducted by some Parties to develop and adopt 

alternatives to methyl bromide for pre-plant soil fumigation, including research for the production of 

propagation material (MBTOC 1994, 1998, 2002, 2007; TEAP 2008 2009ab). Commercial adoption 

of alternatives has been achieved using outreach, market approaches, and MLF projects. The 

development and widespread adoption of floating tray and similar systems for production of tobacco 

seedlings had been an outstanding success, removing a dominant methyl bromide use in many 

countries. 

A statistical analysis undertaken by MBTOC for expert assistance with CUNs was conducted to 

evaluate alternatives to methyl bromide for pre-plant fumigation (Porter et al. 2006). It mainly 

concentrated on production of strawberry fruit and tomatoes. However, it identified alternatives 

which are technically and economically feasible to replace methyl bromide and the relative 

effectiveness for many pathogens which affect the nursery sectors. Analyses from strawberry fruit 
104 May 2010 TEAP Progress Report 

trials showed that a large number of alternatives used alone or in various combinations had mean 

estimated yields which were within 5% of the estimated yield of the standard methyl bromide with 

chloropicrin (Pic) treatment (methyl bromide/Pic 67:33). Of these, a number of alternatives led to 

results that were statistically indistinguishable from those with methyl bromide/Pic treatments. These 

included chloropicrin alone, 1,3-dichloropropene (1,3-D) + Pic, 1,3-D/Pic + metham sodium. methyl 

iodide + Pic, which was registered in the majority of US States in 2008 (excluding California), is 

currently undergoing review for registration in several countries. 

Efficacy standards for alternatives to methyl bromide used as a certified nursery treatment require a 

higher standard of pest control than for alternatives used for annual crop production in a fruiting field. 

The objective of the treatment for certified nursery treatment is not to optimize yield of fruit for a 

single year, but rather to produce a high quality root system that is free of damaging pests and 

pathogens and will perform well when transplanted to the production (fruiting) fields. As shown 

below, a number of these alternatives have been adopted as effective alternatives for nursery uses in 

many Non-Article 5 countries that once used methyl bromide for nursery uses (MBTOC 2007; TEAP 

2008, 2009ab; EC 2008). Alternatively, substrates using soilless mixes are proving very effective in 

replacing methyl bromide for many nursery uses. 

As mentioned previously, the use of methyl bromide for pre-plant soil treatment under the QPS 

exemption amounts to an estimated 2,850 tonnes (Table). In 2003, 1,491 tonnes were sought for 

Critical Use Exemptions by 7 Parties, ie. Australia, Canada, 4 member States of the EC, Israel, Japan, 

New Zealand and the US of which approximately 1,050 tonnes have been replaced with alternatives. 

These include predominantly 1,3-D/Pic mixtures, chloropicrin used alone or increased use of soilless 

substrates for many nursery uses (strawberry runners, fruit and ornamental plant nurseries, forest 

nurseries, bulb nurseries and others) and methyl iodide/Pic. The above chemical alternatives, together 

with dazomet, have effectively phased out methyl bromide use for turf in Australia (M. Mitchell R 

and R Fumigation pers. comm. 2009). Methyl iodide/Pic mixtures, whilst not yet registered in many 

regions of the world, is being accepted as a direct replacement for methyl bromide in most pre-plant 

nursery uses, although concern for the potential for phytotoxicity has also been noted (CDFA 2009). 

Steam and solarisation are also approved alternatives in California in containerised production 

systems. 

The production of propagation materials is subject to strict health standards and often certification 

requirements, which frequently require the use of methyl bromide or a suitable alternative. In many 

cases, inspection or prevalence thresholds do not exist for endemic pests and often there are limited 

studies on the levels of pests carried on the propagation material due to the difficulties in potential 

litigation if reported. Many soil-borne pathogens (especially fungi) can be isolated from and spread 

on propagation material (DeCal et al. 2004 and 2005), but their levels are often insignificant to those 

found in the soils where the source material is planted. In the past, MBTOC undertook a survey under 

which showed that methyl bromide does not control all pathogens in soil. Other studies have also 

shown that plants grown in soils treated with methyl bromide contain pathogens, which are known to 

occur in the regions to which they are exported (De Cal et al.2004; 2005). To overcome this 

deficiency, there is potential for many alternatives to be used for propagation material without 

increased risk of disease in the final production field. 

In the case of strawberry runners for example, methyl bromide is used to meet the certification 

standards for strawberry runner stock. Since a single strawberry runner grown in year one can expand 

to several million runners over three generations in soil, the reduction of pests in an early generation 

of the multiplication process is of particular importance in preventing the accumulation of large pest 

and disease populations later. The same is true for stock plants used for producing cuttings of many 

ornamental plants. 

The certification typically specifies a low tolerance of particular pests and diseases, but rarely would 

report a level of detection for pathogens, except nematodes. In most of the multiplication stages, 

certification is only achieved by visual inspection of above ground plants and not by direct 
May 2010 TEAP Progress Report 105

measurement of diseases i.e., lesions on roots. In the US the nursery stock certification standard 

states that “All nursery stock shall be kept ‘commercially’ clean with respect to established pests of 

general distribution. Commercially clean shall mean that pests are under effective control, are 

present only to a light degree, and that only a few of the plants in any lot or block of nursery stock or 

on the premises show any infestation or infection, and of these none show more than a few individuals 

of any insect, animal or weed pests, or more than a few individual infestations of any plant disease”. 

Additionally, the nematode free certification standard states that “Any sample in which nematode is 

detected shall be considered infested and not eligible for certification under the provisions of this 

article” (3 CCR § 3055.5). 

8.3.4.1.1 Alternatives to methyl bromide for strawberry runners 

There are several accepted alternatives to methyl bromide for the production of propagative material. 

Methyl iodide and 1,3-D, either alone or in combination with chloropicrin, are proving extremely 

effective in several countries and for several US nursery sectors e.g. Kabir et al. (2005). A recent 

version of Californian Nursery Inspection Procedures Manual: Item #7 “Approved treatment and 

handling procedures to ensure against nematode pest infestation”, lists 1,3-D and methyl iodide as 

alternative treatments to achieve certification requirements related to nematode control, although the 

potential for phytotoxicity with methyl iodide in sandy soils is noted (CDFA 2009), and methyl iodide 

is not currently registered in California. Steam and substrates are also considered suitable options for 

treating soil that will be used in containerized nursery production systems and for achieving the high 

health status involved. 

Strawberry production from transplants fumigated with methyl bromide alternatives was evaluated in 

Spain (López-Medina et al. 2007); results indicated that treatment with 1,3-D alone or 1,3-D/Pic are 

efficient alternatives to methyl bromide for high elevation strawberry nurseries. As a result, 1,3-D/Pic 

and Pic alone have totally replaced the use of methyl bromide in the Spanish strawberry runner 

industry (García-Méndez et al. 2008; López-Medina et al. 2007; De Cal et al. 2004), and are used as 

the key alternatives to replace methyl bromide in many other countries which have phased out methyl 

bromide e.g., Italy, Belgium, UK. Runia et al. (2008) published a review of the various combinations 

of chemical and cultural practices used in northern Europe for the control of nematodes and the major 

diseases attacking strawberry runners. 

These alternative fumigants are registered and available in regions producing strawberry runners in 

the US, but are not approved as a certified nursery treatment with the exception of 1,3-D under 

specific soil texture, temperature, and moisture conditions. Local regulations may also limit the use 

of some of the alternatives for health reasons. Pre-plant soil treatments with MI/Pic, Pic followed by 

dazomet and 1,3-D/Pic followed by dazomet were shown to be potential alternatives to methyl 

bromide for strawberry runner production in California (Kabir et al. 2005). MI/Pic is now being 

adopted by the strawberry runner industry in the south-east United States (USA 2009 CUN for 

strawberry runners). Nursery yields and subsequent fruit yields in California were found to be similar 

to those obtained with methyl bromide when treated with MI/Pic, or 1,3-D followed by dazomet and 

chloropicrin followed by dazomet, although economic considerations may influence adoption 

(Fennimore et al. 2008). In Australia, 1,3-D/Pic is being used in the northern warmer regions. 

Although it gave excellent control of pathogens, it has not been adopted in the cool, high elevation 

nurseries due to phytotoxicity (Porter et al. 2009). Methyl iodide has been very effective and is likely 

to be adopted in Australia when it is registered. 

8.3.4.1.2 Non-chemical alternatives - substrates 

An alternate approach to chemical soil treatments is the production of nursery stock in bags or 

containers of different types, using soilless substrates (MBTOC 2007). Substrates are becoming 

increasingly adopted in many countries as they avoid the need for methyl bromide (Walters et al. 

2008). 
106 May 2010 TEAP Progress Report 

Strawberry plug plants were found to be a viable alternative to soil fumigation, as long as specific 

requirements associated to this technology are met (Durner et al. 2002; Sances 2005). Maintaining 

good hygiene levels for plug plants is essential to their further expansion. Contamination can produce 

outbreaks of diseases, especially some airborne diseases, which can proliferate under the controlled 

conditions of plug production. 

Economically feasible production systems that produce high quality propagation material have been 

identified. In Japan for example, a simple, economically feasible system using trays filled with 

substrate proved particularly useful for the production of strawberry runners. Various materials were 

used as substrates (e.g. rockwool, peat moss, rice hulls, coconuts husk and bark) and they can be 

reused after sterilising with solar heat treatment or hot water (Nishi and Tateya 2006). Increased 

profits and earlier fruit yield have been shown when using plug plants in north Florida fruit 

production fields where early harvests are critical for competing with fruit grown in south Florida 

(Hochmuth et al. 2006) and Brazil (Giménez et al. 2009). Plugs have not been shown to be cost 

effective in fruiting fields in the main production area in south Florida. 

Soil-less propagation systems are also well developed for ornamental plants, for example roses, where 

a technique known as rose “stenting” involves multiplication of grafted cuttings on different 

substrates. Cutting and grafting are performed as a single action, which greatly speeds up the 

propagation process. In only three weeks the resulting “miniplant” measuring 15-18 cm and with 

fully functional roots can be transplanted to the production field for roses grown for cut-flowers. The 

system has proven cost effective in California (Joshel and Melincoe 2004). Originally developed in 

the Netherlands, this technique is now in wide use in many countries around the world where 

production of rose propagation material is important, for example France, Ecuador, Colombia and 

Uganda. A robot has been recently developed in the Netherlands (http://www.rootinghormones.com/Video_Robot.htm) to reduce the need for hand labour and to speed up the process of 

plant propagation. For rose nurseries producing propagative material for garden roses, the mini-plants 

would still have to be transplanted to field nurseries which much be treated to meet certification 

standards, so the need for methyl bromide or an approved alternative would remain. 

Cuttings and slips of a wide variety of propagation materials including ornamental plants, fruit trees, 

forest trees and others, which are subjected to certification requirements are also produced in 

substrates in many countries around the world that export such materials internationally. 

8.3.4.1.3 Non-chemical alternatives - steam 

Steam is in wide use for treating used substrates recycled for use for the production of propagation 

materials in Europe (EC Management Strategy 2008) as well as in other countries around the world, 

including Article 5 Parties producing propagation materials which are subjected to certification 

requirements, for example The Netherlands, Costa Rica and Colombia. Runia et al. (2008) published 

a review of the various combinations of chemical and cultural practices used in northern Europe for 

the control of nematodes and the major diseases attacking strawberry runners. 

8.3.4.2 Economic feasibility 

Trials conducted in California using different steam application with or without solarisation (Gilbert 

et al. 2009) have shown that pest control is equal or better than that achieved with methyl 

bromide/Pic, particularly in the case of weeds. The cost of disinfesting soils with different methods 

presently available have been evaluated by Fennimore and Goodhue (2009) with encouraging results. 

Such methods could be adapted to nursery production for relatively low acreage production crops and 

are in fact recognized in certification standards. 
May 2010 TEAP Progress Report 107

Research with strawberry plug plant production in Florida showed an increased net income when 

using this method, through higher and earlier fruit yield and reduced water and energy consumption 

(Hochmuth et al. 2006). Early fruit yield was also confirmed by Giménez et al. (2009) in Brazil. 

8.3.4.3 Market penetration 

Presently, there is widespread adoption of alternatives for pre-plant soil use in many countries, and 

their market penetration has been 100% in sectors and areas which have phased out methyl bromide 

previously sought under the ‘Critical Use Exemption’ process in the Montreal Protocol. For instance 

in Spain, Italy, UK, Belgium and Poland 1,3-D/Pic or Pic alone have been widely adopted in the 

strawberry runner and other plant nursery industries, previously reliant on methyl bromide. 

Registration prevents some alternatives, such as methyl iodide and some mixtures (eg 1,3-D/Pic) from 

being available for all uses of methyl bromide presently classified under QPS exemptions (MBTOC, 

2007; TEAP, 2008; 2009; EC, 2008). The key issue to assist their use is to give consideration of 

alternatives for inclusion under regulations or certification rules, which may affect their use for 

production of propagative material. It is noted that efficacy requirements for certification 

programmes for propagative materials are more rigorous than efficacy requirements for plants in 

fruiting fields. 

Commercial adoption of methyl iodide for example, is taking place at a very fast rate in US states 

such as Florida where it has recently become registered for a wide range of crops including 

ornamentals, forest nurseries and turf (US CUN Ornamentals 2009). 

Steam is in widespread use for treating used substrates that have been recycled for use in the 

production of propagation materials in Europe (EC Management Strategy 2008) as well as in other 

countries around the world, including Article 5 Parties that produce propagation materials which are 

subjected to certification requirements, such as Costa Rica and Colombia. 

8.3.4.4 Regulatory requirements and other drivers 

8.3.4.4.1 Strawberry runners, turf and other propagative material 

The United States used methyl bromide for treatment of soil used to produce strawberry runners under 

the QPS exemption. Although Chile classified this same use as QPS at one point, in 2009 it notified 

the Ozone Secretariat that they did not consider this use to qualify for the QPS exemption and it is 

thus included within the controlled uses of methyl bromide. 

The United States is now the only Party to the Montreal Protocol that classifies pre-plant fumigation 

of soil where propagation materials subjected to strict health requirements are produced as a QPS 

treatment (Federal Register USEPA 2003). 

The Final Rule (Federal Register - 68 FR 2138) that exempts methyl bromide for QPS in the United 

States states that the exemption applies “for use with plants for planting that are to be transported 

(complete with rootstock) from one distinct locality to another, and that requires that methyl bromide 

is used to meet official quarantine requirements specifying that the underground portions of the 

propagative material are to be free from quarantine pests”. Further, the document states that the 

exemption is only ‘ to meet official quarantine requirements of the destination to which such material 

will be transported’. The document further specifies a process to rectify compliance if sent to a place 

without official quarantine requirements. The interpretation of the rule appears broader than just for 

quarantine pests (see Section 8.3.4.1). 

Pre-plant fumigation of soils with methyl bromide to produce plants for propagation or turf is distinct 

from treatments of soil to eliminate recognised quarantine pests either in soil transported as a substrate 

or treated in situ. The key difference is that pre-plant soil use is often applied many months prior to 
108 May 2010 TEAP Progress Report 

harvest of the plants and treatment is used to minimise spread of common endemic pests (for example, 

many soil-borne fungal pathogens and nematodes). In contrast, treatment of soil or substrate that is 

either imported or exported as a commodity (to grow plants in) is sometimes fumigated with methyl 

bromide as a quarantine measure to ensure freedom from a pest not found in the region to which it is 

exported. Also, equipment moving between countries or between quarantine jurisdictions and which 

may be contaminated with soil that is difficult to remove, is often fumigated with methyl bromide as a 

precaution against introducing a quarantined pest into a new area. 

There has been an assumption that methyl bromide provides disease free material when used as a preplant treatment, when in reality low levels of pathogens are often found, If certification is used as a 

requirement, these generally specify a pathogen threshold and these can help with assessment of the 

suitability of an alternative. 

Pre-plant soil use of methyl bromide for nursery material which is under certification is mostly used 

for regulation of non-quarantine pests, and this should not be confused with use of methyl bromide for 

treatment of incursions or outbreaks of quarantine pests which fall under the QPS exemption (ie the 

potato cyst nematode in the USA). The former is performed to comply with a high health requirement 

usually involving pests (nematodes, fungi and weeds) which are widespread or have been reported 

and are known to occur within the region. 

The responses provided by Parties to the 2009 QPS Taskforce report identified that Parties are 

interpreting the definitions for pre-plant soil use under QPS differently (Table 8-1). As shown in 

Table8-5 there are further sectors where this definition applies in the United States. 

Table 8-1: Parties that may and may not categorise pre-plant fumigation of soil during production 

of propagation material of high plant health status to be QPS 

Pre-plant fumigation with 

methyl bromide 

Parties that have classified 

this use as QPS 

Parties that have NOT classified this use 

as QPS and classify it as a controlled use1

Bulb propagation USA Australia, EC 

Deciduous nurseries USA EC (Belgium, France, UK), Israel, New 

Zealand 

Rose nurseries USA Australia 

Forest nurseries USA EC (France) 

Strawberry nurseries USA Argentina, Australia, Canada, EC (Belgium, 

Spain, France, Italy), Israel, Lebanon, New 

Zealand 

Raspberry nurseries USA EC (UK, France) 

Turfgrass (sod) USA Australia 1

Parties that have used methyl bromide for this use but have phased out its use or are phasing out its use under the 

‘Critical Use’ Process or MLF projects 

MBTOC considers that nearly all pre-plant soil use of methyl bromide for nursery stock and turf use 

is for treatment of endemic pests, except methyl bromide used for containment of pest incursions e.g., 

about 400 tonnes of methyl bromide annually for potato cyst nematode in two States. The pre-plant 

uses of methyl bromide for QPS are not consistent with the definition of quarantine as defined by the 

Parties because the treatments target endemic pests and not quarantine pests. Many Parties have 

applied for ‘Critical Use’ exemptions for these uses under the Montreal Protocol. As mentioned, the 

United States has provided information for its use under QPS in the QPS Task Force reports in 2009 

(TEAP 2009ab). 
May 2010 TEAP Progress Report 109

8.3.4.4.2 Forest plants 

Regulations in the US appear to be a driver for the increased use of methyl bromide under the QPS 

rather than the Critical Uses Exemption (CUE). Recently the States of Alabama, Arkansas, Georgia, 

Louisiana, Mississippi, North Carolina, Oklahoma, South Carolina, Tennessee, Texas and Virginia 

have updated their phytosanitary regulations to enable their forest nurseries to qualify for methyl 

bromide under the QPS exemption. These States use QPS-MB in accordance with an: 

• EPA 2003 ruling that tree seedlings that are shipped across state boundaries (interstate) 

qualify for QPS-MB use; 

• EPA 2004 ruling that tree seedlings that are shipped within the state would not qualify for 

QPS-MB use unless the state’s requirements included language that specifically prohibited 

movement between local jurisdictions “... unless the commodities are free of pests”; and 

• Amendment to Section 19 of the Plant Protection Act that requires the Secretary of 

Agriculture to determine whether a methyl bromide treatment should be authorized as an 

official control to prevent the introduction or spread of plant pests or weeds either across state 

boundaries or across localities within a State. 

The allocation of QPS-MB for forest nursery users will lead to a reduction by the US for the same 

users that have also qualified for CUE-MB, thereby avoiding over-allocation of methyl bromide to 

users that are present in both programmes. 

8.3.5 Alternatives for logs 

8.3.5.1 Technical feasibility 

Methyl bromide is the most widely used fumigant for logs and the largest single commodity treated 

using methyl bromide. It does have some limitations i.e., limited penetration, particularly across the 

grain and into wet timber. Most arthropods associated with timber are quite susceptible to methyl 

bromide but much higher dosages are required to kill fungi e.g., see Rhatigan et al. (1998). Green 

logs are problematic to treat due to the high moisture content (80%), presence of bark (very 

adsorbent), size and large volumes. Overall, methyl bromide is currently the best log fumigant that is 

registered and available. 

Treatments of logs may need to be rapid, such as at point of export or import, to avoid charges and 

congestion at ports associated with occupying restricted port area for the treatment. Where quarantine 

treatments can be applied outside port areas, such as prior to export or in-transit, alternatives to 

methyl bromide that take a longer time can be used. Many pests of quarantine significance, which 

attack green wood, do not re-infest dry and debarked wood. 

Kiln-drying of lumber kills insect pests some of which also may be of quarantine concern (see page 

111 in Section 0: Heat treatment), Specific QPS alternatives for logs are discussed below, followed 

by discussion of some processes under development. 

8.3.5.1.1 Reduction in methyl bromide dosage 

Treatment specifications for logs have not been harmonised worldwide and schedules vary with 

country of import and target pest. This is because the quarantine security requirements are set by the 

importing country in accordance with their unique quarantine requirements—a right guaranteed by the 

World Trade Organization. Korea requires 25 gm-3 for 24h at 12-15°C (Yu et al. 1984), China 120 

gm-3 for 16h at 5-15°C, and Malaysia requires 128 gm-3 for 24 hour exposure at the higher 

temperature of 21°C. 
110 May 2010 TEAP Progress Report 

Significant savings of methyl bromide could be achieved by reducing the fumigation rate in situations 

where the use can be shown to be excessive. Using New Zealand as an example, the consumption of 

methyl bromide by New Zealand could be reduced by 53 tonnes per annum by reducing the methyl 

bromide fumigation rate from 120 to 80 gm-3 (Ken Glassey, pers. comm. 2010). Examination of the 

data generated in New Zealand show that the lower dosage of methyl bromide is effective for 

controlling the target pests. However, permission to use the lower dose in commercial practice is 

determined by the importing country in according to the level of quarantine security demanded by that 

country to satisfy its unique quarantine requirements. 

A new ISPM is being drafted for the international movement of wood, although its acceptance by the 

Parties to the IPPC will not necessarily result in a reduction in methyl bromide used for wood 

packaging treatments. This will include two categories of treatments, firstly those already in use in 

bilateral trade and with efficacy against specific pests. The second category will be for classes of 

wood (round wood, sawn wood and mechanically processed wood) and will be based on the draft 

criteria for future ISPM-15 treatment submissions and use the same decision-tree approach. A call by 

the IPPC for potential treatments of wood moving in international trade was issued in 2009. 

8.3.5.1.2 Alternatives for logs - fumigants 

Phosphine 

New Zealand has pioneered the use of phosphine for the in-transit fumigation of Pinus radiata logs 

destined for China. It is now routinely used as a quarantine and pre-shipment measure and has 

partially replaced methyl bromide for this purpose. However, phosphine in-transit can only be used to 

treat logs shipped below deck in the holds, which is about two-thirds of each shipment. 

One of the major disadvantages of phosphine when compared to methyl bromide is the long exposure 

time (up to 10 days) required, but this is overcome by applying the phosphine in transit. Considerable 

efficacy data has been developed in support of this methyl bromide alternative (Hosking and Goss 

2005; Zhang 2003; Zhang and van Epenhuijsen 2005). However, efficacy data for the wood wasp 

Sirex noctilio, a quarantine pest of concern for India, has yet to be obtained to the level required for 

approval for trade with India. 

The current dosage specification requires at least 200 ppm phosphine (v/v, 0.28 gm-3) to be 

maintained for 10 days. Due to sorption of the gas by the logs (Zhang 2004) top-up of phosphine is 

required 5 days into the voyage to prevent the concentration falling below 200 ppm. In-transit tests 

have shown an even gas distribution throughout the loaded ship holds. High concentrations of CO2

also occur within the ship holds during the fumigation period that may increase the insecticidal action 

of the fumigant. The current dosage specification is based on the Australian experience with stored 

grain pests (insects) and is likely to be significantly higher than required where no insect resistance is 

involved (Frontline Biosecurity 2005). 

Phosphine is typically produced in the reaction of aluminium or magnesium phosphide with water. 

There are some formulations of phosphine available in cylinders as technical grade, pure compressed 

gas or diluted with CO2. The gas is highly toxic to insects and has remarkable penetration ability 

(Spiers 2003). Because the egg and pupal stages of insects respire slowly, they are generally more 

tolerant than the larval and adult stages which respire relatively quickly. Phosphine is generally 

ineffective against fungi infesting timber. 

Phosphine has long been used for the treatment of grain insects but repeated treatment of grain silos 

and poorly conducted fumigations has led to high levels of phosphine resistance in stored grain pests 

in some countries (Zettler 1997, Collinson 1999). Such resistance is not an issue for one way 

commodities such as forest produce and extrapolation of data on dosage requirements from grain 

insects may not be relevant for forest produce. 
May 2010 TEAP Progress Report 111

Sulfuryl fluoride 

Sulfuryl fluoride is a similar fumigant to methyl bromide except that the fumigation temperature 

usually needs to be higher to achieve the same level of pest mortality for all stages including the egg 

stage. Sulfuryl fluoride penetrates wood significantly better than methyl bromide (Scheffrahn and 

Thoms 1993). Sulfuryl fluoride is reported to have a large global warming potential (Papadimitriou et 

al. 2008). 

Methyl isothocyanate/ Sulfuryl fluoride mixture 

The mixed gas of MITC and SF was registered in Japan in 2004 for logs infested with forest insect 

pests. MITC does have high sorption characteristics and an odour (UNEP 2001). MITC used in 

mixture with CO2 is effective against wood borers, bark beetles, and ambrosia beetles at 40-60 gm-3

for 24hrs at 15°C (Naito et al. 1998); and it was found to be particularly effective against pinewood 

nematode (Soma et al. 2001). 

Pine wood nematode were killed in a large scale test using 97,400, 59,500 and 22,700 individuals 

with SF 27 gm-3 + MITC 27 gm-3 at 10°C, SF 21 g m-3 + MITC 21 gm-3 at 15°C and SF 15 gm-3 + 

MITC 15 gm-3 at 25°C, respectively (Soma et al. 2006). The sulfuryl fluoride/methyl isothiocyanate 

mixture is under evaluation for inclusion in the quarantine schedule in Japan. 

Methyl iodide 

In Japan, the developments of alternative chemicals to methyl bromide for imported logs has been 

carried out by the Ministry of Agriculture, Forestry and Fisheries, manufacturers and other bodies 

concerned with methyl bromide use. Methyl bromide use for logs is the largest use of this fumigant 

for plant quarantine in Japan. Methyl iodide is not used for the disinfestation of quarantine pests in 

logs as it is currently registered for logs or other post-harvest uses in only a few countries in the 

world. 

Complete mortality of the pinewood nematode and the longhorn beetles, Monochamus alternatus and 

Arhopalus rusticus, were achieved at 84 gm-3 at 10°C, 60 gm-3 at 15°C, 64 gm-3 at 20°C, 48 gm-3 at 

25°C respectively using methyl iodide 50% and carbon dioxide 50% (Kawakami et al. 2004). This 

mixture is now registered in Japan for timber treatment and is in the process of being included in the 

quarantine schedule. The limited amount of research that has been undertaken suggests it is no better 

than methyl bromide in controlling pathogens in wood and may be inferior (Schmidt and Amburgey 

1997). 

Cyanogen 

Cyanogen, sometimes referred to as ethanedinitrile, shows promise but is yet to be registered or used 

commercially. Its registration is pending in Australia. More data are needed, however, in order to 

realise the considerable potential for cyanogen as a methyl bromide alternative for logs (Wright et al.

2002). 

8.3.5.1.3 Alternatives for logs – non fumigants 

Heat treatments 

Heat treatment has been accepted as a quarantine treatment for logs and timber to be shipped to the 

USA and many other countries for many years (e.g. USDA 1996). The general specification requires 

the wood to reach a core temperature of 71°C for 60 minutes. Kiln drying of timber to a moisture 

content of less than 20% using temperatures over 70°C is often a commercial requirement but also has 
112 May 2010 TEAP Progress Report 

long been accepted as a quarantine treatment by most importing countries. Currently, 56°C core 

temperature for 30 minutes is required under ISPM-15 for wood packaging material. 

Heat treatment of unprocessed logs is an approved risk mitigation measure for importation into the 

USA (Morrell 1995). Steam heat is a more effective quarantine measure than dry heat (USDA 1994; 

Dwinell 2001). Moist heat treatment is an integral part of log conditioning prior to peeling and has 

the additional benefit of eliminating quarantine pests. 

Moist heat treatment can be, if done to a level necessary for pest kill, an integral part of log 

conditioning prior to peeling veneers and has the additional benefit of killing any quarantine pests that 

might be present in the wood. 

A considerable volume of literature addresses thermal mortality of insects and has been reviewed by 

Hosking (2002a). Jamieson et al. (2003) provides a good general summary of the literature on heat 

mortality of insects and fungi. A better summary of heat treatment applications for forestry produce is 

that of Dwinell (2001). 

Irradiation 

Gamma irradiation is currently approved for the disinfestation of logs into Australia at a rate of 10 

kGy (1.0 Mrad). However, its practical application must overcome a number of hurdles, not the least 

being the construction of large irradiators to handle logs and bulk wood products. 

Irradiation is also limited by poor penetration into freshly cut logs, potential damage and dosedependent degradation of wood products such as fibre board and paper, variation in effect on different 

insect groups, and very high dosages required to eliminate fungi (Morrell 1995). 

Water soaking or immersion 

Water soaking or immersion provides a way to control pests on imported logs. Immersion of some 

logs destined for plywood manufacture is a useful process as it improves the quality of the products. 

The storage of logs in water or under water spray has long been accepted as an effective treatment for 

terrestrial insects and fungi. Salt water immersion of logs for 30 days is an approved treatment for 

logs into Japan but contamination of waterways with bark is an issue. The upper surface of the logs 

above the water level is sprayed with an insecticide mixture such as dichlorvos as part of the pest 

management strategy (Reichmuth 2002). 

The potential for use of water soaking for quarantine treatment of imported logs is limited by the large 

area of water required and the undesirable side effects of ponding large volumes of logs, making its 

application on a large scale unlikely. 

Sawn Timber 

Conversion to timber frequently avoids the need to fumigate for many markets that require fumigation 

of logs. Due to a lack of infrastructure, cost, tariffs and customer requirements (e.g., veneer) this may 

not be a viable option in most cases. 

Debarking 

Bark removal has long been a key strategy in reducing contamination of logs and a way to reduce the 

risk of logs and sawn timber carrying certain insects and fungi of quarantine concern. 

While debarking removes surface contamination and also bark and cambium, which are areas 

particularly prone to pest attack, it does not affect insects and fungi already in the wood (USDA 

1992). Many countries require debarking of all imported logs. Because of the high cost, and the 
May 2010 TEAP Progress Report 113

requirement by customers in major Asian markets that bark remain on logs, its application as a 

quarantine treatment is limited and frequently only carried out on high value logs. 

Microwaves 

Microwaves are essentially a heat treatment using electromagnetic energy in the 10 – 30,000 MHz 

range. It seems unlikely, however, that microwave irradiation has application in the treatment of logs 

because of the large quantities exported. Scaling up microwave technology to mitigate against 

quarantine risk in wood packaging faces significant challenges. 

8.3.5.2 Economic feasibility 

Treatments of logs may need to be rapid, such as at point of export or import, to avoid charges and 

congestion at ports associated with occupying restricted port area for the treatment. Where quarantine 

treatments can be applied outside port areas, such as prior to export or in-transit, alternatives to 

methyl bromide that take a longer time can be used. Many pests of quarantine significance, which 

attack green wood, do not re-infest dry and debarked wood. 

Some types of logs that are primarily coniferous that are shipped in high volume, they have 

comparatively low value and they are shipped long distances. This trade is very price sensitive to 

changes in freight costs, exchange rates and treatment costs. In contrast, there is also a large trade in 

hardwood logs that has significant value to some countries of over $1billion and each log is valued at 

several thousand dollars when used for making veneer, for example. Therefore, the economic value 

that a new treatment brings to the log trade depends mainly on the type of log, its market destination 

and intended use. 

Phosphine is less expensive than methyl bromide for the treatment of logs when it is applied at the 

point of export as an in-transit treatment: $0.93 per m3

 for logs exports from New Zealand to Japan, 

compared with $3.50 per m3

 for methyl bromide (Self and Turner 2008). The cost effectiveness of intransit use of phosphine is dependent on the length of transit. Its use on shorter transit shipments 

would add significant costs (approximately $1,000 per hour (Self and Turner 2008)) to shipping due 

to delays. On longer transits phosphine can be more cost effective than methyl bromide. This is 

because, compared to methyl bromide, the dosage rate is lower, and it is faster to apply which reduces 

costly moorage time in the port. The sailing time is sooner as the ship avoids having to stay in port 

for at least 36 hours while the hold is fumigated and then vented. A fumigation technician is required 

for the voyage to add more fumigant, monitor for leaks and vent the holds. This method can only be 

used for logs stowed in the holds, which is normally about two-thirds of the cargo, and the balance of 

the cargo on deck must be fumigated with methyl bromide under tarpaulin on the wharf prior to 

export. 

Sulfuryl fluoride is about 50% more expensive in the United States than methyl bromide due to 

sulfuryl fluoride’s higher cost per unit of volume and the larger amount needed for the treatment 

(John Sansone, pers. comm. 2010). Most treatments of logs occur in temperate climates that have 

temperatures less than 25°C for much of the year which would make the treatment uneconomic in 

comparison with methyl bromide treatment. The recommended minimum temperature is 15°C. 

Methyl iodide or methyl iodide / CO2 have similar application rates to methyl bromide but require 

premixing with CO2 which adds cost on top of the more expensive price of the chemical. Both 

treatments are under evaluation in Japan for the control of log pests. While the chemical cost is not 

the major component of the fumigation cost it will add to the overall cost of treatment. No 

commercial sized applications have been undertaken to verify the economics of log fumigation with 

methyl iodide. 
114 May 2010 TEAP Progress Report 

The cost of cyanogen is unknown. Both heat treatment and irradiation of large volumes of logs are 

uneconomic. 

Heat is a technically feasible alternative but because of the energy required and the large amount of 

the unprocessed logs being shipped, it is rarely an economic alternative to fumigation. 

The use of irradiation for decontaminating logs in export trade does not appear to be economically 

feasible at this time, but may be useful in managing pests on high-value forest products that cannot 

normally be heat treated or fumigated. 

Due to a lack of infrastructure, increased cost, tariffs and customer requirements, conversion to sawn 

timber may not be viable option in most cases. Conversion of logs to sawn timber that carry a lower 

quarantine risk is a technically feasible alternative, but would have significant trade implications. 

Some particular timbers and end uses may be unsuitable for conversion to lumber for technical and 

end use reasons. The current log trade in many cases relies on conversion to lumber and more highly 

processed products at the importing country. This provides employment in the importing country, as 

well as greater control over what the timber is converted to, but at the cost of greater quarantine risk. 

Moving the point of conversion of logs from importing country to the exporter would have substantial 

economic implications. The trade from some countries with high labour costs and limited milling 

infrastructure may be lost to those that can provide lower cost conversion. 

8.3.5.3 Market penetration of alternatives 

Phosphine in-transit on those parts of the shipment carried under deck is the only commercially used 

alternative currently for under bark pests. China has approved a specific treatment schedule for 

sulfuryl fluoride on logs for fumigation in Germany and other countries prior to export. Data on the 

use of sulfuryl fluoride under this treatment schedule are not available and the extent of the market 

penetration of sulfuryl fluoride for this use is unknown. 

The alternative must be effective against the pests of concern for the particular importing country and 

for the treatment to be economic. For instance, efficacy has yet to be proven to a quarantine level for 

wood wasps and pine wood nematode using phosphine, which holds up the market penetration of the 

use of in-transit phosphine. 

The current market penetration for alternatives for logs is very small. Of the 58 million m3

 of logs 

imported into China, India, Japan and Korea in 2007, only 800,000m3

 (1.3%) was treated with 

phosphine. This volume could be increased to 8.9 million m3

 if all four countries receiving logs from 

the USA, Canada and New Zealand accepted phosphine fumigation of below-deck logs. Acceptance 

of phosphine as an alternative would potentially save about 1,200 tonnes of methyl bromide per year, 

even though it is still only about 15% of the global log trade. 

Based on the 2008 trade statistics for logs imported by Japan, MBTOC estimated that Japan could 

replace about 500 tonnes of methyl bromide with methyl iodide, methyl iodide/CO2 and/or methyl 

isothocyanate/sulfuryl fluoride mixture if those chemicals are approved in Japan by the Japanese 

government for the treatment of imported logs. 

8.3.5.4 Regulatory requirements and other drivers 

All countries have a chemical registration process that over time has become more rigorous and 

expensive making it difficult to register new chemicals or new uses for existing ones. While it is 

easier to gain approval for the treatment of non edible products such as logs and timber, it can still 

take between five to ten years for final approval of a new treatment. There is also a high probability 

of not being successful at the end of the process, after investing much time and money. 
May 2010 TEAP Progress Report 115

Acceptance of an alternative is also based on time and cost. As exported product may be competing 

with domestic or another country, and therefore any additional treatment costs or delay may make the 

trade unviable. 

A high level of efficacy is required for treatments to ensure that pests of quarantine concern do not 

establish in the importing country. History has shown that incursions of forest pests can cause billions 

of dollars worth of damage (e.g., the Asian longhorn beetle, the emerald ash borer) or even drive 

species to extinction (Chestnut blight and American elm blight). 

Acceptance of alternatives requires negotiation between officials of the importing and exporting 

countries. Science and research finding play an important part in this process. However, due to a lack 

of technical personnel, funding, expertise or other resources the negotiations can take years to obtain 

market access for an alternative treatment. If a treatment is approved at the international level, an 

included in a standard such as heat for ISPM-15, the negotiation time can be reduced significantly. 

Japan attributed several technical and regulatory reasons (Akio Tateya pers. comm. 2010) for its 

approximately 50% reduction in the consumption of methyl bromide for QPS in 2009 (542 tonnes) 

compared to 2006 (1,039 tonnes): 

• A concerted programme by MAFF to improve gas retention in fumigation chambers; 

• Reduction in dosage when the treatment can be carried out at higher temperatures, 

recirculation equipment is present and other criteria; 

• On board fumigation using phosphine of non-food commodities, such as bamboo from 

Taiwan; 

• Import of genetically modified crops that are less susceptible to pest infestation than crops 

that have not been genetically modified; 

• A reduction in products that are subject to plant quarantine e.g. imported timber is subject to 

plant quarantine but not processed wood; 

• On the basis of pest risk analyses following ISPM-2 criteria, a reduction in the number of 

pests classified in Japan as regulated quarantine pests; 

• Reductions of imports to Japan due to tariffs imposed on raw wood exports by the exporting 

country e.g. Russia; 

• Greater use of heat treatment for wood packaging material as heat treatment is less costly than 

methyl bromide; 

• Alternatives to methyl bromide have been registered e.g., for timber sulfuryl fluoride, methyl 

isothiocyanate, carbon dioxide and sulfuryl fluoride, and methyl iodide but they are not yet in 

use as quarantine treatments on processed timber. 

8.3.6 Alternatives being investigated and under development 

8.3.6.1 Sawn timber and wood packaging material 

The 2009 revision of ISPM-15 (IPPC 2009) did not recognize any alternative to methyl bromide 

except heat, but several potential alternatives to heat and methyl bromide are under evaluation. The 

Technical Panel on Phytosanitary Measures that advises the Standards Committee of the IPPC on 
116 May 2010 TEAP Progress Report 

technical evaluations on alternatives, reports that several potential alternatives have been submitted 

and are under evaluation (Table 8-2). 

The evaluation panels have requested additional efficacy data for the potential alternatives to methyl 

bromide shown in Table 8-2. Species of Agrilus planipennis (Emerald Ash Borer), Anoplophora 

glabripennis (Asian longhorned beetle), Bursaphelenchus xylophilus (Pinewood nematode), various 

bark beetles, sawflies and many other forest pests are key pests that must be controlled to a very high 

level of quarantine security by any alternative. 

Table 8-2: List of potential treatments for ISPM-15 under IPPC evaluation 

Sulfuryl fluoride 

Sulfuryl fluoride and MITC mixture 

Hydrogen cyanide 

Microwave heating 

Phosphine 

Methyl iodide 

Of the alternatives for ISPM-15 being considered, the data submitted for sulfuryl fluoride are 

sufficient to support Probit-9 efficacy for sulfuryl fluoride fumigation against Anoplophora 

glabripennis in wood packaging material, but not for pinewood nematode. The Technical Panel on 

Phytosanitary Measures has sufficient information to support the 99.99683% (Probit-9) efficacy of a 

methyl iodide schedule against pinewood nematode with but not for Anoplophora. Phosphine data 

submitted are not yet sufficient to demonstrate efficacy against either of the two key pests. Although 

only two of many quarantine pests that have to be controlled by alternative treatments, effectiveness 

against these two pests would indicate potential as a quarantine treatment and worthy of additional 

effort. 

The requirement for mortality data showing a high level of efficacy for wide range of pests is a major 

barrier to development and approval of additional treatments for ISPM-15. The standard also needs 

approval from all member parties. Details of current requirements for submission of potential 

alternatives are given in ISPM-28. Criteria for future ISPM-15 treatment submissions are being 

considered by the IPPC’s Technical Panel on Phytosanitary Measures. 

Some National Plant Protection Organisations recognise other treatments for wood packaging material 

and similar products, instead of methyl bromide or heat treatments undertaken according to the 

treatment criteria contained in ISPM-15. These treatments may be post entry or prior to export and 

are generally based on bi-lateral agreements between countries interested in a specific trade. 

Australia, for example, requires off shore treatments of timber packaging and dunnage that have not 

been treated in accordance with ISPM-15 to be treated at specified dosages of several alternatives, 

including fumigation with sulfuryl fluoride, or ethylene oxide or treatment with heat, gamma 

irradiation or some timber preservatives (ICON 2009). 

8.3.6.2 Grains and similar foodstuffs 

8.3.6.2.1 Pre-shipment treatments 

Alternatives that act at least as fast as methyl bromide would be welcomed in many export situations, 

as these would minimise delays handling the export consignment with associated costs and grain 

handling limitations. 
May 2010 TEAP Progress Report 117

At this time there are no agreed, widely available and approved pre-shipment treatments that will 

match the treatment speeds of large consignments that can be achieved with methyl bromide 

fumigation, though there are some in the regulatory approval process in a few countries. The 

fumigants sulfuryl fluoride, cyanogen and carbonyl sulphide, and synergised ethyl formate all have 

potential to give similar treatment times and throughputs to methyl bromide (MBTOC 2007), 

although these are not registered in most countries. 

8.3.6.2.2 Quarantine treatments 

Microwave technology used in laboratory tests was reported as effective in controlling Karnal bunt 

(Tilletia indica) teliospores in 10 seconds compared to 96 hours using methyl bromide (Ingemanson 

1997). Scale up to large quantities of grain is problematic. 

Alternative treatments to methyl bromide are needed for various snails of quarantine significance (e.g. 

Achitina fulica, Cernuella spp. Theba pisana). Methyl bromide fumigation is usually the only 

approved quarantine measure for these pests when associated with grain shipments. Other processes, 

including HCN and CO2 fumigations, may be more effective (e.g. Cassells et al. 1994), but are not 

approved and not registered. 

Phosphine is not accepted for controlling Sitophilus species because the pupal stage of Sitophilus 

granarius (a regulated quarantine pest for Japan) could not be killed completely at the dosage rates 

and fumigation conditions used in commercial quarantine fumigation (Mori and Kawamoto 1966). 

On the other hand, sulfuryl fluoride has higher efficacy against pupal stages of several stored product 

insects, although the egg stage is the most tolerant (Furuki et al. 2005; Bell et al. 2003). Fumigating 

with a mixture of phosphine and sulfuryl fluoride gas kills all stages of Sitophilus species, using the 

good properties of both fumigants. Tests with mixtures of phosphine and sulfuryl fluoride are in 

progress in Japan. 

8.3.6.3 Pre-plant soils use 

8.3.6.3.1 Alternatives for forest nurseries 

Research on forest nurseries reported that chloropicrin alone, or in combination with herbicides (when 

weeds pose problems) or 1,3D/Pic (when nematodes are a problem), were as effective alternatives for 

methyl bromide used as a QPS treatment (South 2008). Alternatives providing effective include 

chloropicrin (Pic) alone (South 2007; 2008); 1,3-D/Pic (South 2008), 1,3-D /Pic/metham sodium 

(South 2008); metham sodium + Pic (Cram et al. 2007); dazomet (Enebak et al. 2006); and methyl 

iodide (Enebak et al., 2006; Quicke et al. 2009). Pic and metham, when used in conjunction with 

low-permeability barrier film (LPBF), may provide an effective technical alternative. Enebak (2007) 

found that the application rate of methyl bromide was significantly reduced with LPBF. 

More recently, research results from the Area-wide Pest Management project for methyl bromide 

alternatives in the south Atlantic region of the US showed that methyl iodide/Pic (50:50) and dimethyl 

disulfide (DMDS) / Pic were equally effective to methyl bromide for controlling weeds and 

nematodes in forest nurseries (Quicke et al. 2009). Further, populations of Trichoderma spp, which 

are essential for adequate development of the seedlings, were preserved at the same level as when 

methyl bromide was used (Quicke et al. 2009). Methyl iodide is now registered and available in the 

region where the trials were conducted. Registration of DMDS in the US is pending approval by the 

registration authorities. 
118 May 2010 TEAP Progress Report 

8.3.6.3.2 Alternatives for other kinds of propagation materials 

Further successful trials have been reported on rose nurseries (Hanson et al. 2006; 2009). MI/Pic, 

1,3-D and 1,3-D/ Pic with high-density polyethylene film (HDPE) plus 1,3-D/Pic with Virtually 

Impermeable Film appear to provide weed control similar to methyl bromide in perennial tree 

nurseries (Shrestha et al. 2008, Schneider et al. 2009). 

Recent research to determine soil treatments that are effective to eliminate the quarantine pathogen 

Phytophthora ramorum from ornamental nursery beds in California (Yakabe et al. 2010), showed 

that treatments with Pic, metham sodium and methyl iodide were effective in eliminating the pathogen 

to undetectable levels. Dazomet was also effective as long as it was fully incorporated into the soil 

and then tarped. 

Steam proved effective for eliminating P. ramorum from ornamental nursery beds in California as 

long as soil was heated to temperatures above 40 °C (Yakabe et al. 2010). Steaming systems and 

application methods are being evaluated in California, in an effort to identify the most feasible 

approach to this technique (Gilbert et al. 2009). 

DMDS + chloropicrin produced promising results in the forest nursery sector, although the former is 

not yet registered in the United States (Weiland et al. 2008; Quicke et al. 2007, 2008, 2009). 

8.3.6.4 Logs 

There is active research in progress to develop alternatives for logs but gaining the required efficacy 

data is very difficult as laboratory rearing has not yet been achieved to the numbers required, most 

insects are seasonal, and the commodity is large and variable. 

8.3.6.4.1 Phosphine 

Research in China and Japan has demonstrated that phosphine killed 10 species of forest insects of 

quarantine concern including cerambycids, scolytids and platypodids. Oogita et al. (1997) fumigated 

the cerambycids (Semanotus japonica, S. japonicus, Callidiellum rufipenne, Monochamus alternatus, 

the scolytids (Phloeosinus perlatus, Cryphalus fulvus and Xyleborus pfeili) and the platypodids 

(Platypus quercivorus and P. calamus)) with phosphine at concentrations of 1.0 and 2.0 gm-3 for 24 

and 48h at 15°C and 25°C. S. japonica and P. perlatus eggs were killed at 2.0 gm-3 for 24 hours at 

15°C, but larvae and pupae of all species were not killed at 2.0 gm-3 for 48h at 15°C. At 2.0 gm-3 for 

48h at 25°C, all stages of C. fulvus and X. pfeili, except larvae of C. fulvus, were killed. The work 

concluded that more than 48h was required for complete mortality. 

In New Zealand, two phosphine log fumigation trials were completed in 2009 (Wang W. et al. 

unpublished), using sea containers loaded with commercial export logs and field collected insectinfested logs. The initial dosage of aluminium phosphide in the treatment container was equivalent to 

2 gm-3 of phosphine gas. Phosphine concentration was maintained at over 200 ppm v/v (0.28 g m-3) 

during the 10-day fumigation period with one to three additional applications of aluminium phosphide 

pellets. Penetration of the phosphine into export logs at an average moisture content of 59% and 79% 

to a depth of 80mm achieved an average exposure of 183 ppm.hr (0.25 g h m-3) and 265 ppm.hr (0.37 

g h m-3) respectively in the two trials. 

A total of 680 insects extracted from infested logs in the treatment chambers were dead after 

phosphine fumigation and the mortality rate was 100%. All the 561 insects extracted from the 

controls were alive. Insects included Cerambycidae; Arhopalus ferus (Mulsant) larvae, Prionopolus 

reticularis (White) larvae, Ichneumonidae; Rhyssines larvae (Sirex noctilio parasite) and Scolytidae; 

Pachycotes pergrinus (Chapuis) adults, Hylastes ater (Paykull) adults, Hylastes eggs, Hylurgus 

ligniperda (Fabricus) larvae, Hylurgus adults, and Hexatricha pulverulenta (Westwood) larvae. 
May 2010 TEAP Progress Report 119

This work confirmed laboratory trials carried out by Zhang (2004b) that included four replicates of 

94-102 eggs of A. ferus, which were successfully killed by 0.28 g m-3 phosphine for 10 days. In 

another later trial, a further four replicates of 100-253 A. ferus eggs were killed at a mean of 0.34 g m3

 phosphine over seven days. The length of time required to complete treatments restricts its 

commercial acceptability. 

The “Florani” experiment showed that phosphine could be successfully used as an in-transit fumigant 

for eliminating the pinewood nematode from pine chips (Leesch et al. 1989; Dwinell 2001). 

Data are being collected on the efficacy of phosphine controlling wood pests in both New Zealand 

and Canada, in order to improve the usefulness of this alternative. 

8.3.6.4.2 Sulfuryl fluoride 

Data are being collected on the efficacy of sulfuryl fluoride for controlling wood pests in the USA and 

China, in order to assess the usefulness of this alternative for the disinfestation of logs. 

8.3.6.4.3 Methyl isothocyanate/ Sulfuryl fluoride mixture 

Research on alternatives for logs evaluating the efficacy of MI and MITC/SF/ mixtures has been 

completed in Japan and both treatments are under the process of inclusion under the relevant 

regulations. However, instructions or procedures for conducting gas measurements and safety devices 

to protect fumigators from gas exposure still need further work. 

8.3.6.4.4 Methyl iodide 

Data are being collected on the efficacy of methyl iodide for controlling wood pests in the New 

Zealand, France and the USA, in order to assess the usefulness of this alternative for the disinfestation 

of logs. 

Methyl iodide successfully killed oak wilt fungus at rates similar to methyl bromide (Tubajika 2006). 

Methyl iodide is expected to be adopted by Japan as a quarantine treatment in the near future. Lack of 

registration in other countries for post-harvest uses severely limits its availability for quarantine 

treatment of forest pests in other countries. 

8.3.6.4.5 Cyanogen 

It is not known if work is continuing with cyanogen for the treatment of logs as it appears to penetrate 

high moisture content timber well but may have a high sorption rate (Barak and Ducom pers. comm. 

2010). 

8.3.6.4.6 Heat 

This literature suggests few if any insects can survive even short exposure (less than 24h) to 

temperatures above 50°C, but some fungi are more tolerant. Direct exposure of gypsy moth eggs 

(Hosking 2001) resulted in 100% mortality at the lowest temperature (55°C) and shortest exposure 

time (5minutes) tested. Fungi were more variable in their response to temperature and exposure time. 

Some fungi required exposures of up to 6 hours at 57°C (Morrell 1995) while others were killed by 

exposure to 60°C for 10 minutes (Ridley and Crabtree 2001). 

Heat treatment by steam has been shown to eradicate all tested fungi when 66°C is held at the centre 

of wood for 1.25 hour (Miric and Willeitner 1990; Newbill and Morrell 1991), but Dwinell (2001) 
120 May 2010 TEAP Progress Report 

reported that neither the APHIS-approved methyl bromide treatment for timber nor heat treatment up 

to 81°C killed all saprophytic fungal pathogens in imported hardwood pallets. Many fungal 

pathogens are also very tolerant of methyl bromide (e.g. see Rhatigan et al. 1998). Trials with heat 

treatment using steam are proposed in the USA (Ken Vick pers. comm. 2010) 

8.3.6.4.7 Irradiation 

No continuing work on irradiation treatment of logs is known to MBTOC. 

8.3.6.4.8 Microwaves 

No continuing work on microwave treatment of logs is known to MBTOC. 

8.3.7 Summary of technical and economic feasibility and market penetration 

Chapter 8.3 showed that there were many potential alternatives to methyl bromide used for QPS in the 

four sectors that consume more than 75% of global methyl bromide: sawn timber and wood packaging 

material, grains and similar foodstuffs, soils and logs. 

Some alternatives were registered and potentially available for use, but they needed to be added to 

approved treatment schedules. In some cases, alternatives that were registered and included in 

treatment schedules still depend on international negotiations for them to put into practice according 

to the appropriate level of quarantine security agreed between the trading partners. Standards 

developed by the IPPC have a potentially valuable role to play in this regard as they can be accepted 

multilaterally, since the treatment conditions have been agreed by the Parties in that convention, 

which reduces and in some cases eliminates the need for significant bilateral discussions. 

The economic feasibility of the treatments depends mainly on the circumstances where the alternative 

is to be used, the cost of specific equipment, and the cost of training staff in its operation. In the case 

of heat treatments for wood packaging material, Parties are reporting its widespread use and that in 

some cases it was more economical than methyl bromide fumigation. Parties also reported that heat 

was safer and more convenient to use than methyl bromide. Although it is not possible to generalise 

to all alternatives and indicate that they will be equally affordable for convenient to use, it is possible 

to say that as the technology becomes more widespread the cost reduces and the experience in the 

technology increases, which reduce the barriers to its more widespread acceptance. 

The market penetration was known reasonably well for the four commodities in this review, according 

to the knowledge and experience of the members of the MBTOC-QPS sub-committee. The market 

penetration for a new alternative such as in-transit phosphine treatment of logs was relatively low, 

compared to phosphine for the treatment of grain and foodstuffs which had a very high market 

penetration globally. The market penetration of an alternative depended largely on the supplydemand for the commodity, which was often unpredictable and subject to significant increases or 

decreases in volume. In this regard, the potential use of an alternative could also be constrained by 

the requirements of the end user e.g. logs for veneer were exported as logs and not as sawn lumber. 

Where technology is not currently available, subchapter 3 documents some of the research that is 

being undertaken to find alternatives. Many examples of such research have been provided in 

previous reports by TEAP and MBTOC, and an update of these will be provided in the 2010 

Assessment Report which is due in December 2010. 
May 2010 TEAP Progress Report 121

8.4 Feasible Scenario for the Global Replacement of Methyl Bromide Used for 

Quarantine and Pre-Shipment 

8.4.1 Introduction and mandate 

Paragraph 3(3) of Decision XXI/10 requests: 

 “An update of Table 9.1 of the 2009 Task Force report to include economic aspects, and to take 

account of the information compiled under this paragraph, distinguishing between Article 5 and non 

Article 5 parties and between quarantine and pre-shipment uses separately;” 

Table 9.1 from the TEAP (2009) Task Force report estimated a feasible scenario for technically 

replaceable use of QPS methyl bromide globally, based on technically feasible alternatives discussed 

in the report. The Table constituted an initial attempt at such estimation, recognising that there were 

many limitations for estimation at the time. 

This Chapter takes estimations further by considering economic aspects and distinguishing between 

quarantine and pre-shipment uses of methyl bromide, with a separate scenario for Article 5 and NonArticle 5 Parties according to mandate in Decision XXI/10. 

8.4.2 Feasible scenarios for quantities of methyl bromide 

Consumption of methyl bromide per category of use was estimated in response to Decision XX/6. 

For this, several sources of information were used, including direct response from about 24 Parties, 

surveys conducted previously (including the UNEP/ROAP survey of QPS uses in Asia and the Pacific 

and the 2004 QPS survey), previous QPS reports and others. Because all countries did not report 

consumption of QPS methyl bromide in response to XX/6 and other surveys, including some major 

QPS methyl bromide consuming countries, the consumption estimates gained for each sector are 

lower estimates. Actual consumption is likely to be higher. 

It was apparent that the breakdown of use by categories was different in Article 5 and Non-Article 5 

Parties and that it is necessary to account for specific circumstances in the different regions involved 

when considering possible replacements of methyl bromide with alternatives. For example, logistical 

issues, use of alternatives already in place, and availability of technologies or infrastructure were 

important considerations when estimating replaceable amounts. 

The proposed scenarios for Article 5 and Non-Article 5 Parties are described in the following Sections 

and Tables. 

8.4.2.1 Article 5 Parties 

The principal categories of use of methyl bromide for QPS purposes in Article 5 Parties were logs 

(25%), wood packaging material for compliance with ISPM 15 (19%) and grains (16%). A large 

proportion of the consumption on grain is estimated to be used for pre-shipment. No pre-plant soils 

uses were classified as QPS in Article 5 Parties. As stated above in this report Asia is the major 

consuming region (TEAP 2009). A suggested best-case scenario for the replacement of methyl 

bromide for the main uses recorded by Article 5 Parties is presented in Table 8-3 

8.4.2.2 Non-Article 5 Parties 

The main categories of use in Non-Article 5 Parties were soils in situ (30%), logs (17%), grain (7%), 

and wood packaging material for compliance with ISPM-15 (5%) (TEAP 2009). A suggested bestcase scenario for the replacement of methyl bromide for these uses in Non-Article 5 Parties is 
122 May 2010 TEAP Progress Report 

presented in Table 8-4. Due to specific considerations, pre-plant soils uses are discussed separately in 

the section below and presented in Table 8-4. 

8.4.2.3 Estimated amount of methyl bromide that could be replaced for QPS soil uses 

In the absence of official data that had been requested from the party, MBTOC-QPS estimated the 

quantity of methyl bromide that had been categorised by the Party as QPS on soil according to data 

provided in the Critical Use Nominations by the United States for use in a range of sectors. Based on 

these data MBTOC made best estimates of the quantity of methyl bromide being consumed for soil 

uses, the alternatives that were available to replace methyl bromide, and the amount of methyl 

bromide that could be replaced (Table 8-5). 

Nearly all the estimated 1,476 tonnes of the remaining methyl bromide would have a technically 

feasible alternative if MI/Pic was registered in all States at a high enough application rate to meet 

certification standards for these relevant sectors in the USA. MI/Pic is considered a one-to-one 

replacement for methyl bromide for all soil uses, except where phytotoxicity issues and low label 

rates limit its use. The amount of methyl bromide that could be replaced may be none, partial or all 

depending on the extent of restrictions on the use of some alternatives, for example regulatory 

constraints, practical limitations or economic issues. 

For some sectors, in particular caladiums, sweet potatoes, golf and sod turf grass uses of methyl 

bromide cited in Table 8-5, the estimated quantities may need further examination pending 

submission of official information by the Party. MBTOC found that the use of methyl bromide that 

had been categorized as QPS by the Party for turf grass fumigation is likely to have declined due to 

the economic recession, whilst the use for caladiums appears to have more than doubled. Currently 

there is no consumption of methyl bromide for sweet potatoes that has been categorised as QPS by the 

Party. Uneconomic uses of methyl bromide may become economic again in the future, and therefore 

it seemed reasonable in these cases to show alternative estimates of methyl bromide consumption 

using square bracket notation. MBTOC-QPS reiterates its request for information from the Party on 

the consumption of methyl bromide that it has categorised as QPS. 

One MBTOC-QPS member has expressed his disagreement with parts of this chapter. A signed 

minority report from this MBTOC member is expected to be submitted for inclusion in the final 

TEAP 2010 Progress Report. 

8.4.2.4 Estimated replaceable quantities – summary 

Quantities of QPS methyl bromide given for the four major categories of QPS consumption in Tables 

8-3 and 8-4 represent 6,225 tonnes in total from a reported annual consumption in 2007 of 10,614 

tonnes. As noted in TEAP (2009), there is a substantial discrepancy between that reported under 

Article 7 by Parties and that estimated from various data sets that have the consumption (use) 

specified by category of use. Part of the discrepancy is attributable to incomplete data with data absent 

from several larger consumers of QPS methyl bromide. The total use in Tables 8-3 and 8-4 represent 

73% of the 8486 tonnes identified QPS uses for 2007. 

Data in Tables 8-3 and 8-4 allow estimates of total immediately replaceable fraction of 2007 QPS use 

of methyl bromide of at least 935 and 1,060 tonnes in Article 5 and Non-Article 5 countries, being at 

least 1,995 tonnes in total. This is 32% of total consumption for the four main categories of QPS use. 

The upper estimate of the replaceable fraction is at least 2,571 tonnes or 42% of the total QPS for 

these categories. 
May 2010 TEAP Progress Report 

Table 8-3: Estimated replaceable fractions for various QPS uses using presently available technologies for Article 5 

QPS category Principal alternative 

technologies 

Economic feasibility 

Estimated methyl bromide use (tonnes) for 2007 a

Fraction of use replaceable by alternatives immediately available 

Comment

Wood packaging material (ISPM-15) 

Heat treatment, alternative fumigants 

Some countries use either heat or methyl bromide, establishing heat is feasible in these circumstances. Some countries use heat almost exclusively. 

893 >60% Alternativ

considerat

Grains and similar Foodstuffs – quarantine 

Alternative fumigants and controlled atmospheres 

Rapid acting alternatives need development and proving. Current alternatives require construction of additional storage at point of entry if throughput is to be maintained. 

329 <10% Alternativ

available 

Grain and similar foodstuffs – preshipment 

Fumigants, protectants, CA, integrated systems 

Alternatives may require change in export procedures and some infrastructure changes. 

765 30-70% Rapid acti

registered exporting official pr
124 May 2010 TEAP Progress Report 

QPS category Principal alternative 

technologies 

Economic feasibility 

Estimated methyl bromide use (tonnes) for 2007 a

Fraction of use replaceable by alternatives immediately available 

Comment

Soils, in situ Alternative soil 

fumigants 

 0 Not applicable 

Logs Alternative fumigants, 

conversion to sawn timber (lumber), immersion, debarking, heat and drying 

Conversion to sawn timber (lumber) at point of export only where there is a price insensitive demand for higher value products without alternative sources of supply 

1371 10-20% Alternativ

developmspecific trInfrastructpossible adebarked, shipment, influence economic Debarking componen

Data (2007) were supplied by the Parties to the Ozone Secretariat in response to Decision XX/6. Data (2005) from the Regional Office for Asia and 2008; ROAP) were used when 2007 data were not available. 
May 2010 TEAP Progress Report 

Table 8-4: Estimated replaceable fractions for various QPS uses using presently available technologies for Non-Ar

QPS category Principal 

alternative technologies 

Economic feasibility 

Estimated methyl bromide use (tonnes) for 2007 a

Fraction of use replaceable by alternatives immediately available 

Comm

Wood packaging material (ISPM-15) 

Heat treatment, nonwood pallets Some countries use either heat or 

methyl bromide, establishing heat is feasible in these circumstances. Some countries use heat almost exclusively. 

263 60-80% Alterna

conside

Grains and similar foodstuffs – quarantine 

Alternative fumigants and controlled atmospheres 

Rapid acting alternatives need development and proving. Current alternatives require construction of additional storage at point of entry if throughput is to be maintained. 

251 <10% Alterna

availab

Grain and similar foodstuffs – preshipment 

Fumigants, protectants, CA, integrated systems 

Alternatives may require change in export procedures and some infrastructure 

73 >80% Not app

fumigaand rap
126 May 2010 TEAP Progress Report 

QPS category Principal 

alternative technologies 

Economic feasibility 

Estimated methyl bromide use (tonnes) for 2007 a

Fraction of use replaceable by alternatives immediately available 

Comm

changes. 

Soils, in situ Alternative soil 

fumigants, sometimes with inspection, substrate, steam 

Telone/pic can be used in California but at risk of failed certification through inspection. MB assumed to be effective 

1476 About 50%, 

provided the alternatives not only meet certification standards but are accepted by regulatory authorities 

Used foMethyl CaliforSee Tabderivatithe adja

Logs Alternative 

fumigants, conversion to sawn timber (lumber), immersion, debarking, heat and drying 

Conversion to sawn timber (lumber) at point of export only where there is a price insensitive demand for higher value products without alternative sources of supply 

804 10-20% Alterna

under dconsideInfrastravailabconverstimber, have suparticuleconomused as an alter

Data (2007) were supplied by the Parties to the Ozone Secretariat in response to Decision XX/6. Data (2005) from the Regional Office for Asia aused when 2007 data were not available.
May 2010 TEAP Progress Report 127

Table 8-5: Estimated Consumption of methyl bromidethat has been categorized by the 

Party for soil and the proportion of methyl bromide that was estimated to be 

replaceable with alternatives 

Sector Best Estimate 

Minus 

reduction for 

uptake of 

alternatives 

(CUNs)1

Amount of 

use 

requiring 

methyl 

bromide 

Possible 

Alternatives2

Bulbs 261 78 183 30% uptake of 1,3-

D/Pic 

Forest nursery 

seedlings - 

Southern US 

310 310 0 MI/Pic 

Forest nursery 

seedlings –

Western US 

100 100 0 MI/Pic 

Forest nursery 

seedlings – 

northern US 

45 45 0 MI/Pic 

Ornamentals - 

Chrysanthemum 32 16 16 3-Way, MI/Pic 

Ornamentals –

Caladium5

 193 [450] 193 0 3-Way, MI/Pic 

Nursery – Fruit & 

Nut Deciduous 207 62 145 30% uptake of 1,3-D/Pic 

Nursery - 

Raspberries 25 7 18 30% uptake of 1,3-

D/Pic 

Nursery – Roses 208 61 147 30% uptake of 1,3-

D/Pic 

Strawberry 

runners 460 0 460 

Turfgrass – Sod3 680 340 340 

50% uptake of 1,3-

D/Pic, dazomet, 

MI/Pic 

Turfgrass – Golf4 [110] [0] 55 55 

50% uptake of 1,3-

D/Pic, dazomet, 

MI/Pic 

Sweet potato6 [224] [0] 112 112 50% uptake of 1,3-

D/Pic, herbicides 

Total (tonnes) [2855] [2778] 1476 

1 Reductions for uptake of alternatives only considered alternatives that were registered at the time of this report. If 

technical feasibility only was considered then 95% of uses have an alternative, as methyl iodide/chloropicrin is 

considered a one-to-one replacement for methyl bromide for nearly all uses

2 3-Way consists of three soil fumigations in each successive year, beginning with a 1,3-D + Pic application, 

followed by a Pic application, followed by a metham-sodium or metham-potassium application 

3,4 Possibly overestimated as turf grass for golf is recently not economic for transport across State boundaries 

because of the economic recession. The amount that can be replaced could be zero because of EPA 

restrictions on the use of some alternatives, practical limitations (coverage, dose insufficient) and off-target 

environmental damage caused by alternatives to local water resources. 

5

 Consumption may be larger at 450 tonnes. 6 Previously reported consumption may be currently zero 
128 May 2010 TEAP Progress Report 

8.4.3 Summary 

MBTOC-QPS found that there is opportunity to replace varying amounts of methyl bromide presently 

used for QPS purposes, depending on category of use and whether the use is carried out in Article 5 or 

Non-Article 5 Parties. 

It was estimated that in Article 5 Parties more than 60% of the methyl bromide used in sawn timber 

and wood packaging material could be replaced by heat or alternative fumigants; less than 10% of the 

methyl bromide used as a quarantine treatment in grains and similar foodstuffs could be replaced by 

alternative fumigants and controlled atmospheres, and 30-70% for pre-shipment treatments in grains 

and similar foodstuffs could be replaced by fumigants, protectants, controlled atmospheres and 

integrated systems; and 10-20% of the methyl bromide used in logs could be replaced by alternative 

fumigants, conversion to sawn timber (lumber), immersion, debarking and heat. There was no 

categorisation of methyl bromide as QPS used on soil in Article 5 Parties countries. 

MBTOC-QPS estimated that in Non-Article 5 Parties that more than 60-80% of the methyl bromide 

used in sawn timber and wood packaging material could be replaced by heat or non-wooden pallets; 

less than 10% of the methyl bromide used as a quarantine treatment in grains and similar foodstuffs

could be replaced by alternative fumigants and controlled atmospheres, and more than 80% for preshipment treatments in grains and similar foodstuffs could be replaced by fumigants, protectants, 

controlled atmospheres and integrated systems; about 50-95% of the methyl bromide used in soil 

could be replaced by alternative fumigants, provided the alternatives meet certification standards and 

a key alternative, methyl iodide/Pic was available; and 10-20% of the methyl bromide used in logs 

could be replaced by alternative fumigants, conversion to sawn timber (lumber), immersion, 

debarking and heat. 

The technical and economic feasibility of alternatives to methyl bromide used for QPS in all countries 

depended mainly on the efficacy against quarantine pests of concern, the infrastructural capacity of 

the country, end-use customer requirements, phytosanitary agreements where relevant, and logistical 

requirements and regulatory approval for the use of the alternative. 

8.5 Draft Methodology for Assessing the Feasibility of Alternatives, the Impact 

of their Implementation and of Restricting Methyl Bromide for Quarantine 

and Pre-Shipment 

8.5.1 Mandate and scope 

Paragraph 3(4) of Decision XXI/10 requests: 

“A description of a draft methodology, including assumptions, limitations, objective parameters, the 

variations within and between countries and how to take account of them, that the Technology and 

Economic Assessment Panel would use, if requested by the Parties, for the assessment of the technical 

and economical feasibility of alternatives, of the impact of their implementation and of the impacts of 

restricting the quantities of methyl bromide production and consumption for quarantine and preshipment uses;” 

For the purpose of completing this task, paragraph 3(4) was interpreted as consisting of three sections: 

1. A description of a draft methodology ... for the assessment of the technical and economical 

feasibility of alternatives; 

2. A description of a draft methodology ... for the assessment of the impact of the 

implementation of alternatives to methyl bromide for QPS; 
May 2010 TEAP Progress Report 129

3. A description of a draft methodology ... for the assessment of the impact of restricting the 

quantities of methyl bromide production and consumption for quarantine and pre-shipment 

uses. 

Paragraph 3(4) was interpreted to require consideration of specific criteria including any assumptions, 

limitations, objective parameters, the variations within and between countries and how to take 

account of them. Therefore, in each of these sections these criteria have been considered and 

elaborated, where appropriate. 

It was acknowledged that the draft or similar methodologies described in this report might be used in 

the future by TEAP to provide information on QPS for the consideration of the Parties, if such 

information were to be requested by the Parties. 

8.5.2 Description of the methodology that could be used to assess technically and 

economically feasible alternatives to methyl bromide for quarantine and preshipment uses 

8.5.2.1 Introduction 

The protection of agriculture, forests and ecosystems from damaging exotic pests that can be 

accidentally imported during the course of trade is a priority for most countries. Although biological 

invasions from new pest species can be difficult to quantify financially, they have been estimated to 

cost more than $100 billion per year in the United States (TEAP 2009; Table in this report). 

Along with other control methods, methyl bromide as a broad spectrum fumigant is one of the most 

important procedures that is currently used on a diverse range of products to avoid the accidental 

shipment of unwanted pests. It can be applied prior to export or on arrival to control pests of 

quarantine concern. 

The three QPS categories of methyl bromide use – QPS in trade and transport of goods between 

countries, domestic (intra-country) quarantines and pre-shipment use – are distinct in some aspect. 

However the main point of similarity, all involve control of pests to some level of biological security, 

allow a common concept of what is an alternative to methyl bromide to be defined. 

A significant proportion of the methyl bromide for QPS is used domestically in some countries to 

prevent the spread of pests of quarantine concern within a country. This includes an “incursion 

response” that aims to prevent the establishment and/or spread of quarantine pests. 

In addition to the use for official phytosanitary measures, there is also some use of methyl bromide to 

control pests of quarantine concern associated with human health, animal health and indigenous 

environment e.g., mosquitoes, fire ants. Some treatments applied prior to export may not be officially 

required, but methyl bromide is sometimes used to kill quarantine pests in order to reduce the risk of 

rejection of the consignment in the importing if country quarantine pests are intercepted. 

Despite its usefulness in protecting the environment of many countries and in facilitating trade, 

methyl bromide’s ozone-depleting properties, its toxicity and its detrimental impact on products have 

resulted in the search for equivalent alternatives procedures and technologies that provide an 

appropriate level of phytosanitary protection. 

8.5.2.2 Uses of methyl bromide for soil that were categorised as QPS 

The United States reported the use of methyl bromide for some soil treatments (Anon 2009) for the 

production of propagation material, such as nursery stock, strawberry runners,. The Party categorised 

these methyl bromide fumigations as qualifying for the QPS exemption as they were carried out to 
130 May 2010 TEAP Progress Report 

comply with the requirements of various US States for certification of high plant health status for 

propagation materials, including lack of nematode infestation. Plants for propagation in the US are not 

eligible for certification if nematodes are detected in a sample of the propagation material. Methyl 

bromide and some alternatives (1,3-D) are applied to the soil in which the plants are grown to meet 

this nematode-free requirement. In the case of nematodes, the detection of a single nematode of 

economic importance is sufficient to make all plants grown in the area represented by that sample 

ineligible for certification. In practice, inspection of propagation material for nematodes is not part of 

the certification process when the field has been fumigated with methyl bromide. Therefore, growers 

producing propagation material prefer to use methyl bromide as, unlike the approved alternative 

(1,3D-Pic), there is no subsequent test that would make any plants grown in the fumigated area 

ineligible for certification. Plants grown in methyl bromide fumigated fields are deemed to have 

passed the certification process and can be marketed without further inspection. Plants grown in nonmethyl bromide fields must be inspected at the end of the growing season and presence of nematodes 

causes the field to fail the certification process and plants grown in that field are not eligible to be 

marketed as certified plants. Growers therefore prefer to fumigate the field with methyl bromide 

without a test and have no risk of failure, rather than apply the alternative with the test and risk failure 

of the field. 

The use on soil for production of propagation materials with certified high plant health status was 

listed by TEAP in its May 2009 report in response to Decision XX/6(7) under “categories of use it 

has identified that have been classified as quarantine and pre-shipment use by some Parties but not 

by others”. An explanation of why this use was considered to be QPS was provided by the US and 

included in TEAP (2009b). The use of alternatives to methyl bromide for this use is discussed further 

on in the Section: Alternatives to methyl bromide for strawberry runners. 

This use for soil was the second largest global use of methyl bromide under the QPS exemption. The 

reported consumption of methyl bromide for QPS was 1,483 tonnes in 2005. Consumption for this 

use occurred only in the United States. A more detailed analysis by MBTOC of information recently 

provided by the Party since 2003, according to information provided to MBTOC as a result of the reclassification by the United States of soil uses from CUE to QPS, indicated that the consumption of 

methyl bromide for soils for this use had almost doubled in 2010 to 2,850 tonnes, compared to 

amounts consumed 3-5 years earlier (see also Table 8-5). MBTOC made best assessments of the 

information available and seeks further information from the Party that would further define 

consumption of methyl bromide for soil uses under the QPS exemption for many different 

propagation materials. 

The pests and diseases involved in certification in the United States are widely distributed in both the 

source and receiving areas of the propagation material. Its use for this purpose is therefore 

inconsistent with the requirements and intent of the definitions of quarantine in the Montreal Protocol 

(TEAP 2009a; see Annex 2 for the definition of a quarantine pest in this report). Fumigation of soil 

with methyl bromide, or the use of several alternatives (1,3-D/Pic and methyl iodide/Pic), applied to 

the soil several months before up-rooting the propagation material, are reported to be extremely 

effective treatments that prevent the spread of nematodes and other pests (fungi and weeds) from the 

single production field to the numerous fruiting fields. Complete eradication of pests is not 

guaranteed. A past review in response to paragraph 8 of Decision XVII/9 by MBTOC showed that 

nematodes and fungal pathogens can survive methyl bromide treatment and that plants grown in 

treated soils can have levels of diseases which may or may not meet specified levels of tolerance 

(MBTOC 2006). MBTOC believes that methyl bromide fumigation of soil may be sufficient to reduce 

nematode levels to the standard required by the US, but in this case it is unlikely to meet the rigorous 

standard required of a quarantine treatment. The treatment has not been shown to prevent the transfer 

of nematodes from one region to another to the Probit-9 standard of security, which is typically 

applied in quarantine treatments. 

TEAP notes that the United States has requested methyl bromide for the same end users under both 

the Critical Use Exemption process and the QPS Exemption. In these cases and according to the 
May 2010 TEAP Progress Report 131

United States submission, the requirement for plant health is similar and specifies that the plants are 

essentially free from pests and diseases. TEAP notes that use of methyl bromide can be replaced 

under both categories by the implementation of alternatives, which have been adopted by other Parties 

in these sectors (see Section 8.3.4.1 and Table 8-5). The treatment of endemic nematodes, weeds and 

fungi, which are not under official quarantine and are not quarantine pests according to the definition 

used in the Montreal Protocol, may not qualify for a QPS exemption. Parties may wish to consider 

action for solving this problem. 

8.5.2.3 Definitions 

Methyl bromide is used by Parties to the Montreal Protocol to prevent the introduction, 

establishment and/or spread of quarantine and non‐quarantine pests. In proposing methodology 

that could be used to assess technically and economically feasible alternatives to methyl bromide for 

QPS uses, and to indicate the range of treatments that are permitted by the Montreal Protocol, it is 

assumed that the definitions of quarantine applications remain as defined by the Parties in Decision 

VII/5; and as defined for pre-shipment treatments applied to control non-quarantine pests in Decision 

XI/12. For clarity, these definitions are also shown in Annex 1 of this report. 

In the remainder of this chapter, it is assumed that a QPS treatment is: 

Any official procedure for the killing, inactivation or removal of pests, or for rendering pests 

infertile or for devitalisation1

. 

In the Montreal Protocol, ‘official control’ applicable to a quarantine treatment is one that: 

.., is performed by, or authorised by, a national plant, animal or environmental protection or 

health authority. 

For pre-shipment applications, official requirements are:

... those which are performed by, or authorized by, a national plant, animal, environmental, health 

or stored product authority. 

8.5.3 Technical feasibility of an alternative 

In accordance with the request in paragraph 3(4) of Decision XXI/10, the methodology that could be 

used to assess feasible alternatives to methyl bromide for QPS uses is discussed firstly from a 

technical perspective and secondly from an economic perspective. 

The methodology that could be used to assess an alternative as technically feasible could include the 

requirement that it has been “authorised by, a national plant, animal or environmental protection or 

health authority on the basis of its proven efficacy for killing, inactivating or removing pests, or 

rendering pests infertile or for devitalisation”. Where an alternative is also used to facilitate 

international trade, it must also “achieve a contracting Party’s appropriate level of protection”2 or 

quarantine security. 

Therefore, as a working definition for the purpose of addressing the request by the Parties in 

paragraph 3(4) of Decision XXI/10, a technically feasible alternative to methyl bromide that is used as 

a phytosanitary treatment against quarantine and non-quarantine pests is: 

 

1 IPPC. 2009. ISPM No. 5. Glossary of Phytosanitary Terms. Last updated 25.01.2010. 

2 ISPM No.5 (IPPC). 
132 May 2010 TEAP Progress Report 

“An officially-required treatment that has been authorised by, a national plant, animal or 

environmental protection or health authority which achieves an appropriate level of phytosanitary 

protection”. 

Conversely, an alternative that had not been authorised by, a national plant, animal or 

environmental protection or health authority as a phytosanitary treatment would not be considered 

as a technically feasible alternative to methyl bromide at the time of assessment. 

Because the treatment has been officially authorised, the alternative is supported by data that have 

been generated using appropriate scientific procedures, including where relevant an appropriate 

experimental design; and the data are verifiable, reproducible, and based on statistical methods and/or 

on established and accepted international practice. 

Additional to authorisation, an alternative must also be logistically feasible so that it can be used in 

commercial practice. A treatment may need to be applied at the point of entry to kill pests incepted 

on import, under conditions when both space and time are limited. For some countries that have 

stringent phytosanitary requirements, treatment on arrival is an important element of maintaining 

national bio-security. 

The alternative should not significantly reduce the marketability3

 of the regulated article4 being 

treated. In some cases, such as when military equipment is fumigated to control arthropods and other 

contaminants, the treatment must not affect the functionality of the equipment. 

The customer requirements may preclude the use of some officially authorised options e.g., sawn / 

kiln-dried lumber that has been treated in a way that eliminates pest risk, but the product is not 

acceptable to the customer as only whole logs are acceptable for the manufacture of wood veneer. 

Registration of the alternative by pesticide and other regulatory authorities would typically include 

consideration of any adverse effects on the environment, off-target organisms, human and animal 

health. Conversely an alternative available in one country may not be available in another due to not 

meeting the needs of the regulatory authority. These effects would thus not need to be specifically 

considered in any methodology for assessment of alternatives as they are covered by the approval 

process. The chemical alternatives should be applied in a way that does not increase the risk of the 

target organism developing biological resistance to the treatment. 

Obtaining the data to support technical negotiations that result in a bilateral agreement for an 

international phytosanitary treatment can take many years depending on the target pest, the proposed 

treatment and the importance policy officials in each country assign to the process. Once agreed, the 

treatment is applicable to the specific pest/commodity combination and treatment conditions that have 

been agreed and cannot be applied to a wider range of pests and commodities. 

8.5.4 Economic feasibility of alternatives 

The methodology that could be used to assess an alternative as a QPS measure as economically 

feasible could include the requirement that its net returns are determined relative to a methyl bromide 

treatment. 

Net return is a preferred measurement in any proposed methodology since the cost of an alternative 

can increase or decrease significantly, and its impact on the value of the product may change and is 

dependent mainly on what the market is willing to pay. In the case of increased costs, they can 

 

3 The ability to market and sell the product. Some treatments cause unacceptable damage to the product under conditions that kill the pest and therefore are not able to be used 

commercially. 

4 Any plant, plant product, storage place, packaging, conveyance, container, soil and any other organism, object or material capable of harbouring or spreading pests, deemed to 

require phytosanitary measures, particularly where international transportation is involved. ISPM No.5 (IPPC). 
May 2010 TEAP Progress Report 133

sometimes be offset by increases in price in the market at per unit costs that may or may not be 

significant to the end client. 

Determining the economic feasibility of the development of an alternative to methyl bromide for ‘pest 

incursions’ is not the focus of this draft methodology since the economics of this are less restrictive 

than those that are under consideration for other areas where QPS alternatives are required. For a 

destructive pest, the costs of failing to manage or eliminate the pest can be very high (see Table), so 

the cost differential between methyl bromide and the alternative may not be important, provided it is 

at least as effective as methyl bromide treatment. 

An alternative should be implemented without significant market disruption and the sectors that 

benefit as a result of the adoption of the alternative should be identifiable. 

8.5.5 Description of the methodology for the assessment of the impact of the 

implementation of alternatives to methyl bromide for quarantine and preshipment uses 

TEAP assumed that this task required a description of the methodology for the assessment of the 

impact on the environment, as paragraph 3(4) of Decision XXI/10 provided an unspecific statement in 

relation to impact. In this regard, the methodology for the assessment of the impact of alternatives, 

firstly on the atmospheric environment and secondly the impact of an invasive pest on agriculture, 

forestry and ecosystems (the environment protected in many countries by official phytosanitary 

measures). 

8.5.5.1 Impact of an alternative on the atmosphere 

If required by the Parties, TEAP and the Scientific Assessment Panel could assess the impact of the 

implementation of an alternative to methyl bromide for QPS uses on the atmosphere using 

internationally-accepted methods for calculating changes to ozone depletion and global warming, 

which are the two impacts that are most commonly measured. 

The Equivalent Effective Stratospheric Chlorine (EESC) could be used to measure the contribution of 

the substance in the atmosphere as this is directly related to ozone depletion. The EESC was used in 

the WMO 2002 Scientific Assessment to gauge the effectiveness of the control measures in the 

Montreal Protocol. It is assumed that the EESC would decrease since methyl bromide would be 

eliminated as a result of its replacement with a substance that was not ozone-depleting. 

The global warming potential (GWP) of a substance is its global warming impact relative to the 

impact of the same quantity of carbon dioxide over a 100 year period. If the alternative to methyl 

bromide has been assigned a GWP, the radiative forcing of the alternative could be measured 

according to the quantity of the substance emitted to the atmosphere. 

An alternative to methyl bromide may have other detrimental effects on agriculture, forests and 

ecosystems that would need to be measured and reported, such as residual pesticides that contaminate 

water and soils, and pesticide dips that are used for the disinfestation of cut-flowers in some countries. 

Determining the environmental impact of various components involved in a systems approach that 

achieves the required level of phytosanitary security can be particularly challenging and timeconsuming. 

If the Parties considered it important, TEAP could also report on the impact of the implementation of 

alternatives to methyl bromide for QPS uses on the health of humans and animals as a result of a 

review of officially-published documents developed as part of the regulatory assessment of the impact 

of an alternative on water, food and air quality. TEAP would pay particular attention to the likely 

impact of an alternative on worker safety since this is a serious health concern for portside workers 
134 May 2010 TEAP Progress Report 

may be exposed to methyl bromide when opening shipping containers that were fumigated prior to 

export. There may also be health concerns associated with the exposure of nearby communities to 

methyl bromide or an alternative.

8.5.5.2 Impact of the an invasive pest on agriculture, forests and ecosystems 

Methyl bromide fumigations are one of a number of measures used to prevent or restrict introduction 

of pests and diseases into new areas. In many cases, methyl bromide treatment is the sole available 

quarantine measure that is available for particular goods that will allow the trade between specific 

countries to proceed. There are numerous examples of situations where assessments have been made 

of the cost of restriction of trade and impact of incursions that might have been prevented through 

effective quarantine measures, including methyl bromide use. 

If the alternative is officially authorised as described in Section 8.5.2.2 and the treatment applied as 

intended, the risk of inadequate disinfestation should be minimal as the treatment would have been 

approved on the basis of supportive data that had been generated as a result of the use of appropriate 

scientific procedures. 

Without the availability of alternatives to methyl bromide for QPS, there was a strong likelihood of 

disruption to international trade if the exemption for QPS were not available, resulting in a reduction 

in the benefits from trade (Margolis et al. 2005). Importing countries may have to forego foreign 

products and raw materials (Roberts et al. 1999, Mumford 2002), while exporting countries may lose 

access to markets (Li et al. 2008, Turner et al. 2007). Just as important was the environmental 

damage done by introduced quarantine pests and the reality of the critical role played by methyl 

bromide in preventing the spread of these pests to new locations. 

Li et al. (2008) used an economic model of the global forest sector to estimate the economic impact of 

a gradual ban on the global trade of roundwood. They predicted that such a ban would lead to a 

significant reduction in producer revenues (quantity produced times price received) for major log 

exporters, e.g. 16% reduction for Russia and 10% for New Zealand. For some Article 5 and NonArticle 5 Parties that rely to a large extent on export receipts from methyl bromide-treated 

commodities, the exemption was considered very important as it specifically avoided the equivalent 

of a ‘...new non-tariff barriers to trade...’ (Decision VI/11), if such an exemption were not in place. 

Studies of insect interceptions and establishment however, confirm the role of increased trade as 

potential pathways for introduction of non-indigenous species (Work et al. 2005, McCullough et al. 

2006). Biological invasions by new pest species into a country can have serious adverse effects 

economically and environmentally e.g., lost recreational opportunities, damage to important food and 

industrial crops, extinction of indigenous species, and direct costs of pest containment or eradication 

(Holmes et al. 2009). An objective of quarantine treatments is to prevent establishment of these new 

pest species in areas that have been free of them. 

The combined economic costs of new pests may be significant, with implications for environmental 

policy and resource management. Estimates of the economic impact of invasive pests (see citations in 

Turner et al. 2004, Holmes et al. 2009 and Brockerhoff et al. 2010) vary widely (Table 8-6) because 

of differences in the costs and benefits included, and how an economic value is placed on these. 

However, full economic impact assessments have rarely been undertaken at a national level, with the 

exception of Presetemon et al. (2006) for logs and lumber and Jabara et al. (2008) for wood packing 

material. Prestemon et al. (2006) also included the additional impact of increased stringency of 

phytosanitary regulations placed on log exports to avoid pest spread to export markets. In addition, it 

is not usually possible to put a monetary value on environmental changes that new pests cause when 

introduced into a new habitat. 

In addition, the most significant impact of pest establishment and spread may be a reduction of 

environmental services, which have a non-market value (Holmes et al. 2009). Placing a monetary 
May 2010 TEAP Progress Report 135

value on changes in environmental services that new pests cause when introduced into a new habitat 

can be complicated, though not impossible (citations in Holmes 2010). The economic costs of the 

reduction in environmental services associated with the effect of exotic forest pests include the value 

of lost enjoyment of recreation and natural beauty (Marler & McCrea 1977), and lost property value 

(Tyrväinen 1999). 
136 May 2010 TEAP Progress Report 

Table 8-6: Estimates of economic costs of exotic forest pests (for sources of information see Turner et al. 2004)

Cost Cost estimate ($ 106)2 Pest Country/ Region Year/ PeriEradication NZ$10 Orgyia thyellina New Zealand 1997  NZ$100 Teia anatoides New Zealand 2003-  NZ$3.98 Ophiostoma novo-ulmi New Zealand 1989-2004 Reduced harvest value US$4.2 Lymantria dispar USA 1933-1952  US$219.6 Lymantria dispar Pennsylvania 1969-1987  NZ$97.9 Orgyia thyellina New Zealand 1997  US$35-US$5841 Defoliator insects Western USA 1990  US$33.35-US$1670 Bursaphelenchus spp. Western USA 1990  US$24.9-US$240.6 Lachnellula willkommii Western US 1990  US$201-US$1500 Ips typographus Western USA 1990 

US$81.1-US$331.4 Annosus root disease Western USA 1989 

 US$4.34 Orgyia pseudotsugata USA 1983  US$2100 Plant pathogens USA 2000  US$2100 Insect pests USA 2000  NZ$6.1 Dothistroma pini New Zealand 1989  NZ$22.5 Dothistroma pini New Zealand 2004  NZ$5.4 Diplodia pinea New Zealand 1961-1989  NZ$13.8 Cyclaneusma minus New Zealand 1989  NZ$50.9 Cyclaneusma minus New Zealand 2001  NZ$60.8 Cyclaneusma minus New Zealand 2004  NZ$3.6 Armillaria spp. New Zealand 1989  NZ$37 Armillaria spp. New Zealand 2004  US$108-US$999 Cronartium fusiforme USA 1992 

C$12.7 – C$33.1 billion Numerous Canada 2006 

Control NZ$1.2 yr-1 Dothistroma pini New Zealand 1989  NZ$1.6 yr-1 Dothistroma pini New Zealand 2004  US$0.66 Orgyia pseudotsugata Northwest USA 1983  US$49 Cronartium fusiforme Southern USA 1992  NZ$34.7 Orgyia thyellina New Zealand 1997 Urban forest loss NZ$1.5 Ophiostoma novo-ulmi New Zealand 1993  NZ$10 100 Ophiostoma novo-ulmi New Zealand 1999 

NZ$116.7 Forest pathogens New Zealand 2003 

 NZ$290.5 Lymantria dispar New Zealand Undated 

NZ$1.5 Orgyia thyellina New Zealand 1997 

 NZ$19,450 Agrilus planipennis United States 2009-2019 

1 Estimates are not directly comparable due to differences in methodology, year of valuation, area of pest impact, etc. 2 Cost estimates are nominal, varying in their base year, and are in different curr
May 2010 TEAP Progress Report 137

The eradication of a newly discovered pest is generally difficult, often highly controversial, and 

frequently requires substantial resources costing millions of dollars and commitment of those in 

charge of an operation and the many stakeholders (e.g., Myers and Hosking 2002; Simberloff 2002 

2003). It is therefore better to prevent incursions of new pests by providing adequate exclusion of 

products presenting a pest risk and to provide disinfestation treatments for those permitted entry under 

specific conditions, than to attempt eradication after an incursion. 

However, as Brockerhoff et al. (2010) found there are ample examples of successful eradication 

campaigns. These include several recent successful eradication campaigns against tree-defoliating 

Lepidoptera in New Zealand (at a cost of $NZ 94 million) and North America (e.g., Myers and 

Hosking (2002); Suckling et al.(2007)). A number of other pest insects and diseases have been 

successfully eradicated, including the Mediterranean fruit fly (Ceratitis capitata) in Mexico, parts of 

Central America, Chile, Australia and California (several times) (Hendrichs et al. 2002); and the red 

imported fire ant (Solenopsis invicta) in New Zealand (Sarty 2007). 

Although there have been some successes in eradicating certain important exotic pests after 

inadvertent introduction to a new area, in most cases where quarantine pests have been introduced, 

eradication was either impossible or not feasible for many reasons, including inadequate eradication 

tools for the species in question, extensive spread before detection, and cost or regulatory concern 

about the methods that would have to be employed to effect eradication. For these reasons, countries 

involved in trade have relied on effective quarantine measures to prevent the accidental import and 

establishment of new pest species. Along with other pest control methods, methyl bromide has been a 

key tool for this for over 70 years. 

8.5.6 Description of the methodology for the assessment of the impact of restricting 

the quantities of methyl bromide production and consumption for quarantine 

and pre-shipment uses 

8.5.6.1 Consumption of methyl bromide for quarantine and pre-shipment 

TEAP (2009) reported global methyl bromide consumption for QPS of approximately 10,000 tonnes 

in 2007. Non-Article 5 Parties have in general decreased their consumption of QPS and some have 

phased out, whereas Article 5 Parties have increased their consumption significantly. 

Article 5 Parties used about 6,235 tonnes for QPS in 2007, which exceeded the use in Non-Article 5 

Parties (5,997 tonnes) for the first time. China, India, Indonesia, Malaysia, Republic of Korea, 

Singapore, Thailand and Vietnam were the dominant users in Asia (Figure). Latin American and 

African countries on the other hand used relatively little. 

It appears that Parties that consume methyl bromide for QPS are now in the minority. About 22% of 

all Parties globally reported consumption of methyl bromide for QPS, compared to 49% that once 

consumed methyl bromide and have now stopped using it, or 29% that never used it at all for QPS. 

Parties that do not use methyl bromide for QPS, or once consumed it but no longer do so, may have 

replaced it with alternatives or may simply have stopped using it. However, it is possible that some 

exporting Parties that did not report consumption of methyl bromide for QPS relied on methyl 

bromide applied by the importing country for market access in the event that methyl bromide was 

applied for a pest of quarantine concern detected on entry. As the reporting by Parties does not 

provide information to this level of detail, further analysis of imports by some countries would be 

required to determine the extent to which some countries rely on the methyl bromide of others for 

market access. 
138 May 2010 TEAP Progress Report 

In the case where an exporting 

country bans the use of methyl 

bromide for QPS, and the 

importing country has not changed 

its requirement to allow an 

alternative to methyl bromide to be 

used by the exporting country, the 

importing country may require 

fumigation with methyl bromide in 

another country en route, or on 

arrival. The ability of governments 

to detect such uses of methyl 

bromide depend on fumigators 

maintaining good fumigation 

records and in governments 

collecting and analysing the 

records in order to determine the 

uses for which alternatives are available and could be used. 

For countries or regions that have phased out their uses of methyl bromide for QPS, such as the 

European Union, it would be useful if such Parties removed from their legislation the requirement for 

the exporting country to use methyl bromide, in circumstances where an alternative that provides the 

appropriate level of quarantine security is available. For example, in the EU legislation methyl 

bromide is only required in one case which is for export of oak logs to control oak wilt. However, 

when fumigation is specified in Directive 2000/29/EC as an option, the fumigant itself is 

generally not specified. This means that the EC does not specify that plants or plant products are 

required to be fumigated with methyl bromide. To be accepted by the EC, however, the 

fumigation treatment must be carried out to the specified requirements that have been approved 

by the EC Standing Committee on Plant Health. 

Directive 2000/29/EC specifies the use of methyl bromide in only two cases8: 1) Treatment of 

oak logs (Quercus L.) with bark attached that are exported from the United States of America to 

Europe; and 2) Treatment of wood-packaging material. Methyl bromide fumigation for oak logs 

with bark attached and for wood packaging material is not required under specific conditions 

when alternative treatments or procedures are used. Methyl bromide fumigation is not required 

by the EC if the oak wood meets one of the following conditions: (a) all round surfaces are 

removed, or (b) bark-free and dried to <20% moisture, or (c) bark-free and treated with hot-air or 

hot water treatment, or (d) sawn and kiln-dried to <20% moisture (Council Directive 2000/29/EC 

as amended, Annex IV, Part A, Section 1.3). These conditions may result in the imported material 

not be acceptable to the end user e.g., logs used for veneer, resulting in the use of methyl bromide to 

fumigate whole logs. 

These and other objective parameters that show variations in methyl bromide consumption for QPS 

within and between countries and regions would be important to elucidate further when proposing 

methodology for the assessment of the impact of restricting the quantities of methyl bromide 

production and consumption for QPS uses. In proposing this methodology, the work undertaken to 

supply information to the Parties would benefit from any guidance that the Parties may wish to 

provide that would focus the TEAP’s work on particular groupings of countries or scenarios that 

would be of most benefit to the Parties. 

0

1,000

2,000

3,000

4,000

5,000 Asia

Africa

Latin America

Figure 8-1: Consumption of methyl bromide (tonnes) for 

QPS in developing countries, 1997-2007 (Source: Ozone 

Secretariat data)
May 2010 TEAP Progress Report 139

TEAP (2009) described the main categories of use that could be used for data collection. Data are 

needed from the Parties by: 

1. Category of use; 

2. Quantity of use in latest year for which data are available; 

3. Target pests and level of biosecurity required for the QPS measure; 

4. Economic value of the QPS measure using methyl bromide; 

5. Effectiveness and availability of potential alternatives for the particular use. 

They are discussed below in relation to QPS consumption data, the experiences of Parties that have 

phased out methyl bromide for QPS, and the design of the any restriction on methyl bromide for QPS 

that might be agreed in the future by the Parties. 

8.5.6.2 Domestic use of methyl bromide for QPS treatments 

Apart from methyl bromide that is used on import to control pests of quarantine concern, or on 

exports under bilateral arrangements, it is also used domestically to prevent the spread of pests of 

quarantine concern within a country. 

For some countries such as Argentina, domestic use consumes more methyl bromide for QPS than 

any other use, whereas in others such as Australia the consumption is about 10% of total methyl 

bromide use. Japan does not use any methyl bromide for QPS to prevent the spread of pests of 

quarantine concern within Japan. 

Some countries use methyl bromide domestically for QPS to eradicate a pest (an ‘incursion response’) 

that has been introduced but has not established. These treatments may need to be undertaken 

annually or even several times in the same year. Methyl bromide is considered essential in many 

cases by quarantine authorities for controlling pest incursions and preventing pests from becoming 

established. 

Determining the financial value of the ecosystem (forestry, food production, recreational and other 

resources) being protected in each country would be the prerogative of each Party and not work that 

TEAP could easily undertake. However, TEAP would include in its methodology any estimates of 

the likely cost of a alternative in relation to methyl bromide, and the influence that the implementation 

of an alternative might have on the trade flows of the major commodities identified in this report as 

being most commonly fumigated with methyl bromide. 

These examples of the domestic consumption of methyl bromide for QPS are generally not under 

federal or national control but may be under the control of competent or regulatory authorities that do 

not necessarily report the quantity used at the national or federal level. As the quantities of methyl 

bromide are not known for domestic uses in some countries, and in order to assess the impact of 

restricting the quantities of methyl bromide for this purpose, TEAP would request Parties to obtain 

information on the amount of methyl bromide consumed for QPS domestically, the categories of use 

and the prospects of alternatives being used for this purpose. 

8.5.6.3 Methyl bromide reported as QPS consumption 

In the methodology for the assessment of the impact of restricting the quantities of methyl bromide 

production and consumption for QPS uses, TEAP would suggest obtaining the most recent reports on 
140 May 2010 TEAP Progress Report 

QPS consumption that have been submitted annually by Parties to the Ozone Secretariat pursuant to 

Article 7 of the Montreal Protocol. 

The limitations of these reports are that some Parties have not reported or that they report 

inconsistently from one year to the next. Some Parties do not yet have a mechanism in place for 

determining the quantity of methyl bromide used on exports for QPS. TEAP proposes to take account 

of these limitations by extrapolating the information for missing years from existing information 

where this is feasible, and/or by contacting the Party / National Ozone Unit in the country concerned 

to determine if any further information can be made available. 

Once the information is contained in a database, TEAP would suggest analysing the information for 

trends in the consumption of methyl bromide for QPS in the relevant Parties. For example, TEAP 

(2009) reported that there were nine on-Article 5(1) Parties in 2007 that reported QPS consumption 

pursuant to Article 7, and of these two Parties accounted for 82% of the methyl bromide consumption 

for QPS. 

Treatment on arrival is common in some countries that have stringent quarantine standards. 

Treatment on import of products from many countries allows these products to be placed on the 

domestic market of the importing country. Treatment on arrival is therefore important for trade with 

many countries. These data would indicate that the TEAP methodology should examine the 

disinfestation treatments carried out by relatively few Parties in the Montreal Protocol, with the 

understanding that these uses facilitate the trade with many Parties that themselves may not use 

methyl bromide for QPS. TEAP would request data from countries on the amount of methyl bromide 

used for treatment on import, the types of commodities treated and the countries that shipped them. 

On the basis of reports submitted by Parties in 2009 to the Ozone Secretariat on uses of methyl 

bromide for QPS, TEAP would include in the methodology an assessment of the quantity of methyl 

bromide that was reported to be used for specific categories of use. TEAP (2009) reported that just 

over half the methyl bromide used for QPS in 2007 was used on commodities prior to export, whereas 

only about 15% was used on commodities when a pest was detected on import. Less methyl bromide 

on import could be expected since most National Plant authorities prefer to have disinfestation 

treatments at the point of origin since there is typically sufficient time for the treatment at that location 

and the phytosanitary risk is less when the treatment is carried out in the exporting country. 

TEAP (2009) also reported that about 75% of the methyl bromide consumed for QPS was applied to 

products in four major categories: sawn timber and wooden packaging material; grains or similar 

foodstuffs; pre-plant soil use; and logs. This indicated that the alternatives that had been applied in 

many countries for these uses could provide a useful lead in determining their suitability in countries 

using methyl bromide for QPS. 

The relatively large consumption of methyl bromide for QPS by relatively few countries does not 

mean that TEAP would focus its methodology only on these countries. In many cases, a relatively 

small volume of methyl bromide is very important for trade from low volume consuming (LVC) 

Parties. Therefore understanding the trade flows and methyl bromide consumption in LVC Parties 

would be incorporated into the TEAP methodology. 

In general for all Parties that use methyl bromide for QPS, TEAP would put in place methodology 

that would measure the change from the baseline (methyl bromide for QPS) as a result of the loss of 

methyl bromide or its replacement with an alternative. This could be tested under the assumption that 

demand for the product remains the same but the conditions for market access change. What are the 

regulatory barriers? What is the impact if the alternative is less costly than methyl bromide? Some of 

the impacts would be difficult to measure since there is no single economic construct that can be used 

to assess changes in the markets, most markets are price sensitive according to supply and demand, 

the extent of the inventory varies according to the market and the commodity, and the options for 

diverting trade may be limited in the event that methyl bromide is not replaced with an alternative. 
May 2010 TEAP Progress Report 141

TEAP would also propose including in the methodology an examination of any data that is held by 

competent or regulatory authorities on the uses of methyl bromide for QPS. Decision XI/13 in 2001 

encouraged Parties to monitor the use of QPS-MB by commodity and quantity as a way of targeting 

the efficient use of resources when developing and implementing technically and economically 

feasible alternatives. 

TEAP proposes to request Parties to provide information on methyl bromide consumed for QPS in 

specific categories, the quarantine pests involved, the amounts used for regulated non-quarantine 

pests, the reasons why a substitute for methyl bromide for a particular use had or had not been 

possible, and the costs of the alternative. This information will contribute toward an assessment of 

the potential impact of restricting the quantities of methyl bromide production and consumption for 

QPS uses. 

8.5.6.4 International Plant Protection Convention 

In 2008, the International Plant Protection Convention that is responsible for phytosanitary 

(quarantine) issues adopted a Recommendation on Replacement or Reduction of the Use of Methyl 

Bromide as a Phytosanitary Measure1

. It noted that, to reduce the risk of introduction of some 

quarantine pests, the need for methyl bromide remained until a range of equivalent alternatives had 

been developed. Inter alia, it encouraged Parties ‘to put in place a strategy that will help them to 

reduce the use of methyl bromide for phytosanitary measures and/or reduce emissions of methyl 

bromide’. The strategy included actions to replace methyl bromide, such as reducing use, physically 

reducing emissions, accurately recording methyl bromide use, and guidelines for appropriate use of 

methyl bromide as a phytosanitary measure. 

As part of the methodology for the assessment of the impact of restricting the quantities of methyl 

bromide production and consumption for QPS uses, TEAP proposes close collaboration with the IPPC 

on issues related to the use of methyl bromide, and on the use of alternatives to methyl bromide for 

phytosanitary treatments. 

The collaboration between TEAP and the IPPC could include, inter alia, gaining a better 

understanding of the role and impact of IPPC standards that facilitate trade; the likely impact on the 

consumption of methyl bromide of any new treatments added to ISPM-15 for the treatment of wood 

packaging material; and how regulatory and other issues impede or support the adoption of methyl 

bromide alternatives for QPS uses. 

8.5.6.5 Trade that depends on the use of methyl bromide for QPS 

There are some commodities that are traded between countries that are dependent on methyl bromide 

fumigation for the disinfestation of pests of quarantine concern for this trade to occur. The most 

useful example to illustrate this is the trade in logs from countries such as the USA and New Zealand 

to South Korea, China and India. This trade is characterised by unpredictable demand which can 

increase significantly within a short time period. For example, the log trade from New Zealand in the 

first quarter of 2009 was equivalent to the entire trade the year previously. Although in-transit 

phosphine has been approved as an alternative to methyl bromide as a result of a bilateral agreement, 

the bulk of the trade is still dependent on methyl bromide. 

Apart from this international trade where quarantine pests are controlled, there is also trade in 

commodities such as grain that undergoes a pre-shipment fumigation with methyl bromide prior to 

shipment. These treatments are authorised by the authorities described in Section 8.5.2.3 above, and 

 

1 IPPC (2008) IPPC Recommendation on Replacement or Reduction of the Use of Methyl Bromide as a Phytosanitary Measure. Recommendation for the Implementation of the IPPC. 
142 May 2010 TEAP Progress Report 

are carried out to reduce the population of non-quarantine pests that can, if left unchecked, reduce the 

quality of the commodity. 

In order to the assess the impact of restricting the quantities of methyl bromide production and 

consumption for quarantine and pre-shipment uses, TEAP proposes including methodology to better 

understand the value of the trade that depends on methyl bromide, the trends that are taking place 

particularly at a time of improvement in the global economy, the impact on this trade of not having 

access to methyl bromide in the event that an technically and economically feasible alternative is not 

available, and the quantities of methyl bromide that are required to facilitate this trade. 

As part of this methodology, TEAP also proposes obtaining information on the likely time that would 

be required to negotiate a bilateral trade agreement for an alternative; the impact of tariffs on trade, 

the domestic infrastructure (e.g. saw mills) and legislation that enhance or reduce the prospects for the 

implementation of technically and economically feasible alternatives; and the types of alternatives 

that might be available that meet customer specifications for logs. 

Some exporting countries are required to use methyl bromide for QPS prior to shipment to meet the 

regulatory or similar requirements in the importing country for the trade in a particular commodity. In 

this case, the exporting country is not able to eliminate its use of methyl bromide for this use and still 

maintain trade. 

The importing country may be willing to accept an alternative treatment to methyl bromide for an 

equivalent level of quarantine security, but has not yet reviewed its regulatory requirements to make a 

change to eliminate the need for methyl bromide. Decision XI/13 in 2001 encouraged Parties to 

review their national plant, animal, health and stored product regulations with a view to removing the 

requirement for the use of methyl bromide for QPS where technically and economically feasible 

alternatives exist. TEAP would propose including methodology that would quantify the amount of 

methyl bromide that is used for this purpose, the name of the regulation that requires this use, the 

commodity involved, and alternatives that may or may not be available to substitute for this use. 

For bilateral treatments, many countries do not specify the treatment that is to be applied in the 

exporting country to control pests of quarantine concern that could be present on commodities 

imported. Instead, the level of quarantine security that is required to be achieved is specified. The 

exporting country then must prove with research that the treatment and conditions it proposes to 

achieve the importing country’s desired level of quarantine security. 

TEAP would apply the same methodology used for the logs to other sectors where there is significant 

international trade flows in order to construct a more complete picture of the global trade that depends 

on methyl bromide. 

8.5.6.6 Experiences of the phase out of methyl bromide for QPS in some countries 

TEAP (2009) reported that some countries have either not reported methyl bromide consumption for 

QPS, or reported this consumption in the past but no longer use methyl bromide for QPS. This would 

imply that alternatives to methyl bromide for QPS have been adopted, or that trade in products that 

depended on methyl bromide for export or import no longer takes place. The extent of the restriction 

to phase out methyl bromide for QPS is dependent on the extent to which methyl bromide can be 

replaced by alternatives or not. The phase out of methyl bromide for QPS in these countries can 

therefore provide some important quantitative and qualitative information on the impact of restricting 

or eliminating quantities of methyl bromide for this use. 

In proposing methodology for the assessment of the impact of restricting the quantities of methyl 

bromide production and consumption for QPS uses, TEAP proposes to obtain information to 

understand the procedures, planning process, regulatory environment, cost, logistics, research & 

development and other details that resulted in the phase out of methyl bromide for QPS in some 
May 2010 TEAP Progress Report 143

countries. TEAP would document areas where trade continued or increased as a result of the adoption 

of an alternative, and situations where trade was reduced or halted as a result of having no recourse to 

methyl bromide. The environmental impact of introduced pest species would be compared between 

countries that have and have not phased out the use of methyl bromide for QPS use. In situations 

where there is a loss of trade, it can take many years for the trade to re-establish to similar volumes. 

The adoption rate of an alternative is often highly dependent on its cost. For example, in some 

countries such as Argentina heat treatments of solid wood packaging to ISPM-15 standard now 

account for all of the ISPM-15 disinfestation treatments despite methyl bromide also being available 

for this purpose. Although no detailed investigation has been carried out, it is likely that the users 

selected heat because it was less expensive and not hazardous to human health compared to methyl 

bromide (Eduardo Willink MBTOC pers. comm. 2010). 

For the major categories that consume methyl bromide for QPS and for the relevant countries, TEAP 

proposes to include methodology that assesses the cost threshold for when alternatives become 

economic to adopt, the cost of the research for those alternatives and government subsidies that were 

potentially available to support the change. TEAP would document uses of methyl bromide and 

quantities that were unlikely to be replaceable because of the lack of finance to support the transition 

away from methyl bromide. 

TEAP proposes requesting this information from relevant Parties and commercial interests, and by 

using its membership and that of MBTOC to follow up with Parties and commercial interests in the 

relevant countries. 

8.5.6.7 Other methods to reduce emissions of methyl bromide 

Another method to reduce some emissions of methyl bromide is to attach equipment that 

recovers/destroys or recovers-recycles-destroys any methyl bromide used for QPS. Methyl bromide 

fumigations for QPS except for soil fumigations normally occur in well-sealed fixed facilities or 

shipping containers, which facilitates the attachment of equipment for recovery, recycling and 

destruction. Recapture may, depending on the absorption by the commodity being fumigated, result in 

40 – 90% reduction in methyl bromide emissions. 

Experience with recapture and recycling equipment in conserving methyl bromide continues to 

accumulate (see TEAP 2009 for details). One country has dual chambers that vents used methyl 

bromide from one chamber and recycles it to an adjacent chamber using about 30% less methyl 

bromide than would otherwise be used. However, some countries do not allow re-use of methyl 

bromide on food or other products, whereas others allow this use. Some countries or states have 

recapture and destruction facilities working and a significant amount of gas is being destroyed, 

resulting in the possibility of the Party deducting the destroyed amount from their consumption data 

submitted under Article 7. The cost of capturing and destroying methyl bromide is reported to be 

approximately double the cost of the fumigation treatment. 

TEAP proposes to include a determination of the usefulness and financial significance of such 

equipment within its methodology for assessing the impact of restricting the quantities of methyl 

bromide production and consumption for QPS uses. 

8.5.6.8 Design of the restriction influences TEAP’s proposed methodology 

The design of any QPS restriction will have an impact on the feasibility of the transition from methyl 

bromide to alternatives for QPS, and the methodology that TEAP could put in place to assess the 

impact of restricting the quantities of methyl bromide production and consumption for quarantine and 

pre-shipment uses. 
144 May 2010 TEAP Progress Report 

8.5.6.8.1 Timeframe for any proposed restriction 

As a result of TEAP’s collection and analysis of consumption data supplied by the Parties and 

described above, TEAP may be in a position to improve on estimates of the quantity of methyl 

bromide for QPS that could and could not be replaced by alternatives over different time scenarios. 

Allowing a Party sufficient time to replace methyl bromide used for QPS with an alternative will 

improve the prospects for compliance with any proposed restriction that the Parties might agree in the 

future. It would also allow importing countries sufficient time to amend any requirements to permit 

the use of an alternative in the exporting country, rather than methyl bromide, which might otherwise 

be the case. 

8.5.6.8.2 Flexibility of choice 

The Parties may also see other factors as important, such as allowing a Party flexibility in the choice 

of methyl bromide uses that are replaced with alternatives. Flexibility has been an important 

cornerstone of the phase out of other ODS in the Montreal Protocol. 

8.5.6.8.3 Exemption pathway 

An exemption pathway may also be seen as useful whereby a Party would be able to gain access to 

methyl bromide for QPS and exceed the national restriction, in the event that a technically and 

economically feasible alternative for this use was not available. This may be important for 

maintaining trade that depends on methyl bromide, in the light of unpredictable and relatively quick 

changes in trade volume that are known to occur (see Section 8.5.6.5 above). 

The procedures that have been developed for the assessment of nominations for Critical Uses of nonQPS methyl bromide may provide guidance to the Parties on the options for the evaluation of any 

recourse to a similar exemption that may be considered by the Parties for QPS. Unpredictable and 

relatively quick changes in trade volume and trade partners, sudden changes in bilateral phytosanitary 

requirements following pest outbreaks, and the need for a rapid response to enable pest eradication 

suggest that any exemption pathway should be efficient and speedy. 

8.5.6.8.4 Pre-shipment 

TEAP (2009) reported that, according to a data recently submitted by the Parties in 2009, the use of 

methyl bromide for pre-shipment appeared to be small compared to its use in the past. Because these 

data were relatively limited, TEAP would propose including methodology to specifically assess where 

methyl bromide was still being used for pre-shipment, the applications by category, and the quantities 

of methyl bromide being consumed for this purpose. Further data on pre-shipment and alternatives 

for this use would determine the importance of this use for Parties. 

Pre-shipment targets unregulated non-quarantine pests that usually affect storage and end-use quality. 

Pre-shipment applications are not within the scope and mandate of the IPPC, as that Convention is 

concerned with regulated quarantine and non-quarantine pests in international trade. Removing preshipment would also remove the inconsistency in the classification of uses as pre-shipment or 

quarantine by the Parties due to differences in interpretation of quarantine and pre-shipment that have 

been defined by the Parties to the Montreal Protocol. 

8.5.6.8.5 Timing and impact of any restriction on the funding of alternatives 

The MLF provides financial assistance to Parties in accordance with Article 10 of the Montreal 

Protocol. Significant financial assistance to Article 5 Parties is not usually provided until the Parties 

agree a control measure for the reduction and phase out of a specific ODS use. Currently, methyl 
May 2010 TEAP Progress Report 145

bromide for QPS is exempted from phaseout under the agreed control measures and therefore and 

therefore there has been little expenditure by the MLF to date on projects in Article 5 Parties on 

alternatives to methyl bromide for QPS. 

Section 8.5.6.1 showed that while some Parties were decreasing and even eliminating their 

consumption of methyl bromide for QPS, some Parties and in particular those in Asia had increased 

their consumption of methyl bromide for QPS significantly in 2007. 

TEAP (2009) reported that consumption for QPS in Article 5 countries exceeded that of Non-Article 5 

Parties for the first time in 2007. This may reflect a combination of the trend towards increased 

treatment at country of origin prior to shipment, increased trade from Article 5 countries at risk of 

infestation by quarantine pests (requiring QPS fumigation), and adoption of alternatives in NonArticle 5 countries. TEAP would put in place methodology to determine the most likely reason for 

this increased consumption. Continuing increase in methyl bromide consumption for QPS may 

increase the cost to the MLF of eliminating methyl bromide used for QPS in Article 5 Parties. 

8.5.7 Discussion and conclusions 

For many Parties, the use of methyl bromide for QPS is synonymous with its use in facilitating market 

access under conditions that reduce the risk of accidentally introducing exotic pests that have the 

ability to cause significant damage agriculture, forests and ecosystems. However, its positive 

attributes have been offset by its ability to deplete ozone and therefore the Parties through Decision 

XX1/10 have requested information on the methodology that could be used to assess the impact of 

restricting the quantities of methyl bromide for QPS uses. 

TEAP has described methodology that could be used to provide information for the consideration of 

the Parties should they wish to restrict the use of methyl bromide for QPS in the future. The 

informational needs are challenging since the routine reporting by the Parties under Article 7 does not 

sufficiently describe the role that methyl bromide has in facilitating trade flows for some 

commodities, and the importance of treatment on arrival that is carried out in some countries that 

allow trade in a wide range of commodities from many more countries than are reflected in the methyl 

bromide consumption data. 

Apart from the statistics on methyl bromide consumption, TEAP has also suggested how insights can 

be gained from Parties that have phased out their use of methyl bromide for QPS, some as long as 15 

years ago. Much can be learnt from their success, as well as understanding where difficulties 

occurred and where trade for some commodities is pending the implementation of an alternative. 

On the basis of the MBTOC’s review in 2009 and in 2010, there appear to be some uses of methyl 

bromide that are not consistent with the definitions of QPS under the Montreal Protocol. Paragraph 

3(4) of Decision XXI/10 requested TEAP to propose methodology that considered the variations in 

the use of methyl bromide for QPS within and between countries. TEAP therefore notes that there are 

such variations in the use of methyl bromide for QPS, particularly in its use as a soil fumigant (see 

Section 8.5.4 above; and TEAP 2009). Soil uses accounted for approximately 15-20% of the reported 

global consumption of methyl bromide for QPS that was categorised by a Party as QPS in 2007. In 

Table 8-5 above, TEAP estimated that about 50% of the soil uses of methyl bromide that had been so 

categorised were replaceable. TEAP urges Parties to require the uses of methyl bromide to be fully 

consistent with the definitions of QPS agreed by the Parties, as consistency with the definitions would 

significantly reduce the amount of methyl bromide used for QPS. Uses that were agreed by the 

Parties to not be consistent with the agreed definitions could then be identified and excluded from any 

proposed methodology that could be used to assess technically and economically feasible alternatives 

to methyl bromide for QPS. 

The design of the restriction also significantly influences that methodology that TEAP could use to 

assess the impact of any restriction that the Parties may wish to place on QPS in the future. For 
146 May 2010 TEAP Progress Report 

example, compared with other ozone-depleting substances that have been phased out, some QPS 

alternatives require significant time to develop them and to negotiate internationally agreeable levels 

of quarantine security and conditions of use. Trade flows can be fickle, depending on market 

opportunities that require many elements to be in place for the trade to be successful, including an 

effective disinfestation treatment where this became necessary. 

This chapter has therefore highlighted in the methodology description a range of activities that would 

be important for data accumulation, analysis and reporting. TEAP would therefore be pleased to 

receive any comments from the Parties that may wish to contribute to the further development of this 

methodology. 

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8.7 Annexes to chapter 8 

8.7.1 Annex 1: Decision XXI/10 Quarantine and pre-shipment uses of methyl 

bromide 

Recognizing that methyl bromide use for quarantine and pre-shipment purposes is identified 

in the 2006 assessment report of the Scientific Assessment Panel as a remaining uncontrolled 

use of ozone-depleting substances of which the emissions may delay recovery of the ozone 

layer; 

Mindful of the Scientific Assessment report scenarios which calculated that the integrated 

total chlorine and bromine in the atmosphere from 2007 to 2050 (equivalent effective 

stratospheric chlorine, EESC) would be reduced by 3. 2% if all quarantine and pre-shipment 

emissions were eliminated by 2015; 

Mindful that the use of methyl bromide for quarantine and pre-shipment purposes is still 

increasing in some regions, 

Acknowledging the efforts made by Parties to phase-out or reduce the use and emissions of 

methyl bromide for quarantine and pre-shipment purposes, 

Noting that 22 non-Article 5 Parties and 54 Article 5 Parties have reported data on current 

quarantine and pre-shipment consumption, that 31 other Parties which used quarantine and 

pre-shipment in the past have reduced their quarantine and pre-shipment consumption to zero, 

and that 14 additional Parties will cease next year and that a further 27 Parties are scheduled 

to cease consumption by 1 January 2010; 

Noting that the Technology and Economic Assessment Panel’s Task Force1 concluded that 

there are technically feasible alternatives which may replace a large proportion of the 

quarantine and pre-shipment uses of methyl bromide, especially in sawn timber, wood 

packaging material (ISPM-15), grains and similar foodstuffs, pre-plant soils use and logs; 

Aware that, particularly for compliance with ISPM-15, there are more than 6,000 certified 

heat treatment facilities deployed in many countries, and that not-in-kind alternatives (such as 

plastic pallets or cardboard pallets) are available worldwide, including in many Article 5 

countries, and do not require any treatment under ISPM-15; also noting that the ISPM-15 

standard encourages national plant protection organisations (NPPOs) to promote the use of 

alternative treatments approved in that standard; 

Further noting that under the International Plant Protection Convention alternative treatments 

are currently under review; 

Noting the importance of monitoring quarantine and pre-shipment uses of methyl bromide 

and their reporting under Article 7 in order to assess the contribution of quarantine and preshipment uses to methyl bromide emissions into the atmosphere; 

Aware that several Parties have succeeded in reducing quarantine and pre-shipment 

consumption by adopting policy measures such as promoting the adoption of alternatives, 

reviewing regulatory requirements, allowing alternative options, adopting ‘polluter pays’ 

taxes on methyl bromide imports, and/or limiting quarantine and pre-shipment consumption; 

Noting that methyl bromide use and emissions can also be reduced by technical improvements 

in fumigation practices, such as using gas-tight structures, determining minimum effective 

methyl bromide doses, monitoring during fumigation to minimise re-dosing, using recovery 
May 2010 TEAP Progress Report 155

equipment, and treating wood packing materials prior to loading containers rather than 

treating entire loaded containers; 

1. To remind Parties of their obligations to report annual data on the consumption of 

methyl bromide for quarantine and pre-shipment under Article 7 and to establish and 

implement a system for licensing trade in methyl bromide, including quarantine and 

pre-shipment, under Article 4B; 

2. To invite Parties to collect data on quarantine and pre-shipment according to Decision 

XI/13, and to consider using the format provided in the Technology and Economic 

Assessment Panel’s report of April 1999; 

3. To request the Technology and Economic Assessment Panel and its Methyl Bromide 

Technical Options Committee, in consultation with other relevant experts and the 

IPPC Secretariat to provide a report to be considered by the 30th meeting of the 

Open-ended Working Group covering the following: 

(1) A review of available information on the technical and economical 

feasibility of alternatives, and the estimated availability, for the following 

categories of quarantine and pre-shipment uses: 

• Sawn timber and wood packaging material (ISPM-15); 

• Grains and similar foodstuffs; 

• Pre-plant soils use; 

• Logs; 

 (2) The current availability and market penetration rate of quarantine and 

pre-shipment alternatives to the uses listed in paragraph 3(1) above, and their 

relation with regulatory requirements and other drivers for the implementation of 

alternatives; 

(3) An update of Table 9.1 of the 2009 Task Force report to include 

economic aspects, and to take account of the information compiled under this 

paragraph, distinguishing between Article 5 and non Article 5 parties and between 

quarantine and pre-shipment uses separately; 

(4) A description of a draft methodology, including assumptions, 

limitations, objective parameters, the variations within and between countries and 

how to take account of them, that the Technology and Economic Assessment 

Panel would use, if requested by the Parties, for the assessment of the technical 

and economical feasibility of alternatives, of the impact of their implementation 

and of the impacts of restricting the quantities of methyl bromide production and 

consumption for quarantine and pre-shipment uses; 

4. To encourage Parties to apply best-practice measures to reduce methyl bromide 

quarantine and pre-shipment use and emissions, that may include the review of 

required use dosages, gas tightness controls, monitoring during fumigation and other 

measures to minimize methyl bromide dosages, and, in applications where 

alternatives are not yet available, the recovery and possible reuse of methyl bromide, 

and to review the methyl bromide quarantine and pre-shipment requirements for 

possibilities of introducing alternative mitigation measures whenever possible; 
156 May 2010 TEAP Progress Report 

5. To encourage Parties to consider adopting, where possible within their national 

policy framework, incentives to promote the transition to alternatives such as 

deposit/rebate schemes or other financial measures; 

6. To encourage Parties or regions to use the October 2009 Technology and Economic 

Assessment Panel quarantine and pre-shipment task force report to develop 

documents that summarise information on technical options to reduce emissions, and 

on adopted technologies that have replaced methyl bromide quarantine and preshipment applications, the reductions achieved, the investments needed, the operating 

costs, and the funding strategies; 

7. To encourage Parties to implement the recommendations of the third meeting of the 

Commission of the Phytosanitary Measures under the IPPC, also referred to in 

Decision XX/6. 

8.7.2 Annex 2: Definitions of Quarantine and Pre-shipment 

Decision VI/11: Clarification of “quarantine” and “pre-shipment” applications for 

control of methyl bromide

The Sixth Meeting of the Parties decided in Dec. VI/11: 

1. Recognizing the need for non-Article 5 Parties to have, before 1 January 1995, 

common definitions of “quarantine” and “pre-shipment” applications for methyl bromide, for 

purposes of implementing Article 2H of the Montreal Protocol, and that non-Article 5 Parties 

have agreed on the following: 

(a) Quarantine applications, with respect to methyl bromide, are applications to 

prevent the introduction, establishment and/or spread of quarantine pests (including 

diseases), or to ensure their official control, where: 

(i) Official control is that performed by, or authorized by a national plant, 

animal or environmental protection, or health authority; 

(ii) Quarantine pests are pests of potential importance to the areas endangered 

thereby and not yet present there, or present but not widely distributed and being 

officially controlled. 

Decision XI/12: Definition of pre-shipment applications of methyl bromide 

The Eleventh Meeting of the Parties decided in Dec. XI/12 that pre-shipment applications are 

those non quarantine applications applied within 21 days prior to export to meet the official 

requirements of the importing country or existing official requirements of the exporting 

country. Official requirements are those which are performed by, or authorized by, a national 

plant, animal, environmental, health or stored product authority. 

 
May 2010 TEAP Progress Report 157

9 Methyl Bromide Technical Options Committee (MBTOC) 

Progress Report 

This chapter updates trends in methyl bromide (MB) production and consumption for 

controlled and exempted uses, and gives progress in the development and adoption of 

alternatives for preplant soil use, and post harvest and commodity uses of MB. Information on 

registration, re-registration and deregistration of in-kind methyl bromide alternatives is also 

presented in conformity with Decisions Ex. I/4(i) and Ex. I/4(j). 

9.1 MB Production and Consumption Update 

An update on MB production and consumption for controlled uses was compiled primarily 

from the database on ODS consumption and production of the Ozone Secretariat available in 

April 2010. Under the Protocol, consumption at the national level is defined as ‘MB 

production plus MB imports minus exports, minus QPS, minus feedstock’; it thus represents 

the national supply of MB for uses controlled by the Protocol (i.e. non-QPS). Some countries 

have revised or corrected their historical consumption data, and as a consequence official 

figures and baselines have changed. At the time of writing this report, three Article 5Parties 

had not submitted data for 2008. The database for MB is however much more complete than 

in the past. 

9.1.1 Controlled uses 

9.1.1.1 Production of MB for controlled uses 

Trends in the reported production of MB for all controlled uses (excluding QPS and 

feedstock) in all non Article 5and Article 5countries are shown in Figure 9-1 and have been 

falling consistently from 1998 to 2004. In 2005, the total was 18,141 metric tonnes, which 

represented 27% of the production baseline (67,376 tonnes). In 2006, the global MB 

production for controlled uses increased to 19,635 tonnes (29% of baseline), although the 

consumption in both Article 5and non-Article 5countries decreased from the preceding year 

(details can be found in section 9.1.2). Production in 2008 continued the downward trend, 

totalling 10,784 tonnes or 17% of the baseline. 
158 May 2010 TEAP Progress Report 

Figure 9-1: Historical trends in reported global MB production for all controlled uses, 

excluding QPS and feedstock, 1991 - 2008 (metric tonnes) 

‐

10,000

20,000

30,000

40,000

50,000

60,000

70,000

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

MB production (metric tonnes)

Article 2

Article 5

Source: Data for 1991 and 1995-2008 were taken from the Ozone Secretariat dataset of April 2010. 

Data for 1992-94 were estimated from Table 3.1 of MBTOC’s Assessment Report (2002) and Table 

3.1 of MBTOC’s Assessment Report (2007). 

Non-Article 5countries reduced their MB production for controlled uses from about 66,000 

tonnes in 1991 (non-Article 5baseline) to less than 17,603 in 2005. Non-Article 5production 

for controlled uses increased to 18,666 tonnes in 2006 due to increased production in Israel. It 

decreased again in 2007 to approximately 12,191 tonnes, and to 10,146 in 2008, which 

included production for export to Article 5countries. 

Article 5countries reduced their production for controlled uses from a peak of 2,397 tonnes in 

2000 to about 536 tonnes in 2004. It increased to 969 tonnes in 2006. MB production in 

Article 5regions fell from 70% of baseline (1,375 tonnes) in 2003 to 39% of baseline in 2004. 

For 2008 the production amount is 638 tonnes, which represents 49% of the baseline. At 

present, production of MB for controlled uses in Article 5countries takes place entirely in 

China and a MLF project to phase-out this activity is approved and underway. 

9.1.1.2 Global consumption for controlled uses 

On the basis of Ozone Secretariat data, global consumption of MB for controlled uses was 

estimated to be about 64,420 tonnes in 1991 and remained above 60,000 tonnes until 1998. 

Global consumption was reported as 45,527 tonnes in 2000, falling to 26,336 tonnes in 2003 

and 9,902 tonnes in 2008 as illustrated by Fig 9-2 below. 
May 2010 TEAP Progress Report 159

Figure 9-2: Baselines and trends in MB consumption in Non-Article 5and Article 5 

regions, 1991 – 2008 (metric tonnes) 

0

10,000

20,000

30,000

40,000

50,000

60,000

199119921993199419951996199719981999200020012002200320042005200620072008

Year

Baseline non-A5

Baseline A 5

MB consumption non-A5

MB consumption A5

Source: MBTOC estimates calculated from Ozone Secretariat data of April 2010.

9.1.1.3 Consumption trends in Non-Article 5 countries 

Figure 9-2 shows the trends in MB consumption in Non-Article 5 countries for the period 

between 1991 and 2008. The official baseline for Non-Article 5 countries was 56,050 tonnes 

in 1991 and since the consumption has declined steadily. By 2003, this consumption had 

been reduced to about 14,520 tonnes, representing 26% of the baseline. In 2008 the estimated 

consumption based on quantities approved or licensed amounted to 6,996 tonnes tonnes or 

about 12% of the baseline (however, reported use to the Ozone Secretariat was only 4,507). 

For 2009 about 5,870 tonnes were approved or licensed which is a further reduction to 10% of 

the baseline (figure not shown in graph as information for Article 5 Parties is not at this date 

fully available). 

Trends in MB consumption in major Non-Article 5 regions can be summarised as follows: 

• In 1991 the USA, European Community, Israel and Japan used 95% of the MB 

consumed in Non-Article 5 countries. 

• For 2009, permitted levels amounted to 17%, 0%, 17% and 5%, in the same order, 

whilst for 2010 these figures came down to 11%, 0%, 8% and 4% respectively. 

• In the past, MB was consumed for controlled uses by 40 out of 45 Non-Article 5 

countries. The majority of these countries no longer use MB. 

• Of the eleven Parties applying for MB for CUEs in 2007 only five have sought CUEs 

in 2010. Israel has announced that it will not seek further exemptions as of 2012 and 

Japan, in accordance with its phase-out plan, will stop CUN requests for soil uses by 

2013. A phase out plan for postharvest uses is expected from the Party. 

9.1.1.4 Consumption trends in Article 5 and CEIT countries 

Figure 9-2 shows the trend in MB consumption in Article 5 countries in the period between 

1991 and 2008. Trends can be illustrated as follows: 
160 May 2010 TEAP Progress Report 

• The Article 5 baseline was 15,703 tonnes (average of 1995-98), rising to a peak 

consumption of more than 18,125 tonnes in 1998. Article 5consumption was reduced 

to 67% of baseline in 2004 (10,512 tonnes) and 34% in 2008 (5,395 tonnes). 

• Most Article 5 Parties have continued to make substantial progress in achieving 

reductions in MB consumption at a national level. 

Trends at national level can be described as follows: 

• At the time of preparing this report, three Article 5Parties had not reported MB 

consumption for 2008: Ethiopia, Nauru and Timor-Leste. One Party, El Salvador, 

reported export of MB, which was imported previously into the country (i.e. negative 

consumption) 

• In 2008, 87% of Article 5Parties (128 Parties) reported national consumption of less 

than 50% of the national baseline. Only fifteen Article 5Parties consumed more than 

50% of their national baseline. 

• 75% of Article 5Parties (110 Parties) reported zero MB consumption in 2008. This 

shows continued progress since 2002 when 50% of Article 5Parties reported zero MB 

consumption. 

• According to latest reported consumption data (for 2008) only one Article 5 country 

(Iraq) was in non-compliance with the 20% reduction step of 2005. 

• 87% of Article 5 parties (128 parties) reduced their national MB consumption to less 

than 50% of national baseline in 2008 

At regional level, the decrease in consumption has been greatest in Countries with Economy 

in Transition (CEIT) (now reporting zero consumption), followed by Asia and Africa, while 

Latin America is the region with smaller relative reductions, and is the only region that 

consumes more MB now than in 1991 (Fig. 9-3). Some agricultural sectors in Latin America 

are still reporting significant use of MB, including melons in Central America, strawberries in 

Chile and Argentina, and cut flowers in Ecuador, but progress in reduction has been made in 

these countries in 2008 as compared to 2007. 

The status of MB phase-out in Article 5 regions in 2008, compared to the regional baselines 

(1995-98 average) is as follows: 

• Latin America has phased-out 51% of its regional baseline 

• Africa has phased-out 75% of its regional baseline 

• Asia has phased-out 72% of its regional baseline 

• CEIT region has phased-out 100% of its regional baseline 
May 2010 TEAP Progress Report 161

Fig. 9-3: MB Consumption trends (metric tonnes) in Article 5 and CEIT countries 1991 – 

2008 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

1991

1995

199619971998199920002001

2002

20032004200520062007

2008

Year

Latin America and Caribbean

Africa

Asia, Middle East

CEIT

Source: Ozone Secretariat database, 2010 

Substantial progress has been achieved in Article 5countries that consumed the greatest 

quantities of MB. Only 12 Parties still report consumption between 100 and 500 tonnes and 

only two countries remain in the usage category above 500 tonnes. The top 15 MB consuming 

countries together accounted for 80% of the Article 5baseline in the past, and about 86% of 

total Article 5consumption in 2000/1. The top 15 countries reduced MB consumption by 68% 

from 2001 to 2008 (from 14,932 tonnes in 2001 to 4,830 tonnes in 2007). An increase is noted 

in South Africa, increased consumption from 100 tonnes in 2007 to 376.5 in 2008. 

• In the last 4 years alone, the top 15 countries have reduced MB by 49% (from 9,399 

tonnes in 2004 to 4,830 tonnes in 2007). 

• In 2008, MB consumption in the top 15 countries was only 38% of the baseline on 

average 

• By 2008 these large consumers have phased out 76% of their historical peak use of 

MB. 

Many Article 5 countries are finishing or have finished implementing MLF projects to reduce 

or totally phase-out MB. This includes 14 of the 15 largest MB consuming countries (i.e. 

countries that consumed more than 470 metric tonnes, which together accounted for 80% of 

the Article 5baseline consumption). The exception is South Africa, which is currently 

preparing a Global Environment Fund (GEF) project for MB phase-out. Two Parties in this 

group, Brazil and Turkey, which reported consumption larger than 500 tonnes in the past, 

phased out completely and reported zero consumption in 2007. In 2008, Lebanon has joined 

this group. 

9.1.2 Exempted uses 

9.1.2.1 Production for QPS purposes (exempted uses) 

Decision XX/6 required the Ozone Secretariat to post on its website, MB production and 

consumption data reported by the Parties for exempted uses (QPS) under paragraph 3 of A 7. 

The following analysis is based on such data, as well as estimates made by MBTOC in past 

reports (TEAP, 2006; MBTOC, 2002; 2007). 

Reported MB production for exempt QPS uses, as reported to the Ozone Secretariat by 

Parties, rose substantially in 2005 over the long term and decreasing trend. Data reported for 
162 May 2010 TEAP Progress Report 

2006 shows a return to the expected trend, however, 2007 again reflects an increase, followed 

by a significant decrease in 2008 (Fig. 9-4). There has been speculation as to the reasons for 

the sudden increase shown in 2005. These include stock issues, impact of adoption of ISPM 

15 on demand and inclusion of uses previously not considered as QPS. 

Figure 9-4: Reported or estimated QPS production 1990 - 2008 

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

1996 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Year

metric tonnes

Source: MBTOC, 1994, 1998; MBTOC estimates; Ozone Secretariat data, April 2010 

9.1.2.2 Consumption for QPS purposes (exempted uses) 

Figure 9-5 below shows the reported QPS consumption in Article 5Parties and non-Article 

5Parties from 1999 to 2008. When consumption is considered in the light of regional 

groupings of Article 5and non-Article 5countries, the following trends are evident: 

• In 2007 reported consumption for QPS in Article 5countries exceeded that in nonArticle 5for the first time. This trend continued in 2008 

• Total consumption of MB for QPS uses peaked in non-Article 5 Parties in 2000 with 

a reported consumption of 9,646 metric tonnes. In 2006 consumption was reported at 

7,536 tonnes, reducing to 4,949 tonnes in 2007 and 3,136 in 2008. 

• In contrast, reported consumption for QPS uses in Article 5 countries has grown in an 

approximately linear fashion since 2000, from 3,990 tonnes to 5,803 tonnes in 2007 

and 5,906 in 2008. 

• It may be speculated that the reasons for the increases in QPS consumption in Article 

5countries with corresponding decrease in non-Article 5countries results from a 

combination of the trend towards increased treatment at country of origin prior to 

shipment, much increased trade from Article 5countries that are at risk of infestation 

by quarantine pests and requiring QPS fumigation, and concurrent adoption of nonmethyl bromide alternatives in non-Article 5countries (TEAP, 2009) 

Evolution of reported consumption for Article 5and non-Article 5Parties is illustrated in Fig 

9-5 below. 
May 2010 TEAP Progress Report 163

Fig 9-5: MB consumption for QPS uses in Article 5 and non- Article 5Parties 2000 - 2008

0.00

2,000.00

4,000.00

6,000.00

8,000.00

10,000.00

12,000.00

2000 2001 2002 2003 2004 2005 2006 2007 2008

Year

MB (metric tonnes)

A 5 Parties

Non-A 5 Parties

Source: Ozone Secretariat Database, April 2010 

9.2 Alternatives for Soil Treatments 

9.2.1 Key alternatives

Major chemical alternatives (1,3-D/Pic, chloropicrin, metham sodium and metham 

potassium), used alone and/or in combination with other alternatives continue to prove as 

effective as MB and are now widely adopted in many preplant soil applications (TEAP, 

2009a). The recent registration of methyl iodide in the US (in all states except California, 

New York and Washington) of methyl iodide and the adoption of a 3 way fumigant system 

(1,3-D/Pic/metham sodium) (Culpepper et al., 2008) have offered further options for many of 

the remaining uses proving difficult to control with other alternatives. Nevertheless concerns 

on the toxicity of methyl iodide on ornamentals and vegetables still need further clarification 

(Rosskopf et al., 2009; Spadafora, 2009). Dimethyl disulfide (DMDS), a new fumigant (Ajwa 

et al., 2010) is also being tested in various countries and was found to be effective against a 

wide range of galling and non- galling nematodes. It is less effective against fungi and weeds 

(Owens et al., 2009). 

Several Parties previously applying for CUNs particularly for strawberry fruit, tomatoes and 

vegetable crops, have adopted these alternatives on a wide scale. This includes control of 

soilborne pathogens in the more difficult nursery and replant industries where high levels of 

disease control are required to meet quality standards (e.g. certification requirements). 

Formulation changes and more adequate application methods continue to improve the 

effectiveness of several alternatives (Pic EC, 1,3-D/Pic EC) and wider adoption has occurred 

where these are available. In many instances, this has involved a change in cropping practices, 

i.e. slightly longer plant back times and a greater awareness of soil conditions which improve 

the efficiency of alternatives; modifications to application machinery, sometimes with 

economic implications have sometimes been also necessary. 
164 May 2010 TEAP Progress Report 

Some sectors that were formerly heavily reliant on methyl bromide have completely switched 

to other chemical alternatives and improved crop rotation practices; others have adopted more 

diverse types of alternatives including substrates, steam, various combinations of fumigants, 

pesticides (i.e. strobilurines), resistant varieties and grafting onto resistant/tolerant rootstocks 

adopted alone or in combinations with fumigant and not fumigant nematicides (Porter et al,

2007; Louws, 2009; Kokalis-Burelle 2008). 

Methods which avoid the need for methyl bromide, such as cropping in substrates, grafting 

plants onto resistant/tolerant rootstocks (Louws, 2009) and using resistant varieties, continue 

to expand in the ornamental and vegetable industries (TEAP, 2009a). 

One key transitional strategy to reduce MB usage has been the adoption of MB:Pic 

formulations with lower concentrations of methyl bromide (e.g. MB:Pic 50:50 or less). Their 

use can be achieved with application machinery that allows co-injection of methyl bromide 

and chloropicrin or by using premixed formulations. These formulations have proven equally 

effective for controlling soilborne pathogens as formulations containing higher quantities of 

methyl bromide (e.g. 98:2, 67:33) (Porter et al. 2007). 

Low permeability barrier films, LPBF, (e.g. VIF or equivalent such as TIF) allow increased 

retention of MB and extended effective exposure periods for pests, thus controlling pathogens 

and weeds at reduced MB application rates compared to those used with conventional films 

(Gilreath et al., 2008; Santos et al., 2007, 2008). These films allow for substantial reductions 

in dosage rates of MB compared with the minimum effective rate under standard polyethylene 

film. Reductions are typically between 25 – 50% less for MB/Pic 98:2 formulations as well 

as other formulations (67:33, 50:50 and 30:70). Studies are also proving their use for effective 

dosage reduction of alternatives, such as 1,3-D, Pic and methyl iodide (Ou et al., 2007, TEAP, 

2009a). This is important because dosage reduction may increase areas available to be treated 

with specific fumigants that are limited by township caps and may lead to further reduction in 

MB use and possibly reduce the buffer zone requirements which limit adoption of alternatives 

in some countries (Ou et al., 2007; Chow, 2009; Ajwa, 2009; Fennimore, 2009; Freeman, 

2009; Villahoz, 2009). 

Adoption of barrier films has increased substantially for uses in several countries still 

applying for critical us exemptions to methyl bromide, including Japan, Israel and the south 

eastern states of the USA. At present, California prohibits the use of barrier films (VIF) with 

methyl bromide, over concerns of possible worker exposure to MB when seedlings are 

planted or the film is removed (California Code of Regulations Title 3 Section 6450(e)), 

however barrier films can be used to improve efficacy of alternative fumigants. 

An important issue, which should be carefully considered, is the induced accelerated 

degradation of fumigants as a result of their repeated application. It was shown under field 

conditions that MITC is rapidly dissipated following repeated application of metham sodium 

leading to insufficient control of soilborne diseases (Triky Dotan et al., 2009). Similar results 

were shown for 1,3D in Israel (Alon et al., 2009). With the limited available fumigants, 

accelerated degradation is an issue of major concern: an integrated approach would limit 

negative effects, but clearly, the combination of several components (chemical and non 

chemical) is needed as a strategy for soil disinfestation. 

9.2.2 Update on registration of chemical alternatives: 

9.2.2.1 United States 

Methyl iodide (MI) now holds a permanent registration in the US in all states except 

California, New York and Washington. A registration decision for use of MI in California (a 
May 2010 TEAP Progress Report 165

major methyl bromide using state) is expected in 2010. Methyl iodide is registered for use on 

strawberries, peppers, tomatoes, field grown ornamentals, stone fruits, tree nuts, vines (table, 

raisin and wine grapes) and nurseries (forest, strawberry, stone fruit and tree nuts). 

A registration decision on DMDS is also expected in 2010 for use on tomatoes, peppers, 

eggplants, cucumbers, squash, melons, onions, field grown ornamentals and forestry nursery 

crops. A decision on furfural for use on golf courses and sod farms should also come by 

later in the year. 

Due to the global economic slowdown and the concomitant reduction in market demand for 

epoxy resins from which 1,3-D is produced, the supply of 1,3-D, which is a key methyl 

bromide alternative, was significantly reduced in the USA for part of 2009. However, Dow 

Agro Science conducted efforts to secure a substantial increase in the supply of 1,3-D for the 

USA beginning in late 2009 and continuing in 2010. The projected supply of 1,3-D for 2010 

is thus comparable to levels provided in 2006, 2007 and 2008. 

9.2.2.2 Japan 

1,3-D is registered for the control of MNSV of melon, however it can cause phyototoxicity, 

and its efficacy can be variable. 

A mixture of azoxystrobin and metalaxyl M is now under registration review for the control 

of root rot disease of ginger. Table 9-5 below lists alternatives already registered and in the 

process of evaluation or registration in Japan. 

Table 9-5: Registration status of chemical alternatives to MB in Japan 

Use category Alternatives 

available 

Status of 

registration 

Alternatives 

under 

development 

Possible date 

of 

registration 

Chestnut 

(Commodity) 

Methyl iodide Registered 

Cucumber 

(Soil) 

None Attenuated 

virus 

Unknown 

Chloropicrin Registered Methyl iodide Unknown 

Dazomet Registered Amisulbrom Unknown 

Metham sodium Registered Mixture of 

azoxystrobin + 

metalaxyl-M 

Unknown 

1,3-D/ Pic Registered 

Mixture of 1,3-D + 

MITC 

Registered 

Metalaxyl Registered 

Propamocarb Registered 

Ginger (field 

& protected, 

soil) 

Cyazofamid Registered 

 

Green & hot 

pepper (Soil) 

None Attenuated 

virus 

Unknown 

Mixture of 1,3-D/ 

Pic 

Melon (Soil) Registered 

Methyl iodide Registered 

 

Watermelon 

soil 

None Attenuated 

virus 

Unknown 
166 May 2010 TEAP Progress Report 

9.2.2.3 Australia 

The main alternatives registered in Australia for the remaining MB use - the strawberry 

nursery industry - appear in Table 9-6 below 

Table 9-6: Registration status of chemical alternatives to MB in Australia 

Use category Alternatives 

available 

Status of 

registration 

Alternatives 

under 

development 

Possible 

registration date 

Chloropicrin Registered Methyl iodide 2011 

1,3- D Registered EDN unknown 

Metham Sodium Registered 

Strawberry 

Nurseries 

Dazomet Registered 

 

Methyl iodide and ethanedinitrile both have pending registration applications with the 

APVMA (Australian Pesticides and Veterinary Medicines Authority) for use on strawberry 

runners. The registrant for methyl iodide is completing a flux study requested by APVMA in 

order to evaluate bystander exposure. This study will be submitted this year, and a 

registration decision is anticipated in 2011. The registration status of ethanedinitrile is 

unknown at this time. 

In addition, since the only currently registered application rate of MB (25g/m2) exceeds 

MBTOC’s standard of 20g/m2, the Party undertook a 2 year study in 2008 using reduced rates 

(MB:PIC (50:50) @ 375 kg/ha); however, the second year’s results indicated that the lower 

rate did not adequately control root and crown rot on certain varieties of runners. Another 2-

year study has been initiated, but the Party estimates that it will be 2013 before lower MB 

rates could be used. 

9.2.2.4 Canada 

Pic-100 has been registered by PMRA (Pest Management Regulatory Agency) for use by the 

remaining MB user, a strawberry nursery grower, but has not received clearance by the Prince 

Edward Island authorities due to groundwater contamination concerns. 

9.2.2.5 Israel 

In general, there is no change in the status of registration for fumigants since the last progress 

report. Details are presented in Table 9-7 below. Current status of the main alternatives is as 

follows: 

Metham sodium is registered for potato, eggplant, tomato, cucurbits, lettuce, brassicae, 

peanuts, flowers, avocado, replant of various perennials and potting media. However, 

MBTOC has not been informed of any efforts conducted at present to extend this registration 

to other crops. 

Choropicrin is not registered, however initial registration procedures are under way for 

cucurbits (Pic in pure form and combined with DMDS). 

DMDS has been granted a temporary permit for tomato, melon and cucumber against 

nematodes. An extended registration package is expected to be submitted by the end of 2010 

including additional crops. 

1,3- D is registered for cucurbits, carrots, tomato, potato, sweet potato, annual and perennial 

flowers (including gerberas), herbs and strawberries. 
May 2010 TEAP Progress Report 167

1,3-D/Pic has restricted availability in Israel. It is registered for potato, tomato eggplant, 

pepper, strawberry and some cucurbits (watermelon and melon). 

Dazomet is only registered for melon, watermelon and tomato. 

Methyl iodide is currently under registration experiments; however, a registration package is 

not expected to be submitted before 2011. 

9.2.2.6 Europe 

As of 18 March 2010, methyl bromide is no longer registered or authorized in the EC for any 

use, including QPS. Authorisations for use of 1,3-D have expired as of 20 March 2009, but an 

application for reconsideration of 1,3-D registration is under review. Authorisations for use of 

(1) metham sodium / potassium, (2) chloropicrin and (3) dazomet will expire on (1) 13 

January 2011 and (2+3) 31 December 2011 respectively. Applications for reconsideration of 

all three have been submitted. 

9.2.3 Alternatives to methyl bromide for crops where a CUN is sought 

This section provides an overview of the main alternatives to MB adopted for those crops 

presently applying for critical use exemption of MB (CUNs). 

9.2.3.1 Vegetables 

(a) Tomatoes 

Effective alternatives adopted in the tomato sector include chemicals such as 1,3-D/Pic, 

metham sodium and metham potassium, dazomet and methyl iodide. Non-chemical options 

such as substrates, soilless cultivation, grafting, resistant varieties, biofumigation, solarisation 

and steam are also in use (Besri, 2007a, 2007b, Fennimore et al, 2008). These alternatives are 

applied alone or in combination, and are intended mostly to limit the damages of root knot 

nematodes (Besri 2007a, 2007b, Runia, 2006, Culpepper et al., 2008). 

MB use for tomatoes has been entirely phased out from all European countries, as well as 

Australia and Israel (except for the control of broomrape in Israel, Orobanche spp). 

Grafting continues to be adopted as an effective alternative in many countries and is now in 

wide use in Europe, Northern Africa, Central America, and North America. In the USA, this 

technique is still largely limited to greenhouse production and small organic producers, but 

new research is underway to help establish this technology on a wider scale (Louws, 2008; 

Kubota, 2008; Rivard et al., 2009; Bausher, 2009; Freeman, 2009). The introduction of this 

technology to open fields has potential efficacy particularly in melon sector, as part of IPM 

programmes aimed at reducing the use of soil fumigants in vegetable production, although 

with some limitations (Besri 2008; Kokalis-Burelle, 2008; Davis et al., 2008; Lin et al., 

2008; Rivard et al., 2008). Kokalis-Burelle et a.,l (2008) evaluated the combination of 

grafting + fumigants (MB, MI/ Pic, DMDS/ Pic) under metalized barrier films. Recently, a 

grafting robot fitted with an automatic seedling feeder system has been developed. It reduces 

labour and increases the efficiency and accuracy of the grafting technique. Commercial 

availability of this device is expected soon (Kobayashi 2008). The robot has been introduced 

in the US for the production of grafted vegetables (Kokalis-Burelle, 2008). 

In Florida, Telone C-35 was reported to be as effective as MB for controlling root-knot 

nematodes in tomatoes (Dickson, 2007). Nutsedge control has been efficiently achieved in the 

USA with the herbicide halosulfuron. Acrolein combined with other chemicals such as Eptam 
168 May 2010 TEAP Progress Report 

(EPTC), halosulforon or dazomet enhanced control of nutsedge and other weed species 

without adversely affecting yield. Yields were comparable or higher than those obtained with 

MB (Belcher et al., 2007). 

Methyl iodide at various dosages applied under metalized mulch controlled nutsedge to the 

same level as as MB, with highest obtained at 252 kg/ha. Metalized mulch also reduced 

incidence of bacterial wilt (Ralstonia solanacearum) to a greater extent than VIF (Olson and 

Kreger, 2007; Bernal, 2007; Thomas et al., 2009). 

Welker et al (2008) reported that fumigation with DMDS /Pic 80:20 kills inoculum to a depth 

sufficient to produce an economical harvest. 

(b) Eggplant 

Adoption of grafting also continues to expand in the eggplant sector as new and more suitable 

rootstocks become available. In this regard Solanum torvum and other Solanum species seem 

to be particularly efficient to limit the effects of root knot nematodes. In Turkey, yields of 

grafted eggplants were shown to increase by 25-30% in comparison to non-grafted plants. 

Fruit quality was much improved and although planting density remains largely unchanged, 

growers find it possible to leave grafted plants in production for several years, particularly 

when grown on previously solarised soil treated with alternative fumigants (Yilmaz et al., 

2009). 

(c) Peppers 

Different chemical alternatives have proved efficient for the control of soilborne pathogens 

and weeds. For example, methyl iodide/ Pic 50:50 with VIF, DMDS/ Pic and a combination 

of Telone II /Pic and dazomet under LDPE and barrier films were tested in Georgia (USA) on 

bell pepper with excellent results (Culpepper et al., 2007, 2008). 

In Spain, biofumigation has proven successful for peppers grown in the Murcia and CastillaLa Mancha regions (Bello et al., 2008). Biofumigants most commonly applied include goat, 

sheep and cow manure, organic matter from rice, mushroom, olives, brassicas, and garden 

residues. The effect of pepper residues on Meloidogyne incognita populations was also 

evaluated (Piedra-Buena et al., 2007). 

Solarisation in combination with chemical and non-chemicals alternatives has been 

extensively studied for pepper production in different countries (Morra et al., 2007; Santos et 

al., 2008; Sogut and Elekcioglu, 2007; Yucel et al., 2007; Saha et al., 2007). The efficacy of 

soil solarisation in combination with Trichoderma spp., dazomet and fresh chicken manure 

for the control of root knot nematodes was studied by Sogut and Elekcioglu (2007) in Turkey. 

All alternatives significantly reduced nematode incidence and damage. In the USA, Morra et 

al., (2007) found that cultivation of grafted peppers in solarised soil was a promising technical 

solution to substitute chemical treatments of soil disinfection. The impact of solarisation in 

combination with soil fumigants (MB/ Pic, 1,3-D/ Pic, metham sodium) on hot pepper 

production in high-tunnels was studied in Costa Rica (Santos et al., 2008), where nematode 

damage was significantly reduced and yields improved. 

(d) Cucurbits 

Production of grafted cucurbits continues to expand in Mediterranean countries as well as in 

Central America. When combined with other treatments, grafted plants can be grown 

successfully without MB (Beltrán et al, 2008). Rootstocks resistant or tolerant to soilborne 

pests and pathogens such as Fusarium oxysporum are available for melon, watermelon and 
May 2010 TEAP Progress Report 169

cucumber; for Monosporascus cannonballus and Didymella bryoniae for melon; and for 

Phomopsis sclerotiodes for cucumber (Blestos, 2005; Crinó et al., 2007). 

In Israel, grafting is also showing promising results, particularly when this system is carefully 

adapted to the particular growing conditions of each region (Cohen et al., 2007). Grafting is 

commercially adopted for watermelons and is successful for melon cultivars, however some 

incompatibility constraints remain for trellised cultivars. 

In Italy, where melon production is a significant component of the vegetable industry, major 

rootstocks are Cucurbita spp. (‘Shintosa’, ‘RS841’) as well as Cucumis melo (‘Dinero’), 

which are used depending on the season, the growing area and the disease pressure. 

Nevertheless, since 2006 sudden and heavy melon collapses have been observed and 

consistently correlated both to the scion/rootstock combination and the use of exogenous 

auxins basically adopted to increase the yield (Minuto et al., 2009). These results are in 

coincidence with other studies carried out in Israel; the paper further describes growing 

procedures that can encourage the collapse of grafted melons under commercial field 

conditions (Aloni et al., 2008) 

In Morocco, cucurbit grafting enjoys wide adoption at the commercial level. Many rootstocks 

with resistance to most of the soil borne pathogens (except Meloidogyne) are now available. 

Grafting is used as a component of IPM programmes (Besri 2008). 

In the USA, the main focus is still on alternative fumigants, combined with herbicides when 

additional weed control is necessary (Culpepper et al., 2007). Methyl iodide applied under 

metallized tarps has shown to be as efficacious as MB (Hausbeck and Cortright, 2007; Olson 

and Kreger, 2007), but this fumigant is not yet registered for cucurbits. In Florida, 1,3D /Pic 

showed better control of soil borne pathogens of melon than MB/Pic formulations (Olson and 

Kreger, 2007). In Georgia, fumigant combinations using 1,3-D, chloropicrin and methamsodium were as effective as methyl bromide for controlling Meloidogyne incognita, Pythium 

irregulare, Rhizoctonia solani and Cyperus esculentus in squash crops (Desaeger et al., 

2008). 

However, non-chemical alternatives are being increasingly tested in the US. For example, 

physical barriers were tested for weed control: yellow nutsedge emergence in transplanted 

cantaloupe was suppressed by the combined effects of thin-film mulches and competitive size 

differential provided by using cantaloupe transplants (Johnson and Mullinix, 2007). Further, 

Kokalis-Burelle et al., (2008) evaluated the combination of grafting plus fumigants under 

metalized film. Grafted watermelons show potential in the USA for production without MB, 

but commercial growers are reluctant to adopt this technology due to economic concerns. 

Several studies are presently being conducted to address this (Cushman and Huan, 2008; 

Taylor et al., 2008). 

9.2.3.2 Ornamental crops 

Floriculture is a complex industry with many flower types, production cycles and cropping 

systems involved. Alternatives such as fumigants, soilless culture (substrates) steam and 

resistant/ tolerant cultivars have been widely adopted. 

Constraints to adoption of chemical alternatives in the ornamental sector include regulatory 

issues (e.g. township caps, buffer zones) and lack of registration. Insufficient R&D for minor 

ornamental crops is also reported in some countries. However registration of some chemical 

alternatives such as metham sodium, 1,3-D and Pic has been expanded in some countries e.g. 

Israel and Italy and now include additional flower types. 
170 May 2010 TEAP Progress Report 

Alternatives that do not need registration such as steam and substrates are used by many 

growers around the world particularly for flowers grown in protected environments (Borrero 

et al., 2009; Termorshuizen et al., 2006). Steam use is often under discussion because the cost 

of fossil fuels (Fennimore and Goodhue, 2009) but recent research shows that depending on 

the steaming equipment used and other considerations, this option can be economically 

feasible. Trials conducted in California using different steam application with or without 

solarisation (Gilbert et al. 2009) have shown that pest control is equal or better than that 

achieved with methyl bromide/Pic, particularly in the case of weeds. The cost of disinfesting 

soils with different methods presently available have been evaluated by Fennimore and 

Goodhue (2009) with encouraging results. Solarisation has proven to be an efficient 

alternative for some flower types (McSorley et al., 2008; Yilmaz et al., 2009) and is being 

successfully used in combination with fumigants at reduced rates (Gamliel, 2009). Roses, 

carnations, chrysanthemum, and gerberas are the flowers most commonly grown in substrates, 

but other flower types – particularly bulbs of many types - are also produced with this 

cropping system. 

Chemical alternatives include dazomet, metham sodium, metham potassium, 1,3- D, 

chloropicrin, methyl iodide and DMDS applied alone or in specific combinations or 

sequences (Gerik et al., 2009; Rosskopf and Kokalis-Burelle, 2009; Yakabe and MacDonald, 

2010). Application of fumigants with barrier films such as VIF, allows the use of reduced 

rates of chemicals without affecting control levels, including MB (Klose et al., 2007). 

Commercial adoption of methyl iodide is taking place at a very fast rate in US states such as 

Florida where it has recently become registered (US CUN Ornamentals, 2009). 

9.2.3.3 Strawberry fruit 

(a) General 

Formulations of 1,3-D/Pic, Pic alone and metham sodium combined with other fumigants 

have been adopted widely throughout industries applying for CUNs, and have replaced the 

majority of the production area previously treated with MB/Pic mixtures. Of the Parties 

previously applying for CUNs, most have completely implemented these alternatives. 

Australia and France phased out in 2005, the United Kingdom in 2006 and Italy, New 

Zealand and Spain in 2007 (EC 2008). Since 2009, the USA and Israel are the only Parties 

seeking exemptions for this sector. 

Non-chemical alternatives include soilless systems, crop rotation, solarisation, biofumigation 

and use soil mulches. 

(b) California 

The California strawberry fruit industry is the largest remaining critical use for MB 

worldwide, requesting around 750 tonnes of MB for 2012. To further evaluate progress in 

uptake of alternatives, MBTOC continued to monitor historical MB use data in strawberry 

fruit in California. Looking at the MB use areas in California strawberry fruit over time, there 

has been a growth in the state-wide strawberry fruit sector in terms of total production area 

since 2003, whilst during this period there is a reduced reliance on MB. However, this overall 

trend is not representative for the individual strawberry fruit growing districts in California, 

where MB use has increased between 2007 and 2008 to a level of 159 tonnes above the 2008 

CUE. 
May 2010 TEAP Progress Report 171

9.2.3.4 Nurseries and propagation material for strawberries and other crops 

Many types of propagation material (bulbs, cuttings, seedlings, young plants, sweet potato 

slips, and trees) are subject to high health standards. Alternatives to MB need to provide a 

level of pest and pathogen control sufficient to achieve an acceptable yield and quality from a 

clean root system or clean bulbs. This is critical to prevent the spread of economically 

important pests and pathogens from the nursery fields to the fruiting or production fields. 

In some cases, growers have transitioned from the 98:2 formulations of MB that were 

commonly used in the past to 67:33 or 50:50 formulations depending on the pest or pathogen 

to be controlled and the severity of the infestation (Porter et al.,2007). In other cases, only the 

amount of MB is specified in certification requirements, regardless of the formulation 

(CDFA, 2009). The California Dept of Food and Agriculture has recently approved the use of 

methyl iodide, if and when it is registered for use in California (CDFA, 2009) as a certified 

nursery stock soil treatment. Recent research trials indicate some materials (such as methyl 

iodide) and some combinations (such as 1,3-D /Pic) show promise as MB alternatives for 

specific circumstances, although effective rates may be higher than those needed in annual 

crops and use of an effective barrier film is necessary (Schneider et. al, 2008; Schneider et. al, 

2009a; Schneider et. al, 2009b; Walters et. al, 2009). Other materials (such as metham 

sodium and Pic) were not adequate for certified nursery standards (Schneider et al., 2009b). 

An alternate approach to the use of soil treatments is the use of containerized, or soil-less 

substrate, production systems where this approach is economically feasible and is able to 

produce a product, i.e. root system, of acceptable size and quality to the marketplace. 

The requirement for broadacre treatment of nursery soil (to avoid recolonisation from 

adjacent, untreated soil) has hindered adoption of barrier films (LPBF) in some areas (such as 

the US) where gluing of LPBF for broadacre treatment is not commercially available. Recent 

progress on this issue is being made in trials in California (Fennimore and Weber, 2008), 

while trials in Alabama illustrate the logistical problems yet to be solved (Quicke et. al, 2009) 

Cuttings and slips of a wide variety of propagation materials including ornamental plants, 

fruit trees, forest trees and others, which are subjected to certification requirements are also 

produced in substrates in many countries around the world that export such materials 

internationally. 

9.2.3.5 Sweet potatoes 

Nominations were submitted for sweet potatoes used for obtaining high quality disease-free 

transplant material. MB is required to control soilborne fungal, bacterial and nematode pests 

affecting production. Stoddard (2008) tested a number of alternatives to MB for sweet potato 

slips including Pic, PicChlor 60, solarisation, 1,3-D combined with dazomet, plus additional 

treatments (napropamide, dicloran, thiabendazole and flumioxazin). Solarisation and 

untreated control plots required significant hand weeding. 1,3-D and dazomet, and Pic alone 

yielded better and provided greater financial returns than MB although the latter case had 

10% higher weeding costs than MB. 

9.2.3.6 Ginger 

Pythium sp. (Pythium zingiberis) is the major concern for ginger production. In the absence of 

resistant cultivars, disease control is dependent on detecting the pathogen in soil and in 

propagation materials and by planting pathogen-free propagative materials in clean areas. 

Several non chemical control methods have been considered for managing the impact of 

ginger diseases. These include improving drainage of the soil through appropriate ploughing, 

carefully regulating the watering practices and using pathogen-free water sources. Sanitation 
172 May 2010 TEAP Progress Report 

practices should ensure that tools and clothing are free of pathogens before being introduced 

into ginger fields. Infected plants should be immediately removed. Cyazofamid has been 

recently registered for rhizome rot disease of ginger in Japan. Propamocarb is also available. 

These two products are applied as a soil drench around the individual ginger plants. A mixture 

of azoxystrobin and metalaxyl M is under registration review. Methyl iodide is not yet 

registered but seems to offer promising effectiveness, however no data are available as to 

potential phytotoxicity. Phosphorous acid based compounds are also under evaluation as 

potential controls. Finally soilless cultivation has been tested but is still an experimental 

application to ginger cultivation (Hayden et al., 2004). 

Ralstonia solanacearum, Meloidogyne incognita and Pythium sp. are important soil pests in 

China. Pic has been widely used to control bacteria and fungi and showed very good results. 

Phytotoxcity can occur when Pic is applied in the spring and low temperatures are present. 

This problem can be avoided by applying the Pic in the autumn immediately after ginger 

harvest. 

Trials with ginger showed that 1,3-D/Pic capsules applied in the autumn or 1,3-D/Pic, 

DMDS/Pic, MI/Pic, sulfuryl fluoride applied in the spring can control nematodes, bacteria 

and fungi as effective as MB, but these promising alternatives are not presently registered 

(Cao, 2000, pers, comm). 

9.2.3.7 Replant disease 

Replant disease poses a serious economic threat to certain orchards of perennial fruit trees and 

grapevines. The economic implications are exacerbated by the long production life of 

orchards and vineyards. Producers are reluctant to adapt to alternatives unless proven to be 

effective over a reasonable time span. A number of medium to long term scientific studies 

such as the USDA Pacific Area-wide Pest Management Program are now coming to some 

preliminary conclusions resulting in a pronounced shift to alternatives by producers. 

Since 2006, MI has been registered in several key regions of the world and MI/Pic (50:50) has 

been shown to be equally as effective as methyl bromide for controlling replant disease. In 

states where MI has not been registered, the most appropriate chemical alternatives include 

1,3-D used singly or with Pic, or Pic alone(Brown et al., 2009). These can be used 

successfully where the required dosage rates are allowed under prevailing local regulations. 

Amounts of MB requested under the CUE have however been very significantly reduced (US 

Orchard Replant CUN, 2010), which could indicate successful adoption of alternatives. 

9.2.3.8 Weeds 

(a) Broomrape

Broomrapes (Orobanche spp.) are root parasites of higher plants that depend entirely on their 

hosts for nutrients. They parasitise a wide range of economically important hosts, such as 

tomato (greenhouses and open field), sunflower, chickpeas, groundnuts, potato, crucifers, 

carrots, herbs, melon and watermelon, rendering soils useless for crop production. Many 

alternatives to MB have been reported but unfortunately no single method of control provides 

complete protection against this parasite, which makes an integrated approach combining 

various techniques necessary. The main challenge with broomrape control is reducing the 

seed bank in heavily infested soil, which is no longer in production such as processing tomato 

fields in Israel. Abanga et al., (2007) have described a community-based integrated 

management approach for controlling broomrape in seven countries in the Near East and 

North Africa (NENA) where this weed causes serious problems. Nadal et al. (2008) have 
May 2010 TEAP Progress Report 173

demonstrated that glyphosate is a suitable herbicide for the control of O. crenata attacking 

narbon bean in Southern Spain, however, this treatment can be phytotoxic for some high 

value crops such as tomatoes. Recently Muller et al., (2009) reported the potential use of 

Fusarium as a biopesticide against O. ramosa. 

An integrated approach, including the application of herbicides to the soil and foliar 

application of systemic herbicides, has been tested over the last 10 years in many field 

experiments. Control of O. aegyptica in processing tomatoes has been effective, and was 

achieved by applying sulfosulfuron as a soil solution and imazapic on tomato foliage. These 

experiments demonstrated that the efficacy of O. aegyptica control is highly correlated with 

the rate and timing of herbicide application. In order to ensure precise timing of application, a 

decision support system (DSS) termed PICKIT for O. aegyptica control in processing tomato 

was developed. PICKIT is based on risk assessment and the following submodels: (i) growing 

degree days and (ii) herbicide rate optimisation. Both models were validated under field 

conditions using a minirhizotron camera (Hershnehorn et al., 2009, Eizenberg et al., 2009) 

(b) Nutsedge 

Yellow and purple nutsedge (Cyperus spp) are a key target for critcal use of MB that still 

requires effective alternatives in some circumstances. In the past year, trials involving 

combinations of herbicides and combinations of fumigants have shown these to be effective. 

Webster et al., (2008) showed that glyphosate minimized nutsedge tuber production, is 

economical, and poses no herbicide carryover issues to vegetables. Also, in Alabama (US) a 

tomato field study showed that yellow nutsedge was controlled with acrolein combined with 

other herbicides and metham sodium. The successful combinations included acrolein with 

Eptam, halosulfuron or metham sodium. (Belcher, et al., 2007). In Florida, Gilreath and 

Santos (2008) have used combined fumigant programs with either Pic and fosthiazate or 1,3-

D/Pic + metham sodium applied together with herbicides (napropamide+ trifluralin) in preemergence and post-directed trifloxysulfuron, showing improved control of nutsedge. In a 

separate study, Santos (2009) showed that combinations of either napropamide and Smetolachlor or EPTC followed by metham-K provided similar levels of control as MB/Pic. 

In a Florida study, DMDS, under VIF and metalized film, controlled yellow nutsedge as well 

as MB/Pic in a tomato field trial (Olson and Kreger, 2007). Thomas et al., (2009) used 

colored plastic mulches with Telone C35, which controlled weeds and prevented nutsedge 

penetration, by retaining the fumigant and allowing passage of infra-red and red light through 

the film while restricting other photosynthetically active wavelengths. The IR and red lights 

changed the morphology of nutsedge from a hard plastic-penetrating point to a soft leafy 

structure that cannot tear the film. 

In Georgia trials with MB/Pic (67/33), methyl iodide/Pic (50/50) and the 3 way approach 

(consisting of the application of 1,3-/D followed by chloropicrin, and then by metham 

sodium) were evaluated on peppers. Nutsedge was controlled at similar levels with MB/Pic, 

methyl iodide/Pic and the 1,3-D/Pic/metham combinations. DMDS did not perform as well 

as MB/Pic (Culpepper et al., 2007). 

In California, Wang et al., (2009) compared rotations of spring cantaloupe with winter 

broccoli (with a summer fallow period) in fields infested with yellow and purple nutsedge, 

with alternative rotations that included hand hoeing, a crop of wheat and Sudan grass, wheat 

followed by solarisation, and sweet corn with a halosulfuron application followed by Sudan 

grass. Solarisation was the most effective treatment for purple nutsedge but economic returns 

were negative. All methods controlled yellow nutsedge effectively especially when a summer 

fallow period was observed, but economic returns varied significantly. Currently, selective 
174 May 2010 TEAP Progress Report 

preplant herbicides followed by a metham sodium application is also in use in Florida 

vegetable production (Santos, 2009). 

9.2.3.9 Virus diseases of cucurbits and peppers 

Cucumber green mottle mosaic virus (CGMMV), Kyuri green mottle mosaic virus 

(KGMMV), Melon necrotic spot virus (MNSV) and Pepper mild mottle virus (PMMoV) are 

important pathogens of watermelon, melon, cucumber (CGMMV, KGMMV , MNSV) and 

peppers worldwide. Seeds, grafted seedlings, soil, plant sap and cuscuta (Cuscuta subinclusa, 

C. lupuliformis , C. campestris) are the main means of transmission for these viruses. 

The only country requesting a critical use to control these viruses is Japan, which will 

nevertheless be phasing out this application by 2013 (Tsuda 2008; Tateya 2009). Japan has 

made significant efforts in developing transitional measures to help achieve the phase-out, 

which are expected to be in place by 2012. Such measures include IPM programmes 

involving crop rotation, resistant varieties, amending the soil with cellulose and wrapping 

roots with paper, all of which reduce the severity of the virus attacks (Nishi et al., 2008; 

Fukaya , 2008; Ooizumi et al., 2008). Soilless culture using different kinds of substrates 

(paddy rice, peat moss, bark tip, vermiculite and others) is under development (Fukaya, 

2008). Preimmunisation with an attenuated virus is also reported as a promising means of 

protection against aggressive strains (Nishi et al., 2008; Fukaya, 2008; Kubota, 2008). 

9.3 Structures and Commodities 

The Progress Report for MBTOC Structures and Commodities (SC) contains the following 

sections: 

• Regulatory Update 

• Environmental Concerns in Conflict with the Use of MB Alternatives 

• Personnel Issues 

• Update on Pest Control Methods in Mills and Food Processing in the United 

Kingdom 

• Special Report on Pest Control Issues of Fresh Dates 

• Research Update – Efficacy of Alternatives 

• References 

9.3.1 Regulatory Update 

Regulatory approval of MB alternatives has in most cases stalled, and in some cases been 

revoked. As noted in the introduction to the CUN report for structures and commodities, 

unless there are additional regulatory approvals, and an increased commitment to use 

alternatives that are approved or which do not require approval, CUNs for structures and 

commodities seem set to continue for several years and likely at the current levels 

9.3.1.1 Sulfuryl fluoride (SF) 

In Australia, Canada, the US and Europe, there has been no change for approximately two 

years in the extent of approvals required for the use of sulfuryl fluoride (SF), a key alternative 

for uses in food processing structures and commodities. In France, approval of the use of SF 
May 2010 TEAP Progress Report 175

on fresh chestnuts has been withdrawn. The SF treatment resulted in a fluoride residue in 

chestnuts which exceeded the European Union 25 ppm MRL. 

In two instances (Australia and US) CUN applicants report regulatory interpretations 

concerning the use of SF which they believe prevents its use; in both those cases, MBTOC 

believes the registration and the label should permit the use of SF. 

Specifically, the applicant for Australian rice reports that although SF has been registered, the 

registration does not include packaged rice. MBTOC has reviewed the SF label in Australia 

finding, SF is registered for rice, polished rice and wild rice against all stages of stored 

product pests in silos, food handling and processing facilities, mills, warehouses, temporary 

and permanent fumigation chambers (Dow Profume Label Australia, 2008). 

Additionally, in the US, the California applicant for dates reported that SF is approved only 

for dried dates. However, the dates harvested in the US are considered by MBTOC to have 

already been dried on the tree prior to harvest in that their moisture content is approx 17-23% 

(John Davies pers comm to MBTOC). This moisture content does not conform to the 

definition of high moisture dates in other date growing regions of the world. In the US dates 

at the time of harvest are referred to as ‘fresh’, but this is a marketing term. The concept of 

‘fresh’ is not pertinent or informative to this discussion. MBTOC believes it is reasonable to 

interpret the regulation as allowing the use of SF on these dates in the US. 

In Canada, although registration for SF was achieved for structures several years ago, 

maximum residue levels for the fluorine residue in food resulting from the SF treatment of the 

food processing structure has not been set; this is a contributing factor to the ongoing CUN 

for flour milling and pasta facilities. The reason for this is that food products and ingredients 

are commonly found in silos, in warehouses and finished product stores in mills and pasta 

processing facilities. 

In France, SF has been registered for logs, but there remain practical use which affect 

adoption for this purpose. For Europe, there is no MRL for fluoride residues resulting from 

SF treatment of dried fruit. Similarly to Canada, in the EU there is no food contact registration 

for SF in flour mills. Large mills containing integral flour bins are experiencing very difficult 

practical implementation problems with SF fumigation. Other than in the UK, the SF supplier 

is not advocating the combined use of SF and elevated temperatures, although MBTOC 

recommends this combined treatment. Heat treatment alone is not feasible for these large 

mills. 

In the United States SF is a major methyl bromide alternative for post harvest uses. In 2004 

and 2005 the US EPA established tolerances for SF use on dried fruits, tree nuts, pistachios, 

cereals, small grains, coffee, coconut, cottonseed, legume vegetables as well as on processed 

foods such as pasta, cake mixes, cookies, crackers, powered milk and eggs where fluoride 

residues may result from the use of SF to fumigate the space and equipment where these 

foods are processed. The Fluoride Action Network (FAN) objected to these tolerances 

arguing that adverse effects and precursor effects can occur at lower doses which should have 

precluded EPA from making the “reasonable certainty of no harm” safety finding required to 

establish tolerances. To assess the safety of fluoride levels to humans from all routes of 

exposure (drinking water, toothpaste, pesticide residues, etc.) EPA’s Office of Water 

requested the National Academy of Sciences (NAS) to review the current drinking water 

standards for fluoride. A March 2006 NAS report recommended that the current drinking 

water standard (MCLG of 4 mg/L) should be reduced. EPA’s Office of Water is evaluating 

the NAS report and working on a revised risk assessment. Any changes to the drinking water 

standard will be taken into account when EPA responds to FAN’s objections. 
176 May 2010 TEAP Progress Report 

In the US, although there is registration for the use of SF in structures and tolerances for many 

food products, the list of foods on the SF label is not as inclusive as is the list of foods on the 

methyl bromide label. This is the main reason for the ongoing CUN for pet food facilities and 

for the requested use of MB in food processing facilities. Food products and ingredients are 

commonly found in silos, in warehouses and finished product stores in mills, processed food 

facilities and pet food facilities. MBTOC has suggested that changes be made such as moving 

foods out of the fumigation area, sectioning off the fumigation areas or tarping the foods. 

Applicants report that moving food commodities out of the facility before a fumigation would 

cost too much, that sometimes sectioning off the food stores can not be done, and that tarping 

off foods during SF fumigation would not meet regulatory requirements. 

MBTOC notes that these regulatory issues are separate from issues surrounding the now 

intensified question of SF environmental issues, which are discussed separately below. 

9.3.1.2 Methyl Bromide 

Regulatory problems associated with MB alternatives have to be viewed in context of 

possible upcoming regulatory events with MB as well. Currently, the US EPA is in reregistration process for MB, and it has published the intention to reduce worker exposure 

limits. Currently the re-registration eligibility decision calls for worker exposure limits of 

1ppm for an 8 hr time-weighted average, but since there were concerns about that limit it is 

under review. Currently, the clearance level is 5ppm,. (The term clearance level refers to that 

level after a facility fumigation aeration which allows re-entry of personnel) . Industry users 

of MB in the US have supplied the worker exposure data for facilities but now the worker 

exposure data for QPS use is being generated. All MB users are trying to work out if it will be 

possible to mitigate worker exposure rates through new labor practices. 

9.3.1.3 Methyl Iodide 

There have been two regulatory changes that are more positive. Methyl iodide was registered 

for fresh chestnuts in Japan in 2009. However, Government of Japan says that supplies will 

not be present in Japan until 2011. Since chestnut fumigation takes place on farms, farmer 

training in the safe use of the fumigant is also needed. 

9.3.1.4 Phosphine 

Several years ago MBTOC was given regulatory interpretations that phosphine was approved 

for dried beans in California, but there was a difference of opinion about the regulatory 

interpretation and treatment logistical problems which then resulted in CUNs for dried beans 

for a few years. This year, however, there was no CUN for dried beans; we assume that both 

the regulatory interpretation and the logistical problems have been solved. 

In May of 2008, the International Maritime Organization issued Circular 1264 

Recommendations on the safe Use of Pesticides in Ships applicable to the Fumigation of 

Cargo Holds. This Circular has allowed “In-Transit Fumigation” of plant and animal 

products. This Circular formalizes the practice of fumigation on board vessels using 

PHOSPHINE Fumigants only. This circular re-enforces the advantage of using Phosphine as 

an alternative to Methyl Bromide as a fumigant for disinfesting plant and animal products. 

At this time there are now many bulk carries of plant and animal products that are using 

Phosphine fumigants as Phytosanitary requirements for the control of insect and mite pests of 

plant and animal products that may be carried into the cargo holds with goods (introduced 

infestation). 
May 2010 TEAP Progress Report 177

9.3.1.5 Heat treatment 

MBTOC notes that heat treatment to disinfest structures does not require regulatory approval. 

Heat is effective and in use in many of the other companies included in the industry sectors 

which generate CUNs for MB. Problems achieving technical efficacy with heat have been 

reported, but it is also reported that with effort technical efficacy can be achieved with no 

damage to the structure. Also noteworthy is the increasing adoption of spot heat treatment for 

equipment reported in many structural applications. We note that full site heat treatment can 

cause problems for facilities where food products and ingredients are commonly present; heat 

treatment of commodities is usually not recommended due to food quality restraints. Food 

commodities could be removed before heat treatment; this however, would increase the 

workload and requires time and effort which would vary depending on facility. 

9.3.2 Environmental Concerns in Conflict with the Use of MB alternatives 

Transition away from methyl bromide use for treatment of food processing facilities and 

structures in non Article 5 countries has come to rely heavily on availability of SF. MBTOC 

advises the Parties that environmental concerns about using sulfuryl fluoride amongst milling 

and food processing companies should not be underestimated as an obstacle to adoption of 

this MB alternative. All flour milling and food processing CUNs in 2010 noted environmental 

concern with using SF, either in the context of regulatory uncertainty or milling and food 

processing customer demand for companies to reduce their carbon footprint. 

MBTOC notes the following statement from MOP 21, Decision XXI/9 

(Hydrochlorfluorocarbons and Environmentally Sound Alternatives) (para 8): “To encourage 

Parties to consider reviewing and amending as appropriate, policies and standards which 

constitute barriers to or limit the use and application of products with low- or zero-GWP 

alternatives to ozone-depleting substances, particularly when phasing out HCFCs.” Parties 

may wish to consider the potential similarity (or not) in its concerns for HCFCs and SF. 

According to the US pet food industry, use of SF could easily eviscerate any reductions in 

carbon emissions that pet food makers are able to realize. Pet food sector companies reported 

that use of SF could potentially expand a company’s carbon footprint and that such a situation 

is likely to be viewed by retailers and consumers with much disapproval. 

The rice milling sector reports that their industry is currently being driven by international and 

some national customers that are designing sustainability plans for their own needs and 

sending the plans down the food supply chain. One of the most basic requirements is to 

reduce the carbon footprint in every step of the chain. Rice producing fields are currently at a 

severe disadvantage for their inability to mass-utilize no-till practices. Adding a climate 

change contributor (SF) to the same supply chain is counterintuitive and contrary to customer 

requirements of reducing the carbon footprint and controlling global warming 

Of note, Walmart, the largest retailer in the United States, announced on February 25, 2010, 

that it wants its suppliers to eliminate “20 million metric tons of greenhouse gas emissions by 

the end of 2015.” Millers and food processors point to this as an example of the reasons they 

must continue to use MB and not switch to SF fumigation. 

As background to this issues, in 2009, research was published indicating that SF has a much 

higher global warming potential than previously considered (Millet et al., 2009). Its 

atmospheric life-time is estimated as 36 years, about 8 times greater than previously thought, 

with the oceans as the dominant sink. These new reports indicate SF may be 4,800 times more 

effective at trapping heat in the atmosphere than carbon dioxide (St. John, 2009). The GWP of 

SF is comparable to that of CFC 11 (Muhle et al., 2009). By comparison GWP of R-134a is 

only 1410 and venting is prohibited under the Clean Air Act. California is currently using 
178 May 2010 TEAP Progress Report 

50% of all SF produced. According to Anderson in 2009 the current SF use in California is 

equal to the CO2 emissions of 1 million vehicles over 1 year (Anderson, 2009). 

Dow AgroSciences, the main supplier of SF in North America and Europe, has successfully 

obtained the necessary registrations for use of SF, but further information on MRLs is being 

requested by various authorities for extensions of registration to cover the wide range of 

commodities on the methyl bromide label. Dow is aware of the global warming challenge and 

is monitoring developments. 

9.3.3 Personnel Issues 

In January 2010, TEAP co-chairs decided to reorganize MBTOC to form a subcommittee for 

quarantine and pre-shipment issues (QPS). As a result, six of the members of the MBTOC 

subcommittee formerly known as Quarantine, Structures and Commodities (QSC) were 

transferred to QPS subcommittee. The resulting MBTOC Structures and Commodities (SC) 

subcommittee now includes 12 members from 9 countries, 2 of which are from Article 5 

countries. All members of MBTOC SC also have considerable expertise and experience in 

quarantine and pre-shipment issues. 

MBTOC SC may be unable to operate if the EU members are not funded to attend MBTOC 

meetings. Human resources in the field of control of stored product pests is exceptionally thin 

worldwide due to most countries having closed or considerably decreased stored product 

research institutes; for this reason, MBTOC cannot easily replace its current members 

Additionally, in December 2010, the MBTOC SC member from Belize resigned due to 

change in her employment. We appreciated her contribution and wished her well in her new 

work. 

9.3.4 Update on Pest Control Methods in Mills and Food Processing in the 

United Kingdom 

In the UK, methyl bromide was formerly used by most flour mills on an annual basis as a full 

site treatment. Food production premises were occasionally MB treated. Now all mills and 

food production premises have adopted a more intensive IPM program which includes 

intensive monitoring of infestation levels and regular precisely documented cleaning and 

pesticide applications. The IPM program is designed to minimize the possibility of needing a 

full site treatment. 

If the localized infestation is detected by the intensive monitoring, perhaps in a machine or a 

room of the building, then it is treated with spot heat treatment. One advantage of spot heat 

over fumigation is that, unlike fumigation, heat treatment does not require that production be 

stopped. The affected area is normally isolated with thermal sheeting or another type of 

suitable enclosure. The floor and the other immediately adjacent areas to the equipment or 

room are treated with insecticidal dust or spray in case of insect escape from the heated 

equipment. Heat is applied from portable equipment to raise the internal temperature in all 

parts of the treated area to a minimum of 52 ̊C for a minimum of 1 hr. This spot treatment 

normally takes between 5-12 hours. 

Using these procedures MB has been successfully replaced in all flour mills and food 

processing facilities in the UK where it was formerly used as a full site treatment. The overall 

cost of fumigation to the UK flour milling and food processing sectors has been reduced. The 

reason is that formerly 50-60 full site MB were conducted each year, but for the past three 

years, the number of full site treatments has been reduced to an average of 10 per year. 

Admittedly, each full site treatment now costs approximately 3x more than the MB treatments 
May 2010 TEAP Progress Report 179

used to cost. IPM costs have also increased, but the need to phase out MB was not the only 

driver to improve IMP in flour mills and food processing facilities. The need to reduce worker 

dust inhalation and to improve food quality and safety were also contributing factors requiring 

IMP improvements. 

9.3.5 Special Report on Pest Control Issues of Fresh Dates 

Parties, particularly the North African countries of Algeria and Tunisia, have discussed with 

deep concern the problem of controlling pests in high-moisture dates. Currently methyl 

bromide is used by several Parties to disinfest dates and prevent fermentation. In 2003, 

MBTOC noted that technically and economically effective alternatives were not been 

identified for fresh, high-moisture dates. The Parties then passed Decision XV/12, which 

noted the problem and its resulting impact on MB use in those countries. The Decision also 

indicated a need for a project to identify suitable alternatives and a workshop to share this 

information. 

In 2008, UNIDO took the initiative to respond to Decision XV/12. A MBTOC SC group of 

experts carried out an extensive preliminary investigation of potential pest control techniques 

for this sector. Five alternatives were tested. As a result of this study, considerable 

information about potential alternatives was identified and discussed at a UNIDO workshop 

in Vienna in 2009 on the replacement of methyl bromide for disinfestation of high moisture 

dates. 

As a result of the study and discussions during the workshop, one of the key technical 

problems to be addressed was the lack of information on the moisture content of dates in 

various producing countries. MBTOC members considered moisture content to be a key 

determinant for the selection of an effective disinfestant. It became apparent that “dates at 

high moisture content” such as it appears in Decision XV/12 must be specifically defined. 

Consequently, the following definition was accepted and approved: 

“Dates at high water content”, so called “fresh dates”, are dates of the Deglet-Nour variety 

with a moisture content from 30 to 40% (compared to the net weight). The colour of such 

dates is light and somewhat transparent. These dates are marketed still attached to small 

branches. The relative humidity in equilibrium with these high-moisture dates allows the 

rapid development of yeasts resulting in fermentation, if the dates are either stored or 

fumigated in gas tight conditions. Gas tightness sufficient for fermentation can also occur in 

consumer packaging. In contrast, dates with moisture content between 17-23 % may be 

considered as dried fruit.” 

In 2009, UNIDO decided not to conduct the research, which had been recommended to 

further this investigation. 

In 2009, two MBTOC SC members (Ducom, France and Reichmugh, Germany) and the 

USDA scientist currently conducting date research (Walse), visited the date growing area in 

the Coachella Valley of California. This valley is the primary date production site in the 

United States. The visit included packing and storage areas and infrastructure. Deglet Noor 

and Medjoul varieties are grown in this area. However, the moisture content of the dates at 

harvest is region specific; it is 17-23% in California compared to 35-40% in North Africa. 

Thus, MBTOC considers US dates as "dried fruit" and the dates in North Africa as "high 

moisture fruit", leading to different regulatory considerations. The SF label in the US includes 

dried dates; MBTOC interprets this to mean that these California dates can be subject to 

treatment with SF under the US label. USG is requested to investigate this regulatory 

interpretation. 
180 May 2010 TEAP Progress Report 

All dates require post harvest disinfestations of field insect pests. In California, chamber 

fumigations with MB are presently used for disinfestation of freshly harvested dates. The 

exposure is 24 g/m3

 methyl bromide for 12 hours. At present, tarpaulin fumigations with 

phosphine, typically lasting 3-30 days, are utilized for stored-dates disinfestations. 

Given the infrastructural, logistic, food quality, and pest-control scenarios facing the 

California date industry, phosphine treatment may be an alternative for those dates that can be 

stored for two weeks. If a regulatory interpretation is made that California dates can be SF 

treated, it could be an alternative for a quick disinfestation of these dates, provided that the 

temperature during treatment is higher than 25°C. 

Researchers with Dow AgroSciences, a supplier of SF, reported the investigation of the 

efficacy and economics of using SF on dates in California. Previous work showed that 2.1x 

more SF was required than MB, and this resulted in an increased cost. Improved painting and 

door sealing reduced half-loss time to 12-15 hours. Adding a small fan further improved 

treatment efficacy. These changes resulted in the efficiency of only needing the same volume 

of SF as was formerly used with MB, with resulting cost savings. In California about 70% of 

dates are fumigated in stacks of bins under tarps on yards when time is not critical. Dates 

might be stored, under fumigation, for weeks or even months. The tarp stacks are fairly gas 

tight; SF fumigation of these tarp stacks could be conducted with lower dosage and longer 

fumigation times (Williams, MBAO, 2009). Chemical fumigation is not the only alternative 

for dates; controlled atmosphere (CA) is both effective and in commercial use. In Tunisia, one 

of the biggest dates producers (in Kebili) built a CA Terminal. The facility has a capacity of 

1300 tonnes per year and performs 70 treatment shifts per year. Treatment time (including 

pull down and ventilation) is 5 days from products coming in until products coming out for 

further processing. 

The insect that is the target of the process is Ectomyelois Ceratoniae , and the type of dates 

that is treated is the "Deglet Nour" (high and low moisture) (Vroom, 2010). 

9.3.6 Research Update – Efficacy of Alternatives. 

Of the recent research papers on control of pests of stored products and in mills and food 

processing structures, the following are most closely pertinent to the CUNs. 

Difficulties remain in achieving sufficient pest kill efficacy for pests infesting dry-cure pork 

(also referred to as ham) and cheese in storages in the US. Shilling of Mississippi State 

University is leading a multi-state research project in this field. He reported that tests of 

carbon dioxide and ozone show lack of efficacy and lack of practicality against mites. Initial 

work on phosphine showed efficacy but also showed changes in odor of the pork. Earlier 

work by this group using SF indicated lack of efficacy. (Shilling, 2009a, 2009 b). MBTOC 

notes that mites are one of the key pests of cured pork and that mites will not be controlled by 

the phosphine treatment. Additionally, phosphine is not registered for this purpose in the US. 

The results of this ongoing study have reduced MB use in this traditional food processing 

sector by improving IPM processes, facility sanitation and by an improved understanding of 

the pest-food process complex. This research is ongoing. 

Walse of USDA-ARS is leading a study to develop methods to control of pests of fresh dates 

using SF. Since problems with dates are a concern in several countries we have prepared a 

separate section on issues surrounding control of pests in dates, below. 

Research continues to test the effectiveness of SF in other foods as well. Reichmuth reported 

on a collaborative project with Barakat of Cairo University on rice moth (Corcyra 

cephalonica) to SF. This moth is a pest of cocoa, rice, peanuts, chocolate and biscuits and 

dried fruit in Africa, India, China and Mediterranean. They researched effectiveness at 27 ̊C 
May 2010 TEAP Progress Report 181

because that is closer to ambient temperature in Africa. Age of eggs was a factor in tolerance; 

younger eggs more resistant. CT of about 500 (4.19mg/l) was needed for an effective 5-day 

treatment. Reducing the fumigation time to 3 days requires an increased fumigant 

concentration. In Germany, it is more common to use longer fumigation times and lower 

fumigant concentrations because allowable residue levels are lower. For other countries, the 

Dow AgroSciences Fumiguide® indicates a CT of 1500. 

Also in Germany, the same research tream reported on 1-4-day-old eggs, larvae and pupae of 

the warehouse moth, Ephestia elutella (Hcobner) (Lepidoptera) were investigated for their 

susceptibility to SF under different conditions. Each life stage was exposed for 18 h, 24 h or 

48 h, to 11.6 g/m3 or 21.3 g/m3 at 15 ̊C, 20 ̊C or 25 ̊C and 65% relative humidity. Within 18 

h of exposure, all larvae and pupae of E.elutella died at 11.6 g/m3 at all three temperatures. 

The 1 and 2- day-old eggs were generally more susceptible, whereas the 3 and 4-day-old eggs 

were more tolerant to the SF treatment. All eggs of all ages were controlled within 48 h of 

exposure to the concentration of 21.3 pl 1.3 g/m3

 at temperatures of 20 ̊C and 25 ̊C (Baltaci et 

al., 2009). 

Ciesla and co-workers in Bordeaux, France investigated the influence on CT and temp on Red 

Flour Beetle (RFB) and Confused Flour Beetle (CFB) eggs. They investigated the use of low 

dosages of SF, at elevated temperatures and longer fumigation times in mills of 5000 – 7500 

m3. The intent was to provide treatment guidance in view of the relatively low fluoride 

residue tolerances in the EU following mill fumigation with SF. Temperature was found to be 

the most important factor leading to good ovicide kill with RFB eggs; at 30 ̊C there was 100% 

mortality. Eggs of CFB are easily killed. Increasing the mill temperature to 30 ̊C or higher 

allowed the use of 25% less SF. (Ciesla et al, 2009) 

Muhareb evaluated combining SF, propylene oxide (PPO) and carbon dioxide (CO2) as a 

treatment for dried fruit and nut commodities infested with stored product insects. Mixing SF 

and PPO created no new chemicals. The chamber was first put under vacuum, then PPO was 

added, then normal air pressure was established and SF added. They used 10% CO2, which 

was a safety factor and also allowed a 36% decrease in fumigant required. They observed a 

72% reduction in the fumigant requirement when the combination of PPO, SF and CO2 was 

used and there was 100% mortality of RFB eggs. Cost comparison of the fumigants alone 

showed the mix was about 25% of the cost of SF fumigation alone when you want LC95% for 

CFB eggs. 

Also investigating combination of fumigants, in this case, for control of pests in rice were 

Naito and co-workers in Japan. Fumigation tests using sulfuryl fluoride (SF) and phosphine 

(PH) were conducted to develop an alternative to methyl bromide fumigation. Egg, larval, and 

pupal stages of Sitophilus granarius and S. zeamais were tested. SF fumigation showed high 

efficacy toward larval and pupal stages of both weevils: The stages were killed completely at 

10 mg/l for 24 hours at 15 ̊C. However, the mortalities of the egg stage of each weevil were 

26.4 and 3.6%, respectively, with SF showing the least efficacy toward the egg stage. Mixture 

gas fumigation of SF 30 mg/l and PH 2 mg/l for 24 or 48 hours at 15 ̊C was conducted to 

cover the weak point of SF. The mixture gas fumigation showed high efficacy toward all 

stages: however, 100% mortality was not obtained in the pupal stage of S. zeamais by the 

mixture gas for 48 hours. This result was not in accord with the result of SF fumigation. Then, 

mixture gas fumigations taking account of the order of the injection of both gases and the 

pace of increase of PH gas concentration were conducted, and this made clear that these 

factors affected the mortality of larval and pupal stages of both weevils. These results 

indicated that mixture gas fumigation of SF and PH has promise as an alternative to methyl 

bromide fumigation, but it is necessary to take into account the method of the PH dosing 

(Naito, et al., 2007). 
182 May 2010 TEAP Progress Report 

In structural research with sulfuryl fluoride, Chayaprasert and co-workers at Kansas State 

continue to try to characterize the factors that affect efficacy of SF fumigation studying 

predictive factors of environmental and facility-specific conditions. Past fumigation data as 

the primary means for evaluating the structural sealing quality of a current fumigation is not 

adequate. Predictions of fumigant leakage rate and fumigation performance should 

incorporate quantifiable sealing effectiveness and weather information for the planned 

fumigation period. Comparisons between SF and MB fumigations indicated that under similar 

weather conditions and fumigation practices the leakage characteristics of SF and MB do not 

differ. In practical situations where the dosage requirements for SF and MB are typically not 

the same, however, the leakage rates of SF and MB fumigations could be different due to the 

buoyancy effect. Nevertheless, the magnitude of the difference may or may not be significant 

depending on other factors such as sealing quality, wind speed and direction, and ambient 

temperature (Chayaprasert, 2009). 

Arthur of USDA also looked at the efficacy of combination methods, in this case of pyrethrins 

plus insect growth regulator in aerosols used to reduce pest populations. There is an additive 

effect of the two insecticides. CFB is more tolerant species to this treatment, so 3% 

pryrethrin-+IGR (Dyacon) gave best results. If the pest concern is RFB, a 1% solution will 

work and it will cost less (Arthur, 2009). Several food processing companies are now reported 

to use aerosols as part of IPM to reduce the need for full site treatments. 

Brijwani and co-workers at Kansas State University looked at heat treatment factors in a 

cereal plant that has 180 rooms. This facility is now solely heat treated, and heat treatments 

are done every month. Efficacy improvements now allow for a 17-hr heat treatment, which 

saves time and money. The study advised to increase the heating rate to kill pests faster and 

the result will be a shorter heat treatment. Pests will survive in cool spots, below 50 ̊C. and 

also in flour residues, so it is important to direct heat to otherwise cool spots and remove 

flour residues (Brijwani, 2009). 

Berte worked in the Barilla pasta factory in Italy to study the effect of heat treatment as a 

disinfestation treatment in the pasta manufacturing structure. In 1994, Barilla decided to stop 

using MB in favour of alternative techniques. For this reason and for the growing attention 

that Barilla is paying towards the environment, a mill heat treatment was experimented in 

2005, and heat was also applied in a large pasta factory in 2007. Hot-air treatment is based on 

the principle according to which insects and their eggs, larvae and chrysalids die at 

temperatures starting from 45 ̊C due to the result of protein coagulation. The gradual heating 

of the pasta factory (~60,000 m3

), needed to eliminate insect pests, was achieved by using the 

heat produced by production driers, air-treatment plants and thermal convectors. To check 

whether all the developmental stages (eggs, adults, larvae) of the pests were dead and to 

evaluate treatment effectiveness, 30 bioindicator kits were provided each containing the 

following species: Plodia interpunctella (eggs and larvae), Tribolium castaneum (eggs, larvae 

and adults), a mixed population of Lasioderma serricorne, and a mixed population of 

Sitophilus oryzae. After having tested heat treatment with success in Barilla mills, it can be 

confirmed that it is applicable and effective in large pasta factories. The researchers 

concluded that when the required temperature is maintained for ~40 h, species mortality in all 

developmental stages could be observed. Treatment with hot air can therefore be used 

together with other precautionary measures in the fight against pests. 

Boina and co-workers at Kansas State University, proposed a model for predicting survival of 

mature larvae of Tribolium confusum during facility heat treatments. Their model was 

developed to predict survival of mature larvae, which is the most heat-tolerant stage of the 

confused flour beetle, Tribolium confusum (Jacquelin du Val), at elevated temperatures 

between 46 ̊ and 60 ̊C. Their model can be used to predict survival of mature larvae of T. 

confusum during heat treatments of food-processing facilities based on time-dependent 

temperature profiles obtained at any given location. 
May 2010 TEAP Progress Report 183

Control of pests of dried fruit is a concern of several countries and the basis for a CUN from 

the United States. Two recent studies confirmed the effectiveness of phosphine treatment for 

dried figs. Quality of fruits treated with phosphine (MgPH3

), at 600 ppm for 3 or 5 days and at 

1000 ppm for 5 days under tarpaulin was monitored. The tested concentrations and exposure 

periods provided 100% mortality in test insects. Fumigation with phosphine for 3 to 5 days at 

600 ppm is recommended for the dried fig sector since no negative effects were detected on 

fruit quality parameters after 6 months of storage under ambient conditions (Meyvac and Sen, 

2007). 

Also working in Turkey with dried figs, Aksoy and co-workers examined the effect of 

magnesium phosphide as a methyl bromide alternative in controlling major pests of dried figs 

and the effect of fumigation on dried fig quality. Magnesium phosphide treatment of a dried 

fig stack at 600 and 1000 ppm phosphine for 3 days under tarpaulin provided 100% mortality 

in test insects and no negative effect on fruit quality for 9 months in storage under ambient 

conditions (Aksoy, et al., 2008). 

Controlled atmosphere methods and technologies have become well established commercially 

in several countries with little published research. CA ́s are based on the establishment of a 

low-oxygen environment, which kills pests. CA’s are established by means of an oxygen 

converter system. The best method to use for this system is the use of a pressure swing 

absorption converter. Low oxygen levels vary between 0.5% and 1.5%. It can be applied in 

airtight environments ranging from 1m

3 

to 1000 m

3

. Insects in all stages are eliminated 

(99,996% Lt) because of the lack of oxygen which causes the insects, larvae and eggs to dry 

out and suffocate. The infected products are exposed to CA in airtight rooms equipped to 

control temperature, oxygen and humidity, within a specified range of parameters known to 

be lethal to the pest. The treatment normally requires 1 to 6 days, depending on the type and 

level of infestation. 

In this study, Sen and co-workers in Turkey examined the efficacy of controlled atmosphere 

methods for sun-dried figs. The research was carried out in a pilot fumigation chamber 

designed by EcO B.V., AG Numansdorp, The Netherlands (a MBTOC member was an owner 

of this company.) The objective was to test the effectiveness of controlled atmosphere (CA) 

(in this case defined at decreased O2 at 1+or-0.5%) at elevated temperature (41 ̊C) in 

controlling the major storage pests, fig moth (Ephestia cautella), Indian meal moth (Plodia 

interpunctella), and dried fruit beetle (Carpophilus spp.). In addition, major quality 

parameters of dried figs were analyzed soon after the treatments, and after 4 months of 

storage under ambient conditions, in comparison with MB-treated controls (60 g/m3 for 24 h). 

The CA treatment can be recommended as a post-harvest MB alternative for dried figs since it 

provided 100% control of the pest species tested, had neutral or positive effects on dried fruit 

quality and required comparatively short (~ 26 h) treatment times compared with other MB 

alternatives (Sen et al., 2010). 

Riudavets et al (2009) conducted a study confirming the efficacy of using modified 

atmosphere packaging (MAP) with a high CO2 content to control pests in final food products 

during their storage, distribution and marketing. The study included a spectrum of species and 

all of their developmental stages that could be present in a wide range of processed food 

products 

Pons et al (2009) confirmed the efficacy of using CO2 in big bags and containers to prevent 

pests’ development in rice, dried herbs and cocoa . Since rice and other postharvest 

commodities are often stored in silos, there has been an investigation about the potential to 

use CA in silos in Switzerland, a Dutch Company, together with Silo Olten A.G. and the Pest 

Control Company Desinfecta A.G. started to commercialize the idea of silo’s equipped with 

the CA technique. This lead to a successful implementation of CA based silo’s treatment 

against a variety of insects. The technique is applied in the following manner: nitrogen is 
184 May 2010 TEAP Progress Report 

injected at 6 Bar, which even with a leakage rate of 20% a regime of less than 1% oxygen can 

be accomplished (and pest control achieved) (Vroom, 2010). 

9.4 Quarantine and Preshipment 

Decision XXI/10 requested the TEAP and its MBTOC, in consultation with other relevant 

experts and the IPPC, to provide a report to be considered by the 30th OEWG. The report 

should cover: 

1. A review of available information on the technical and economical feasibility of 

alternatives, and the estimated availability, for main categories of QPS uses: a. Sawn timber 

and wood packaging material (ISPM-15); b. grains and similar foodstuffs; c pre-plant soil 

uses and d; logs 

2. A review of the current availability and market penetration rate of QPS alternatives to the 

uses listed in above, and their relation with regulatory requirements and other drivers for the 

implementation of alternatives; 

3. An updated estimate of amounts of MB presently used for QPS purposes that may be 

replaced with alternatives including economic aspects, distinguishing between Article 5 and 

non-Article 5 Parties and between quarantine and pre-shipment uses separately. A preliminary 

estimate was presented in a previous QPS report submitted to the Parties (TEAP, 2009b). 

4. A description of a draft methodology, including assumptions, limitations, objective 

parameters, the variations within and between countries and how to take account of them, that 

the TEAP would use, if requested by the Parties, for the assessment of the technical and 

economical feasibility of alternatives, of the impact of their implementation and of the 

impacts of restricting the quantities of methyl bromide production and consumption for QPS 

uses. 

In response to this Decision, the MBTOC- QPS sub-committee has prepared a comprehensive 

report included as Chapter 8 of this TEAP Progress Report. MBTOC-QPS estimated that 

about 1,995-2,571 tonnes of methyl bromide used for QPS were immediately replaceable 

globally for the four main categories of QPS, which represents 32-42% of total consumption 

for these major categories of use. 

9.5 Economic Aspects of Methyl Bromide Alternatives

9.5.1 Background 

The experience that MBTOC has gained in the economic assessment of CUNs shows that the 

following points should be considered in deciding on the information required for the 

assessment of the economic feasibility of alternatives to the use of methyl bromide: 

• The economic assessment starts with a financial analysis of the impact of the relevant 

activity with methyl bromide and with the alternatives on the ‘bottom line’ of 

individual firms. 

• All nominations for a CUE should include a full financial argument whether or not 

the nomination is based on technical feasibility. This is to provide for situations 

where MBTOC may differ on the issue of technical feasibility. 

• Accounting systems to measure financial performance differ across jurisdictions. 

However, the basic components for assessing financial feasibility described below, 
May 2010 TEAP Progress Report 185

i.e. revenue and costs, are universal. Accounting systems can also be ignored as they 

are unlikely to change between the use of methyl bromide and the next best 

alternative. 

• A financial analysis typically provides a snapshot of circumstances given existing 

prices of inputs and outputs. However, in some cases, it will be necessary to 

supplement the financial analysis with a more comprehensive economic analysis, if 

the adoption of alternatives is expected to change the structure of supply and/or 

demand for inputs and outputs. In this case, the elasticities will change, leading to 

different budget outcomes. Such partial equilibrium analyses (i.e. analyses of the 

changes in the input and output markets most directly affected) could be necessary for 

commodities and structures, soils, or QPS uses. 

• Furthermore, it may become necessary to extend the scope of the analysis to take 

account of the general equilibrium effects of such changes (i.e. the indirect effects of 

changes in these markets on other markets). General equilibrium analyses typically 

require considerable resources and will not be used often, but may become necessary 

in, for example, assessing the impact of the phase-out of QPS uses. 

• As a final step, economic tools can also be used to assist in answering questions about 

the economic impact of environmental implications of the changes proposed in a 

CUN. 

• Nevertheless, it is MBTOC’s considered opinion that a partial budget analysis will 

suffice in most economic assessments of CUNs. 

9.5.2 Components of an assessment of financial feasibility 

In assessing financial feasibility the calculation of each of the following key components is 

done for two cases; (i) the firm operating with methyl bromide and (ii) the firm operating with 

the next best alternative for each use: 

• Gross revenue measures the earnings of the firm, broadly the quantity of the product 

sold times the average selling price per unit. Where gross revenue is not expected to 

change as a result of the adoption of an alternative (e.g. in the case of the fumigation 

of a mill), it is not necessary to consider gross revenue. 

• Variable costs are those costs of production that vary with the amount produced, e.g. 

fumigation costs. They may be thought of as the quantity of the input used times the 

cost per unit of input. Borrowing costs for capital equipment (see capital costs below) 

and the remuneration to the owner are conventionally excluded from variable costs. 

• Fixed costs are those costs of production that do not vary with the amount produced, 

i.e. they are incurred whether or not there is any production, e.g. salaries. Fixed costs 

may be difficult to deal with in situations where firms produce more than one 

product, as they then have to be allocated to different products produced by the firm. 

• Capital costs are classified as fixed costs; e.g. investment in new machinery. Capital 

includes a time element as it generates revenues over more than one production cycle 

and its costs are spread over time through interest on borrowing. Where transition to 

an alternative involves investment in capital equipment, the costs of such equipment 

should be spread over the economic life of the asset. 
186 May 2010 TEAP Progress Report 

• The Gross Margin is what remains from gross revenue after subtracting certain 

variable costs. The process of calculating the gross margin is conventionally referred 

to as partial budgeting because it does not include fixed and capital costs. 

• Net Revenue (or Net Returns) is what remains from gross revenue after subtracting 

variable, fixed and capital costs 

9.5.3 Estimating the components for assessing financial feasibility 

• A responsible financial assessment requires sufficient data to construct a partial 

budget for the current use (in this case production with methyl bromide) as well as for 

the next best technically feasible alternative practice. 

• However, enterprise budgets in farming are difficult to construct because of: 

o The diversity of firms in terms of size, age and geographic location, etc.; 

o The diversity of conditions that can affect input use as well as gross revenue; 

o Changes introduced as a result of the adoption of the next best alternative, 

such as increased risk of loss in production, increased variability in yields or 

efficacy, missed market windows, etc.; 

• Because of this diversity, it is important that the presentation of the budgets be 

accompanied by explicit statements of the way in which each figure was calculated. 

• In all these cases, it is not always possible to provide proprietary information on 

individual firms. Hence, data should be provided for either a ‘typical’ or an average 

enterprise, i.e. one that shares similar physical, economic, etc. characteristics as the 

firm(s) in question. 

• The information regarding financial feasibility must be assessed for internal 

consistency, completeness, and reasonableness. Because there are virtually no 

published sources on the financial feasibility of the adoption of methyl bromide 

alternatives, MBTOC is largely dependent on the Parties to provide objective sources. 

To this end, the work of MBTOC will be made easier if the data that is provided 

has been verified by a third party, e.g. via banks that serve the clients in question, 

government agencies such as extension services, and farmer study groups, etc. 

• In terms of financial feasibility, the following considerations apply: 

o Alternatives that result in negative net revenues are not financially feasible. 

o In the unlikely event that the gross revenues are higher and costs are lower, 

the alternative is financially feasible. 

o In the unlikely event that changes in costs and revenues are absolutely equal, 

the alternative is financially feasible because of the environmental benefits 

accruing. 

o When costs and revenues increase or decrease simultaneously, the result is 

ambiguous, and there is a need to define default values. 

• Default values: 
May 2010 TEAP Progress Report 187

o Financial feasibility criteria are needed for those cases where net revenue 

declines but remains positive. Thus, Parties asserting that methyl bromide 

alternatives are not financially feasible should explain why projected impacts 

are of sufficient magnitude to support their claim. 

o MBTOC has adopted the default assumption that alternatives leading to 

decreases in net revenues of around 15 to 20 percent or more are not 

financially feasible. 

9.6 References 

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Adam, B. D. (2007). Cost comparison of methyl bromide and ProFume® for fumigating a food 

processing facility: a report to the National Pest Management Association and Dow 

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fumigants in the soil and its impact on nematode and parasitic weeds mortality. Proceedings of 

the 7th International symposium of soil and substrate disinfestation. Leuven Belgium. 

Aloni, B., Karni, L., Deventurero, G., Levin, Z., Cohen, R., Katzir, N., Lotan-Pompan, M., Edelstein, M., 

Aktas, H., Turhan, E., Joel, D.M., Horev, C. and Kapulnik, Y. (2008). Possible mechanisms for 

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Arthur F.H., Sutton A.E., Zhu K.Y., and J.F. Campbell (2009). Residual effect of pyrethrin -methoprene 

aerosols to control Red Flour Beetle and Confused Flour Beetle. Annual International Research 

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Beltrán R., A. Vicent, J. García-Jiménez, and J. Armengol (2008). Comparative epidemiology of 

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Bernal R.F. (2007). Effect of Midas (chloropicrin 62 %, methyl iodide 33%) on the control of 

Meloidogyne incognita in greenhouses of Salto, Uruguay. In: Annual International conference 

on Methyl Bromide alternatives and emissions reductions, October 29-November 1, 2007, San 

Diego, California, 33-1, 33-4 

Berte, E. (2008). "The heat treatment in a pasta factory as alternative to the fumigant use." Tecnica 

Molitoria 59(11): 1313-1316. 

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the international research conference on methyl bromide alternatives and emissions reductions, 

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Besri, M. ,(2007b). Current situation of tomato grafting as alternative to Methyl Bromide for Tomato 

production in Morocco. In: International research conference on methyl bromide alternatives 

and emissions reductions, October 29- November 1, 2007, San Diego, California, 62-1, 62-5 

Besri, M. ,(2008) Cucurbits Grafting as Alternative to Methyl Bromide for Cucurbits Production in 

Morocco. Proceedings MBAO Conference, Orlando (FL) 2009, 60-1 60-5. 

Blestos, F.A. (2005). Use of grafting and calcium cyanamide as alternatives to methyl bromide soil 

fumigation and their effects on growth, yield, quality and Fusarium wilt control in melon. 

Journal of Phytopathology 153 (3): 155-161. 

Boina, D. R., B. Subramanyam and S. Alavi (2008). "Dynamic model for predicting survival of mature 

larvae of tribolium confusum during facility heat treatments." Journal of Economic Entomology 

101(3): 989-997. 

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Montreal protocol, Contemporary Economic Policy, 23(3), July: 376-393 

Desaeger, J.A., Seebold, K.W., Csinos, A.S. (2008). Effect of application timing and method on efficacy 

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Duniway, J. M. (2002). Status of chemical alternatives to methyl bromide for pre-plant fumigation of soil. 

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Muhareb, J., Hartsell P., Hurley J.B., and B. Pena (2009). Evaluation of combination of sulfuryl fluoride 

and CO2 for stored product insects. Annual International Research Conference in MB 

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Naito, H., N. Ogawa, N. Tanigawi, M. Goto, T. Misumi, Y. Soma, T. Imamura and A. Miyanoshita (2007). 

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Odeh, O., S. Upendram and B. Subramanyam, (2004). Heat treatment as an alternative to Methyl Bromide 

for structural treatment of food-processing facilities: an economic analysis, Selected Paper for 

Presentation at the Western Agricultural Economics Association Annual Meeting, Honolulu, 

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Olson S.M., and R. Kreger (2007). Efficacy of midas (50/50) as a soil fumigant for tomato production. . 

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plant nutrient uptake. Procedings MBAO Conference, San Diego, California 

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Runia, W.T. and L.P.G. Molendijk (2006). Improved efficacy of metham sodium by rotary spading 

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Santos, B. M. (2009). Drip-applied metham potassium and herbicides as methyl bromide alternatives for 

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Santos, B.M., J.P. Gilreath, J.M. López-Aranda, L. Miranda, C. Soria, and J.J. Medina. (2007). Comparing 

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Santos, T. M., Mora-Bolaños, J. E., and Solórzano-Arroyo, Z. J. A. (2008). "Impact of solarisation and soil 

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Schneider, S. M. and B. D. Hanson. (2009a). Effects of fumigant alternatives to methyl bromide on pest 

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Conference on Methyl Bromide Alternatives and Emission Reductions. November 10-13, 2009 

Taylor, M., Bruton, B., Fish, W., Roberts, W.(2008) Cost it analyses of using grafted watermelon 

transplants for fusarium wilt disease control. Acta Horticulturae 782: 343-350 

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Termorshuizen, A.J., E. van Rijn, D.J. van der Gaag, C. Alabouvette, Y. Chen, J. Lagerlöf, A.A. 

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10 Evaluations of Critical Use Nominations for Methyl 

Bromide and Related Matters – Interim Report 

10.1 Scope of the Report 

This 2010 interim report provides evaluations by MBTOC of CUNs submitted for methyl 

bromide (MB) in 2011 and 2012 by Parties in accordance with Decision IX/6 (Annex I, 

MOP16). CUNs were submitted to the Ozone Secretariat by the Parties, in accordance with 

Decision XVI/4 (Annex II of this report). Parties are encouraged to ensure their submissions 

are in accordance with the timetable set out in Annex I, Decision XVI/4. 

This interim report also provides information from Parties on stocks (Decision Ex.1/4 (9f)), 

an update on registration issues affecting availability of alternatives for preplant and post 

harvest uses (Decision Ex. 1/4 (9i) and (9j)), partial information on actual MB consumption 

for critical uses (Decision XVII/9), apparent adoption rates of alternatives, as evidenced by 

trend lines on reduction of MB CUNs (Decisions XIX/9, XX/5), consideration of national, 

sub national and local regulations and law on the use of MB alternatives (Decision XX/5) and 

summaries of emission control, research and appropriate efforts (Decision XXI/11, para 9). It 

is noted that trend lines on adoption do not necessarily indicate true adoption rates for 

alternatives, because the use of stocks of MB may be available to the same sector or areas of 

production may have increased or fallen within the sector due to a range of circumstances. 

Standard presumptions used in the 2010 round were the same as those used in the 2009 round. 

MBTOC S has updated references to substantiate its standard presumptions for MB dosage 

rates in previous reports, no further updates have been provided in this report. These standard 

presumptions are subject to continual review, however any changes are required to be 

approved by Party’s at the preceding MOP to the year of assessment (Decision to be 

presented to the MOP for notification of the Parties as required in Annex 1, MOP16). 

MBTOC S has initial responsibility for the pre-plant uses and alternatives of MB. MBTOC 

Structures and Commodities (MBTOC SC) has initial responsibility for issues concerning MB 

uses and alternatives for structural and commodity treatments. MBTOC QPS has initial 

responsibility for preparation of a report for the 29th OEWG as required in Decision XXI/10. 

Evaluations of CUNs for the two categories are reported separately below. Outcomes from 

deliberations by the three MBTOC subcommittees were discussed and vetted via electronic 

communication. Recommendations made by MBTOC S were circulated to MBTOC SC and 

vice versa, as part of the process of reaching consensus within the whole committee. The 

economists attended parts of the three subcommittee meetings which were held at Sanlucar, 

Spain from 12-16th April, 2010. 

10.2 Critical Use Nominations for Methyl Bromide 

10.2.1 Mandate 

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

production plus imports minus exports) of MB is to be phased out in Parties not operating 

under Article 5(1) of the Protocol, by 1 January 2005. However, the Parties agreed to a 

provision enabling exemptions for those uses of MB 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. TEAP and its MBTOC provides guidance to the Parties’ 

decisions on critical use exemptions in accordance with Decisions IX/6 and Annex I of 

Decision XVI/4. Refer to Annexes I of this report for a copy of Decision IX/6. 
May 2010 TEAP Progress Report 196

10.2.2 Fulfilment of Decision IX/6 

Decision XVI/2 and Decision XXI/11 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 nomination. Where some of the conditions 

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

and economic evaluation. Several Parties presented action plans to phase out MB and in the 

absence of full detailed information in nominations this was considered appropriate effort 

under Decision IX/6. The full text for Decision IX/6 can be found in Annex I at the end of 

this document. MBTOC reduced a nomination when a technical alternative was considered 

effective or, in a few cases, when the Party failed to show that it was not effective. In this 

round of CUNs, as in previous rounds, MBTOC considered all information provided by the 

Parties, including answers to questions requested by MBTOC, up to the date of the 

assessment. 

Now that technically effective alternatives have been identified for most applications, 

regulations on the use of these alternatives and comparative information on the economic 

feasibility/infeasibility of their use compared to MB are critical to the outcomes of present 

and future CUNs. Without this information, further CUNs may not be assessable, as MBTOC 

will be unable to analyse the impact of national, subnational and local regulations and law as 

required in Decision XX/5. In many cases, MBTOC has proposed existing commercially and 

economically feasible alternatives and potential research and regulatory issues to Parties that 

could assist the phase out of MB. Parties are encouraged to review the new section in the 

Progress Report concerning economic analysis as guidance to improving the economic 

information in the CUNs. 

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

requested that, in cases where a nomination relies on the economic criteria of Decision IX/6, 

MBTOC’s report should explicitly state the central basis for the Parties economic argument 

relating to CUNs. 

10.2.3 Consideration of Stocks - Decision Ex.1/4 (9f) 

One criterion for granting a critical use under Decision IX/6 is that methyl bromide for the 

use “is not available in sufficient quantity and quality from existing stocks of banked or 

recycled methyl bromide” (para. 1 (b) (ii)). Parties nominating critical use exemptions are 

requested under decision Ex.I/4(9f) to submit an accounting framework with the information 

on stocks. Since the consideration of stocks is an active area of negotiation for the Parties, 

MBTOC has not made an adjustment to a nomination to account for stocks held and has 

relied on Parties to make this adjustment. 

In accordance with Decision XVIII/13(7), a summary of the data on stocks reported by the 

Parties from 2006 to 2009 for the preceding year and summarized in Table 10-1 to 10-5 

below. Parties may wish to consider this information in the light of Decision IX/6 1(b)(ii). 

Efficient functioning of commerce requires a certain level of “pipeline” stocks and additional 

stocks to respond to emergencies. Additionally, stocks may be held on behalf of other Parties 

or for exempt uses (feedstock and QPS uses). The correct or optimal level of stocks for 

virtually every input to production is not zero. 
May 2010 TEAP Progress Report 197

Table 10-1: Quantities of MB (metric tonnes) ‘on hand’ at the beginning and end of 2005, 

as reported by Parties in 2006/2007 under Decision XVI/6. 

Quantity of MB as reported by Parties (metric tonnes) 

Party Critical use 

exemptions

authorized 

by MOP for 

2005 

Amount 

onhand at 

start of 

2005 

QuantityAcqu

ired forCUEs 

in 2005 

production 

+imports) 

Amount 

available 

for use in 

2005 

Quantity 

used for 

CUEs in 

2005 

Amount 

on hand 

at the 

end of 

2005 

Australia 146.6 0 114.912 114.912 114.912 0 

Canada 61.792 0 48.858 48.858 45.146 3.712 

EC 4 392.812 216.198 2 435.319 2 651.517 2 530.099 121.023 

Israel 1 089.306 16.358 1 072.35 1 088.708 1 088.708 0 

Japan 748 0 594.995 594.995 546.861 48.134 

New 

Zealand 

50 6.9 40.5 47.4 44.58 2.81 

USA(a) 9 552.879 7 613 not reported 7 170 443 

(a) Additional information on stocks was reported on US EPA website, September 2006: MB inventory held 

by USA companies: 2004 = 12,994 tonnes; 2005 = 9,974 tonnes. 

Table 10-2: Quantities of MB ‘on hand’ at the beginning and end of 2006, as reported by 

Parties in 2007/2008 under Decision XVI/6. 

Quantity of MB as reported by Parties (metric tonnes) 

Party Critical use 

exemptions 

authorized 

by MOP for 

2006 

Amount on 

hand at 

start of 

2006 

Quantity 

acquired for 

CUEs in 2006 

(production + 

imports)

Amount 

available 

for use in 

2006 

Quantity 

used for 

CUEs in 

2006 

Amount 

at the end 

of 2006 

Australia 75.1 0 55.308 55.308 0 

Canada 53.897 3.713 41.969 45.682 44.114 1.568 

EC 3 536.755 114.953 1 462.747 1 577.700 1 558.557 19.114 

Israel 880.29 0 840.6 840.6 840.6 0 

Japan 741.4 70.735 488.81 559.545 540.207 19.338 

USA 8 081.753 9 974(a) 

443(b) 

6 924 16 898 6 425 8 170(c) 

(a) Amount of pre-2005 stock on hand. 

(b) Amount of stocks at the end of 2005 from production/imports specifically made for CUEs (acquired 

in 2005). 

(c) The sum of 499 tonnes of stocks produced/imported in 2006 specifically for CUEs, plus 7,671 

tonnes stocks acquired pre-2005. 
May 2010 TEAP Progress Report 198

Table 10-3: Quantities of MB ‘on hand’ at the beginning and end of 2007, as reported by 

Parties in 2008/2009 under Decision XVI/6. 

Quantity of MB as reported by Parties (metric tonnes) 

Party Critical use 

exemptions 

authorized 

by MOP for 

2007 

Amount on 

hand at 

start of 

2007 

Quantity 

Acquired for 

CUEs in 2007 

(production 

+imports) 

Amount 

available 

for use in 

2007 

Quantity 

used for 

CUEs in 

2007 

Amount 

on hand 

at the 

end of 

2007 

Australia 48.553 0 45.832 45.832 45.832 0 

Canada 52.874 0.897 38.073 38.970 38.622 0.348 

EC 689.142 31.635 484.842 516.477 508.031 8.446 

Israel 966.465 0 940.675 940.675 750.225 190.45 

Japan 636.172 23.417 479.290 502.707 485.113 17.594 

USA 6 749 7 671(a) 4 314 11 985 4 269 6 503(b) 

(a) Amount of pre-2005 stocks 

(b) The sum of 45 tonnes of stocks produced/imported in 2007 specifically for CUEs, plus 6,458 

tonnes stocks acquired pre-2005. 

Table 10-4: Quantities of MB ‘on hand’ at the beginning and end of 2008, as reported by 

Parties in 2009 under Decision XVI/6. 

Quantity of MB as reported by Parties (metric tonnes) 

Party Critical use 

exemptions 

authorized 

by MOP for 

2008 

Amount on 

hand at 

start of 

2008 

Quantity 

Acquired for 

CUEs in 2008 

(production 

+imports) 

Amount 

available 

for use in 

2008 

Quantity 

used for 

CUEs in 

2008 

Amount 

on hand 

at the 

end of 

2008 

Australia 48.450 0 41.037 41.037 41.037 0 

Canada 42.19 0.348 32.937 33.285 31.281 1.997 

EC 245.146 6.409 206.146 212.555 212.463 0.092 

Israel Reported incomplete information 

Japan 443.775 24.467 392.994 417.461 409.937 7.524 

USA 5 336 1 730 

6458(a) 

3 036 9464 4 083 5381(b) 

269(c) 

(a) Amount of pre-2005 stocks 

(b) Includes the pre-2005 stocks 

(c). Amount of unused allocation for CUEs which will be reduced from following years production 
May 2010 TEAP Progress Report 199

Table 10-5: Quantities of MB ‘on hand’ at the beginning and end of 2009, as 

reported by Parties in 2010 under Decision XVI/6. 

Quantity of MB as reported by Parties (metric tonnes) 

Party Critical use 

exemptions 

authorized 

by MOP for 

2009 

Amount on 

hand at 

start of 

2009 

Quantity 

Acquired for 

CUEs in 2009 

(production 

+imports) 

Amount 

available 

for use in 

2009 

Quantity 

used for 

CUEs in 

2009 

Amount 

on hand 

at the 

end of 

2009 

Australia 37.61 0 33.278 33.278 33.278 0 

Canada 39.1 1.997 30.276 30.276 23.8 6.38 

EC 

Israel Not Reported 

Japan 305.380 11.882 278.616 290.498 286.532 3.966 

USA Not Reported 

10.2.3.1 Stocks 

TEAP notes that the amount of MB stocks held by the US at the end of 2008 is still 

substantially greater than the total critical use allocation in a given year. In 2006, the US 

predicted that pre 2005 stocks for preplant soil uses would be exhausted by 2009, yet a major 

proportion of the pre 2005 stocks could still be available. TEAP notes that the US has made 

allowances for some of the use of these stocks as critical allowances for CUNs and suggests 

that Parties may wish to seek clarification on how the remaining stocks will be apportioned. 

10.2.4 Reporting of MB Consumption for Critical Use - Decision XVII/9 

Decision XVII/9(10) of the 17th MOP requests TEAP and its MBTOC to “report for 2005 and 

annually thereafter, for each agreed critical use category, the amount of methyl bromide 

nominated by a Party, the amount of the agreed critical use and either: 

(a) The amount licensed, permitted or authorised; or 

(b) The amount used 

Since the start of the CUN reviews in 2003, MBTOC has provided the amounts of MB 

nominated and agreed for each critical use (Annexes III and IV). Not all Parties supply data 

under Table 2 of the accounting framework, set out on p. 65 of the Handbook on Critical Use 

Nominations (version 6 of December 2007). Data reported here for (a) and (b) above is thus 

incomplete. 

Tables and figures in this report (Table 10-4, Figures 10-1 and 10-2) show the nominated MB 

amounts and the apparent rate of reduction in MB or adoption of alternatives achieved by 

Parties. It should be noted that for those countries that have pre-2005 stocks of MB that are 

being drawn down, the reductions in CUEs from year to year cannot be taken directly as 

evidence of alternative adoption since pre-2005 stocks may have been sold into the same 

sectors. Table 10-7 and 10.8 in particular shows the amounts nominated and approved for 

‘Critical Use’ in 2011 and 2012 for preplant soil use by Party. 
May 2010 TEAP Progress Report 200

10.2.5 Trends in Methyl Bromide Use for CUEs since 2005 

As part of the requirements of Decision XVII/9, trends in phase out by Parties are shown 

below. Since 2005, there has been a progressive trend by all Parties to reduce their 

nominations for consumption for preplant soil uses and post harvest uses, although this has 

occurred at different rates. Figs 10-1 and 10- 2 show the trends in the reduction in amounts 

approved/nominated by Parties for ‘Critical Use’ from 2005 to 2012 for some key uses. The 

complete trends in phase out of MB by country, as indicated by change in CUE, are shown in 

Annexes V and VI. 
May 2010 TEAP Progress Report 201

Figure 10-1: Amounts of MB exempted for CUE uses in preplant soil industries from 2005 

to 2011. Solid lines indicate the trend in CUE methyl bromide. Dashed lines indicate 

quantity of MB nominated by the Parties in either 2011 or 2012. 

Cucurbits and Melons

0

200

400

600

800

1000

1200

1400

2005 2006 2007 2008 2009 2010 2011 2012

Year

metric tonnes

France

Greece

Israel

Italy

Japan

USA

 

Cutflowers

0

50

100

150

200

250

300

350

400

2005 2006 2007 2008 2009 2010 2011 2012

Year

metric tonnes

Australia

Belgium

France

Greece

Israel

Italy

Portugal

Spain

USA

Orchard Replant

0

100

200

300

400

500

600

700

800

2005 2006 2007 2008 2009 2010 2011 2012

Year

metric tonnes

France

USA

 

Peppers and Eggplant

0

200

400

600

800

1000

1200

1400

2005 2006 2007 2008 2009 2010 2011 2012

Year

metric tonnes

Belgium

France

Italy

Japan

Spain

USA

Strawberry Fruit

0

500

1000

1500

2000

2500

2005 2006 2007 2008 2009 2010 2011 2012

Year

metric tonnes

Australia France Israel Italy New Zealand Spain UK USA

Tomatoes

0

500

1000

1500

2000

2500

3000

3500

2005 2006 2007 2008 2009 2010 2011 2012

Year

metric tonnes

Belgium Greece

Italy USA
May 2010 TEAP Progress Report 202

Figure 10-2: Amounts of MB exempted for CUE uses in mills and food processing facilities 

from 2005 to 2012. Solid lines indicate trend in CUE methyl bromide. Dashed lines 

indicate quantity of MB nominated by the Party in either 2011 or 2012. 

 Food Processing and Mills

0

100

200

300

400

500

600

2005 2006 2007 2008 2009 2010 2011

Year

metric tonnes

Belgium

Canada

France

Germany

Greece

Israel

Italy

UK

USA
May 2010 TEAP Progress Report 

Table 10-6: Summary of Critical Use Nomination (2005 – 2012 in part) and Exemption (2005 – 2011 in part) for Amounts of MB GCUN/CUE Process. (Note: A breakdown of CUN and CUE amounts by sector is given in Annex III and IV) 

 Quantities Nominated Quantities Approved  2005 2006 2007 2008 2009 2010 2011 2012 2005 

(1ExMOP 

and 

16MOP) 

2006 

(16MOP+ 

2ExMOP+ 

17MOP) 

2007 

(17MOP + 18MOP) 

2008 

(18MOP

+ 

19MOP)

2009 

(19MOP)

20

(20M

+ 

21M

Australia 206.950 81.250 52.145 52.900 38.990 37.610 35.450 34.660 146.600 75.100 48.517 48.450 37.610 36Canada 61.992 53.897 46.745 42.241 39.115 35.080 19.368 

+3.529 

16.281 61.792 53.897 52.874 36.112 39.020 30

+3

European Community1 5754.361 4213.47 1239.873 245.00 0 0 0 0 4392.812 3536.755 689.142 245.146 0 Israel 1117.156 1081.506 1236.517 952.845 699.448 383.700 232.247 * 1089.306 880.295 966.715 860.580 610.854 290Japan 748.000 741.400 651.700 589.600 508.900 288.500 249.420 221.104 748.000 741.400 636.172 443.775 305.380 267New Zealand 53.085 53.085 32.573 0 0 0 0 0 50.000 42.000 18.234 0 0 Switzerland 8.700 7.000 0 0 0 0 0 0 8.700 7.000 0 0 0 USA 10753.997 9386.229 7417.999 6415.153 4958.034 3299.490 2388.128 1181.779 9552.879 8081.753 6749.060 5355.976 4261.974 3232

+2

TOTALS 18704.241 15617.837 10677.552 8297.739 6244.487 4044.380 2928.142 1453.824 16050.089 13418.200 9160.714 6990.039 5,254.838 3572

2005 – Belgium, France, Germany, Greece, Italy, Netherlands, Poland, Portugal, Spain, and the United Kingdom. 2006 – Belgium, France, Germany, Greece, Ireland, Italy, Latvia, Malta, Netherlands, Poland, Portugal, Spain, and the United Kingdom. 2007 – France, Greece, Ireland, Italy, Netherlands, Poland, Spain, and the United Kingdom 2008 – Poland, Spain 

* Not yet available. 1 Members of the European Community which had CUNs/CUEs included: 
204 May 2010 TEAP Progress Report 

10.2.6 Evaluations of CUNs – 2010 round for 2011 and 2012 exemptions 

All three sub committees of MBTOC met together at the Agricultural Research and Education 

Center (IFAPA) in Chipiona, Spain from 12 through 16 April 2010 to conduct a review of 

CUNs as requested by Parties, to update reports, discuss issues of registration of alternatives 

and other matters. Three MBTOC economists attended the meetings, spending time in each 

subcommittee. MBTOC welcomed a new economist member from New Zealand who has 

expertise in economic issues related to MB use for QPS. MBTOC also welcomed one new 

member for the QPS subcommittee. 

The meetings were held as required by the time schedule for considerations of CUNs given in 

Annex I referred to in Decision XVI/4. Consensus decisions were made in subcommittees, but 

all comments made by members were considered in final recommendations. Outcomes from 

deliberations by the MBTOC Soils and MBTOC Structures and Commodities subcommittees 

were discussed in plenary and via electronic communication as part of the process of reaching 

consensus within the whole committee. 

During the meeting MBTOC S held a bilateral meeting with the US delegation and the 

Californian Strawberry Commission and MBTOC-SC had a bilateral with the US delegation. 

One Party (Israel) submitted nominations for preplant soil use in the 2011 round and four 

Parties (Australia, Canada, Japan, and the USA) submitted nominations for both preplant soil 

use and post harvest use in 2012. Australia also submitted a supplementary CUN for preplant 

soil use. Israel did not submit a nomination for dates. Canada’s nominated amounts for post 

harvest in one sector for both 2011and 2012. All these Parties have submitted nominations in 

previous CUN rounds. The total number of 36 nominations was submitted by five Parties and 

was the same number as in the last round. In 2008, Japan indicated in correspondence prior to 

the 28th OEWG that it plans to phase out all preplant soil uses of MB by 2013 and in April 

2010, Israel indicated it would not be submitting any further CUN nominations after this round. 

MBTOC SC has been informed that Japan will submit a phase out plan for its postharvest MB 

use later this year. 

In Structures and Commodities, Parties continue to make progress on CUNs, reducing many 

MB uses by continuing to resolve the inter-related issues of treatment logistics, costs, trade 

demands and effectiveness of alternatives. But unfortunately, in the case of the majority of 

CUNs for structures and commodities, progress in adopting alternatives has stalled. In this 

interim report, MBTOC has recommended reductions in many of the CUNs as described below. 

MBTOC informs the Parties that without an increased research focus, regulatory approvals of 

alternatives and a commitment to requiring the use of the alternatives that are available, CUNs 

may well persist at current levels for several years or longer. 

MBTOC has sometimes recommended quantities of MB for 2011 or 2012 which are different 

from those nominated. The grounds used for these recommendations are given in detail after 

the relevant CUNs in Tables 10-12 and 10-13. The adjustments for preplant soils use may in 

part be to account for presumptions given in Tables 10-9 and 10-10. 

In paragraph 20 of Annex 1 referred to in Decision XVI/4, Parties, among other things, 

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

statement relating to CUNs. Tables 10-12 and 10-13 provide this information for each CUN. 

This information was prepared by MBTOC economists. 

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

alternatives, scale-up of alternatives, economic issues and, to a much smaller degree, the 

technical unavailability of alternatives. In structures and commodities CUNs noted considerable 

concern about switching from methyl bromide to sulfuryl fluoride given the SF’s high GWP. 
May 2010 TEAP Progress Report 205

This situation is discussed further in the Progress Report. For the most part, technical 

alternatives exist. Additionally, MBTOC notes that some Parties continue to struggle with the 

ability to adapt previously identified alternatives to their circumstances, within their definition 

of economic feasibility. 

10.2.7 Critical Use Nominations Review 

In considering the CUNs submitted in 2010, as in previous rounds, both MBTOC 

subcommittees applied the standards contained in Annex I of the final report of 16 MOP, and, 

where relevant, the standard presumptions given below. In particular MBTOC sought to provide 

consistent treatment of CUNs within and between Parties while at the same time taking local 

circumstances into consideration. 

In evaluating the CUNs for soil treatments, MBTOC used the standard presumptions set out in 

Table 10-9 and assumed that a technically feasible alternative to MB would need to provide 

sufficient pest and/or weed control for continued production of that crop to existing market 

standards. 

For commodity and structural applications, it was assumed that technically and economically 

feasible alternatives 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, while ensuring the 

costs were economically feasible in the context of that nomination, to the extent that could be 

determined. 

Unless otherwise indicated, the most recent CUE approved by the Parties for a particular CUN 

was used as baseline for consideration of continuing nominations. 

10.2.8 Disclosure of Interest 

As in the past, all MBTOC members have prepared disclosure of interest forms relating 

specifically to their level of national, regional or enterprise involvement for the 2010 CUN 

process, according to a standardised format developed by TEAP. The Disclosure of Interest 

declarations can be found on the internet at 

http://ozone.unep.org/Assessment_Panels/TEAP/index.shtml. As in previous rounds, some 

members withdrew from a particular CUN assessment or only provided technical advice on 

request for those nominations where a potential conflict of interest was declared. 

10.3 MBTOC Soils: Final Evaluations of 2010 Critical Use Nominations for 

Methyl Bromide

10.3.1 Summary of outcomes 

In the 2010 round, 27 CUNs were submitted for soil uses, 9 for 2011 and 18 for 2012. A further 

supplementary CUN was submitted by Australia for the strawberry runner sector in 2011 for 

5.95 tonnes. Interim recommendations were made on all nominations, which were for 238.197 

tonnes for 2011 and 1271.649 tonnes for 2012. The recommended amounts totalled 230.447 

tonnes for 2011 and 1164.452 t for 2012 (Tables 10-7 and 10-8). 

MBTOC acknowledged the substantial reductions made by Israel and USA in this round and the 

action plans to phase out MB in Israel by the end of 2011 and for Japan by the end of 2012. 
206 May 2010 TEAP Progress Report 

Table 10-7: Summary of MBTOC S final recommendations for 2011 and 2012 by country for 

CUNs received in 2010 for preplant soil use of MB (tonnes)

CUE approved at 21st

MOP 

CUN for 2011 and 2012 MBTOC-S Interim 

Recommendation 

Country 

2010 2011 2011 2012 2011 2012 

Australia 23.840 5.950 29.790 5.950 29.760 

Canada 5.261 5.261 5.261 

Israel 290.878 232.247 224.497 

Japan 224.451 216.120 216.120 

USA 1977.830 1020.478 913.311 

Total 290.878 238.197 1271.649 230.447 1164.452 
May 2010 TEAP Progress Report 207

Table 10- 8: Summary of the interim recommendations by MBTOC S (in square brackets) for 

CUE’s for preplant uses of MB (tonnes) for 2011 and 2012 submitted in the 2010 round. 

10.3.2 Issues related to CUN Assessment for Preplant Soil Use 

Key issues which influenced assessment and the need for MB for preplant use of MB in the 

2010 round were: 

i) Increased adoption and registration of methyl iodide (MI or iodomethane) with 

barier films in most states of the USA (not California) in mid 2008 which has led to 

commercial adoption on large sale areas in the US and substantial reduction in the 

US nominations in SE and Florida. 

ii) Continued and progressive acceptance of a 3 way fumigant strategy (1,3-

dichloropropene, metham sodium, Pic) as being effective for nutsedge and pathogen 

control in USA. 

Years 

Country and Sector 2011 2012 

1. Australia 

1. Strawberry runners [5.95] [29.760] 

2. Canada 

1.Strawberry runners [5.261] 

3. Israel 

1. Broomrape protected 

2. Cucumber 

3. Cut flowers open field 

4. Cut flowers& bulbs protected 

5. Melon protected & open field 

 6. Strawberry fruit - Sharon and Gaza 

7. Strawberry runners - Sharon and Gaza 

8. Sweet potatoes 

TOTAL 

[12.500] 

[12.500] 

[23.292] 

[52.335] 

[35.000] 

[41.875] 

[27.000] 

[20.000] 

[224.497] 

4. Japan 

1. Cucumber 

2. Ginger open field 

3. Ginger protected 

4. Melon 

5. Pepper green & hot 

6. Watermelon 

TOTAL 

[26.162] 

[42.235] 

[6.558] 

[67.936] 

[61.154] 

[12.075] 

[216.120] 

5. USA 

1. Cucurbits 

2. Eggplants (field) 

3. Forestry nursery 

4. Nurseries stock: fruits, nuts & flowers 

5. Orchard replant 

6. Ornamentals 

7. Pepper (field) 

8. Strawberry (field) 

9. Strawberry runners 

 10. Sweet potatoes 

 11. Tomatoes (field) 

TOTAL 

[59.500] 

[6.904] 

[34.230] 

[1.591] 

[18.324] 

[48.164] 

[206.234] 

[756.515] 

[3.752] 

[8.709] 

[54.423] 

[1020.478] 
208 May 2010 TEAP Progress Report 

iii) Changing regulations on key alternatives, particularly 1,3-D township caps and 

buffer zones on 1,3-D, metham sodium and Pic used alone or in mixtures. 

iv) Introduction of a new formulation of 1,3-D/Pic (Picchlor 60) in the USA which 

increases the use of 1,3-D in areas affected by township caps. 

v) Effect of restrictions on use of high rates of Pic (greater than 200 kg/ha (20 g/m2

)) in 

some counties of California. 

vi) Lack of acceptance in specific sectors that alternatives exist, e.g. orchard replant in 

heavy soils, and nursery industries. 

In this round, the US indicated that it had reclassified further quantities into QPS for the forest 

nursery sector. Israel indicated an intention to no longer seek CUNs beyond this round (ie. 

from 2011 onwards) and in previous rounds Japan has indicated it will no longer seek any 

nominations beyond 2012. 

In the 2010 round, MBTOC also used adoption data of alternatives in specific regions where it 

was available, such as the Californian Department of Pesticide Regulation commodity and 

pesticide data to help with assessment. 

MBTOC continues to urge Parties to consider review of regulations covering the registration, 

use and adoption of alternatives, particularly review of barrier films to reduce dosage rates of 

MB and the alternatives, and associated emissions. As in the previous round, Parties have 

found alternatives more difficult to adopt for propagation materials, such as strawberry runners 

and nurseries. There is a lack of research studies to develop and demonstrate effectiveness of 

alternatives in these sectors. This lack of research effort leads MBTOC to conclude that several 

of the CUNs do not to fully satisfy the requirements of Decision IX/6 and urges Parties to 

increase studies in these sectors. The impact of current reviews of VOC emissions in California 

may also have a major impact on the use of MB and alternatives. 

MBTOC also notes that a large proportion of MB has been nominated for uses where 

regulations or legislation prevent reductions of MB dosage. For many uses, the mandatory use 

of MB is specified at a high dosage for either treatment of certified propagation material or 

because regulations prevent use of barrier films which otherwise could have reduced the MB 

dosage rate. Also regulations on the use of alternatives are preventing their uptake for a 

substantial proportion of the remaining CUNs for preplant soil use. MBTOC urges the Parties 

to align their local policies and regulations with internationally accepted methodologies and to 

allow use of MB alternatives that lie within the Montreal Protocol’s goals. 

10.3.2.1 Registration of alternatives for preplant uses - Decision Ex I/4 (9i) and (9j) 

Decision Ex. I/4 (9i) requires MBTOC “To report annually on the status of re-registration and 

review of methyl bromide uses for the applications reflected in the critical-use exemptions, 

including any information on health effects and environmental acceptability”. Further, Decision 

Ex I/4 (9j) requires MBTOC “To report annually on the status of registration of alternatives 

and substitutes for methyl bromide, with particular emphasis on possible regulatory actions 

that will increase or decrease dependence on methyl bromide”.

Methyl iodide, a major alternative to MB, is now registered in all but three states in the United 

States, including the south east region and Florida for field-grown ornamentals, peppers, 

strawberries and tomatoes. (Registration is still pending in California, Washington and New 

York states). This registration has been expanded in 2009 and includes strawberries, tomatoes, 

peppers, ornamentals, stone fruits, nut crops, vine crops (including table and wine grapes), turf, 

conifer trees and nursery crops. Trials with MI continue being conducted in Japan, Australia, 

New Zealand, Turkey, Morocco, South Africa, Israel, Italy, Costa Rica, Guatemala, Brazil, 

Mexico and Chile, and the registration process is proceeding in most other countries applying 

for CUEs, including Australia, Israel and Japan. To ensure that the mitigation measures for MI 
May 2010 TEAP Progress Report 209

will be consistent with the measures being required for the other fumigants, the label 

requirements are presently being reexamined in the USA. 1,3-dichloropropene, may be subject 

to similar provisions when the soil fumigants are evaluated together again in 2013. 

The EC has further reported that registration for 1,3-D and other alternatives including 

chloropicrin, dazomet and metham sodium are under review. A grace period for the registration 

of 1,3-D became due on 20 March 2009 and was extended, but its future registration is 

uncertain. 

A number of other chemicals which may be alternatives to MB are being considered for 

impending registration in specific countries recently, including dimethyl disulphide (DMDS) in 

Europe and the USA and MI in Australia respectively. 

10.3.2.2 Update on rates of adoption of alternatives for preplant uses - Decision XIX/9 

As of the 2010 round, Decision XIX/9 para. 3 requests: ‘ the Technology and Economic 

Assessment Panel to ensure that recent findings with regard to the adoption rate of alternatives 

are annually updated and reported to the Parties in its first report of each year and inform the 

work of the Panel’. 

Technical alternatives (Porter et al, 2006) exist for almost all uses requesting CUNs, but uptake 

of alternatives varies between countries, crops and the pest pressure. In general similar 

alternatives are being adopted by the same sectors throughout a number of countries, although 

the rate of adoption has varied depending on regulations on their use, differences in registration 

between countries and other market forces. In this round as in previous rounds of CUNs, 

MBTOC has recognised that time is needed to effect phase-in of alternatives and has accepted 

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

IX/6. 

Figures 10-1and 10-2 in this report show the apparent reduction rates for MB use achieved by 

many Parties in a number of key sectors. As noted above, true reduction and adoption rates may 

vary from the rate of change of CUN/CUE because of factors such as use of stocks or transfer 

of approved MB between categories The CUN reviews presented in Table 10-12 also provide 

detail of some of the key alternatives that Parties have and should consider to further replace 

MB for the remaining uses. 

Further guidance from the Parties, particularly Australia, Canada and the US of expected rates 

of adoption of alternatives following registration, would assist MBTOC in evaluation of CUNs 

in future. 

10.3.2.3 Sustainable alternatives for preplant uses 

For preplant soil uses of MB, the regulatory restrictions on 1,3-dichloropropene and Pic are 

preventing further adoption of these products in the USA, particularly California and this is 

putting pressure on industries to retain MB. 

MBTOC urges Parties to consider the long term sustainability of treatments adopted as 

alternatives to MB, to continue to adopt environmentally sustainable and safe chemical and 

non-chemical alternatives for the short to medium term and to develop sustainable IPM or nonchemical approaches for the longer term. Decision IX/6 1(a)(ii) refers to alternatives that are 

‘acceptable from the standpoint of environment and health’. MBTOC has consistently 

interpreted this to mean alternatives that are registered or allowed by the relevant regulatory 

authorities in individual CUN regions, without reference to sustainability. On occasion of this 
210 May 2010 TEAP Progress Report 

meeting, MBTOC was able to visit flower growers in Southern Spain who have successfully 

adopted biodisinfestation as an efficient and sustainable alternative to MB. 

10.3.3 Standard presumptions used in assessment of nominated quantities. 

The tables below (Tables 10-9 and 10-10) provide the standard presumptions applied by 

MBTOC Soils for this round of CUNs. These standard presumptions were first proposed in the 

MBTOC report of October 2005 and were presented to the Parties at 17th MOP. Studies and 

reports to support them have been provided in previous reports and were revised for some 

sectors after consideration by the Parties at the 19th MOP. The rates and practices adopted by 

MBTOC as standard presumptions are based on maximum rates considered acceptable by 

published literature and actual commercial practice. 

As in the evaluations in previous years, MBTOC considered reductions to quantities of MB in 

particular nominations to a standard rate per treated area where technical evidence supported its 

use. As a special case, MBTOC continues to accept a maximum rate of 200 kg/ ha (20 g/m2

) 

with high Pic-containing mixtures with barrier films for certified nursery production, unless 

regulations prescribed higher rates. However, studies have indicated that rates of 200 kg/ha 

(20g/m2

) or less of MB: Pic 50:50 were effective with barrier films for production of ‘certified’ 

nursery material. 

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. 
May 2010 TEAP Progress Report 211

Table 10-9: Standard presumptions used in assessment of CUNs for the 2009 round – soil 

treatments. 

Comment CUN adjustment Exceptions 

1. Dosage rates Maximum guideline rates for 

MB:Pic 98:2 are 25 to 35 g/m2 with 

barrier films (VIF or equivalent); 

for mixtures of MB/Pic are 12.5 to 

17.5 g MB/m2

 for pathogens and 

nutsedge respectively, under barrier 

films depending on the sector. All 

rates are 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, TIF) 

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 Pic (Pic) is not 

registered 

4. MB/Pic 

Formulation: 

Weeds/nutsedge 

ass 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 Pic or Pic-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, 

emission regulations on MB, 

or open field production of 

high health propagative 

material 

Table 10-10. Maximum dosage rates for preplant soil use of MB by sector used in the 2009 

round (standard presumptions).

Maximum MB Dosage Rate (g/m2) in MB/Pic mixtures (67:33, 50:50) 

Film Type considered effective for:

Strawberries and 

Vegetables 

Nurseries* Orchard Replant Ornamentals 

Barrier films - 

Pathogens 

12.5 15 15 15 

Barrier films - 

Nutsedge 

15.0 17.5 17.5 17.5 

No Barrier films 

– Pathogens 

20 20 20 20 

No Barrier films - 

Nut sedge 

26 26 26 26 

* Maximum rate unless certification specifies otherwise 
212 May 2010 TEAP Progress Report 

10.3.4 Adjustments for standard dosage rates using MB/Pic formulations 

One key transitional strategy to reduce MB dosage has been the adoption of MB/Pic 

formulations with lower concentrations of MB (e.g. MB/Pic 50:50, 45:55 or less). These 

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

formulations containing higher quantities of MB (e.g. 98:2, 67:33) (e. g. Porter et al., 1997 and 

2006; Melgarejo et al., 2001; López-Aranda et al., 2003; Santos et al., 2007; Hamill et al.,

2004; Carey and Godbehere, 2004; Gilreath and Santos, 2005; Hanson et al., 2006). Parties are 

urged to consider even lower dosage rates of MB for the remaining CUNs. This includes rates 

as low as 75 kg/ha (7.5 g/m2

) with mixtures of 30:70 or 33:67 mixtures (at 250 kg/ha) or 100 

kg/ha (10 g/m2

) of MB in 250 kg/ha of 50:50 MB/Pic mixtures in conjunction with barrier films 

(Table 10-11). 

Table 10-11: Actual dosage rates applied during preplant fumigation when different rates 

and formulations of MB/Pic mixtures are applied with and without barrier films. Rates of 

application reflect standard commercial applications rates. 

MB/Pic formulation (dose of MB in g/m2 Commercial ) 

application 

rates of 

formulation 98:2 67:33 50:50 30:70 

A. With Standard Polyethylene Films 

400 39.2 26.8 20.0 12.0 

350 34.3 23.5 17.5 10.5 

300 29.4 20.1 15.0 9.0 

B. With Low Permeability Barrier Films (LPBF) 

250 24.5 16.8 12.5 7.5 

200 19.6 13.4 10.0* 6.0 

175 17.2 11.8 8.8 5.3 

* Note: Trials from 1996 to 2008 (Annex III) show that a dosage of 10g/m2 (e.g. MB/Pic 50:50 at 

200kg/ha with LP Barrier Films) is technically feasible for many situations and equivalent to the 

standard dosage of >20g/m2 using standard PE films 

10.3.5 Use/Emission reduction technologies - Low permeability barrier films and 

dosage reduction 

Decision XXI/11 (para 9) requested further reporting on Decision IX/6 to ensure Parties 

adopted emissions controls where possible. For preplant soil use, this includes the use of 

barrier films and lowest effective dose of MB with mixtures of chloropicrin. Other methods 

include deep shanking and use of ammonium thiosulphate and different irrigation technologies 

(Yates et al 2007). These latter technologies have not been reported or adopted widely by 

Parties and need to be evaluated more widely for future CUN uses. 

In south east USA the reported use of barrier films in vegetable crops has expanded to over 

20,000 hectares and it is also exclusively used with the alternative MI to assist its effectiveness 

at low dosage rates (Allan, pers. comm., 2008; Chism, pers.comm, 2009). An exception to the 

adoption of barrier films is in the State of California in the USA where a regulation currently 

prevents use of barrier films with MB (California Code of Regulations Title 3 Section 6450(e)), 

but not with the alternatives. Barrier films are consistently improving the performance of 

alternatives at lower dosage rates. 
May 2010 TEAP Progress Report 

Table 10-12: Final evaluations of CUNs for preplant soil use submitted in 2010 for 2011 or 2012 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

Australia Strawberry runners 35.750 37.500 35.750 35.750 29.790 29.790 23.840 5.95 29

MBTOC comments 2010:

MBTOC recommends the supplementary nomination of 5.95 tonnes of MB for use in 2011. The second year of a 2-year study showed t

did not adequately control root and crown rot on the Festival variety and currently could not be used as it is not registered. Therefore the was accepted for the 2011 nomination. MBTOC recommends a reduced CUE of 29.760 tonnes for use in 2012. The reduction by MBTOC is based on adoption of the soilless pgeneration. The key pests affecting strawberry runner production are fungi (Phytophthora, Pythium, Rhizoctonia, Verticillium spp.) and wRaphanus spp., Poa annua, Cyperus spp). The CUN states that MB:Pic 50:50 at an MB dose of 25 g/m2 is required to meet certification 

exceeds MBTOC’s standard presumption of 20 g/m2, but this rate continues to remain unregistered. The Party’s first 2-year effort using 

resulted in unsatisfactory results in the second year of testing. The Party has indicated, however, that it is initiating a second 2-year trial 

which should be completed in September 2011. The Party states that the most promising alternative, MI/Pic has been demonstrated in ccompare with the efficacy to MB:Pic. The registrant has indicated that additional data has been requested by the national registration ausubmitted this year and should lead to registration in 2011. If MI:Pic is available, it would allow for further reduction of the nomination. A considered ineffective due to phytotoxicity and doubling of plant back times in the heavy and wet soil conditions in the high elevation regthe Victorian Strawberry Certification Authority (VSICA) completed the second year of a 2-year development program for soil-less systemstrawberry runners. Results indicated that the productivity of the soil-less system is similar to the current method of production in MB:Pic of the soil-less system compares favourably with the current method of production. VSICA plans to establish a commercial facility by 20eliminate VSICA’s need for MB for foundation stock in 2011/2012. MBTOC suggests the following actions by the Party: (1) Report the firof 20 g/m2 of MB with its next CUN submission and report to MBTOC the tentative second year results by August 2011; (2) Provide a com

registration status of MI and EDN, (3) Provide the results from the new trials using recaptured MB & Pic as well as a comprehensive plan Since the production of 60,000 foundation generation plants has been found to be economically feasible, the Party needs to provide the their assertion that any further expansion in future generations is not economically feasible, (5) consider other methods (new barrier filmsemission controls. MBTOC comments on economics 2010: The nomination states “The second part of a two year trial that evaluated the economic and biological feasibility of production of foundaticomplete. It compared productivity with the status quo system of production in MB:Pic treated soil in insect proof cages. Results confirm feasibility of adopting the soil-less system for production of the foundation generation of runners (A1).” The CUN further states “The eco

favourably with the current methods of production.” Comments requested in Dec. XX1/11 (para 9)

• Dec. IX/6 b(i) Emission control: No, barrier films are not being used and the regulations require higher MB rates of use than t

Standard LDPE films are still used because they are reported to perform the same as barrier films in the cold temperatures and heavy w
214 May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

production and the Party states that barrier films provide no further effectiveness. • Dec. IX/6 b(iii) Research program: Yes, ongoing research is being conducted in (a) supporting reduced application rates of Mof MI; unknown for EDN; (c) use of recaptured MB & Pic. • Dec. IX/6 b(iii) Appropriate effort: The nomination demonstrates a research effort with a number of key alternatives, but comm

confronted with significant regulatory obstacles 

Strawberry runners (PEI) 

Canada 6.840 6.840 7.995 7.462 7.462 7.462 5.261 - 5.2

MBTOC comments 2010: MBTOC recommends 5.261 tonnes for this use in 2012. The CUN for 2012 is based on a reduced rate for MB of 20 g/m2, and MBTOC ain the absence of formal registration for this dose rate. The Party has attempted to replace MB with 1,3-D, but 1,3-D was banned for use 2003 due to ground water contamination. Chloropicrin (PIC 100) has been registered by PMRA, but the PEI authorities have denied a pewater testing has been conducted. MI registrant has not applied for registration in Canada. The company has also been testing organic different varieties. Reduced yields resulted (yield reductions ranged from 40% - 70%). One variety using the organic production system conventional production. Organic trials continued in 2009. While MB:Pic 67:33 @ 500 kg/ha is the only use rate registered for strawberry standard presumption of 200 kg/ha, the grower petitioned PMRA to use a lower rate under barrier films. PMRA, in the absence of a formpermission to use a lower rate, but at the grower’s own risk and liability. In 2008 the grower tested two plots totalling 2.4 ha using 25% & and expanded the area tested in 2009. The results were comparable using the reduced rates with barrier films. The CUN for 2012 is basof 200 kg/ha for the entire area to be fumigated. For future submissions, MBTOC suggests actions for the Party to (1) complete the neceobtain the PIC 100 permit and (2) test the adoption of soilless cultures for at least part of the production cycle, (3) consider MI. MBTOC comments on economics 2010: The nomination was not based on economic arguments. Comments requested in Dec. XX1/11 (para 9)

• Dec. IX/6 b(i) Emission reduction: Yes, uses barrier films with reduced application rate of MB conforming to MBTOC’s presum• Dec. IX/6 b(iii) Research program: Yes, focus has been on organic production testing, but trials with MI not being conducted. 

Dec. IX/6 b(iii) Appropriate effort: The Party demonstrates an active research program and is seeking registration of PIC100 
May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

Israel Broomrape None None 250.000 250.000 125.000 12.500 - 12.500 

MBTOC comments 2010:

MBTOC recommends 12.500 tonnes for this use in 2011. The nomination is for a specific species of broomrape (A. aegyptica) greenhou

is additional to the outdoor field nominations in previous years. MB use for a national broomrape eradication on outdoor field crops has byears 2007, 2008, 2009 and 2010, however the allocated amounts have not been utilized. It is MBTOC’s understanding is that previous 

has not been produced, and therefore is unavailable for this nomination. In the the 2010 nomination, the Party confirms that Telon EC is the control of O. aegyptica the main species parasitizing tomato however the registration is unclear and use may not be resolved for all s

a stand alone application or in sequential application with MS suppresses broomrape when applied under plastic sheets through the drip greenhouses. The Party has also identified some alternatives for controlling low infestations of Orobanche (e.g. solarization). In addition MBTOC has identified other alternatives, such as Sulfonylurea, imazapic, and imazomox (Eizenberg et al, 2004), (Abanga et al., 2007; N

Barrier films are used to reduce rates by 50% and also emissions. The Party discusses an on-going research program in the nominationMBTOC comments on economics 2010: The nomination states that since an eradication program is being proposed, the standard format of an economic evaluation is not appropsupporting evidence, that biological control of broomrape with either the aid of a parasitic fly or with Fusaria do not provide economic ansMBTOC takes note of these statements in light of the fact that the nomination is not based on economic arguments. Comments requested in Decision XXI/11 (para 9)

 Dec. IX/6 b(i)- Emission Reduction: Yes, the Party is using barrier films and standard rates.

 Dec. IX/6 b(iii)- Research Program: No, the research is supposedly on-going, but is not reported in the nomination. 

 Dec. IX/6 b(iii)- Appropriate Effort: Israel has indicated that it will no longer be applying for CUE’s after 2011. 

Cut flowers-bulbsprotected Israel 303.000 240.000 220.185 114.450 85.431 63.464 - 52.955 

MBTOC comments 2010:

MBTOC recommends uced amount of 52.330 tonnes for this use in 2011. MBTOC does not approve use for MB on substrates being 0.6

2012 the Party will totally phase out MB uses. There is very little change from nominations submitted in previous years, particularly in 20still based on transitional measures – high barrier films with reduced rates. In spite of this, registration of certain alternatives such as metexpanded to additional flower types. More expansion of registration is expected this year. Substrate production protocols are now availathey claim they are yet to be developed ("artificial" production is not critically impacted by local conditions and this makes experiences fronotes the Party has adjusted MB dosages used for carnations grown in Ghaza to 25 g/m2. MBTOC is aware that carnation cultivars resis

and commercially used and accepted by international markets. 
216 May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

MBTOC comments on economics 2010: No economic arguments are provided in the nomination. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes, barrier films are currently used in protected flowers and rates conform with MBTOC’s 

 Dec IX/6 b(iii) Research program: No. Poor to no research have been conducted on alternatives. This appears to be an orph

methyl bromide program and is dependent on research from other sectors.  Dec. IX/6 b(iii) Appropriate effort: Israel has indicated that it will no longer be applying for CUE’s after 2011. 

Cut flowers-open field 

Israel 77.000 67.000 74.540 44.750 34.698 28.554 - 23.292 - 

MBTOC comments 2010:

MBTOC recommends the nominated amount of 23.292 tonnes for this use in 2011. The nominated amount was an 18% reduction over t

MBTOC recognizes that in 2012 the Party will totally phase out MB uses. Overall, due to the MB phase out stated by the Party, there is vsubmitted in previous years, particularly in 2009 and 2010. Phase-out efforts are still based on transitional measures - barrier films with rnomination is for open field production of cut flowers, which are mainly affected by weeds (Cyperus spp in particular) and nematodes (ro

as Longidorus) and fungi. MBTOC does not consider MB necessary for controlling ectoparasitic nematodes in these cropping systems. L

alternatives on flowers such as 1,3-D+Pic, dazomet and metham sodium, continue to be the major constraints affecting substitution of Mtrials. MB formulations with higher chloropicrin content are also not registered. In spite of this, registration of metham sodium and 1,3-D additional flower types. More expansion of registrations of potential alternatves are expected this year. Solarisation has been proven to bflower types (Choi et al., 2007; Yakabe and MacDonald, 2010) and is being successfully used in combination with alternative chemicals sMBTOC comments on economics 2010: No economic arguments are provided in the nomination. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes, barrier films are currently used in open field flowers and rates conform with MBTOC’s 

 Dec IX/6 b(iii) Research program: No. Poor to no research has been conducted on alternatives. This appears to be an orpha

bromide program and is dependent on research from other sectors.  Dec. IX/6 b(iii) Appropriate effort: Israel has indicated that it will no longer be applying for CUE’s after 2011. 
May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

Israel Cucumber None None 25.000 18.750 - 15.937 - 12.500 - 

MBTOC comments 2010: MBTOC recommends 12.500 tonnes for this use in 2011. The recommended quantity represents a 21.6% reduction from the 21th MOP a

available alternatives, such as grafted plants, improved sanitation and possible uptake of other alternatives (MS and 1,3-D). The need foof the intensive indoor cucumber cultivation in the central part of Israel could be considered as a niche request. The crop was not submit2006 since the crop’s key pathogen problems were resolved commercially at a satisfactory level. Cucumbers are grown in open ended pannum in the proximity of the residential houses of cooperative family and private family farms. A large proportion, 70%, of the critical us(Achituv), where the growers specialized for years in the cultivation of indoor cucumbers for the domestic market. The reasons for this nonew race of F. oxysporum f. sp. radicis cucumerinum. The pathogen is highly virulent and the infestation level particularly high in the affe

entire greenhouses in a short period of time. The required MB will be aimed at the eradication of the pathogen. Although MS combined wapplication of the mixture in winter at low temperature it may cause crop phytotoxicity and buffer zones limit its use. The Party also states degradation in field studies. MBTOC acknowledges that alternatives, such as MS+1,3-D, 1,3-D/PIC, grafting, sanitation programs; soilles2004; Lieten, 2004; Savvas and Passam, 2002; Mutitu et al., 2006) may be feasible alternatives for part or all of the nomination. It encoutechnical and economic feasibility of alternatives (grafting, substrates, and grafting + nematicides) and consider a reassessment the buffalternatives in use with barrier films and reduce the nomination further. MBTOC comments on economics 2010: No economic arguments are provided in the nomination. Comments requested in Dec. XX1/11 (para 9)

• Dec. IX/6 b(i) Emission reduction: Yes, barrier films and dosage rates conform to the standard presumptions. • Dec. IX/6 b(iii) Research program: Limited reporting of any research, but have used information from other sectors. 

Dec. IX/6 b(iii) Appropriate effort: Efforts in IPM technology, promotion of grafted seedlings. Israel has indicated that it will no longer b

Israel Melon - protected 

and field 

125.650 99.400 105.000 87.500 87.500 70.000 - 35.000 

MBTOC comments 2010: MBTOC recommends 35.000 tonnes for this use in 2011. The request is reduced to half of last year’s nominaadoption of a pesticide through drip systems which uses new application technology, eg. Azoxystrobin. Monosporascus cannonballus is 

Valley. MB is being used for spring melon in the Arava because of low temperatures prevailing at planting time and short plant back. The kg/ha (25 g/m2) of 98:2 MB under barrier films (LDPF) complies with MBTOC ́s standard presumptions. Additionally, MBTOC understand

very effective control of Monosporascus and are now available to the growers (Pivonia et. al; 2008; Israel melon CUN, Pivonia et al 2009

MB/Pic mixtures and the fungicide, fludioxonil, are effectively used for Monosporascus in other countries under similar conditions, but flueffective in Israel (e.g. Stanghelini et al. 2003; Martyn 2002, Pivonia et al 2009). MBTOC understands the transition to the alternatives is transition rate based on other countries experience. Another encouraging alternative is grafted melon (Cohen et al, 2007). On melon, hocompatibility and fruit quality require an additional research effort. Furthermore, new diseases, such as crown rot of melons and cucumbe
218 May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

pathogen has already invaded the relevant area. MBTOC suggests the following actions by the Party: (1) to consider further expansion o(2) consider formulations with more chloropicrin (MB/Pic 67:33, 50:50) as they are effective and (3) non chemical alternatives, such as gMBTOC comments on economics 2010: The nomination states that granular Basamid, is similar in mode of action to MS, however is not feasible economically because of a dramBasamid and waiting period constraints. CUN provides the results of a financial comparison between the use of MB and different formulasignificant losses when the alternatives are not used, with the closest comparator being Basamid 60, which shows losses of net revenue not able to verify the accuracy of these data. MBTOC notes that the nomination is not based on economic arguments. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes, barrier films are is used and MB dosage rates conform with standard presumptions

 Dec. IX/6 b(iii): Research program: Yes, current trials have validated previous research. 

 Dec. IX/6 b(iii): Appropriate effort: Active research program reviewing pesticide application and fumigant registration. Israel h

applying for CUE’s after 2011.

 Strawberry fruit - protected (Sharon and Ghaza) 

 196.000 196.000 93.000 105.960 77.750 

(42.75 Sharon, 35.00 Ghaza 

 57.063 (32.063 Sharon, 25.00 Ghaza) 

 - 28.500 

(Sharon) 20.50 (Ghaza)

 Israel 

MBTOC comments 2010: MBTOC recommends 21.375 tonnes for Sharon for this use in 2011 and 20.500 tonnes for Ghaza making a total of 41.875 t for this use reduced the amount by 11% and MBTOC has reduced by a further 14% based on increased uptake of MS followed by Telon EC which hkey pests affecting strawberry fruit are fungi (Rhizoctonia solani, Colletotrichum acutatum, Macrophomina phaseolina, Verticillium dahlia(Meloidogyne hapla), and weeds (Cyperus rotundus, purple nutsedge). The Party is concerned particularly about Macrophomina control

results with metham sodium formulations. Previous research has also shown that Telon EC followed by MS was effective. Telone EC h

shank applied, i.e. 100 m compared to 250 m, however the registration is unclear. Bromopic is registered, but past results with applicatiuntil recently when trials are evaluating it under barrier films. MBTOC acknowledges the Party for indicating an intention to not submit CMBTOC comments on economics 2010: The nomination shows that the gross and net revenue of all considered alternatives (Telopic, Bazamid and Telodrip) are higher than for Mdue to registration and buffer zone issues. 
May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes, however further dosage reduction would be possible if use of Bromopic with barrier filhigh buffer zones  Dec. IX/6 b(iii) Research program: Yes, however trials on key alternatives as shown above do not appear to be being conduct

Dec. IX/6 b(iii) Appropriate effort: The nomination indicates limited information on progress with alternatives, but that the Party will not 

in 2012. 

Strawberry runners (Sharon and Ghaza) 

None None - 31.900 28.075 

15.825 (Sharon) 12.250 (Ghaza) 

22.320 - 13.500 

(Sharon) 13.500 (Ghaza) 

Israel 

MBTOC comments 2010: MBTOC recommends 13.5 t for Sharon and 13.5 t for Ghaza for this use in 2011. The key pests affecting strawberry runner production a

Verticillium dahliae, Fusarium and Phytophthora spp., Sclerotinia sclerotiorum, Macrophomina phasoeolina), root knot nematodes and pu

MB 98:2 at a rate of 500 kg/ha (50 g/m2) with standard polyethylene films and 250 kg/ha (25 g/m2) with barrier films are necessary to me

and Sharon respectively. The Party stated that 1,3-D + PIC mixture has been the leading alternative; however, adoption of this alternativbuffer which significantly limits its use in the Sharon strawberry nursery growing area which is heavily populated. Hot gas application metgrowing area because the plots are small, adjacent to houses and there are no injection tools or qualified applicators in the area. MBTOC with alternatives that meet the pathogen tolerance required to meet the certification standards. The reduction is based on barrier films beMBTOC comments on economics 2010: No economic arguments are provided in the nomination. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes for Sharon and No for Ghaza as MBTOC is unclear on the availability of barrier films. Fpossible if use of Bromopic with barrier films was not prevented because of high buffer zones  Dec. IX/6 b(iii) Research program: Yes, however trials on key alternatives as shown above do not appear to be being conduct

Dec. IX/6 b(iii) Appropriate effort: The nomination indicates limited information on progress with alternatives, but that the Party has ind

by the end of 2011. 
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Israel Sweet Potatoes None None None 111.500 95.000 20.000 - 20.000 

MBTOC comments on 2010: MBTOC recommends 20.000 tonnes for 2011 (compared to 95 t used in 2009 and 20 t in 2010) for production of sweet potato transplantincluded use for field grown crops, but now the nomination is only for seedbeds and clean propagation material. MBTOC recognizes the In the light sandy soils root-knot nematodes- Meloidogyne spp. the scab pathogen Streptomyces ipomoea and Pythium spp. are the dise

propagation purposes. The applicant states that they expect registration of MB alternatives (eg. Telone II) by 2010, but this has not yet bresistant cultivars are available, but they are not commercially desirable in Israel. No data is presented from trials since 2006, although thmetham sodium (Adochem super) 400 l /ha was an excellent alternative for MB and registration was sought. The Party has not provided 

conducted from that date. The MB rates stated in the CUN are consistent with MBTOC’s standard presumptions and barrier films are beiUSA with Pic as an alternative indicate that it provides better yields and returns to growers than MB. Solarization also significantly increaherbicides may also become a MB alternative (Reference: http://mbao.org/2008/027Stoddard.pdf). MBTOC expects that if any disease c

to 2011 that the quantity of MB nominated will be adjusted downward to reflect the availability of the alternative(s). In the absence of thissuitability of the use of alternative varieties resistant to nematodes which are used effectively in other countries. MBTOC comments on economics 2010: The Party states that “the semi-commercial application of Telon on a total area of 100 ha in 2005 led to unsatisfactory results and econoapplication of Telon 200+MS 400 l/ha results in higher gross and net revenue than MB 350 kg/ha. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 (i) Emission reduction: Yes, barrier films and rates comply with MBTOC presumptions are being followed. 

 Dec. IX/6 (iii) Research program: No, has not been updated since 2006, but the Party has identified alternatives that are in the Dec. IX/6 (iii) Appropriate effort: The Party has identified an intention to phase out MB by the end of 2011..

Japan Cucumber 88.300 88.800 72.400 51.450 34.300 30.690 27.621 - 26

MBTOC comments on 2010: MBTOC recommends 26.162 tonnes for this use in 2012. The recommended amount is based on the reduction that the Party has made 

the same pathogen problems as the cucumber. Japan had made public an action plan to complete phase out of methyl bromide for soil unational management strategy for critical use nomination of methyl bromide to the Ozone Secretariat in April 2008. MBTOC acknowledge

by using a number of alternatives in 2013. The nomination is based on the need to control particular viruses of cucumber, since 2005. Globally, such viruses are not considered as survive in crop debris for several years. The problem mainly arises from continuous monoculture. An integrated program including cultura

with a non-host, removal and destruction of crop debris, cleaning and sanitation of the greenhouse and the surrounded area, and pathogeffective in similar situations around the world. The Party has indicated that rotation to non-susceptible hosts such as tomatoes and straw
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reduce virus incidence (Matsuo and Suga, 1993). As a transition strategy, MBTOC urges the Party to increase adoption of LPBF which a

50%. MBTOC recognises the unique farming system used for cucumber in Japan which has been in place for many years. However, in production has already shifted to substrates in greenhouse conditions and has become the most widely used technique for eliminating a pathogens. Inexpensive and simple systems (buckets, bags, etc.) are available for this kind of production and are widely used in around Budai, 2002; Savvas and Passam 2002; Akkaya & Ozkan, 2004; Engindeniz, 2004). The Party is encouraged to consider substrate prodcan produce higher yields than MB (MBTOC, 2002, 2006; Batchelor 2000, 2002; Savvas and Passam 2002). Studies conducted in Japan feasible option (Fukuda and Anami 2002, Sakuma and Suzuki 1995). MBTOC notes however that even when growing in substrates there of sanitation and for the use of pathogen free transplants. Large numbers of growers can be trained to use substrates systems in a short many MLF projects (UNEP/TEAP, 2004). The CUN states that the Aichi Agricultural Research Centre (2005) identified the effectiveness in pot tests. MBTOC encourages the Party to continue to pursue the registration of methyl iodide for soil uses (methyl iodide was registe2004, under JMAFF registration No. 21407). MBTOC comments on economics 2010: No economic arguments are provided in the nomination prior to testing for technically feasible alternatives. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes, barrier films are used in part of applications and rates in the nomination conform to the 

 Dec. IX/6 b(iii) Research program: Yes, a certain trials are now energetically undertaken now to find alternative technology to 

debris humus acceleration by input of wheat bran as the material for the microbe reproduction, use of bag culture with fertigation of the mmanure, peat moss, rice bran and mountain soil and use of bio-decomposition pot for avoiding contact of seedling root with the virus conin extract of Lentinus edodes mycelia just before planting has been tested.Dec. IX/6 b(iii) Appropriate effort: Party has identified an action plan that will phase out MB by the end of 2012.
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Japan Ginger (Field) 119.400 119.400 109.701 84.075 63.056 53.400 47.450 - 42

MBTOC comments 2010: MBTOC recommends the requested rate of 42.235 t for 2012 (a reduction of 5.215 t or 11.5% from 2011). This was mostly achieved by 

reduction in dosage rates. Fields are now fumigated on alternative years rather than yearly. Several regions now use dosage rates as lo

are within or lower than MBTOC’s standard presumptive rates. The nomination is for control of Pythium spp. (P. ultimum var. ultimum, P. ginger fields using MB (98:2) applied from small cans. The party has provided MBTOC with a list of studies that indicate highly promising alternatives by 2013, the date for complete phase out of MB in Japan. MBTOC comments on economics 2010: The nomination states that hot water treatment can possibly be considered as a technically feasible alternative under specific topographiand running costs are high, hence it is not economically feasible. No data are provided to support this argument. CUN provides data that using alternatives such as dazomet or Metalaxyl are lower that for MB. MBTOC is not able to verify the accuracy of these data. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX-6 (i) Emission reduction: Yes, barrier films and rates complying with MBTOC presumptions are being followed except 

cans.  Dec. IX-6 (iii) Research program: Yes, the research program has been updated and the party has identified alternatives that a

Dec. IX-6 (iii) Appropriate effort: The Party has identified an action plan that will phase out MB by the end of 2012.

Japan Ginger (protected) 22.900 22.900 14.471 11.100 8.325 8.300 7.036 - 6.5

MBTOC comments 2010: MBTOC recommends the total requested amount of 6.558 tonnes for 2012. This represents a reduction of 6.8% reduction from 2011 ye

LBPF. The nomination is for control of Pythium spp. (P. ultimum var. ultimum, P. zingiberium) in protected ginger fields using MB (98:2) a

regions now use dosage rates as low as 16-20 g/ m2 under LBPF which are within or lower than MBTOC’s standard presumptive rates. M

the Party with the results of numerous studies which have highly promising results for the implementation of alternatives by 2013, the da

Japan. MBTOC comments on economics 2010: Substantially as above Comments requested in Dec. XX1/11 (para 9)

 Dec. IX-6 (i) Emission reduction: Yes, barrier films and rates complying with MBTOC presumptions are being followed except 

cans.
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 Dec. IX-6 (iii) Research program: Yes, the research program has been updated and the party has identified alternatives that a Dec. IX-6 (iii) Appropriate effort: The Party has identified an action plan that will phase out MB by the end of 2012. 

Japan Melon 194.100 203.900 182.200 136.650 91.100 81.720 73.548 - 67

MBTOC comments 2010: MBTOC recommends a reduced amount of 67.936 tonnes for this use in 2012. The recommended quantity rthe 21th MOP approved amount based on uptake of available alternatives, e.g. steam, soil less culture, grafting, pathogen free seeds, 1,3 

as rotation, root isolation and sanitation. Japan has an action plan to complete phase out of methyl bromide for critical use nomination forevised national management strategy to the Ozone Secretariat in April 2008. MBTOC acknowledges that the Party will phase out MB by 2013 and lead to a reduction of 10 % by adoption of alternatives and low permeable barrier film with the dose rate reduction in 2011. Thto control a particular virus of melons. Globally, this virus is not considered as a soil-borne pathogen but can survive in crop debris for searises from continuous monoculture. An integrated program including cultural practices has been proven to be effective in many other corotation to non-susceptible hosts such as tomatoes and strawberries is an effective way to reduce virus incidence (Matsuo and Suga, 19increase adoption of LPBF which allow for reducing MB doses by up to 50%. MBTOC recognises the unique farming system used for meplace for many years. However, in many countries some melon production has already shifted to substrates in greenhouse conditions antechnique for eliminating a wide array of soil-borne plant pathogens. Inexpensive and simple systems (buckets, bags, etc.) are available widely used in around the world (Leoni and Ledda, 2004; Budai, 2002; Savvas and Passam 2002; Akkaya & Ozkan, 2004; Engindeniz, 2implemented correctly can produce higher yields than MB (MBTOC, 2002, 2006; Batchelor 2000, 2002; Savvas and Passam 2002). Studless culture as a feasible option (Fukuda and Anami 2002, Sakuma and Suzuki 1995). MBTOC notes however that even when growing ifor a high degree of sanitation and for the use of pathogen free transplants. Large numbers of growers can be trained to use substrates sexperienced in many MLF projects (UNEP/TEAP, 2004). Resistant root stocks are now available in Japan. However, according to the pato all the pathogen races. High yielding varieties resistant to the virus are available. Steam has also been found to control the virus, partiMBTOC notes that Pic and MB/Pic mixtures and the fungicide, fludioxonil, are effectively used for Monosporascus in other countries undet al. 2003; Martyn 2002). MBTOC comments on economics 2010: The nomination argues that no alternatives are technically or economically feasible, while the economic (and technical) feasibility of the ibeing trialled at present. The nomination argues that there is an important market window for melons in Japan, while virus-resistant varieThese statements are supported by budget data. MBTOC is not able to verify the accuracy of these data. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes, barrier films and rates conform to the standard presumptions. Dec. IX/6 b(iii) Research program: Yes, several control technologies are now checked whether they are adaptable to each sp
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complete replacement of methyl bromide. Those are appropriate use of the mixture of chloropicrin and 1,3 D to control MNSV without anselection of resistant variety in the respective production regions, effectiveness on the rotation by tomato. Dec. IX/6 b(iii) Appropriate effort: Party has identified an action plan that will phase out MB by the end of 2012. Pepper (green & hot) 

Japan 187.200 200.700 156.700 121.725 81.149 72.990 65.691 - 61

MBTOC comments 2010: MBTOC recommends 61.154 tonnes for this use in 2012. The Party nominated an amount representing 7% refor 2011 (2012: 61.154 t, 2011: 68.260 t) and has indicated it will not apply for further nominations under their action plan. According to thintroduction and deployment of alternatives, more distribution of low permeable barrier film with the dose rate reduction and reduction of every two years. Five regions applied for MB: Miyazaki: 72.9 ha (20.717 t), Kagoshima: 32.6 ha (6..006 t), Ibaraki: 116.3 ha ha (25.593 tWakayama: 4.5 ha (1.818 t). The total area nominated is 258.2 ha, 61.101 t, The average MB rate is 236 kg/ha. However, the MB rates v(184kg/ha to 400 Kg/ha) according to the pest pressure : Japan provided a comprehensive National Action Plan detailing step wise phas

chemical alternatives:( Bag culture with fertigation, Inoculation of attenuated virus as vaccine, development of the bio-decomposed pot fohydroponics, solarization) and chemical alternatives( dazomet, metam sodium, chloropicrin and chloropicrin capsule) .The Party believes widely accepted in the future. The development of resistant varieties is progressing well for the control of some viral strains. Soil less cultusing various substrates (disease free soil from mountain, paddy field, peat moss, coconuts shell and timber bark) are being used. Also, L4 Miogi) are currently available to some PMMoV strains, plant vaccination by attenuated virus (Kanda, 2008), grafting on resistant root sfeasible alternatives. Others such as biological control, wrapping the underground part of seedling with easily decomposing paper and sodevelopment. MBTOC comments on economics 2010: No economic arguments are provided in the nomination. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i)- Emission reduction: No, but the use of barrier films varies from region to region with some regions not using ba

however conforms to MBTOC’s standard presumptions. Dec. IX/6 b(iii)- Research program: Yes, a detailed research program is on-going.  Dec. IX/6 b(iii)- Appropriate effort: The Party has presented a detailed research program in place, in accordance with DecisioParty will be able to phase out MB completely by 2013 in alignment with their National Management Plan. 
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Japan Watermelon 129.000 98.900 94.200 32.475 21.650 14.500 13.050 - 12

MBTOC comments 2010: MBTOC recommends 12.075 tonnes for this use in 2012. This represents a 9.25% reduction of the approved 

21st MOP. The recommended quantity represents a 10% reduction from the 20th MOP approved amount based on uptake of available a

culture, grafting, pathogen free seeds, 1,3 D+Pic and cultural practices such as rotation, root isolation and sanitation. Japan had made pphase out of methyl bromide for critical use nomination for soil use in 2013 and submitted revised national management strategy for criticbromide to the Ozone Secretariat in April 2008. MBTOC acknowledges that the Party will phase out MB by using variety alternatives in 2by adoption of alternatives and low permeable barrier film with the dose rate reduction in 2011. 

The nomination is based on the need to control a particular virus of watermelons. Globally, this virus is not considered as a soil-borne pa

debris for several years. The problem mainly arises from continuous monoculture. An integrated program including cultural practices has other countries. The Party has indicated that rotation to non-susceptible hosts such as tomatoes and strawberries is an effective way to rSuga, 1993). MBTOC urges the Party to increase adoption of LPBF which allow for reducing MB doses by up to 50%. MBTOC recognisefor watermelons in Japan which has been in place for many years. However, in many countries some watermelon production has already conditions and has become the most widely used technique for eliminating a wide array of soil-borne plant pathogens. Inexpensive and sare available for this kind of production and are widely used in around the world (Leoni and Ledda, 2004; Budai, 2002; Savvas and PassEngindeniz, 2004). Substrate production, when implemented correctly can produce higher yields than MB (MBTOC, 2002, 2006; Batchel2002). Studies conducted in Japan support soil less culture as a feasible option (Fukuda and Anami 2002, Sakuma and Suzuki 1995). Mwhen growing in substrates there is a critical need for a high degree of sanitation and for the use of pathogen free transplants. Large numuse substrates systems in a short period of time as experienced in many MLF projects (UNEP/TEAP, 2004). Resistant root stocks are noaccording to the Party, the root stocks are not resistant to all the pathogen races. High yielding varieties resistant to CGMMV are also avto control the virus, particularly in the upper soil layer.MBTOC comments on economics 2010: No economic arguments are provided in the nomination. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: No, barrier films are used for part of the nomination, but rates conform to the standard pres

 Dec. IX/6 b(iii) Research program: Yes, research effort have been conducted on key fumigant and non chemical alternatives. 

 Dec. IX/6 b(iii) Appropriate effort: Extensive action plan showing research efforts for phase out by 2013. 
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United Cucurbits 1,187.800 747.839 592.891 486.757 407.091 302.974 195.698 - 59States 

MBTOC recommendation for 2010: MBTOC recommends 59.500 tonnes for this use in 2012. From this amount, 4.076 t are for Georgia squash, 3.285 t for Georgia cucumb

38.321 t for the Southeast region and 1.739 t for MarDel. MBTOC recognizes the reduction made by the Party of 70% down from 2011 re

way combination of 1,3 D + chloropicrin, followed by chloropicrin alone, followed by metam-sodium, that shows good results against key fumigation. MBTOC recognizes the for cucurbit growers who can only use either 1,3-D + chloropicrin or metam-sodium+chloropicrin in fall-season funematode pests, the yield loss estimates used in last year’s nomination continue to be applicable. While one study in 2006 showed good chloropicrin and the herbicides napropamide + halosulfuron or metolachlor + trifloxysulfuron in small plots of Florida tomatoes (Santos et applicable to cucurbits because neither metolachlor or trifloxysulfuron are registered in the US for cucurbits, and halosulfuron can have pMBTOC stresses the need of considering also non chemical methods within an integrated pest management strategy. Hausbeck, Lamour and others (2004) have reported many efficient management strategies to control Phytophthora on pepper, including hosts (carrots, beans, onions, asparagus, soybeans, alfalfa), cultural control (water management, plant density, soil amendments, protecuse of registered fungicides (Mefonoxan, Dimethomorph, Zoxamide + Mancozeb, Copper hydroxide+dimethomorph). MBTOC notes the varieties are considered as alternatives for long lasting crops in many Mediterranean countries (Bello, et al., 2001). Yellow nutsedge emewas suppressed by the combined effects of thin-film mulches and competitive size differential provided by using cantaloupe transplants (Incorporating Brassica spp. residue to reduce populations of soilborne fungi of watermelon was also tested, with interesting results (NjorMBTOC comments on economics 2010: The nomination notes that the treatment known as UGA-3-WAY is being tested, as is another potential alternative, Dimethyl disulfide (DM

However, further testing of both is required. CUN provides detailed partial (and provisional) budgets for Georgia and Florida that show thapplication may yield equal (Florida) or higher (Georgia) net farm income than MB but that the Fall application results in negative net farm Comments requested in Dec. XX1/11 (para 9)

• Dec. IX/6 b(i) Emission reduction: Yes, barrier films used in all of the applications. 

• Dec. IX/6 b(iii) Research program: Yes, studies were conducted in other crops such as tomatoes, which are relevant also cucurbits (Hausbeck and Cortright (2007), showed that cucurbit plant vigor was measured to determine fumigant/mulch performance undplastic mulch for the control of Fusarium oxysporum. Of the fumigants used in the study, the MB and MI treatments resulted in cantaloup

general, treatments under LPDE had higher plant vigor when compared with plants grown under barrier films. Research continues to also 

resistant watermelon stock that can be grafted on a commercially feasible basis. Other studies were also given in the CUN for these cropDec. IX/6 b(iii) Appropriate effort: 
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United Eggplant 76.721 82.167 85.363 66.018 48.691 32.820 19.725 - 6.9States 

MBTOC comments 2010:

MBTOC recommends 6.904 tonnes which is the total requested amount by the Party. The Party has made a 65 % reduction in MB use fr

Party’s for 2011 (19.725 t). MBTOC acknowledges the substantial reduction by the Party for uptake of alternatives, particularly the use o3.061 t are for Georgia and 3.843 t are for Florida. US nomination is only for those areas where the alternatives are still under extensive (nutsedge, nematodes and P. capsici) is high. The Party is projecting rates of 125 kg/ha both for pathogens and for nutsedge. The Party the “UGA 3-WAY”, consisting of three successive soil fumigations, beginning with 1,3-D + Pic application, followed by a Pic application, fmetham-potassium application (Culpepper, 2007) is an alternative for MB in spring crops. For summer and fall crops, this system needs areas with moderate to high nutsedge pressure. In addition, metham sodium and metham potassium in the fall require longer waiting pecould result in missed market windows. A further constraint to adoption of the UGA-3 WAY is that 1,3-D is restricted in areas of Karst topvulnerable to leaching from 1,3-D. This research is on-going, however specific studies conducted or in progress since the last nominatioParty states that trials with dimethyl disulfide (DMDS) plus Pic are promising, but this combination does not effectively control certain gra

2008). Trials will continue with this alternative. An application to register DMDS is under consideration at USEPA. MI is not registered f

only for those areas where the alternatives are still under extensive evaluation and pest pressure (nutsedge, nematodes and P. capsici) formulation (MB/Pic) is widely used in Florida but does not provide information about the formulation used in Georgia. MBTOC considers amount may be possible with changes to formulations of 30:70 used in combination with barrier films commercially feasible. MBTOC connon chemical alternatives e.g. grafting, biofumigation, soil less culture... which are widely used in many countries and regions with similaimportant to note that MB is not used in any other non Article 5country on eggplant. There is no indication in the nomination that research MBTOC comments on economics 2010: The nomination notes that the treatment known as UGA-3-WAY is being tested, as is another potential alternative, Dimethyl disulfide (DM

However, further testing of both is required. CUN provides detailed partial (and provisional) budgets for Georgia and Florida that show thapplication may yield equal (Florida) or higher (Georgia) net farm income than MB but that the Fall application results in negative net farm Comments requested in Decision XXI/11 (Para 9)

 Dec. IX/6 b(i) Emission reduction: No, there is no information in the nomination about the use of VIF or equivalent film, howeconsistent with the use of barrier films and MBTOC’s standard presumptions  Dec. IX/6 b(iii) Research program: Yes, equivalent research is on-going in similar sectors, however specific studies conducted 

nomination were not cited in the CUN  Dec. IX/6 b(iii) Appropriate effort: The Party is increasing uptake based on adoption of alternatives such as the Georgia 3-Waimplement grafting, resistant root stocks, etc. may facilitate the phase out of MB in areas where regulatory constraints prevent the use of 
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Forestry nursery 

United 192.515 157.694 122.032 131.208 122.060 117.826 93.547 - 34States 

MBTOC comments 2010:

MBTOC recommends an amount of 34.230 tonnes for this nomination in 2012. MBTOC recognizes a reduction in the nominated amount 

amount, but was informed by the Party that some of this amount was moved into QPS MB. Despite requests from the Party it is unclear wbeen moved into QPS. The nomination indicates 100% reduction by three groups and 48% for the remaining three groups (the Southern 

Cooperative, the Michigan Seedling Growers, and the Northeastern Forest and Conservation Nursery Association. Key pests are nutsed

recognises that propagative material requires a very high level of soilborne pest and pathogen control in order to avoid their wide spread 

nurseries with moderate or high pest pressure where alternatives are not effective. Nutsedge has no effect on certification, but the Party 5%. MBTOC requests that further nominations clearly show the trend in yield loss caused by nutsedge, nematodes or fungal pathogens following fumigation with MB and alternatives and a breakdown of the economic comparisons to MB treatment. The nomination is for cer

forest nursery regions. CUN is based on economic infeasibility of use of substrates and the lack of effective alternatives for control of nu

pathogens and nematodes. The key alternatives which have been shown to be as efficient as MB are MI which has been found effective 

registered; chloropicrin alone (South, 2007; 2008); 1,3-D/Pic (South, 2008) 1,3-D /Pic/metham sodium (South, 2008); metham sodium + 

(Muckennfuss et al., 2005; Enebak et al., 2006). DMDS + Pic has produced encouraging results (Quicke et al, 2007) although the former pest management systems have also been shown to be effective (South et al., 2006; Hildebrand et al., 2004). The Party acknowledged tconjunction with barrier films (LPBF) may provide an effective technical alternative and avoid crop injury. Enebak (2007) found that with Lsignificantly reduced. Gluing of LPBF remains a challenge (Quicke et al., 2009; Walters et al., 2009). The Party states that gluing of LPBfumigation of nursery stock is not commercially available, but progress has been made in this respect. LPBF will be adopted when the eflocally and commercially available, however, MBTOC expects that future nominations will be based on its use. MBTOC considers that gtreatment to reduce pressure from nutsedge. However, this herbicide has been shown to cause phytotoxicity under nursery conditions. Jcontrol of weeds in Iowa Nurseries with different herbicides. MBTOC acknowledges the initiation of large scale, 5-year demonstration triwith promising results (Quicke, 2007; Quicke, 2008; Weiland, 2008). Recent findings confirm the promising results of MI, MI/Pic, DMDS, pathogen or weed pressure was given (Quicke, 2009; Weiland, 2009). Limited substrate production of these crops is reported as econohowever MBTOC is aware that International Paper produces over 40 million tree seedlings per year in substrates in their Brazil operationeffort on use of substrates, better methods for gluing barrier films, and use of MI. MBTOC comments on Economics 2010: The Party states that estimated costs of fumigation per hectare for northeastern nurseries average $8,300 for iodomethane (98:2), $10,5$4,820 for methyl bromide (98:2). CUN notes that there are no yield losses with the use of iodomethane, hence if these cost differences 

find iodomethane to be economically infeasible. However, CUN shows losses in net operating revenue of 7% (Southern Forest Nursery M(Northeastern Forest and Conservation) respectively. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b (i) Emission reduction: No. Barrier films are not used, but rates conform to the standard presumptions without ba
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effectively and the lack of commercial availability of gluing LPBF have restricted the ability to use barrier films. Dec. IX/6 b (iii) Research program: Yes. Research effort has been conducted on alternatives. 

Dec. IX/6 b (iii) Appropriate effort: The reduction and research indicates appropriate efforts.

Nurseries stock (fruit, nut, flower) 

United 45.800 64.528 28.275 51.102 25.326 17.363 7.955 - 1.5States 

MBTOC comments 2010: MBTOC recommends a total of 1.591 tonnes for this use in 2012. This comprises 0.191 tonnes for roses, and 1.400 tonnes for the CalifoCenter. MBTOC notes the large reduction in this nomination, which is 80% less than last year’s approved amount. The rates conform to This nomination is for propagation materials that need to be certified as free of pests and diseases (CDFA,2009; USDA-APHIS,2007). Thcertification requirements, regardless of the formulation (CDFA, 2009). The California Dept of Food and Agriculture has approved the use certified nursery stock soil treatment for certain crops under specific conditions and recently added methyl iodide (MI), if and when it is re2009). MBTOC recognises that propagative material requires a very high level of soilborne pest and pathogen control in order to avoid tResearch trials indicate some materials (such as MI) and some combinations (such as 1,3-D /Pic) show promise as MB alternatives for seffective rates may be higher than those needed in annual crops and use of an effective barrier film is necessary (Schneider et. al, 2008; et. al, 2009b; Walters et. al, 2009). Other materials (such as metham sodium and chloropicrin) were not adequate for certified nursery stAdvances using alternatives are being made (Hanson et al., 2007; Hanson et al., 2007; Hanson et al., 2009). Few effective herbicides arCalifornia (Shrestha et al., 2008). An alternate approach to the use of soil treatments is the use of containerized, or soil-less substrate, p

approach is economically feasible and is able to produce a product, i.e, root system, of acceptable size and quality to the marketplace. Mresearch on chemical and non-chemical alternatives and on high barrier films in hope (anticipation?) of the future approval for use in CalMBTOC comments on economics 2010: The nomination concludes that 1,3-D+Chloropicrin is an economically feasible alternative to MB in California Rose production where Telosimilar conclusion is reached with regard to California deciduous fruit and nut nursery trees; however, township restrictions and certificatusing Telone® and render it technically infeasible. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes. Barrier films cannot be used for this nomination in California, but rates conform to the 

 Dec. IX/6 b(iii) Research program: Yes, An area wide program is evaluating the key alternatives, including methyl iodide/Pic a

Dec. IX/6 b(iii) Appropriate efforts: A range of alternatives are being considered and commercialised.
230 May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

United Orchard replant 706.176 527.600 405.400 393.720 292.756 215.800 183.232 - 18States 

MBTOC Comments for 2010: MBTOC recommends a CUE of 18.324 tonnes be approved for this use in 2012. This includes 12.700 t fo

1.844 t for walnuts, 1.660 t for almond and 1.494 t for wine grapes. MBTOC acknowledges that the CUN is a 90% reduction from the preCUN is for orchard/vineyard replant disorder of unknown etiology for a portion of replant sites in California where alternatives are not suitrestrictions or physical characteristics such as unacceptable soil type, moisture or topography. The CUN is for heavy soils or soils which depth to kill of old roots and the associated pathogens in deeper soil. Regulatory constraints (maximum labelled rated) prevent the use oeffective. The best alternatives for orchard replant that have been identified are 1,3-D or 1,3-D with chloropicrin, chloropicrin alone, and/ocoarse-textured soils (Caprile and McKenry, 2006; Wang et al., 2009; Browne et al., 2007; Browne et al., 2008; Beede et al., 2008). Undconditions (less than 12% to 1.5 meters) 1,3-D is an effective management tool for replant problems and is currently used to replant the sites. Although a two year fallow was found to be effective under Mediterranean conditions by Bello, et al., 2004, Schneider, et al., 2004 

sufficiently eliminate the causative nematodes. Recent promising results with rootstocks such as Nemaguard, Viking, Krymsk1, and FlorMcKenry (2006). Additional alternatives proven to be effective include IM or 1,3-D and spot treatments applied through GPS-controlled sapplication system (Browne et al, 2007; 2008). The Party confirms that MB/Pic 67:33 formulation is used for California stone fruit raisin g

well for almond and walnut at a dose rate of 20g/m2. 

MBTOC comments on economics 2010: Walnut and almond orchards: The CUN refers back to the partial budget and mentions that MB results in about $530 more per hectare th

However the NPV and IRR (close to 14%) of both alternatives are similar. MBTOC notes that there is an error in Table 1 of the CUN. Losbe higher because of higher tree mortality rates. California Stone Fruit: CUN states that differences in net operating revenue for even smsubstantial. This analysis suggests that the benefits of methyl bromide alone are approximately $125/hectare. The result is a decrease oboth alternatives have a negative NPV although MB provides additional benefits. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction –Yes. Barrier films cannot be used for this nomination in California, but rates conform to the 

 Dec IX/6 b(iii) Research program - Yes, an area wide program is evaluating the key alternatives, including methyl iodide/Pic, s

 Dec. IX/6 b(iii) Appropriate efforts - A range of alternatives are being considered and commercialised. 
May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

United States 

Ornamentals 154.000 148.483 137.835 138.538 107.136 84.617 64.307 - 48MBTOC comments 2010: 

MBTOC recommends the requested amount of 48.164 tonnes for this use in 2012. This includes 46.950 t for California and 1.214 t for Fl

25% reduction in the nominated amount compared to the previous amount approved, including a significant reduction of 90% in Florida. a 4 year transition to available alternatives. In Florida, methyl iodide (MI) is now registered and other alternatives are available, for examor in combination with chemicals (McSorley et al, 2006; McSorley et al, 2008). The nomination is for a large number of species, mostly gmain species using MB are gladioli, lilies and snapdragon. Additional species using MB in California include calla lily, delphinium, dianthuhypericum, iris, larkspur, liatris, matthiola, and ranunculus. MB is needed to control diseases (e.g., Fusarium spp., Pythium spp., Phytopplant parasitic nematodes (e.g., root knot, root lesion, stunt and dagger), weeds (e.g. Cyperus spp. Portulaca, Ambrosia and others), and Party has adjusted dosage rates for all regions to 20 g/m2, which conforms to MBTOC’s standard presumptions. MBTOC considers alter

types in California, for example 1,3-D/Pic, metham sodium and combinations (Klose et al., 2007, Klose, 2008). Steaming systems and apevaluated in California, in an effort to identify the most feasible approach to this technique (Gilbert et al, 2009). MBTOC recognizes the pMI on ornamentals. MBTOC encourages the Party to conduct appropriate trials to facilitate the transition to MI/Pic if and when registratio

encourages continued research on non-chemical and chemical alternatives. MBTOC comments on Economics 2010: A major change in this CUN is the availability of iodomethane in Florida (registered in 2008), but not in California. Its economic impacts aare relatively small. The partial budget of Florida lilies resulted in a 4% loss as a percentage of net operating revenue. In California the asignificant negative economic impact on growers; however, the data show that growers incur a loss even when using MB. Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: Yes, for part of the nomination. Barrier films are currently used in Florida. Barrier films can

regulatory constraints. Rates conform to the standard presumptions with barrier films. Dec. IX/6 b(iii) Research program: Yes, research efforts have been conducted on alternatives. 

Dec. IX/6 b(iii) Appropriate efforts: The nomination indicates significant efforts have been made to switch to alternatives. Substantial refforts particularly in Florida. In California, efforts have been made within the constraints imposed by regulations. 

United Strawberry (field) 2052.846 1,730.828 1,476.019 1,349.575 1,269.32 1,007.477 812.709 - States 

MBTOC comments for 2010: MBTOC recommends a reduced CUE of 649.348 tonnes for this use in 2012. This comprises an overall reduction of 14% of the nominat1.647 t for Eastern USA and 3.272 t for Florida. The Party reduced the nomination by 7% over the amount approved at the 21 MOP. At tCalifornian Strawberry Commission presented data that predicted they would only require 667.667 t of MB in 2012 which was less than t
232 May 2010 TEAP Progress Report 

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CUE for 20073

CUE for 20084

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CUN for 2011 (addtl or new) 

CU20

Party. The request had not been officially reduced by the Party at the time of writing this report. MBTOC acknowledges the excellent infFor California, the Party nominated 751.000 t (3927 ha at 170 kg/ha). This is an 11% reduction of the recommended volume for 2011. In producing districts for which MB is nominated are Oxnard, Watsonville/Salinas and Santa Maria, with in 2010 respectively almost 5000 hstrawberry fruit (predicted). The most recent PUR data (2003-2008) show that alternatives based on 1,3-D, Pic and metham have been wdistricts (i.e. excellent adoption in Oxnard and some adoption in Watsonville/Salinas). In California, 1,3-D use has more than doubled fro(2008). PUR data indicate that in Ventura county alone the adoption rate of MB alternatives has been about 800 ha per year (between 2progress, over the period 2003-2008, the Santa Maria strawberry fruit area has more than doubled its MB use, an expansion which is larMaria overall size of production area. The approved CUE for strawberry fruit in California was just over 1000 t in 2008, however PUR use used in the same year. PUR use data for 2008 also show that 98:2 and 67:33 formulations are still being used on 17% of the use area, aCalifornia strawberry area. The 2007 use rates of MB dose in formulations for 50:50 mixtures are 170 kg MB/ha (i.e. 170 kg Pic/ha) compMB/ha (i.e. 158 kg Pic/ha) respectively. Both dose rates respect the restrictions on use of Pic and enable 50:50 formulations to be used wkg/ha in its CUE-CUN for 2011-2012 respectively. In California the nomination was reduced to take account of further uptake of alternativalternatives are available and technically feasible. Data on 2010-12 township caps have shown room for further uptake of alternatives bain some counties (Pic EC, Metham and Pic). In the areas affected by township caps, trials with alternatives that do not contain 1,3-D (suc+ dazomet, often with LPBF) provided yields that are statistically comparable with MB (Ajwa et al., 2002, 2003, 2004, 2005, 2006; Nelson 2005, 2006ab). Pic EC provided an average 99% yield compared to MB, with low variance (studies cited in TEAP, 2006). VOC regulationgrowers to use barrier films in California. These films can be used with alternatives and can reduce the dosage rates required for effectivCalifornia, weed management research showed that the herbicide oxyfluorfen can be applied safely to strawberry for control of common strawberry production, thereby reducing time required for hand weeding (Daugovish et al., 2008). The registration progress of MI/Pic in C

not expected to become available before 2012-2013. MBTOC urges Party to deliver, for California, an action plan with stepwise reductiotransition to MB alternatives. In Ventura county, MB alternatives are implemented in the areas with township caps. The California Strawbstepwise transition in Monterey county of in total 44% between 2008 and 2012. A proportionate transition is considered feasible in the ottransition from 6565 ha in 2008 to 3791 ha in 2012 (42% transition) is deemed realistic. Hence MBTOC recommends a CUE of 644.429 For the Eastern the Party nominated 1,647 t (11 ha @ 150 kg/ha). This is a transition of 92% from 20 t as per the CUE in 2011. MBTOC realistic given that MI/Pic has been registered in 2008 and is technically feasible for the total nomination area. For Florida, the Party nominated 3,272 t (22 ha @ 150 kg/ha). This is a transition of 92% from 41 t as per the CUE in 2011. Given that tealternatives are available, MBTOC considers this transition realistic. Comments requested in Dec. XX1/11 (para 9)

• Dec. IX/6 b(i) Emission reduction: Yes in Florida and Eastern states, with use of VIF; No in California where VIF is no

accordance with MBTOC standard presumptions; • Dec. IX/6 b(iii) Research program: Yes, there is an ongoing research program, which the CUN refers to; • Dec. IX/6 b(iii) Appropriate efforts: Excellent progress in Florida and Eastern states; In California there is varying eff

districts.
May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

Strawberry runners 54.988 56.291 4.483 8.838 7.944 4.690+ 

2.018 

United 6.036 - States 

MBTOC comments for 2010: MBTOC recommends 3.752 tonnes for California in 2012, but does not accept use in the south eastern States as a suitable alternative is MBTOC accepted the action plan of the Party for 2010 and 2011 for amounts of 2.018 t and 1.346 t respectively in the south east. MBTOsuitable for strawberry fruit production from runners grown in MI treated soil, and accepted that time was required to conduct commercial The submission showed no evidence that these commercial scale up trials were ineffective so MBTOC does not consider further need fo

The CUN does not specify regions for use and applies generally for 3.752 tonnes, however 99% of the hectares are exempted under QPas affecting strawberry runners are weeds (purple and yellow nutsedge), fungi (Rhizoctonia and Pythium spp in SE, Phytophthora, Vertic

(root-knot, sting in CA). Alternatives s that have been evaluated in research trials over the past several years are 1,3-D/chloropicrin, 1,3-D and metam-sodium, and dazomet as a follow-up application to 1,3-D/chloropicrin or chloropicrin (Fennimore et al., 2008b) the latter proThese formulations have been shown to give similar pathogen control in soils and will meet requirements of certification (Kabir et al, 200MBAO). [For California, MBTOC recommends the nomination, but expects that future nominations will show reports of trials with key alteorder to satisfy the criteria of Decision IX/6. The Party's request is based on MBTOC's standard presumption of 200 kg/ha (20 g/m2) of M

production of 'high health' strawberry runners using LPBF and other emission control technologies (TEAP 2005). California regulations pParty did not provide further information on commercial scale up trials requested in the 2009 round. MBTOC comments on Economics: The nomination states that iodomethane is under registration review in California; however registration is not expected in the near futuregrowers are expected to see a yield decrease of 10% with 1,3-D + chloropicrin. Net revenue declines from more than $12000/ha to a losComments requested in Dec. XX1/11 (para 9)

• Dec. IX/6 b(i) Emission control: No, regulations prevent the use of barrier films with MB but barrier films can be used with alte

presumptions. • Dec. IX/6 b(iii) Research program: Yes, ongoing research is being conducted showing that MI/Pic especially is effective, but it 

Dec. IX/6 b(iii) Appropriate effort: MI has qualified for certification use by CFDA, however it is not yet registered

Sweet Potatoes slips 

United None 0.000 0.000 180144 18.144 14.515 11.612 - 8.States 

MBTOC comments for 2010: MBTOC recommends 8.709 t for this use in 2012. Two years of trials indicate that Pic combined with herbicides provide transplants that MB. MBTOC recognizes that this is a 25 % reduction from the 2011 year application. The pathogens of concern are a complex of Pythium (Streptomyces ipomea); Scurf (Monilochaetes infuscans); Fusarium wilt (Fusarium oxysporum); Black rot (Ceratocystis fimbriata), root kn
234 May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

infestation of various weed species. The basis of the nomination is that township caps limit the use of 1,3-D and 1,3-D combinations the The industry sector is now carrying out extensive trials for replacing MB. Telone, the alternative to MB, cannot be used in Dec-Jan and towhich is the fumigation window for slips. MBTOC recognizes the importance of producing pest free seed stock. Trials by Stoddard (2008herbicides is provided transplants that gave yields and returns above that of MB. Second year trials carried out by Stoddard et al. (2009) that showed that pic is a good alternative to MB. Solarization also significantly increased yield and with more effective herbicides may alsis used as it is not permitted in California. The applicant will be conducting the third year of trials in 2010 and in 2011 replicated trial will bcomparable to 2008-09 are obtained with the alternatives are verified from these tests MBTOC expects complete phase out for this sectoMBTOC comments on economics 2010: The nomination shows trial data that reflect that yield increases by 11% with the use of chloropicrin, resulting in a gain in gross and net orespectively. Comments requested in Dec. XX1/11 (para 9)

• Dec. IX/6 b(i) Emission control: No, barrier films are not used in California as legislation prohibits this. Rates comply with 

• Dec. IX/6 b(iii) Research program: Yes, A very active research program is in place to find alternatives and the party has i

being implemented. • Dec. IX/6 b(iii) Appropriate Effort: The Party has identified an action plan that will phase out MB as soon as alternative te

effective.

United Tomatoes (field) 2876.046 2,476.365 2,065.246 1,406.484 1,003.876 737.584 292.751 - States 

MBTOC comments 2010: 

MBTOC recommends 54.423 tonnes the total requested amount by the Party. The Party has made a 81.4 % reduction in MB use from th

for 2011 (292.751 tonnes). Of this amount, 0.073 t is for Maryland, 0.646 t for Virginia, 8.164 t for SE, 3.882 t for Georgia, and 41. 657 t fthe substantial reduction by the Party for uptake of alternatives, particularly the use of the “UGA 3-WAY”, consisting of three successive D + Pic application, followed by a Pic application, followed by a metham-sodium or metham-potassium application as well as the increasUGA 3-WAY has been shown to be effective for tomatoes in Georgia, but has not yet been successful in other parts of the Southern US addition, 1,3-D is restricted in areas of Karst topography where ground water is vulnerable to leaching from 1,3-D. The time limitations oof MI and Pic have been removed and this product has shown good efficacy against key tomato pests, including nutsedge, in a number oreceived state-level approval in 47 US states (California, Washington, and New York are the exceptions at this time). However, the Party necessary before Midas achieves a full adoption. Constraints: (1) the cost of MI formulations which is higher than MB, (2) growers and evaluate MI use in the various local production conditions covered by this nominations, and (3) growers and applicators will need to makadapt to the lower flow rates typical with less expensive MI application rates and to avoid the corrosion of some metals that can occur wi
May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117 

CUN for 2011 (addtl or new) 

CU20

2006).The Party states that trials with DMDS plus Pic are promising, but DMDS is not registered in the US. An application to register DMUSEPA (MacRae and Culpepper, 2008). According to the Party, non chemical alternatives such as grafting soilless culture, are not econ

considers that the party should develop these alternatives which are widely used in many countries and regions with similar climate and Bausher(2009) provides evidence that ‘Big Power’, ‘Beaufort’, and ‘Maxifort’ rootstock can be utilized to manage Soil borne pathogens. .although grafted plants add significantly to input costs at current prices, the net economic result is often positive when infestations are hignomination that research in these areas is continuing. Therefore, MBTOC considers that more research is necessary to demonstrate appdecision IX/6. It is important to note that MB is not used any more in developed countries on tomato. MBTOC comments on economics 2010: CUN concludes that iodomethane would be the economically feasible alternative for use in Eastern and Florida US tomato production in features, but a transition period is required. In areas where karst features are not present it appears that tomato growers can use a comb

sequentially (1,3-D, chloropicrin, and metam-sodium/potassium) and achieve yields that are comparable to those produced by using metComments requested in Decision XXI/11

- Dec. IX/6 b(i)- Emission Reduction: No, there is no information in the nomination about the use of VIF or equivalent film, how

consistent with the use of barrier films - Dec. IX/6-b(iii)-Research Program: Yes, the research is on-going, however specific studies conducted or in progress since th

the nomination - Dec. IX/6-b(iii)-Appropriate Efforts: The Party made large reductions recently. Consideration of grafting, resistant root stockMB in areas where regulatory constraints prevent the use of some of the chemical alternatives. 

11ExMOP and 16MOP 216MOP+2ExMOP+17MOP 3MOP17+MOP18 4MOP18+MOP19 5MOP19+MOP20 6MOP20 7MOP21 
236 May 2010 TEAP Progress Report 

10.4 Interim CUN Report – Issues Specific to MBTOC Structures and 

Commodities 

MBTOC met at the Agricultural Research and Education Center (IFAPA) in Chiponia 

(Province of Cadiz), Spain. We sincerely appreciated the welcome and hospitality of the IFAPA 

staff and the Government of Spain. MBTOC Structures and Commodities met concurrently and 

in the same location as MBTOC Soils and QPS. 

Our agenda was to assess the 2010 CUNs, to prepare the Progress Report and begin 

assignments for the Assessment report. As part of our work a short bilateral meeting was held 

with USG to discuss questions about the CUNs. Additionally, MBTOC SC conducted a field 

trip to a rice growing and processing cooperative in Isla Mayor, Spain (Arrozua company). 

There, with the kind assistance of the management and their fumigation company (Roca Difisan 

SL), MBTOC reviewed their modern phosphine fumigation, rice processing and storage 

methods. It was a very instructive learning experience. 

Parties continue to make progress on some CUNs, reducing many MB uses by continuing to 

resolve the inter-related issues of treatment logistics, costs, trade demands and effectiveness of 

alternatives. But unfortunately, in the case of the majority of CUNs for structures and 

commodities, progress in adopting alternatives has stalled. MBTOC has questioned Parties 

about regulatory avenues and possible adaptations of potential alternatives, has encouraged and 

cajoled. We have provided extensive examinations of the research, have written lengthy 

correspondence and text boxes with ideas and concerns and held lengthy bilateral discussions. 

In this interim report MBTOC has recommended reductions in many of the CUNs as described 

in the table below. MBTOC informs the Parties that without an increased research focus, 

regulatory approvals of alternatives and a commitment to requiring the use of the alternatives 

that are available, CUNs may well persist at current levels for several years or longer. 

This year the Government of Israel did not submit a critical use nomination for dates. In recent 

years, researchers in Israel have developed heat treatments, then worked to adapt them to suit 

the practicalities required by date packing houses in rural areas. MBTOC congratulates the 

Government of Israel for its ability to achieve phase out of methyl bromide for dates and offers 

appreciation for the ongoing exchange of information about the technical basis for its 

accomplishment. Pest infestation of dates continues to be a problem for date producers in 

several countries as discussed in other parts of this report. 

A resolution of treatment logistics and a regulatory interpretation favoring the use of phosphine 

as an alternative, seems to have contributed to the final phase out of the use of methyl bromide 

for dried beans in the United States. MBTOC congratulates the Government of the United 

States and its applicant for resolving this difficult matter and achieving phase out in the use of 

MB for this commodity. 

The use of methyl bromide in Canadian flour milling continues to decrease. In Canada, 

regulatory approval of sulfuryl fluoride has not been achieved to the extent necessary for full 

adoption because it is registered only for structures and not for food contact. But the extensive 

industry-led research program of past years, and the regulation which allows sharing of the MB 

allotment amongst CUN applicant-industry members, seems effective in reducing use to those 

in most need of the fumigant. 

There was no decrease in the US CUN for flour and rice milling and pet food manufacturing, 

for 2012 over the amount granted by the Parties for 2011. In the US (and Canada), concerns 

about costs and the environmental impact of using sulfuryl fluoride, are cited as slowing 

adoption of that key alternative. This problem is discussed more fully in the Progress Report. 

Additionally, differences between the extent of regulatory approval for food products between 
May 2010 TEAP Progress Report 237

methyl bromide and sulfuryl fluoride prevent SF’s full adoption in these facilities where food 

products are commonly present. 

MBTOC has suggested research and logistical adaptations to circumvent this problem, but no 

information has been sent to us to indicate that trials have been conducted. One recent trial in 

flour mills has been made available to MBTOC. Research in rice mills and pet food facilities 

has not been submitted, although the applicants say they are making research investments. 

MBTOC maintains that differences between flour mills, rice mills and pet food establishments 

are substantive; trials of alternatives in these specific facilities are required and the reports 

submitted to MBTOC if CUNs are to be substantiated. 

Although the use of MB for dried fruit and nuts in the US has very considerably decreased since 

2005, there was only a very minimal decrease in the CUN nominated amounts this year (4.907 

t). When questioned by MBTOC, the Government of the United States has informed MBTOC 

that no further adoption of alternatives seems possible for dried fruit and nut sector. MBTOC’s 

assessment is not in agreement with this viewpoint. 

In the US food processing sector, (the CUN titled for the applicant -- the National Pest 

Management Association NPMA), and the Canadian pasta facility sector have reached an 

impasse that seems to be caused by both inadequate regulatory approval for sulfuryl fluoride 

and a lack of commitment to use heat treatments, even though heat is technically effective and 

does not require regulatory approval. MBTOC notes with dismay, that lack of regulatory 

progress in adoption of sulfuryl fluoride is used as a reason for these sectors to delay adoption 

of alternatives, even though heat treatment as an alternative seems technically feasible and does 

not require registration. 

MBTOC is also concerned that there has been no adoption of alternatives at all for packaged 

rice in Australia. Decreases in use of MB have been achieved because the rice harvest is low so 

less rice is MB treated. The Australian applicant also began using less MB when standard MB 

dosage rates were adopted. The Government of Australia reports that the applicant is unable to 

afford to even begin adopting a technically effective, registered and inexpensive fumigant 

(phosphine), because severe drought in Australia has resulted in very low harvests. This has 

prevented the industry from being able to afford the adoption of alternatives. MBTOC and its 

economists continue to be very concerned about the lack of adoption of alternatives for 

Australian packaged rice when technically effective alternatives are available and because the 

company reports it has returned to normal profitability. In former years Government of 

Australia has indicated that if larger harvests were achieved such that the MB allotment was 

insufficient, then alternatives would be adopted. In correspondence this year, the applicant 

indicated that if a larger harvest is achieved, it would either use an alternative or export or store 

the excess rice (Government of Australia to MBTOC, April 2010). 

The lack of effective and registered alternatives for US dry-cured pork, fresh chestnuts, cheese 

and some date varieties results in the ongoing use of methyl bromide, although at slightly lower 

levels than in previous years. There is a technically effective alternative for fresh chestnuts in 

Japan; however, sufficient quantities of the alternative have not yet been obtained, and farmers 

have not yet been trained in the safe use of the fumigant. MBTOC recommends immediate 

training of farmers and the beginning of market penetration of this fumigant in 2011. 

MBTOC acknowledges that trials to improve the effectiveness of SF as a treatment for dates in 

the US are rigorous and ongoing. 

Unfortunately, there are no alternatives in the pipeline for pork and cheese in storages. Without 

a technical and regulatory change, this use of MB (currently 5,542 kg for both commodities 

spread over two CUNs) is likely to continue for many years. The Party and users may wish to 

adopt improved containment and methyl bromide recapture systems for these uses to mitigate 
238 May 2010 TEAP Progress Report 

emissions, as expected under one of the requirements for CUEs set out in Decision IX/6, para b 

(i). 

MBTOC draws the Parties’ attention to two important problems that prevent us from assisting 

Parties by hampering our ability to provide the best technical assessment of CUNs. CUN 

applicants are not required to report the results of trials of alternatives to their governments or to 

MBTOC and some applicants have been unwilling or unable to substantiate claims of technical 

ineffectiveness or higher costs of alternatives. In the field of postharvest use of MB, where 

published research is at a low level, much of the important assessments are conducted by MB 

users and their fumigation companies, who are also the CUN applicants. There is an inherent 

conflict of interest when the companies requesting the MB are the ones doing the trials and who 

can withhold the information that would allow MBTOC to assess those trials. 

MBTOC has become concerned that some CUN applicants have become complacent and are 

not as focused on adopting alternatives as they should be. We have noted that some Parties are 

not submitting nominations that provide adequate substantiation and depth of information to 

support their CUNs. 

We draw the attention of the Parties to the environmental concerns about the use of SF. The 

high GWP of sulfuryl fluoride as a contributing factor to ongoing MB use should not be 

underestimated. The Progress Report will discuss this situation further. 

10.4.1 Standard Dosage Presumptions and Adjustments for standard dosage 

rates 

MBTOC assessed CUNs for appropriate MB dosage rates and deployment of MB emission/use 

reduction technologies, such as 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 minimisation 

techniques, requesting Parties “...to ensure, wherever methyl bromide is authorised for criticaluse exemptions, the use of emission minimisation techniques that improve gastightness or the 

use equipment that captures, destroys and/or reuses the methyl bromide and other techniques 

that promote environmental protection, whenever technically and economically feasible.” 

With the beginning of the CUN process in 2005, MBTOC published its standard presumptions 

for structures (20g m-3) and indicated that the European Plant Protection Organization’s (EPPO) 

published dosage rates for commodities should be considered standard best practice for 

fumigation world wide. Since that time, and with very little delay, all Parties and fumigators 

have adhered to those practices. The EPPO dosage rates for commodity treatment vary by 

commodity, sorption rate and environmental conditions. They can be found in annexes to the 

MBTOC 2006 Assessment Report (MBTOC, 2007). Where possible, the use of lower dosages, 

combined with longer exposure periods, can reduce MB use while maintaining efficacy. 

(MBTOC. 2007. 2006 Report of the Methyl Bromide Technical Options Committee. 2006 

Assessment Report.) 

10.4.2 Details of evaluations 

Parties have submitted eight CUNs for the use of MB in structures and commodities in 2010. 

The total MB volume nominated in 2010 for non-QPS post-harvest uses was 185.704 tonnes. 

In the 2010 round, one (Canada Pasta) nomination was for 2011 for a total MB amount of 3.529 

tonnes. In the 2010 round, seven were for 2012 for a total MB amount of 182.175 tonnes. 
May 2010 TEAP Progress Report 239

Of nominations for 2011, MBTOC recommended 2.084 tonnes and for 2012, 98.936 tonnes. 

MBTOC did not recommend 86.768 tonnes. 

Table 10-13 provides the MBTOC-SC interim recommendations for the CUNs submitted. 
240 May 2010 TEAP Progress Report 

Table 10-13: Final evaluations of CUNs for structures and commodities submitted in 2010 for 2011 or 2012

Country Industry CUE for 

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CUN for 2011 (Addtl or new) 

CUN for 2012 

Australia Rice 6.150 6.150 .205 9.200 7.820 6.650 4.87 - 4.870 

MBTOC comments 2010: MBTOC recommends 1,948 kg for rice in Australia in 2012. This is a 60% reduction of the Party’s nominated amount of 4,870 kg nominated the same amount for 2012 as was granted by the Parties for 2011. The Accounting Framework indicated that in 2009, kg for rice. Our recommendation for 2012 represents a 44% reduction in the actual use in 2009, for 2012. For the reasons discusscontinues to find that several technically effective and registered alternatives are available in Australia for immediate adoption for rice or rice in silos. In three previous years, MBTOC has recommended a reduction of 15-20% of MB for Australian rice. These reductions should hav

adoption of alternatives. There is no evidence that this has occurred because the Party has based its nominations on harvests forrainfall was greater and water allocations were higher. The usual and feasible adoption rate for alternatives should have allowed a in the second year, followed by 60% in the third year, however this applicant is behind schedule due to the complete lack of adopThe applicant has selected phosphine as its preferred alternative. The Party reports that the applicant can not afford to adopt phothat to begin to adopt phosphine they would have to build 100 silos and 2. that due to low rice harvests the applicant can not afforadopt alternatives at all. MBTOC disagrees on the extent of infrastructural and processing changes required if phosphine were to be adopted. Use of phosprior to packaging would require an increase in the number of sufficiently gastight silos, but the CUN says that packaged rice will not required for the fumigation of packaged rice. If packaged rice is to be fumigated with phosphine, it could be treated in stacks itemporary enclosures which are much less expensive than building new silos. The CUN indicates that the applicant has achieved 

therefore there should be some opportunity to phase in alternatives. Furthermore, the Party has indicated that in the instance of hallocation, the applicant will either export the excess rice or stored for future years. More recently the applicant said it is also considering using SF which would not require extensive new infrastructure. SF treatmenMB use. SF is registered for rice, polished rice and wild rice against all stages of stored product pests in silos, food handling and warehouses, temporary and permanent fumigation chambers (Dow Profume Label Australia, 2008). As in previous years, MBTOC informs the Party that controlled atmosphere technology is effective, does not require registration, numerous countries and the suppliers of controlled atmosphere storage facilities rent the equipment and facilities to users, reduciinvestment. As in previous years, the applicant has said it will only consider phase out if harvests increase, but MBTOC is mandated to expecbegin to adopt alternatives for the harvests they actually have, not the harvest they wish to achieve. MBTOC finds that recent histrelatively low harvests are now prevalent for this region in Australia. Supporting this view is that rice farmers have already borrowallocations and until recently the region continued to experience drought. 
May 2010 TEAP Progress Report 

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CUN for 2011 (Addtl or new) 

CUN for 2012 

Emission Reduction: Yes. The applicant now intends to send all MB-fumigated rice through MB recapture equipment. The applic

a majority percentage of the MB used. Research Program. Unable to assess. A research project in 2009 was interrupted due to the unfortunate death of the scientist in the applicant has indicated that they have chosen phosphine as their alternative; MBTOC does not believe there is a need for furtphosphine. The applicant is now considering sulfuryl fluoride and so should conduct further research on this fumigant as proposecorrespondence. Appropriate effort. Insufficient. As with all postharvest registration issues, neither the applicant nor the Party mandated with Mo

nominations has control over pesticide registration. This applicant, however, has not made appropriate efforts to adopt alternativehave been adopted in spite or registration of technically effective and affordable alternatives being available. Economists need paallow an economic assessmentMBTOC comments on economics 2010: This CUN is partly based on economic arguments. CUN states that two potential technically and economically feasible alternative

and phosphine, have been identified. Sulfuryl fluoride, which requires less significant process changes and investment to implemeNovember 2007 and SunRice commenced trials in January 2009. The Party notes the need to generate supporting data. Phosphconsidered by the Party to be the best solution, both technically and economically, although the applicant requires that the introduinclude a considerable change to processing methods and a substantial infrastructure investment. The CUN shows projected ope

phosphine system would be 15 times that for methyl bromide. The CUN relates the difficulties faced by the applicant in raising thphosphine. CUN states further that the applicant has been unable to finance a transition to phosphine due to continued severe dgrowing area; hence it is unaffordable to them. MBTOC recognizes that the phosphine sytem contemplated by the applicant is a process than the current MB based process. However, it is unclear that construction of one or more pilot silos, or other fumigatioincremental implementation of a phosphine system is unaffordable. The company indicates it has returned to normal profitability. 

Mills 47 

(included 

mills and 

pasta) 

Canada 34.774 30.167 28.650 26.913 22.878 14.107 - 11.020 

MBTOC comments 2010: MBTOC recommends the nominated amount of 11,020 kg for Canada flour mills in 2012. The party’s nomination was a reduction of MB granted by the Parties for 2011. In 2012 there will be 19 mills included in the application, one fewer than in 2011. The applinomination by about half since 2010, due to the results of a multi-year research program and the advent of the new regulation whMB allocation by companies within the CUN. The amount of MB recommended for 2012 will only fumigate 7-8 mills. With this and other CUNs MBTOC remarks that heat treatments (in combination with DE) should also be used, when possible. Tthere may be ongoing problems with achieving the full registration of sulfuryl fluoride. In a recent letter, the Government of Canadavailability of heaters is limited during weekends traditionally used to conduct pest control treatments. MBTOC recommends that 
242 May 2010 TEAP Progress Report 

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CUN for 2012 

logistical problem be intensified. Concerning heat treatments for mills, MBTOC notes that research shows practical/logistical challenges and possible insufficient ewith mills >40,000 m3. MBTOC also notes that in large mills that have concrete basements it might be difficult or economically infe

sufficiently to allow the same degree of control of pest control as can be achieved with a gas fumigant (depending on the weather With a concrete basement acting as a heat sink and refuge for the pests, the pest population rebounds faster. However, there is atreatment can be optimized and effective once it is learned how exactly to conduct the heat treatment in each individual mill. Therto achieve optimization because whole site treatment is usually only done once per year, so it might take several years to really omethod for that particular mill. It would be good to have heat treatment experience and therefore a choice of effective treatments. MBTOC does recognize the need to ensure the optimization of effective heat treatment or fumigation in the context of increasing hygiene. Although this CUN reduces by 18-22% each year, we note, with concern, that this use could be ongoing for several years unless or greater adoption of heat treatment. The applicants report they are awaiting the full registration for SF which would allow contacMBTOC notes that it is possible that the full registration of SF will never occur. Therefore the Party is requested to provide a manallow for phase out of MB in this sector in the eventuality that full registration of SF is not achieved. Emission control. Mills are now not treated annually, which reduces emissions. Ongoing research – Excellent research multi-mill, multi-stakeholder research program in past with several full reports submitted 

DE, SF and elevated temperature, phosphine + CO2, etc). Research has not been reported in past two years; MBTOC is not conresearch in this field is absolutely necessary. When mills are not MB fumigated, they are being heat treated and all are now in enhAppropriate effort in the CUN? Full registration of SF has not been achieved; there is still no food tolerance for F residues from action has been delayed for several years and hinders ability to fully adopt SF as an alternative treatment. Neither the millers nor fumigant registration. In spite of delay in achieving full registration, the mills are continuing to make progress. MBTOC comments on economics 2010: This CUN is not based solely on economic arguments, although economic concerns are indicated. CUN argues that market penemost viable alternatives is being hampered by: • Insufficient evidence that SF can be effective under Canada’s typically cold weather conditions. • Lack of full registration of SF • Current market cost of heat treatment technology and services. • Concerns by the milling industry that repeat fumigations using phosphine may have a cumulative effect of corroding conductive and electronic equipment and controls. The Party has stated in the past that operating margins in this industry are small. This CUN notes that the required use of alternaperiod would add an estimated 2 to 4 per cent to manufacturing costs of wheat flour, semolina and other milled grain products. Thfaced by flour mills make it unlikely a substantial portion of these added costs could be passed on down the supply chain. Regard
May 2010 TEAP Progress Report 

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CUN for 2012 

there are no government subsidies available to offset these increased costs, MBTOC notes that lack of government financial assibeen a consideration in assessments of economic feasibility. The Party has indicated concerns that SF has been shown to have potential and this could result in future constraints on its use, which adds another factor which might slow adoption of SF. 

Pasta (see 

Canada 

mills) 

Canada 10.457 6.757 6.067 4.740 3.529 - 3.529 - 

MBTOC comments 2010: MBTOC recommends 2,084 kg for Canada pasta facilities in 2011. This is a 41% decrease of the amount granted by the Parties fParty nominated 3,529 kg for 2011, which is the same amount granted by the Parties for 2010. There are three facilities, each reqper facility. Concerning the nominated amounts, MBTOC notes that given the facility volumes, the MB nominated is only sufficient fumigation, in two of the pasta facilities. All facilities are making IPM improvements. Facility #1 of the CUN reports poor gastightness and we can not recommend the use gastightness any longer. We note that facility #2 reporting medium gastightness will have to make facility improvements to show gconsidered for any future CUN. In the CUN for the 2009 round, MBTOC recommended that one facility conduct a trial with an alternative and report the results to companies in the sector. Although the facilities have said they conducted SF trials in the sections where food products would not documenting those trials were not submitted to MBTOC. No research reports have been submitted this year. The applicants report they are awaiting the full registration for SF which would allow contact of SF on commodities. MBTOC notes full registration of SF will never occur. Therefore the Party is requested to provide a management plan which will allow for phase othe eventuality that full registration of SF is not achieved. It has been reported that other pasta facilities in Canada and the US use heat alone or SF and elevated temperature for pest contMBTOC has recommended that heat treatments be conducted in Canadian pasta facilities. These applicants however, have not r

results of any heat treatments in their facilities, or elsewhere. The applicants indicate concerns about using heat, but in spite of resubmitted any evidence to support this concern. Heat treatments are successfully conducted at other pasta manufacturers . Heat and IPM have been used for a number of years America, including large pasta facilities comprising mills, interior silos and processing lines (Gyovai, 2009). Europe has more than sector completed the MB phase-out several years ago even in countries that have not registered SF (Buckley 2008). Heat and IPcold northern European countries in which SF is not registered (European Community, 2008). There is ample evidence that heaoptimized and effective once it is learned how exactly to conduct the heat treatment in each individual facility. There is also ample the concerns mentioned by the applicant can be addressed by service providers when they conduct heat treatments. Spot heat trequipment is also a likely alternative. There is a long learning curve to achieve optimization of full site heat because such treatmeonce per year, so it might take several years to fully optimize the treatment method for that particular facility. There is a much shoconduct spot heat treatments; spot heat treatments of infested equipment are used in several food processing companies. It woultreatment experience and therefore a choice of effective treatments, particularly because full registration of SF may not be achiev
244 May 2010 TEAP Progress Report 

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CUN for 2012 

SF can be used for empty structures only and not for food products in Canada. There are some rooms in the pasta plants which cand products which must be sealed off at the time of fumigation. Full registration of SF, including establishment of MRLs for cereaproducts is taking longer than expected and as of April 2010 it has not occurred. However, MBTOC notes that it is not an adequatcontinue to request MB while awaiting a registration change that continues to be delayed and considering that other methods are situations. The other methods include heat alone (either full site or spot heat), SF treatment of non-food facility rooms, and avoidathrough other means. Emissions reduction. MBTOC has not recommended MB use in the one facility reporting poor gastightness. Another facility repgastightness is working to improve but will have to achieve good gastightness to even be considered for a CUN in future rounds.Research effort. Insufficient. Full reports of research and trials of alternatives are required in the types of facilities included in the Appropriate effort. As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protoc

over pesticide registration. Many similar companies have switched to alternatives. As indicated, inadequate effort has been made receives sufficient information about this sector and to supply actual data, research reports and partial budget analysis. MBTOC comments on economics 2010: This CUN is not based on economic arguments. The current CUN adds no economic information. It restates earlier assertions tha costly alternative with technical concerns about damage to building and equipment. The CUN states that cost data on alternatives for pasta manufacturing facilities will be provided “as it becomes available.” MBTOC 

an economic basis for this CUN absent substantiation of the costs of alternatives.

Japan Chestnuts 7.100 6.800 6.500 6.300 5.800 5.400 5.35 - 4.984 

MBTOC comments 2010: MBTOC recommends 3,489 kg for 2012 which is a 30% reduction over the Party’s nominated 4,984 kg for Japan fresh chestnuts 

nominated a 7% reduction for this year over the 2011 amount; the reduction was to be achieved by logistical changes in on-farm fTo date there has been no adoption of alternatives in this commodity, but methyl iodide (MI) was registered for fresh chestnuts in Government of Japan says market supply can not be achieved until 2011. MBTOC notes that since MI has been registered and wis therefore expected that Japan will begin adoption of MI as of the September-October harvest in 2011. In 2011, which MBTOC vadoption, a 15% market penetration of MI should be achievable, with a resulting reduction in MB use. MBTOC also believes that a penetration should be achievable in 2012. Japan says they must take time to train farmers in safe use of the new fumigant, but this necessary training can and should begin 2010 harvest (September – October of 2010). MBTOC sees the need for training in the use of MI. Japan has informed MBTOC thfor MB use on chestnuts will be submitted later. (Japan NMS has indicated an intention to phase out of soil use of MB by 2013.) Tfumigation infrastructure in the switch between MB and MI, but in consideration of the need for on-farm training, MBTOC believes 2012 is both responsible and achievable. 
May 2010 TEAP Progress Report 

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CUE for 20073

CUE for 20084

CUE for 20095

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CUN for 2011 (Addtl or new) 

CUN for 2012 

The Party notes that the price of MI is currently 4x higher than MB, but MBTOC notes that the cost of fumigation is a very small (apercentage of the price of this high value commodity. Therefore, even at current MI price, we do not find the cost of MI fumigation the high value of chestnuts. Furthermore, the MI manufacturer is planning to do some research trials to investigate the use of a lowhich will therefore lower costs. Emission reduction To date regular reductions in MB use through logistical improvements. Research program in past 12 months. Extensive research program has been completed, no further research needed other than of MI can be achieved, and that is optional. There is established efficacy of MI for this purpose in Japan and it has been registereAppropriate effort? Registration for methyl iodide proceeded as per normal and was registered after appropriate review. MBTOC comments on economics 2010: CUN states that an economic assessment has not been conducted because methyl iodide, registered in 2009, is scheduled to be 

2011, but that the price of methyl iodide is expected to be four times higher than MB. 

United Commodities 89.166 87.719 78.983 58.921 45.623 19.242 5.000 - 4.907 

States 

MBTOC comments 2010: MBTOC recommends 2,155 kg for US commodities in 2012. This is a 56% reduction over the amount nominated, based on 75% nomination (829 kg recommended), 50% reduction in walnuts (263 kg recommended) and 0% reduction in dates (1063 kg recom

nominated 4907 kg for commodity use in 2012. The commodities included in the CUN are dried fruit (3,317 kg) (dried plums, figs kg) and dates (1,063kg). The USG reported that until viable options with the registered alternatives are further developed, the dried fruit industry has reachof alternatives. But MBTOC believes there are several lines of action available with registered alternatives to almost entirely avoid fruit and nuts. For example, phosphine, cold storage after heat drying to prevent reinfestation and propylene oxide (when used to insect pests will also be killed) are alternatives that could be used for the commodities in this CUN. SF is also registered for some Germany carbon dioxide under pressure is used to disinfest some dried fruits. The industry acknowledges that dried plums are free of insects when they come out of the dryer and that re-infestation occurs fairinfestation is the reason for these stored commodity treatments. MBTOC’s view is that the industry should work to prevent re-infethis logistical problem be resolved on a priority basis. The USG said in correspondence that the industry has already transitioned possible, but that MB is needed if treatments need to occur around electronic and electrical equipment. MBTOC does not find this Commodity requiring phosphine fumigation can be moved to an appropriate location for fumigation. The Party states that the California dried fruit and nut industries continue to financially support research on methyl bromide alternapplications, but full reports of these tests have not been submitted to MBTOC. 
246 May 2010 TEAP Progress Report 

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CUN for 2011 (Addtl or new) 

CUN for 2012 

The CUN reports that SF is an effective treatment for walnuts. The walnut industry fumigates during 6 months of the year at or be

(supporting temperature data for the San Joaquin and Sacramento Valleys of California was provided). MBTOC notes that small raise the temperature of stacks of fruit or nuts to allow effective treatment with SF. Such methods are in common use in several cworldwide. Additionally MBTOC questions whether presence of pest eggs is indeed a problem in walnuts at time of harvest. Normprogressed to larval stage by harvest; larvae are easier to kill at lower temperatures with SF. The CUN (page 7) says,”Approximately 25 percent of walnuts are sold in the shell. Those that are packed and shipped to Europeof days of the fumigation treatment qualify for quarantine exemptions for Methyl Bromide use. Those that are sold domestically omay apply for a CUE. The remaining 75 percent of walnuts are processed further to create a variety of packaged shelled productsfumigated before they are put in long-term storage or continue in the processing chain due to the key pests. Phosphine can be u

walnuts that are allocated for packaged shelled products because turnaround time is not crucial.” Considering the CUN comments on walnuts, the CUN nominated 527 kg for walnuts and this amount of MB would treat approxim

walnuts or about 2,500 tonnes. Therefore the CUN seems to be requesting MB for the amount of in-shell walnuts sold domesticalwhether this segment might not be needed for immediate domestic sale and if so if logistical improvements might be possible to afor most of this segment. Additionally, controlled atmosphere could be used. The controlled atmosphere treatment of walnuts usemoths is 5 days, in gastight chambers under elevated temperature conditions. Furthermore, propylene oxide treatment is allowed reduce bacteria and mold and this treatment would also kill insect pests. Cold storage is also used by this sector to prevent reinfeWith dates there is an issue of regulatory interpretation. In the United States, sulfuryl fluoride is currently labeled for use on dried harvested in the US are considered by MBTOC to have already been dried on the tree prior to harvest in that their moisture conteDavies pers comm to MBTOC). This moisture content does not conform to the definition of high moisture dates in other date growThe concept of ‘fresh’ is not pertinent or informative to this discussion. MBTOC believes it is reasonable to interpret the regulation on these dates in the US. The USDA Agriculture Research Service scientist has submitted an extensive report of ongoing date research (Walse, 2009). The has not yet been shown to be technically effective because ambient temperature at time of harvest is relatively low; studies have when SF treated at these low temperatures. Although the low temperature problem was mentioned for all three sectors of this CUtemperature is particularly pertinent to dried fruit and dates at the end of the harvest season. The applicants believe that further reovicidal efficacy of SF at temperatures below 21 ̊C (70 °F), as well as on the ovicidal efficacy of propylene oxide/SF combinationsdemand for dates, phosphine treatment could be used. The California Date Commission reports that it is currently testing the efficacy of sulfuryl fluoride on dates, with preliminary results adequate egg kill, even when the amount used is twice that needed for a comparable methyl bromide fumigation. MBTOC acknowresearch program is ongoing and that it has been kept well informed of progress and problems. MBTOC members have been ablconditions at the date processors. Essentially, when ambient temperature was low (<21 ̊C or 70 ̊F), and at dosages where residuregulatory maximum limits, eggs survived. This is predictable. The work is now being done combining SF and elevated temperatuEmissions reduction. This sector has very considerably reduced use of MB, and therefore emissions. Fumigation takes place in enclosures. 
May 2010 TEAP Progress Report 

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CUN for 2011 (Addtl or new) 

CUN for 2012 

Research effort. Research on dates is excellent thus far but more remains to be done, for example, to optimize SF treatment by MBTOC needs detailed and complete reports on research conducted on the other commodities included in this CUN. 

Appropriate effort. Several alternatives are already registered. MBTOC notes that regulatory interpretation of use of SF on dates 

MBTOC believes the US dates are dried at time of harvest. MBTOC comments on economics 2010: The same economic arguments are provided as in the previous year. CUN is not based on economic (in)feasibility. 

NPMA food 

processing 

structures 

(cocoa beans 

removed) 

United 83.344 69.118 82.771 69.208 54.606 37.778 17.365 - 17.365 

States 

MBTOC comments 2010: MBTOC does not recommend this CUN. The Party nominated 17,365 kg, for food processing facilities in 2012, the same amount for 2011. The substantiation for this CUN is unacceptably thin. No studies or reports detailing trials have been submitted that were conductin this CUN. The applicants indicate that trials are conducted but the information will not be submitted to MBTOC; since these samwithholding the results of trials are also the applicant requesting MB, MBTOC finds this situation to be unacceptable. To MBTOC’s knowledge, no flour mills are included in this CUN, but the only study that was submitted to MBTOC supporting this 

study by researchers at Kansas State University; no studies in processed food facilities, herb and spice facilities or cheese stores heat treatment studies have been submitted, although heat treatment is commonly used in this sector in the US and elsewhere. In response to MBTOC’s questions about the use of spot heat treatment for herb and spice milling equipment, MBTOC was suppthe inadvisability of treating organic pasta product with heat, which is not relevant to the subject. Spot heat treatment of equipmenin herb and spice facilities is conducted in other countries. MBTOC asked many questions trying to obtain information about the use of alternatives directly relevant to the facilities included indicated that a review of this CUN required MBTOC to know the numbers and types of facilities included; these questions were nand documentation was not received. USG said that it had informed MBTOC of the types of facilities included in this CUN in 2005completely out of date for a CUN for 2012. USG has not supplied any actual use data for this sector, even for MB use in cheese storages where USG has said that MB fumigthe requirement of government inspectors. The USG told MBTOC that records of failed inspections are not available to the publicanswer because we do not need to know company names we only need to know actual use (if any) of MB for cheese stores. The applicant’s interpretation of the success of the one Kansas State University flour mill study submitted is not in agreement with study authors concluded that, “Both MB treatments killed 100% of all stages in the boxes except for large larvae in a few locations
248 May 2010 TEAP Progress Report 

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CUN for 2012 

mortality of large larvae ranged from 96-98%. SF treatments killed 100% of all stages except eggs. In the May treatment with SFfrom 44 -100% with only two boxes showing 100% mortality, because of under-dosing. Under-dosing occurred because the mill teto be greater than 27oC when it was actually below 27oC. In the second SF trial, only three boxes had egg mortalities that were le

data from the two replications showed that the mean mortalities of eggs and large larvae between MB and SF were not significan

other.” (Hartzer et al, Kansas State University, 2010 in press) Emissions reduction. The sector has considerably reduced MB use and therefore reduction but we have not been provided with gastightness in the facilities included in the CUN Research effort. Insufficient. Full reports of research and trials of alternatives are required in all the types of facilities included in 

Appropriate effort. As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protoc

over pesticide registration. Many of the companies formerly associated with this CUN have switched to alternatives and/or decreaonly once every few years. As indicated, inadequate effort has been made to ensure MBTOC receives sufficient information abouactual data, research reports and partial budget analysis. MBTOC comments on economics 2010: The same economic arguments are provided as in the previous year. CUN is not based on economic (in)feasibility. 

Mills and 

processors 

United 483.000 461.758 401.889 348.237 291.418 291.418 173.023 - 135.299 

States 

MBTOC comments 2010: MBTOC recommends 74,510 kg, for US food processing structures in 2012. This represents a 50% decrease in flour milling, a 50

milling and a zero decrease for pet food facilities from the amounts nominated by the Party. The Party has nominated 135,299 kg structures included in this CUN. This was the same amount granted by the Parties for 2011. The Party nominated flour milling (10(14,511 kg), and pet food manufacturing (13,722 kg), but MBTOC recommends for flour milling (53,533 kg), rice processing (7,25manufacturing (13,722 kg). As in previous years, MBTOC comments that substantiation for this CUN is very thin. In fact, although one flour mill study by reseUniversity was presented, no studies in rice mills or pet food establishments have been submitted. There have been several Nortstudies including a heat treatment study by Kansas State University and those by Canadian companies in association with AgricuCanada, but these were not included or considered by the applicant. Furthermore, the applicant’s interpretation of the success of the one Kansas State University flour mill study submitted is not in agauthors. The study authors concluded that, “Both MB treatments killed 100% of all stages in the boxes except for large larvae in a locations, the mortality of large larvae ranged from 96-98%. SF treatments killed 100% of all stages except eggs. In the May treamortality ranged from 44-100% with only two boxes showing 100% mortality, because of under-dosing. Under-dosing occurred be

temperature was assumed to be greater than 27oC when it was actually below 27oC. In the second SF trial, only three boxes had 

less than 100%. However, data from the two replications showed that the mean mortalities of eggs and large larvae between MB significantly different from each other.” (Hartzer et al, Kansas State University, 2010 in press) 
May 2010 TEAP Progress Report 

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CUN for 2011 (Addtl or new) 

CUN for 2012 

In response to MBTOC’s request in correspondence, short summary paragraphs were sent in letters from USG about trials in rice facilities. This is insufficient information and does not adequately support the CUN. According to the USG, there has been much progress in the alternatives of methyl bromide. Alternatives are not only sulfuryl fluomicrosanitation. The use of fogging, space, and crack and crevice treatments has greatly decreased the number of times structuHowever the Party reports that many companies desire to retain the ability to utilize methyl bromide in the event of a difficult infesMB use on a contingency basis is not a critical use and that an emergency use provision still exists under the Montreal Protocol foThe applicants for US food structures CUN indicate that trials are conducted but the information is proprietary and will not be submthese same organizations withholding the results of trials are also the applicant requesting MB, MBTOC finds this situation to be ainterest. The applicant is assured that proprietary information would be handled confidentially within MBTOC, in addition, companto MBTOC. The Party reports that, “a vast majority of pet food facilities have transitioned away from use of methyl bromide as part of their rouprogram. Companies that have completed the transition away from methyl bromide either view their pest management programs competitive advantage, so we are unable to share specifics on those alternative programs. We can suppose that such programs umicrosanitation, spot heat treatment, insect growth inhibitors, and fumigation treatment with Vapona ULV fogging, phosphine and The CUN indicates that lack of adequate registration negatively impacts the ability of pet food facilities to use sulfuryl fluoride bec

not include pet food and the applicant says that the pet food can not be moved out of the establishment before fumigation with SFThe pet food facility applicants in particular report they are awaiting label extensions for SF which would allow contact of SF on cothat it is possible that this will never occur. Therefore the Party is requested to provide a management plan which will allow for phsector in the eventuality that label extensions for SF are not achieved. In flour and rice milling, a different problem is presented with the use of SF. The GWP of SF has been reported by TEAP and elseapproximately 4000 times that of carbon dioxide (refer to Progress Report for more details). Furthermore more SF is used to fumi(the amount varies from 1.5 to 4x more depending on temperature at time of fumigation). No actual evidence in the form of letters retailers or other industrial customers were presented to MBTOC. In response to MBTOC correspondence, USG said that Walmareduce their carbon footprint and the applicants say this is preventing their use of SF. No new economic data has been presented in this year’s CUN for structures. SF requires elevated temperature in combination ancombined treatment is technically comparable to MB. The cost of SF treatment is higher (with or without additional heat). HoweveProtocol have not indicated that a higher cost is a sufficient reason to avoid using an alternative. MBTOC economists are adopting a standard that a 15-20% decrease in net revenue is still an economically feasible alternative. FTable 5 of CUN, the Party indicates 0.8% loss on gross revenue for the worst case scenario of having to heat a cold manufacturin

(MBTOC notes that only the most dire and completely unlikely circumstance would see the temperature of an entire pet food estaThis table also indicates that 0.06% loss of gross revenue on an elevated temperature-plus-SF treatment when the treatment is retemperature from 4.4 ̊C to 29.4 ̊C plus SF treatment. (Again it is completely unlikely that an entire pet food establishment tempera

In the instance of a SF treatment there would be additional costs of moving the pet food out of the building. Therefore, according standard, both heat treatment alone and elevated temperature plus SF treatment are economically feasible. The comparable data 

were not provided to MBTOC. 
250 May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117

CUN for 2011 (Addtl or new) 

CUN for 2012 

For several years, MBTOC has asked for partial budget analysis for all the sectors included in this CUN, including the flour and ric

these have not been received. In the absence of gross revenue data, we assume the fumigation costs for flour and rice milling sepercentage to pet food manufacturing. Emission reduction. There is still work to be done to improve the sealing of mills and facilities. Improved sealing would allow the 

which would decrease emissions. Research effort: Insufficient. Full reports of research and trials of alternatives are required in all the types of facilities included in Appropriate effort. As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protoc

over pesticide registration. Many of the companies formerly associated with this CUN have switched to alternatives and/or decreaonly once every few years. As indicated, inadequate effort has been made to ensure MBTOC receives sufficient information abouactual data, research reports and partial budget analysis. MBTOC comments on economics 2010: The same economic arguments are provided as in the previous year. CUN is not based on economic (in)feasibility. 

United Cured pork 67.907 40.854 18.998 19.669 18.998 4.465 3.73 - 3.730 

States 

MBTOC comments 2010: MBTOC recommends 3,730 kg for cured pork products in 2012. The Party nominated 3,730 kg for cured pork products in 2012, th

nominated for 2011. Some decrease in the MB nomination has been achieved over the years resulting from IPM, emissions contrimprovements. There is no alternative registered for this use. There is a multi-state, multi-university research program ongoing whalternative treatments, increasing knowledge of pest and dose response to potential alternatives. Initial work on phosphine showeshowed changes in odor of the pork. Earlier work by this group using SF indicated lack of efficacy. (Shilling, 2009a, 2009 b). MBTone of the key pests of cured pork and that mites will not be controlled by the phosphine treatment. Additionally, phosphine is not in the US. MBTOC encourages registration of effective fumigants, once identified. Full reports of this research has been sent to Mcommunicated to the industry sector. MBTOC has been able to observe and confirm the conditions and processing of the cured pincluded in this CUN. Emissions reduction. Over the years the applicants have made facility improvements to improve gastighness, but this is a tradit

and some of the facilities are older and unusual. The research program continues to work with the applicants to improve gastightnprocess improvements which reduce the need for fumigation and result in decreased use of MB. This work needs to continue. Research effort. Excellent research effort to date but more needs to be done. A multi-state, multi-university research program is 

research have been made available to MBTOC. Appropriate effort. As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protoc

over pesticide registration. There are no alternatives registered for the treatment of pests in meat at this time. MBTOC comments on economics 2010: 
May 2010 TEAP Progress Report 

Country Industry CUE for 

20051

CUE for 20062

CUE for 20073

CUE for 20084

CUE for 20095

CUE for 20106

CUE for 20117

CUN for 2011 (Addtl or new) 

CUN for 2012 

CUN states that no economic analysis was done due to the lack of technically feasible alternatives 

11ExMOP and 16MOP 216MOP+2ExMOP+17MOP 3MOP17+MOP18 4MOP18+MOP19 5MOP19+MOP20 6MOP20 7MOP21 
252 May 2010 TEAP Progress Report 

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Stored Walnuts. Proceedings of Methyl Bromide Alternatives Organization conference. 

Orlando Florida November 2008 

Webster, T. M., T. L. Grey, et al. (2008). Glyphosate hinders purple nutsedge (Cyperus rotundus) and yellow 

nutsedge (Cyperus esculentus) tuber production.Weed Science 56(5): 735-742. 

Yates et al (2007). Film permeability measurements in support of USDA-ARS area wide research. Methyl 

Bromide Alternatives Organization conference. Orlando San Diego, November 2007 
258 May 2010 TEAP Progress Report 

Common Acronyms 

1,3-D 1,3-dichloropropene 

A5 Article 5 Party 

CUE Critical Use Exemption 

CUN Critical Use Nomination 

DOI Disclosure of Interest 

EC European Community 

EMOP Extraordinary Meeting of the Parties 

EPA Environmental Protection Agency 

EPPO European Plant Protection Organisation 

MI Methyl iodide (or Iodomethane) 

IPM Integrated Pest Management 

IPPC International Plant Protection Convention 

ISPM International Standard Phytosanitary Measure 

LPBF Low Permeability Barrier Film (including VIF films) 

MB Methyl Bromide 

MBTOC Methyl Bromide Technical Options Committee 

MBTOC QSC Methyl Bromide Technical Options Committee Quarantine, Structures 

and Commodities Subcommittee 

MBTOC S Methyl Bromide Technical Options Soils Subcommittee 

MDI Metered Dose Inhalers 

MITC Methyl isothiocyanate 

MOP Meeting of the Parties 

MS Metham sodium 

OEWG Open Ended Working Group 

Pic Chloropicrin 

QPS Quarantine and Pre-shipment 

QPSTF Quarantine and Pre-shipment Task Force 

SF Sulfuryl fluoride 

TEAP Technology and Economic Assessment Panel 

TIF Totally impermeable films 

USA United States of America 

VIF Virtually Impermeable Film 

VOC Volatile Organic Compounds
May 2010 TEAP Progress Report 259

Annex I to Chapter 10: Decision IX/6 

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. NonArticle 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 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).
260 May 2010 TEAP Progress Report 

Annex II to Chapter 10: Decision XVI/4 

Review of the working procedures and terms of reference of the Methyl Bromide 

Technical Options Committee

Report of the Sixteenth Meeting of the Parties to the Montreal Protocol (Annex I), Prague, 22–26 

November 2004), paragraph 15. 

A. Working procedures of the Methyl Bromide Technical Options Committee relating 

to the evaluation of nominations for critical uses of methyl bromide 

15. An annual work plan will enhance the transparency 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. 
May 2010 TEAP Progress Report 

Annex III to Chapter 10 - Part A: Trend in Preplant Soil Applications List of nominated (2005 – 2012 in part) and exempted (2005 – 2011 in part) amounts of MB granted by Parties under the CUE p

commodity. 

Party Industry Total CUN MB Quantities Total CUE Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2

Australia Cut Flowers – field 40.000 22.350 18.375 22.350 Australia Cut flowers – protected 20.000 10.425 Australia Cut flowers, bulbs – protected Vic 7.000 7.000 6.170 6.150 7.000 7.000 3.598 3Australia Strawberry Fruit 90.000 67.000 Australia Strawberry runners 35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.790 35.750 37.500 35.750 3Belgium Asparagus 0.630 0.225 0.630 0.225 Belgium Chicory 0.600 0.180 0.180 0.180 Belgium Chrysanthemums 1.800 0.720 1.120 Belgium Cucumber 0.610 0.545 0.610 0.545 Belgium Cut flowers – other 6.110 1.956 4.000 1.956 Belgium Cut flowers – roses 1.640 Belgium Endive (sep from lettuce) 1.650 1.650 Belgium Leek & onion seeds 1.220 0.155 0.660 Belgium Lettuce(& endive) 42.250 22.425 25.190 
262 May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2

Belgium Nursery Not 

Predictable 

0.384 0.900 0.384 

Belgium Orchard pome & berry 1.350 0.621 1.350 0.621 Belgium Ornamental plants 5.660 0.000 Belgium Pepper & egg plant 5.270 1.350 3.000 1.350 Belgium Strawberry runners 3.400 0.900 3.400 0.900 Belgium Tomato (protected) 17.170 4.500 5.700 4.500 Belgium Tree nursery 0.230 0.155 0.230 0.155 Canada Strawberry runners (PEI) 14.792 6.840 7.995 7.462 7.462 7.462 5.261 5.261 (a)14.792 6.840 7.995 7Canada Strawberry runners (Quebec) 1.826 1.826 (a) 1.826 1.826 Canada Strawberry runners (Ontario) 6.129 6.129 France Carrots 10.000 8.000 5.000 8.000 8.000 1.400 France Cucumber 85 revised 

to 60 

60.000 15.000 60.000 60.000 12.500 

France Cut-flowers 75.000 60.250 12.000 60.000 52.000 9.600 France Forest tree nursery 10.000 10.000 1.500 10.000 10.000 1.500 France Melon 10.000 10.000 7.500 6.000 France Nursery: orchard, raspberry 5.000 5.000 2.000 5.000 5.000 2.000 
May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2

France Orchard replant 25.000 25.000 7.500 25.000 25.000 7.000 France Pepper Incl 

in.tomato cun 

27.500 6.000 27.500 6.000 

France Strawberry fruit 90.000 86.000 34.000 90.000 86.000 France Strawberry runners 40.000 4.000 35.000 40.000 40.000 28.000 France Tomato (and eggplant for 2005 

only) 

150(all solanaceous) 

60.500 33.250 125.000 48.400 

France Eggplant 27.500 33.250 48.400 Greece Cucurbits 30.000 19.200 30.000 19.200 Greece Cut flowers 14.000 6.000 14.000 6.000 Greece Tomatoes 180.000 73.600 156.000 73.600 Israel Broomrape 250.000 250.000 125.000 12.500 12.500 250.000 2Israel Cucumber - protected new 2007 25.000 18.750 18.750 12.500 25.000 Israel Cut flowers – open field 77.000 67.000 80.755 53.345 42.777 42.554 23.292 77.000 67.000 74.540 4Israel Cut flowers – protected 303.000 303.000 321.330 163.400 113.821 72.266 52.955 303.000 240.000 220.185 Israel Fruit tree nurseries 50.000 45.000 10.000 50.000 45.000 7.500 Israel Melon – protected & field 148.000 142.000 140.000 87.500 87.500 87.500 35.000 125.650 99.400 105.000 8
264 May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2

Israel Potato 239.000 231.000 137.500 93.750 75.000 239.000 165.000 137.500 9Israel Seed production 56.000 50.000 22.400 56.000 28.000 Israel Strawberries – fruit (Sharon) 196.000 196.000 176.200 64.125 52.250 47.500 28.500 196.000 196.000 93.000 Israel Strawberries – fruit (Sharon & 

Ghaza) 

Israel Strawberry runners (Sharon) 35.000 35.000 20 15.800 13.570 13.500 35.000 35.000 28.000 3Israel Strawberry runners and fruit Ghaza 87.875 67.500 67.500 34.000 Israel Strawberry runners (Sharon & 

Ghaza) 

Israel Tomatoes 90.000 22.750 Israel Sweet potato 95.000 20.000 20.000 Italy Cut flowers (protected) 250.000 250.000 30.000 250.000 187.000 30.000 Italy Eggplant (protected) 280.000 200.000 15.000 194.000 156.000 Italy Melon (protected) 180.000 135.000 10.000 131.000 131.000 10.000 Italy Pepper (protected) 220.000 160.000 67.000 160.000 130.000 67.000 Italy Strawberry Fruit (Protected) 510.000 400.000 35.000 407.000 320.000 Italy Strawberry Runners 100.000 120.000 35.000 120.000 120.000 35.000 Italy Tomato (protected) 1300.000 1030.000 418.000 871.000 697.000 80.000 
May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2

Japan Cucumber 88.300 88.800 72.400 68.600 61.400 34.100 29.120 26.162 88.300 88.800 72.400 5Japan Ginger – field 119.400 119.400 112.200 112.100 102.200 53.400 47.450 42.235 119.400 119.400 109.701 8Japan Ginger – protected 22.900 22.900 14.800 14.800 12.900 8.300 7.770 6.558 22.900 22.900 14.471 Japan Melon 194.100 203.900 182.200 182.200 168.000 90.800 77.600 67.936 194.100 203.900 182.200 Japan Peppers (green and hot) 189.900 200.700 169.400 162.300 134.400 81.100 68.260 61.101 187.200 200.700 156.700 Japan Watermelon 126.300 96.200 94.200 43.300 23.700 15.400 13.870 12.075 129.000 98.900 94.200 3Malta Cucumber 0.096 0.127 Malta Eggplant 0.128 0.170 Malta Strawberry 0.160 0.212 Malta Tomatoes 0.475 0.594 New Zealand Nursery material 1.085 1.085 0.000 New Zealand Strawberry fruit 42.000 42.000 24.780 42.000 34.000 12.000 New Zealand Strawberry runners 10.000 10.000 5.720 8.000 8.000 6.234 Poland Strawberry Runners 40.000 40.000 25.000 12.000 40.000 40.000 24.500 Portugal Cut flowers 130.000 8.750 50.000 8.750 Spain Cut Flowers – Cadiz 53.000 53.000 35.000 53.000 42.000 Spain Cut Flowers – Catalonia 20.000 18.600 12.840 17.000 20.000 15.000 43.490 
266 May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2

(+Andalucia) 

(+Andalucia) 

Spain Pepper 200.000 155.000 45.000 200.000 155.000 45.000 Spain Strawberry Fruit 556.000 499.290 80.000 556.000 499.290 0.0796 Spain Strawberry Runners 230.000 230.000 230.000 215.000 230.000 230.000 230.000 UK Cut flowers 7.560 6.050 UK Ornamental tree nursery 12.000 6.000 6.000 6.000 UK Strawberry (& raspberry in 2005) 80.000 63.600 68.000 54.500 UK Raspberry nursery 4.400 4.400 54.500 USA Chrys. Cuttings/roses 29.412 29.412 0.000 USA Cucurbits – field 1187.800 747.839 598.927 588.949 411.757 340.405 218.032 59.500 1187.800 747.839 592.891 4USA Eggplant – field 76.761 101.245 96.480 79.546 62.789 34.732 21.561 6.904 76.721 82.167 85.363 6USA Forest nursery seedlings 192.515 157.694 152.629 133.140 125.758 120.853 106.043 34.230 192.515 157.694 122.032 1USA Ginger 9.200 9.200 0.000 USA Orchard replant 706.176 827.994 405.415 405.666 314.007 226.021 203.591 18.324 706.176 527.600 405.400 3USA Ornamentals 210.949 162.817 149.965 138.538 137.776 95.204 70.178 48.164 154.000 148.483 137.835 1USA Nursery stock - fruit trees, 

raspberries, roses 

45.789 64.528 12.684 51.102 27.663 17.954 7.955 1.591 45.800 64.528 28.275 5
May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2

USA Peppers – field 1094.782 1498.530 1151.751 919.006 783.821 463.282 212.775 28.366 1094.782 1243.542 1106.753 7USA Strawberry fruit – field 2468.873 1918.400 1733.901 1604.669 1336.754 1103.422 1023.471 756.515 2052.846 1730.828 1476.019 1USA Strawberry runners 54.988 56.291 4.483 8.838 8.837 7.381 7.381 3.752 54.988 56.291 4.483 8USA Tomato – field 2876.046 2844.985 2334.047 1840.100 1406.484 994.582 336.191 54.423 737.584 2476.365 2065.246 1USA Turfgrass 352.194 131.600 78.040 52.189 0 131.600 78.04 0 USA Sweet potato 224.528 18.144 18.144 18.144 14.515 8.709 1
268 May 2010 TEAP Progress Report 

Annex IV to Chapter10 – Part B: Post-harvest Structural and Commodity Applications List of nominated (2005 – 2012 in part) and exempted (2005 – 2011 in part) amounts of MB granted by Parties under the CUE p

commodity. 

Party Industry Total CUN MB Quantities Total CUE MB Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 

Australia Almonds 1.900 2.100 1.900 2.100 Australia Rice consumer packs 12.300 12.300 10.225 9.200 

+1.8 

9.200 7.820 5.660 4.870 6.150 6.150 9.205 

Belgium Artefacts and structures 0.600 0.307 0.590 0.307 Belgium Antique structure & furniture 0.750 0.199 0.319 0.199 Belgium Churches, monuments and ships' 

quarters 

0.150 0.059 0.150 0.059 

Belgium Electronic equipment 0.100 0.035 0.100 0.035 Belgium Empty silo 0.050 0.043 0.050 0.043 Belgium Flour mill see mills below 0.125 0.072 See mills 

below 

0.072 

Belgium Flour mills 10.000 4.170 9.515 4.170 Belgium Mills 0.200 0.200 0.200 0.200 Belgium Food processing facilities 0.300 0.300 0.300 0.300 Belgium Food Processing premises 0.030 0.030 0.030 0.030 
May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE MB Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 

Belgium Food storage (dry) structure 0.120 0.120 0.120 0.000 Belgium Old buildings 7.000 0 .306 1.150 0.306 Belgium Old buildings and objects 0.450 0.282 0.000 0.282 Belgium Woodworking premises 0.300 0.101 0.300 0.101 Canada Flour mills 47.200 34.774 30.167 28.650 26.913 22.878 14.107 11.020 (a)47 34.774 30.16Canada Pasta manufacturing facilities (a) 10.457 6.757 6.067 4.740 4.7400 3.529 (a) 10.457 6.757 Canada Commodities 0.068 France Seeds sold by PLAN-SPG company 0.135 0.135 0.100 0.135 0.135 0.096 France Mills 55.000 40.000 8.000 40.000 35.000 8.000 France Rice consumer packs 2.000 2.000 2.000 2.000 France Chestnuts 2.000 2.000 1.800 2.000 2.000 1.800 Germany Artefacts 0.250 0.100 0.250 0.100 Germany Mills and Processors 45.000 19.350 45.000 19.350 Greece Dried fruit 4.280 3.081 0.900 4.280 3.081 0.45 Greece Mills and Processors 23.000 16.000 1.340 23.000 15.445 1.340 Greece Rice and legumes 2.355 2.355 Ireland Mills 0.888 0.611 0.888 
270 May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE MB Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 

Israel Artefacts 0.650 0.650 0.600 0.650 0.650 Israel Dates (post harvest) 3.444 3.444 2.200 1.800 2.100 3.444 2.755 2.200 Israel Flour mills (machinery & storage) 2.140 1.490 1.490 0.800 0.300 2.140 1.490 1.040 Israel Furniture– imported 1.422 1.422 2.042 1.422 0.000 Italy Artefacts 5.500 5.500 5.000 5.225 0.000 5.000 Italy Mills and Processors 160.000 130.000 25.000 160.000 65.000 25.00Japan Chestnuts 7.100 6.500 6.500 6.300 5.800 5.400 5.350 4.984 7.100 6.800 6.500 Latvia Grains 2.502 2.502 Netherlands Strawberry runners post harvest 0.120 0.120 0.120 0 0.120 Poland Medicinal herbs & dried mushrooms 

as dry commodities 

4.000 3.560 1.800 0.500 4.100 3.560 1.800 

Poland Coffee, cocoa beans (a) 2.160 2.000 0.500 2.160 1.420 Spain Rice 50.000 42.065 Switzerland Mills & Processors 8.700 7.000 8.700 7.000 UK Aircraft 0.165 0.165 UK Mills and Processors 47.130 10.195 4.509 47.130 10.195 4.509 UK Cereal processing plants 8.131 3.480 (a) 8.131 
May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE MB Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 

UK Cheese stores 1.640 1.248 1.248 1.640 1.248 1.248 UK Dried commodities (rice, fruits and 

nuts) Whitworths 

2.400 1.256 2.400 1.256 

UK Herbs and spices 0.035 0.037 0.030 0.035 0.037 UK Mills and Processors (biscuits) 2.525 1.787 0.479 2.525 1.787 UK Spices structural equip. 1.728 1.728 0.000 0.479 UK Spices stored 0.030 0.030 0.000 UK Structures buildings (herbs and 

spices) 

3.000 1.872 0.908 3.000 1.872 0.908 

UK Structures, processors and storage 

(Whitworths) 

1.100 0.880 0.257 1.100 0.880 0.257 

UK Tobacco equipment 0.523 0.050 UK Woven baskets 0.770 0.770 USA Dried fruit and nuts (walnuts, 

pistachios, dried fruit and dates and dried beans) 

89.166 87.719 91.299 67.699 58.912 19.242 10.041 4.907 89.166 87.719 78.98

USA Dry commodities/ structures (cocoa 

beans) 

61.519 61.519 64.028 52.256 51.002 61.519 55.367 64.08

USA Dry commodities/ structures 

(processed foods, herbs and spices, dried milk and cheese processing facilities) NPMA 

83.344 83.344 85.801 72.693 66.777 37.778 17.365 17.365 83.344 69.118 82.77
272 May 2010 TEAP Progress Report 

Party Industry Total CUN MB Quantities Total CUE MB Quantities 

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 

USA Smokehouse hams (Dry cure pork 

products) (building and product) 

136.304 135.742 40.854 19.669 19.699 4.465 3.730 3.730 67.907 81.708 18.99

USA Mills and Processors 536.328 505.982 401.889 362.952 291.418 173.023 135.299 135.299 483.000 461.758 401.8
May 2010 TEAP Progress Report 273

11 TEAP and TOC Organisation Issues 

11.1 Current TEAP/TOC membership and TEAP nomination of a 

replacement TEAP Co-Chair 

Currently TEAP has 20 members; this number includes the TEAP co-chairs, the TOC-co 

chairs, and Senior Expert members. Of the 20 members, 7 are from Article 5 Parties and 13 

are from non-Article 5 Parties. As of April 2010, the total membership of the TEAP and its 

six TOCs is about 150 members, including about one third from Article 5 Parties and about 

two thirds from non-Article 5 Parties (which includes a small number of experts from nonArticle 5former CEITs in Eastern Europe and Central Asia). There are an additional 10 

consulting (non-voting) members in the Halons and Refrigeration Technical Options 

Committees. 

In 2010, K. Madhava Sarma (TEAP Senior Expert Member) retired from TEAP and Jose 

Pons Pons (TEAP Co-chair and MTOC Co-chair) retired as TEAP Co-chair, but remains as 

MTOC Co-chair. The consensus of TEAP is to nominate Marta Pizano (Colombia) as TEAP 

Co-chair to replace Jose Pons Pons (Venezuela). Marta Pizano has been a member of 

MBTOC since 1998 and a MBTOC Co-chair since 2005. There are no TEAP nominations for 

a replacement for K. Madhava Sarma. 

11.2 Medical Technical Options Committee (MTOC) 

Jose Pons-Pons has retracted his resignation as Co-chair of MTOC and will continue in this 

role. 

11.3 Methyl Bromide Technical Options Committee (MBTOC) 

The recent strengthening and adjustment of the MBTOC continues to improve the efficiency 

of meetings and the consensus process. In response to Decision XXI/10, TEAP co-chairs 

reorganized MBTOC into three subcommittees: (1) MBTOC-Soils co-chaired by Ian Porter 

(Australia) and Mohamed Besri (Morocco); (2) MBTOC-Structures and Commodities chaired 

by Michelle Marcotte (Canada) and (3) MBTOC-QPS (quarantine and pre-shipment) chaired 

by Marta Pizano (Colombia). 

11.4 Refrigeration, AC and Heat Pumps Technical Options Committee 

(RTOC) 

Parties agreed at MOP-21 to replace retiring RTOC Co-chair Dr. Radhey S. Agarwal (India) 

with Dr. Roberto de Aguiar Peixoto (Brazil), RTOC member since 1996. 

11.5 Volcanic ash complicates and inconveniences TEAP and TOC 

operations 

The airborne volcanic ash from the eruption of the Eyjafjallajokull volcano disrupted air 

travel for some TEAP and MBTOC members attending their respective meetings in Spain in 

April 2010. The TEAP meeting therefore also included consultations of members not present 

at the meeting via telephone conferences and submission of material for review by email. 
274 May 2010 TEAP Progress Report 

11.6 Financial constraints and challenges encountered by TEAP and TOC 

members 

TEAP is grateful for the continuing support of national governments, the European 

Commission, associations and companies that finance time and expenses for the participation 

of experts in the TEAP, TOCs and Task Forces. Over the years it has become increasingly 

difficult for non-Article 5 experts, who work in the private sector, to find funding for travel 

and miscellaneous meeting expenses. Taking also into account the current financial 

circumstances, it is becoming almost impossible for non-Article 5 experts to get enough 

support from their employers to cover the time spent to complete tasks and to sponsor their 

own travel, lodging, and other expenses of attending meetings; as a result, TEAP, TOC and 

Task Force operations are becoming even more difficult to accomplish. 

TEAP would like to remind Parties that TEAP and its TOCs are producing reports and 

technical papers that are technically sound and globally informed at a cost much lower than if 

consultants would be contracted for the same assignments. 

TEAP is urgently requesting all non-Article 5 Party governments to once more look into all 

possibilities to fund certain costs for their national experts. Individual TEAP and TOC 

members, from their side, will also continue to seek funding from governments, associations, 

and companies. 

If Parties prefer to not provide additional funding, TEAP and its TOCs will need to take 

drastic steps to minimise costs; including fewer meetings with smaller committees, fewer 

experts attending the OEWG and MOP, and rationalising membership, as needed. 
May 2010 TEAP Progress Report 275

12 TEAP TOC Membership List Status April 2010 

The disclosure of interest (DOI) of each member can be found on the Ozone Secretariat website 

at: http://ozone.unep.org/Assessment_Panels/TEAP/toc-members-disclosures.shtml. The 

disclosures are updated whenever necessary. 

Technology and Economic Assessment Panel (TEAP) 

Co-chairs Affiliation Country 

Stephen O. Andersen U.S. Environmental Protection Agency USA 

Lambert Kuijpers Technical University Eindhoven Netherlands 

Jose Pons Pons Spray Quimica Venezuela 

Senior Expert Members Affiliation Country 

Thomas Morehouse Institute for Defense Analyses USA 

Shiqiu Zhang Center of Environmental Sciences, Peking University China 

TOC Chairs Affiliation Country 

Paul Ashford Caleb Management Services UK 

Mohamed Besri Institut Agronomique et Vétérinaire Hassan II Morocco 

Biao Jiang Shanghai Institute of Organic Chemistry China 

David Catchpole Petrotechnical Resources Alaska UK 

Sergey Kopylov All Russian Research Institute for Fire Protection Russian Federation 

Michelle Marcotte Marcotte Consulting LLC and Marcotte Consulting Inc Canada 

Roberto de A. Peixoto Maua Institute (IMT), Sao Paulo Brazil 

Marta Pizano Consultant Colombia 

Ian Porter Department of Primary Industries Australia 

Miguel Quintero Consultant Colombia 

Ian D. Rae University of Melbourne Australia 

Helen Tope Energyinter Consultancy Australia 

Ashley Woodcock Wythenshawe Hospital Manchester UK 

Daniel Verdonik Hughes Associates USA 

Masaaki Yamabe National Inst. Advanced Industrial Science and Technology Japan 

TEAP Chemicals Technical Options Committee (CTOC)

Co-chairs Affiliation Country 

Biao Jiang Shanghai Institute of Organic Chemistry China 

Ian D. Rae University of Melbourne Australia 

Masaaki Yamabe National Inst. Advanced Industrial Science and Technology Japan 

 

Members Affiliation Country 

D. D. Arora The Energy and Research Institute India 

Steven Bernhardt Honeywell USA 

Olga Blinova Russian Scientific Center for Applied Chemistry Russia 

Jianxin Hu College of Environmental Sciences & Engineering, Peking 

University 

China 

Michael Kishimba University of Dar-es-Salaam Tanzania 

Abid Merchant Consultant USA 

Koichi Mizuno National Inst. Advanced Industrial Science and Technology Japan 

Keichi Ohnishi Asahi Glass Japan 

Claudia Paratori Coordinator Ozone Programme -CONAMA Chile 

Hans Porre Teijin Aramids Netherlands 

Shuniti Samejima Asahi Glass Foundation Japan 

John Stemniski Consultant USA 

Fatemah Al-Shatti Kuwait Petroleum Corporation Kuwait 

Nee Sun Choong Kwet 

Yive (Robert) 

University of Mauritius Mauritius 
276 May 2010 TEAP Progress Report 

TEAP Flexible and Rigid Foams Technical Options Committee (FTOC) 

Co-chairs Affiliation Country 

Paul Ashford Caleb Management Services UK 

Miguel Quintero Consultant Colombia 

Members Affiliation Country 

Chris Bloom Dow USA 

Row Chowdhury Australia Urethane Systems Australia 

Kyoshi Hara JUFA Japan 

Mike Hayslett Maytag/AHAM USA 

Mike Jeffs ISOPA Belgium

Candido Lomba ABRIPUR Brazil 

Yehia Lotfi Technocom Egypt 

Christoph Meurer Solvay Germany 

Ulrich Schmidt Haltermann/Dow Germany 

Enshang Sheng Huntsman Co China 

Bert Veenendaal RAPPA USA 

Shigeru Wakana Dow Japan 

Mark Weick Dow USA 

Tom Werkema Arkema USA 

Dave Williams Honeywell USA 

Allen Zhang Owens Corning China 

TEAP Halons Technical Options Committee (HTOC) 

Co-chairs Affiliation Country 

David V. Catchpole Petrotechnical Resources Alaska UK 

Sergey Kopylov All Russian Research Institute for Fire Protection Russian Federation 

Daniel P. Verdonik Hughes Associates USA 

Members 

Tareq K. Al-Awad King Abdullah II Design & Development Bureau Jordan 

Jamal Alfuzaie Kuwait Fire Department Kuwait 

Seunghwan (Charles) Choi Hanju Chemical Co., Ltd. South Korea 

Michelle M. Collins Consultant- EECO International USA 

Salomon Gomez Tecnofuego Venezuela 

Andrew Greig Protection Projects Inc South Africa 

Zhou Kaixuan CAAC-AAD PR China 

H. S. Kaprwan Consultant – Retired India 

Nikolai Kopylov All Russian Research Institute for Fire Protection Russian Federation 

David Liddy UK Government/European Commission UK 

Bella Maranion United States EPA USA 

John J. O’Sullivan Bureau Veriitas UK 

Emma Palumbo Safety Hi-tech srl Italy 

Erik Pedersen Consultant – World Bank Denmark 

Donald Thomson Mantoba Hydro & MOPIA Canada 

Caroline Vuillin European Aviation Safety Agency France 

Robert T. Wickham Consultant-Wickham Associates USA 

Mitsuru Yagi Nohmi Bosai Ltd & Fire and Environment Prot. Network Japan 

Robert T. Wickham Consultant-Wickham Associates USA 

 

Consulting Experts 

Thomas Cortina Halon Alternatives Research Corporation USA 

Matsuo Ishiyama Nohmi Bosai Ltd & Fire and Environment Prot. Network Japan 

Steve McCormick United States Army USA 

John G. Owens 3M Company USA 

Mark L. Robin DuPont USA 

Joseph A. Senecal Kidde-Fenwal USA 

Ronald S. Sheinson Naval Research Laboratory – Department of the Navy USA 

Ronald Sibley Defense Supply Center, Richmond USA 
May 2010 TEAP Progress Report 277

Medical Technical Options Committee (MTOC) 

Co-chairs Affiliation Country 

Jose Pons Pons Spray Quimica Venezuela 

Helen Tope Energy International Australia Australia 

Ashley Woodcock University Hospital of South Manchester UK 

Members Affiliation Country 

Emmanuel Addo-Yobo Kwame Nkrumah University of Science and Technology Ghana 

Paul Atkins Oriel Therapeutics Inc. USA 

Sidney Braman Rhode Island Hospital USA 

Nick Campbell Arkema SA France 

Hisbello Campos Centro de Referencia Prof. Helio Fraga, Ministry of Health Brazil 

Jorge Caneva Favaloro Foundation Argentina 

Christer Carling Private Consultant Sweden 

Guiliang Chen Shanghai Institute for Food and Drug Control China 

Antoine Haddad Chiesi Farmaceutici Italy 

Charles Hancock Charles O. Hancock Associates USA 

Eamonn Hoxey Johnson & Johnson UK 

Javaid Khan The Aga Khan University Pakistan 

Nasser Mazhari Sina Darou Laboratories Company Iran 

Robert Meyer Merck Incorporated USA 

Hideo Mori Otsuka Pharmaceutical Company Japan 

Tunde Otulana Aradigm Corporation USA 

John Pritchard AstraZeneca UK 

Rabbur Reza Beximco Pharmaceuticals Bangladesh 

Raj Singh The Chest Centre India 

Roland Stechert Boehringer Ingelheim (Schweiz) Switzerland 

Ping Wang Chinese Pharmacopoeia Commission China 

Adam Wanner University of Miami USA 

Kristine Whorlow National Asthma Council Australia Australia 

You Yizhong Journal of Aerosol Communication China 
278 May 2010 TEAP Progress Report 

TEAP Methyl Bromide Technical Options Committee (MBTOC) 

Co-chairs Affiliation Country 

Mohamed Besri Institut Agronomique et Vétérinaire Hassan II Morocco 

Michelle Marcotte Marcotte Consulting Canada 

Marta Pizano Consultant Colombia 

Ian Porter Department of Primary Industries Australia 

 

Members Affiliation Country 

Jonathan Banks Consultant Australia 

Tom Batchelor Touchdown Consulting Belgium 

Chris Bell Consultant UK 

Antonio Bello Centro de Ciencias Medioambientales Spain 

Fred Bergwerff Eco2, Netherlands The Netherlands 

Aocheng Cao Chinese Academy of Agricultural Sciences China 

Peter Caulkins US Environmental Protection Agency USA 

Ricardo Deang Consultant Philippines 

Patrick Ducom Ministère de l’Agriculture France 

Abraham Gamliel Agricultural Research Organisation Israel 

Raquel Ghini EMBRAPA Brasil 

Ken Glassey MAFF New Zealand 

Eduardo Gonzalez Fumigator Philippines 

Darka Hamel Inst. For Plant Protection in Ag. And Forestry Croatia 

George Lazarovits Agriculture and Agri-Food Canada Canada 

Andrea Minuto CERSAA, Albenga Italy 

Takashi Misumi MAFF Japan 

David Okioga Ministry of Environment and Natural Resources Kenya 

Christoph Reichmuth BBAGermany Germany 

Jordi Riudavets IRTA – Department of Plant Protection Spain 

John Sansone SCC Products USA 

Jim Schaub US Department of Agriculture USA 

Sally Schneider US Department of Agriculture USA 

JL Staphorst Plant Protection Research Institute South Africa 

Akio Tateya Japan Fumigation Technology Association Japan 

Robert Taylor Consultant UK 

James Turner Forest Research Institute (Scion) New Zealand 

Alejandro Valeiro Department of Agriculture Argentina 

Ken Vick United States Department of Agriculture USA 

Nick Vink University of Stellenbosch South Africa 

Janny Vos CABI International The Netherlands 

Chris Watson IGROX UK 

Jim Wells Environmental Solutions Group USA 

Eduardo Willink Ministerio de Agricultura Argentina 

Suat Yilmaz BATEM Horticulture Research Station Turkey 
May 2010 TEAP Progress Report 279

TEAP Refrigeration, Air Conditioning and Heat Pumps Technical Options Committee 

(RTOC) 

Co-chair Affiliation Country 

Lambert Kuijpers Technical University Eindhoven Netherlands 

Roberto de A. Peixoto Maua Institute, IMT, Sao Paulo Brazil 

 

Members Affiliation Country 

Radhey S. Agarwal IIT New Delhi India 

Julius Banks Environmental Protection Agency USA 

James M. Calm Engineering Consultant USA 

Radim Cermak Ingersoll Rand Czech Rep. 

Guangming Chen Inst. For Refrigeration and Cryogenic Eng., Shanghai China 

Denis Clodic Ecole des Mines France 

Daniel Colbourne Consultant UK 

Sukumar Devotta Consultant India 

Martin Dieryckx Daikin Europe Belgium 

Dennis Dorman Trane USA 

Kenneth E. Hickman Consultant USA 

William Hill Consultant USA 

Martien Janssen Re/genT Netherlands 

Makoto Kaibara Panasonic, Research and Technology Japan 

Michael Kauffeld Fachhochschule Karlsruhe Germany 

Fred Keller Consultant USA 

Jürgen Köhler University of Braunschweig Germany 

Holger König Heat AG, Vienna Germany 

Edward J. McInerney Consultant USA 

Petter Nekså SINTEF Energy Research Norway 

Horace Nelson Manufacturer Jamaica 

Alexander C. Pachai Johnson Controls Denmark 

Andy Pearson Star Refrigeration Glasgow UK 

Per Henrik Pedersen Danish Technological Institute Denmark 

Sulkan Suladze Consultant Georgia 

Paulo Vodianitskaia Consultant Brazil 

 

Consulting Experts 

Takuo Hirahara Mitsubushi Electric Corp. Japan 

Lindsey Roke Fisher and Paykel New Zealand