MONTREAL PROTOCOL

ON SUBSTANCES THAT DEPLETE

THE OZONE LAYER

UNEP

REPORT OF THE

TECHNOLOGY AND ECONOMIC ASSESSMENT PANEL

OCTOBER 2011

EVALUATION OF 2011 CRITICAL USE NOMINATIONS FOR METHYL 

BROMIDE AND RELATED MATTERS

FINAL REPORT
ii October 2011 MBTOC Report on 2011 CUNs: Final Report

UNEP

OCTOBER 2011 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATIONS OF 2011 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

FINAL REPORT
October 2011 MBTOC Report on 2011 CUNs: Final Report iii

Montreal Protocol

On Substances that Deplete the Ozone Layer

Report of the

UNEP Technology and Economic Assessment Panel

October 2011

EVALUATIONS OF 2011 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

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

Co-ordination: Methyl Bromide Technical Options Committee

Composition of the report: MBTOC Soils: Co-chairs Ian Porter, Mohamed Besri

MBTOC SC: Co-chair Michelle Marcotte 

MBTOC QPS: Co-chair Marta Pizano

Reproduction: UNON Nairobi

Date: October 2011

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

UNITED NATIONS ENVIRONMENT PROGRAMME

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

Normally from SMI Distribution Service Ltd., Stevenage, Hertfordshire, UK, fax: + 44 1438 

748844

This document is also available in portable document format from

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

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

acknowledgement of the source of the material.

ISBN: 978-9966-20-007-5
iv October 2011 MBTOC Report on 2011 CUNs: Final Report

Disclaimer

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

Assessment Panel (TEAP) Co-Chairs and members, and the Methyl Bromide Technical Options 

Committee (MBTOC) 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, TEAP Co-Chairs and members, and the MBTOC 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, TEAP Co-Chairs and members, and the MBTOC Co-Chairs 

and members or the companies or organisations that employ them.

Acknowledgement

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

Committee acknowledge with thanks the outstanding contributions from all of the individuals and 

organisations who provided support to Panel and Committee Co-Chairs and members. The 

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

sponsoring or supporting organisation.

Methyl Bromide Technical Options Committee:

MBTOC Soils (S) Co-Chairs: Ian Porter (Australia). Mohamed Besri (Morocco) Members of 

MBTOC S: Antonio Bello (Spain); Aocheng Cao (China); Peter Caulkins (USA); Abraham 

Gamliel (Israel); Raquel Ghini (Brazil); George Lazarovits (Canada); Andrea Minuto (Italy); 

Marta Pizano (Colombia); James Schaub (USA); Sally Schneider (USA); JL (Stappies) Staphorst 

(South Africa); Akio Tateya (Japan); Alejandro Valeiro (Argentina); Nick Vink (South Africa); 

Janny Vos (The Netherlands); Jim Wells (USA); Suat Yilmaz (Turkey)

MBTOC Structures and Commodities (SC) Chair: Michelle Marcotte (Canada) Members of 

MBTOC SC Fred Bergwerff (Netherlands); Chris Bell (UK); Ricardo Deang (Philippines); 

Patrick Ducom (France); Alfredo Gonzalez (Philippines); Darka Hamel (Croatia); Christoph 

Reichmuth (Germany); Jordi Riudavets (Spain); John Sansone (USA); Robert Taylor (UK); Ken 

Vick (USA); Chris Watson (UK)

MBTOC Quarantine and Preshipment Chair: Marta Pizano (Colombia), Members of

MBTOC QPS Jonathan Banks (Australia); Tom Batchelor (Belgium); Ken Glassey (New 

Zealand); Takashi Misumi (Japan); David Okioga (Kenya); Ian Porter (Australia); Ken Vick 

(USA) and Eduardo Willink (Argentina).

MBTOC Economists: Jim Schaub (USA); Nick Vink (South Africa)
October 2011 MBTOC Report on 2011 CUNs: Final Report v

OCTOBER 2011 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATIONS OF 2011 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

FINAL REPORT
vi October 2011 MBTOC Report on 2011 CUNs: Final Report

UNEP

OCTOBER 2011 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATIONS OF 2011 CRITICAL USE NOMINATIONS FOR METHYL 

BROMIDE AND RELATED MATTERS

FINAL REPORT – OCTOBER 2011

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

IM 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 QPS Methyl Bromide Technical Options Committee, Quarantine and

Preshipment Subcommittee

MBTOC SC Methyl Bromide Technical Options Committee, Structures and 

Commodities Subcommittee

MBTOC S Methyl Bromide Technical Options Soils Subcommittee

MITC Methyl isothiocyanate

MOP Meeting of the Parties

MS Metham sodium

OEWG Open Ended Working Group

Pic Chloropicrin

QPS Quarantine and Pre-shipment

SF Sulfuryl fluoride

TEAP Technology and Economics Assessment Panel

USA United States of America

VIF Virtually Impermeable Film

VOC Volatile Organic Compounds
October 2011 MBTOC Report on 2011 CUNs: Final Report vii

UNEP

OCTOBER 2011 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

TABLE OF CONTENTS

1 SCOPE OF THE REPORT....................................................................................................1

1.1. DISCLOSURE OF INTEREST..........................................................................................................1

2 CRITICAL USE NOMINATIONS FOR METHYL BROMIDE.......................................3

2.1. MANDATE..................................................................................................................................3

2.2. FULFILMENT OF DECISION IX/6 .................................................................................................3

2.3. CONSIDERATION OF STOCKS - DECISION EX.1/4 (9F) .................................................................3

2.3.1. Reporting of MB consumption for critical use - Decision XVII/9 .............................................6

2.4 TRENDS IN METHYL BROMIDE USE FOR CUES SINCE 2005.........................................................6

2.5. ARTICLE 5 ISSUES ......................................................................................................................9

2.6. CRITICAL USE NOMINATIONS REVIEW ....................................................................................10

2.7. MINORITY REPORTS .................................................................................................................11

3 MBTOC SOILS: FINAL EVALUATIONS OF 2011 CRITICAL USE 

NOMINATIONS FOR METHYL BROMIDE FOR 2012 AND 2013..............................13

3.1 CRITICAL USE NOMINATIONS SUBMITTED ...............................................................................13

3.2. CUN ASSESSMENT FOR PREPLANT SOIL USES...........................................................................14

3.3. ISSUES RELATED TO CUN ASSESSMENT FOR PREPLANT SOIL USE.............................................16

3.3.1. Registration of alternatives for preplant uses - Decision Ex I/4 (9i) and (9j)........................17

3.3.2. Update on rates of adoption of alternatives for preplant uses - Dec.XIX/9...........................17

3.3.3. Sustainable alternatives for preplant uses..............................................................................18

3.3.4. Standard presumptions used in assessment of nominated quantities. .....................................18

3.3.5. Adjustments for standard dosage rates using MB/Pic formulations.......................................20

3.3.6. Use/Emission reduction technologies - Low permeability barrier films and 

dosage reduction.....................................................................................................................21

3.4. MINORITY REPORT...................................................................................................................21

4 FINAL CUN REPORT – ISSUES SPECIFIC TO MBTOC-STRUCTURES AND 

COMMODITIES ..................................................................................................................40

4.1. NEW PROCESS USED BY MBTOC SC TO CONDUCT CUN RE-REVIEWS.....................................40

4.1.1. Resourcing issues in 2011 and in coming years .....................................................................41

4.2. DETAILS OF EVALUATIONS ......................................................................................................42

4.3. MINORITY REPORT USA NOMINATION FOR THE CRITICAL USE OF MB FOR CURED 

PORK........................................................................................................................................43

5 ACTIVITY REPORT FOR 2011 AND WORK PLAN FOR 2012...................................55

5.1. MEMBERSHIP AND PROCEDURAL ISSUES ..................................................................................55

5.2. ACTIVITY REPORT FOR 2011 ....................................................................................................55

5.3. WORK PLAN AND INDICATIVE BUDGET FOR 2012.....................................................................56

6 REFERENCES .....................................................................................................................58

ANNEX 1 - DECISION IX/6 .....................................................................................................................61

ANNEX II - DECISION XVI/4 ..................................................................................................................62

ANNEX III - PART A: HISTORICAL TREND IN MB PREPLANT SOIL NOMINATIONS 

AND EXEMPTIONS ............................................................................................................63

ANNEX IV – PART B: HISTORICAL TREND IN MB STRUCTURAL AND COMMODITY 

NOMINATIONS AND EXEMPTIONS..............................................................................69

October 2011 TEAP Report on 2011 CUNs: Final Report 1

1 Scope of the report

This 2011 final report provides the final evaluations by MBTOC of CUNs submitted for methyl 

bromide (MB) in 2012 and 2013 by four Parties (Australia, Canada, Japan, USA) in accordance with 

Decision IX/6. CUNs were submitted by one Party for research purposes in 2012 and 2013, but these 

were subsequently withdrawn in October 2011 by the Party. CUNs were submitted to the Ozone 

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

Decision XVI/4. 

This final report provides new updated recommendations for the CUNs for which the Parties provided 

further information or requested reassessment, lists the CUNs for which interim assessments have not 

changed and provides information on the CUNs from Parties on stocks (Decision Ex.1/4 (9f)). Partial 

information on actual MB consumption for critical uses (Decision XVII/9) and apparent adoption 

rates of alternatives, as evidenced by trend lines on reduction of MB CUNs (Decisions XIX/9, XX/5) 

are also provided. This condensed report covers full evaluation of CUNs where Parties requested a 

review at or after the 31st OEWG and any other CUNs where circumstances have changed. The 

interim May 2011 TEAP report has further details of assessment in this round (TEAP, 2011). 

Standard presumptions used in the final assessment in the 2011 round were the same as those used 

previously. 

MBTOC Soils (MBTOC S) has initial responsibility for the pre-plant uses and alternatives of methyl 

bromide. MBTOC Structures and Commodities (MBTOC SC) has initial responsibility for issues 

concerning methyl bromide uses and MBTOC Quarantine and Preshipment (QPS) for issues related to 

alternatives for quarantine and pre-shipment. 

Outcomes from deliberations of CUNs by MBTOC S were considered at a MBTOC meeting by 15 

members held in The Netherlands from 10-12 October 2011. The position of those not able to attend 

was communicated via electronic communication. No non attending member disagreed with the 

consensus positions on nominations achieved by MBTOC at the meeting. One nomination however 

failed to achieve consensus at the meeting and a minority report was submitted. 

Deliberations for MBTOC SC were discussed and finalized via electronic communication and each 

member was asked to provide their agreement, disagreement or agreement not to block consensus on 

the final recommendation. Recommendations made by MBTOC S at its face to face meeting and 

those received from MBTOC SC were circulated to all MBTOC as part of finalization of the 

nominations within the whole committee.

In re-assessing nominations that had been categorised as “Unable to Assess” at MBTOC‟s meeting in 

Turkey in March 2011 or had been revised or put forward for reassessment by the Party, MBTOC 

followed Annex 1 of MOP16 states that MBTOC “meets to reassess only those critical-use 

nominations in the “unable to assess” category”. Furthermore, Decision XII/6(4) requires “MBTOC 

to ensure that it develops its recommendations in a consensus process that includes full discussion 

among all available Committee members”.

1.1. Disclosure of interest

As in past reports, all MBTOC members have updated disclosure of interest forms relating 

specifically to their level of national, regional or enterprise involvement for the 2011 CUN process. 

The Disclosure of Interest declarations can be found on the internet at 

http://ozone.unep.org/Assessment_Panels/TEAP/index.shtml and a list of members in Annex III of 

this report. 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. MBTOC co-chairs applied recent guidelines published by TEAP (May 2011) that 

provided guidance to TOCs on the application of declarations of interest to the best extent possible.

October 2011 TEAP Report on 2011 CUNs: Final Report 3

2 Critical Use Nominations for methyl bromide

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 and other relevant decisions, which 

all such uses need to fully comply with in order to be granted an exemption. TEAP and its 

MBTOC provide guidance to the Parties‟ decisions on critical use exemptions in accordance 

with Decisions IX/6 and Annex I of Decision XVI/4. 

2.2. Fulfilment of Decision IX/6

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

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

the full amount of the nomination. Where some of the conditions were not fully met, MBTOC 

recommended a decreased amount when a technical alternative was considered effective or, in 

a few cases, when the Party failed to demonstrate that it was not effective. In this round of 

CUNs, as in previous rounds, MBTOC considered all information provided by the Parties 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. It is important that Parties continue to provide updates on regulatory 

changes with alternatives and MB and a breakdown of the economic feasibility of alternatives 

compared to MB if they are relevant to the nomination. Without this information, further 

CUNs may not be assessable, as MBTOC may not be able to analyse the impact of national, 

subnational and local regulations and law as required in Decision XX/5. In some cases, 

MBTOC has proposed existing commercially and economically feasible alternatives and 

potential research and regulatory issues to Parties that may assist the phase out of MB. 

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. 

2.3. Consideration of stocks - Decision Ex.1/4 (9f)

Under decision Ex.I/4(9f) Parties nominating critical use exemptions are requested 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 the final 

assessment of nominations 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 was reported in 

the May TEAP 2011 report (Tables 2.1 – 2.4). No further information from Parties was 

required for this report. 
4 October 2011 MBTOC Report on 2011 CUNs: Final Report

Table 2-1. Quantities of MB (metric tonnes) ‘on hand’ at the beginning and end of 2005, as 

first reported by Parties in 2006/2007 under Decision XVI/6.

Party

Critical use 

exemptions 

authorized 

by MOP for 

2005

Quantity of MB as reported by Parties (metric tonnes)

Amount 

on hand 

at start 

of 2005

Quantity 

acquired for 

CUEs 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

EU 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 2-2. Quantities of MB ‘on hand’ at the beginning and end of 2008, as reported by 

Parties in 2009 under Decision XVI/6. 

Party Critical use 

exemptions

authorized 

by MOP for 

2008

Quantity of MB as reported by Parties (metric tonnes)

Amount 

onhand 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

EU 245.146 6.409 206.146 212.555 212.463 0.092

Israel

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
October 2011 TEAP Report on 2011 CUNs: Final Report 5

Table 2-3. Quantities of MB ‘on hand’ at the beginning and end of 2009, as reported by 

Parties in 2010 under Decision XVI/6. 

Party Critical use 

exemption 

authorized 

by MOP for 

2009

Quantity of MB as reported by Parties (metric tonnes)

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

Israel Not Reported

Japan 305.380 11.882 278.616 290.498 286.532 3.966

USA 2,276 4,273(a) 2,274 6,547 2,215

1,135(d)

3,063 (b)

59 (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

(d) Stocks used for CUE uses in 2009

Table 2-4. Quantities of MB ‘on hand’ at the beginning and end of 2010, as reported by 

Parties in 2011 under Decision XVI/6. 

Party Critical use 

exemption 

authorized 

by MOP for 

2010

Quantity of MB as reported by Parties (metric tonnes)

Amount on 

hand at 

start of 

2010

Quantity 

acquired for 

CUEs in 2010

(production 

+imports)

Amount 

available 

for use in 

2010

Quantity 

used for 

CUEs in 

2010

Amount 

on hand 

at the 

end of 

2010

Australia 36.44 0 34.167 34.167 34.167 0

Canada 33.277 6.38 23.456 29.836 25.254 3.4

Japan 267 8.82 248.67 257.49 251.159 6.331

USA 1,956 3,063 (a) 1,955 5,018 1,955

613 (d)

1,803(b)

(a) Amount of pre-2005 stocks available at the start of 2010 

(b) Amount of pre-2005 stocks available at the end of 2010.

(d) Stocks used for CUE uses in 2010

In 2006, the US predicted that pre 2005 stocks for preplant soil uses would be exhausted by 

2009, yet pre 2005 stocks are still available in 2011. It is noted that the stocks recently 

reported by the United States (about 1,800 tonnes) were approximately three times the 

quantity nominated by the US for 2013 (about 604 tonnes) and suggests Parties may wish to 

review this information in the light of the Decision IX/6 1(b)(ii) that “...permits production 
6 October 2011 MBTOC Report on 2011 CUNs: Final Report

only if methyl bromide is not available in sufficient quantity and quality from existing 

stocks...”.

It is noted that stocks are privately held in the United States and market forces determine 

when and at what price stocks are used. It is also notes that the US has made allowances for 

some of the use of these stocks as critical allowances for CUNs when licensing critical uses of 

methyl bromide and suggests that Parties may wish to seek clarification on how the remaining 

stocks will be apportioned.

2.3.1. 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). Australia, Canada, Japan 

and the United States that submitted nominations for 2012 and/or 2013 did not supply data 

under Form 2 of the accounting framework as it was not accepted by the Parties (refer p. 65 of 

the Handbook on Critical Use Nominations (version 6 of December 2007). The data reported 

here for (a) and (b) above is therefore incomplete. Some Parties record part of the information 

under their own local reporting requirements.

2.4 Trends in methyl bromide use for CUEs since 2005

The nominated amounts and the apparent rate of reduction in MB or adoption of alternatives 

achieved by Parties are shown in Table 2.5, as well as Figures 2.1. and 2.2. It is 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 pre2005 stocks may have been used in the same sectors. Table 3.1 and 3.2 in particular show the 

amounts nominated by Parties for preplant soil uses and those recommended for „Critical 

Use‟ in 2013. 

Decision XVII/9 requires TEAP to show trends in the phase out of the critical uses of MB by 

the Parties. 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 in the reduction of methyl 

bromide for CUNs by all Parties for preplant soil uses and post harvest uses, although this has 

occurred at different rates. Figs 2.1 and 2.2 show the trends in the reduction in amounts 

approved/nominated by Parties for „Critical Use‟ from 2005 to 2013 for some key uses. The 

complete trends in phase out of MB by country, as indicated by change in CUE, are shown in 

Annexes III and IV.
October 2011 TEAP Report on 2011 CUNs: Final Report 7

Figure 2-1. Amounts of MB exempted for CUE uses in selected preplant soil industries 

from 2005 to 2012. Solid lines indicate the trend in CUE methyl bromide approved by the 

Parties. Dashed lines indicate quantity of MB nominated by the Parties in 2013. ( See table 

3.3 for exact quantities nominated by the Party for 2013)

Cucurbits and Melons

0

200

400

600

800

1000

1200

1400

2005 2006 2007 2008 2009 2010 2011 2012 2013

Year

metric tonnes

Israel

Japan

USA

Strawberry Fruit

0

500

1000

1500

2000

2500

2005 2006 2007 2008 2009 2010 2011 2012 2013

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 2013

Year

metric tonnes

Belgium Greece

Italy USA
8 October 2011 MBTOC Report on 2011 CUNs: Final Report

Figure 2-2. Amounts of MB exempted for CUE uses in the strawberry nursery sector

from 2005 to 2013. Solid lines indicate the trends in CUE methyl bromide approved by 

the Parties. Dashed lines indicate quantity of MB nominated by the Party in 2013.

Strawberry Nursery

0

50

100

150

200

250

200520062007200820092010201120122013

metric tonnes

Australia

Belgium

Canada

France

Israel

Italy

New Zealand

Poland

Spain

USA (a)

 Additional amounts of MB (Estimated 460 t) are exempted under QPS regulations in 

the USA (TEAP 2010).

.
October 2011 TEAP Report on 2011 CUNs: Final Report 9

Figure 2-3. Amounts of MB exempted for CUE uses in mills and food processing facilities 

from 2008 to 2012. Solid lines indicate trend in CUE methyl bromide. Dashed lines 

indicate quantity of MB recommended by MBTOC for 2013. Chart uses Log 10 scale.

Note that a number of countries (Belgium, France, Germany, Greece, Israel, Italy, UK) have 

phased out MB for use in mills and food processing as of 2008

2.5. Article 5 issues

Methyl bromide is due to be fully phased out in A5 Parties by Jan 1 2015, 10 years after full 

phaseout by non-A5 Parties. In both cases, uses for feedstock and QPS are exempted from 

phase out under the control measures described in Article 2H. There is also provision for 

exemption from phase out for uses deemed „critical‟ according to Article 2H, as complying 

with Decision IX/6. 

Presently, nearly 80% of the controlled consumption in A5 Parties has been phased out, well 

ahead of the 2015 deadline. This has been achieved largely as a result of investment projects 

implemented by the Montreal Protocol agencies, with MLF funding. Almost all remaining 

MB consuming Parties have agreements in place with the MLF for full phaseout of methyl 

bromide by 2015 at the latest, very often earlier. These are usually accompanied with 

legislation to ban further consumption of MB for controlled uses, and funding to support on 

going implementation of alternatives therefore promoting the sustainability of the phase out. 

Article 5 Parties may choose to submit nominations for Critical Use Exemptions (CUEs) for 

remaining uses they consider appropriate for year 2015 and possibly subsequently. The first 

CUNs by non-A5 Parties were made in 2003 for CUEs to be in force in 2005. If a similar 

advanced submission period is to be followed, some A5 Parties may choose to submit CUNs 

in 2013 for assessment by MBTOC for potential use as 2015 CUEs.

MBTOC is mindful of the difficult and complex process that occurred during the first round 

of CUNs in 2003. TEAP urges Parties to consider the requirements for CUNs in due time as 
10 October 2011 MBTOC Report on 2011 CUNs: Final Report

set out in the „Handbook on Critical Use Nominations‟ 

(http://ozone.unep.org/Assessment_Panels/TEAP/Reports/MBTOC/Handbook%20CUNversion5-27Nov06.pdf). 

2.6. Critical Use Nominations review

In considering the CUNs submitted in 2011, 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. Standard presumptions for soils are 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. Unless otherwise 

indicated, the most recent CUE approved by the Parties for a particular CUN was used as 

baseline for consideration of continuing nominations. 

In evaluating the CUNs for soil treatments, MBTOC 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 within 20% (MBTOC 2010) of the cost of using methyl bromide for it to be 

considered economically feasible in the context of that nomination, to the extent that could be 

determined. 

In general, CUNs were submitted due to the following issues: regulatory restrictions that did 

not allow partial or full use of alternatives, difficulties in the scale-up of alternatives, 

alternatives considered uneconomical and to a much smaller degree, the technical 

unavailability of alternatives. In structures and commodities CUNs noted that the US 

Environmental Protection Agency has proposed phasing out the use of sulfuryl fluoride for 

postharvest uses. This situation is discussed further in the 2010 Assessment Report and in the 

2011 Progress Report. 

Nominations were submitted for preplant soil use and/or postharvest use in 2013 by Australia, 

Canada, Japan and the USA. The total nominated amount for all countries for 2013 was 

724.611 t and this represented a 50 % reduction to that nominated in 2010 for 2012. This was 

reduced by 27.61 tonnes due to revision of the vegetable CUNs and withdrawal of the 

research CUNs by the US. The final recommendation for 2013 was 610.531 t, ie. 88% of that 

nominated (Table 2.5).

The US submitted a CUN in Jan 2011 that nominated quantities of MB for 2012 and 2013 for 

various research activities associated with benchmarking alternatives to methyl bromide for 

registration and other purposes, improving existing methyl bromide uses, particularly for QPS 

purposes, developing new QPS uses and for work on emission control and reduction for MB.

In May, part of this CUN was recommended by MBTOC for a CUE (for research into cured 

pork disinfestation), subject to the quantities needed not being available from stocks, a 

condition required under Decision XVII/9 (7). The remainder was categorised as „unable-toassess‟ in TEAP May 2011 report.

There was correspondence between MBTOC and the nominating Party subsequent to 31st

OEWG seeking further clarification of aspects of the nomination. The Party withdrew this 

nomination in total (preharvest and postharvest aspects) in October 2011. It stated that it was 

now possible to conduct the required robust research program without access to a CUE.
October 2011 TEAP Report on 2011 CUNs: Final Report 11

2.7. Minority reports 

Consistent with Article 4(1) of Terms of Reference for TEAP as they apply to technical 

options committees, two Minority Reports were submitted by some MBTOC members after 

the October meeting in The Netherlands.

Two signed Minority Reports with technical justification were submitted by MBTOC 

members on nominations from the United States as shown below. The full text of the 

minority reports is shown in Sections 3.4 and 4.3.

Minority Report 1: United States of America nomination for the use of methyl bromide for 

strawberry fruit production in California in 2013.

Minority Report 2: United States of America nomination for the use of methyl bromide for 

cured pork in the USA.

TEAP CO-CHAIR STATEMENT ON MBTOC FINAL CUN REPORT OF OCTOBER 

2011

TEAP co-chairs acknowledge and appreciate MBTOC's thorough and detailed re-assessment 

of the two CUNs judged by TEAP and its MBTOC as “unable to assess” earlier in the year, 

and of the five other CUNs which were either revised or put forward for reassessment by one 

Party. Although MBTOC was able to make final consensus recommendations in most cases, 

regrettably the committee could not reach consensus on two instances, (the US nominations 

for a portion of MB preplant soil fumigation for strawberry fruit and the US nomination for 

cured pork) leading to two minority reports. 

TEAP co-chairs note that the minority report on the US nomination of cured pork was 

submitted by one member who asks that TEAP categorize the recommendation as "unable to

assess”. This request was considered, but mindful of the importance prompt publication, it 

was decided to put forward to Parties the majority and minority recommendations without 

comment.

TEAP co-chairs are aware of the complexity of the Critical Use Nominations and the careful 

and detailed assessment process they entail. TEAP will continue working on deliberation 

process and recusal guidelines to facilitate the work of all of its TOCs and will continue to 

reorganise TOCs and renew expert membership accordingly, taking into consideration the 

continuity and balance as well as the necessary expertise to respond to requirements as set out 

by tasks put forward by the Parties.
12 October 2011 TEAP Report on 2011 CUNs: Final Report

Table 2-5. Summary of Critical Use Nominations and Exemptions

Quantities Nominated Quantities Approved Interim 

Recommendation

2005 2006 2007 2008 2009 2010 2011 2012 2013 2005

(1ExMOP 

and

16MOP)

2006

(16MOP+

2ExMOP+

17MOP)

2007

(17MOP + 

18MOP)

2008

(18MOP

+

19MOP)

2009

(19MOP)

2010

(20MOP

+

21MOP)

2011

(21MOP)

2012 2012* 2013*

Australia 206.950 81.250 52.145 52.900 38.990 37.610 35.450 34.660 32.164 146.600 75.100 48.517 48.450 37.610 36.440

28.710

31.708 32.164

Canada 61.992 53.897 46.745 42.241 39.115 35.080

19.368

+3.529 16.281 13.444 61.792 53.897 52.874 36.112 39.020

30.340

+3.529

19.368 16.281 13.109

European 

Community1

5754.361 4213.47 1239.873 245.00 0 0 0 0 0 4392.812 3536.755 689.142 245.146 0 0

0

0 0

Israel 1117.156 1081.506 1236.517 952.845 699.448 383.700 232.247 0 0 1089.306 880.295 966.715 860.580 610.854 290.878

0

0

Japan 748.000 741.400 651.700 589.600 508.900 288.500 249.420 221.104 3.317 748.000 741.400 636.172 443.775 305.380 267.000

239.746

219.609 3.317

New Zealand 53.085 53.085 32.573 0 0 0 0 0 0 50.000 42.000 18.234 0 0 0

0

0 0

Switzerland 8.700 7.000 0 0 0 0 0 0 0 8.700 7.000 0 0 0 0

0

0 0

USAa10753.997 9386.229 7417.999 6415.153 4958.034 3299.490 2388.128 1181.779+ 

7.445

657.541 

rev. 

641.559 

9552.879 8081.753 6749.060 5355.976 4261.974 3232.856

+2.018

2055.200 993.706 nil 562.328

TOTALS 18704.241 15617.837 10677.552 8297.739 6244.487 4044.380 2928.142 1461.269

706.466

rev.

690.484

16050.089 13418.200 9160.714 6990.039 5,254.838 3572.183 2343.024 1261.304 nil 610.918

 

* Not yet available. 

1 Members of the European Community which had CUNs/CUEs included:

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

a

– The US reduced the nominated amounts on July 14th and later withdraw the research nominations for 2012 and 2013
October 2011 TEAP Report on 2011 CUNs: Final Report 13

3 MBTOC Soils: Final evaluations of 2011 Critical Use 

Nominations for methyl bromide for 2012 and 2013

3.1 Critical Use Nominations submitted 

For the preplant soils CUNs, Australia and Canada submitted similar amounts to the previous 

years highlighting difficulties with phase out of MB for the strawberry nursery sector. In the 

USA almost all sectors were making significant progress towards phase out in this round 

although restrictions on the use of alternatives in California were affecting progress towards 

phase out, particularly in the strawberry fruit sector in California.

In the 2011 nominations, 13 CUNs were submitted for preplant soil uses, 1 for 2012 and 12 for 

2013. This compared to 27 nominations submitted in 2010 but there were fewer in 2011as 

Japan and Israel no longer submitted CUNs. USA did not submit a nomination for forest 

nurseries and sweet potato slips, both of which had been submitted in previous years, but did 

submit a new nomination for research uses in 2012 and 2013 which have since been withdrawn. 

There were substantial reductions in the quantity of methyl bromide nominated by USA for 

2013. As stated in previous reports, Israel and Japan plan to phase out MB in 2011 and 2012 

respectively. 

After the 31st OEWG in Montreal, MBTOC Soils was requested to reassess several nominations 

(the US strawberry fruit, ornamentals, vegetables and research nominations) and MBTOC SC 

two nominations (cured pork and three aspects of the research nomination).

After consultation with members and careful consideration of the complex issues involved, 

which made email discussion cumbersome and virtually impossible, the soils MBTOC cochairs decided to hold a face-to-face meeting. 

Following TEAP instructions arising from the TEAP meeting of May 2011 (TEAP, 2011), the 

meeting was open to all MBTOC members who had indicated an intention to take part fully in 

evaluation of Soils CUN during the August member survey. This includes reading all 

background material in CUNs and all information related to issues surrounding the 

nominations. Questions to further clarify the nominations were sent to the Party and answers 

circulated to members. During this process, the US Party reduced 3 nominations for the 

vegetable and nursery stock sectors and all nominations for research uses. 

MBTOC met from 10-11 October 2011 in Leusden, The Netherlands, to finalise the Soils 

CUNs, discuss procedural issues related to CUN assessments and prepare the final report. On 

12 October there was a field visit to see strawberry runner production and to learn about 

equipment used for runner disinfestation. The four MBTOC Co-Chairs, eight additional 

members of the soils subcommittee, two members of the QPS subcommittee and one MBTOC 

economist attended the meeting. 

The meeting was held as required by the time schedule for the re-assessment of nominations 

categorised as “unable to assess”, or of nominations for which the Parties had submitted 

additional information as described in Annex I referred to in Decision XVI/4. Consensus 

decisions were made in plenary, and all comments made by members were considered in final 

recommendations. A communication system was established to allow those members not 

present, but who had indicated they wished to take part of the deliberations, to participate. One 

MBTOC member made contact with the chairs during the meeting. Minutes of the meeting, 

summarising the conclusions for each day were taken and were circulated to all members 

(including those not present) at the end of each day. Bilateral consultation with the US Party 

was held by teleconference on the afternoon of Tuesday, October 11.
14 October 2011 MBTOC Report on 2011 CUNs: Final Report

3.2. CUN assessment for preplant soil uses

In the interim assessment by MBTOC in May 2011 recommendations were made on all 

preplant soils nominations except for the research nominations for 2012 and 2013 which were 

unable to be assessed. As mentioned, the research nominations were subsequently withdrawn 

by the Party. At the 31 OEWG in Montreal, MBTOC held bilateral meetings with Canada, the 

USA and the Californian Strawberry Commission. The US Party advised that further 

information would be provided to support a review of the strawberry fruit, vegetable and

research nominations by July 15, 2011. Information exchange continued after that date. 

During the final meeting in the Netherlands, MBTOC held a bilateral teleconference with the 

US delegation, and participated in a field tour to see how The Netherlands was producing 

strawberry fruit and nursery plants without methyl bromide and consider the issues for this 

sector in other regions. The total nominated amount for all countries for preplant soil use in 

March 2013 was 661.677 t. This was reduced to 645.695 t (ie reduced by 15.982 t) in 2013 due 

to revision of the vegetable CUNs and withdrawal of the research CUNs by the US. The final 

recommendation for 2013 was 567.442 t, ie. 86% of that nominated (Table 3-1). A nomination 

for research of 6.111t for trials on preplant soil uses by USA for 2012 was also withdrawn.

MBTOC has sometimes recommended quantities of MB for 2013, which are less those 

nominated. The grounds used for these recommendations are given in detail after the relevant 

CUNs in Tables 3-7 and 4-2. The adjustments for preplant soils use may in part be to account 

for presumptions and are given in Tables 3-4 and 3-5.

Table 3-1. Changes occurring to nominated and recommended amounts of MB (metric 

tonnes) for preplant soil uses after the May 2011 interim report. 

Party CUN Initial 

nomination 

by the 

Party

Interim 

MBTOC 

recommen

dation

Revised nomination 

by the Party after the 

30th OEWG

USA Cucurbits 11.899 11.899* 3.887

Peppers 5.673 5.673* 5.605

Tomato 10.741 10.741* 9.107

Nurseries 0.541 0.541* 0.476

Research

2012

6.111 Unable Withdrawn

Research 

2013

6.203 Unable Withdrawn

Total 41.168 19.075

* Further substantiation from the Party was received on July 14th, 2011
October 2011 TEAP Report on 2011 CUNs: Final Report 15

Table 3-.2 Summary of MBTOC S final recommendations for 2013 by country for CUNs 

received in 2011 for preplant soil* use of MB (tonnes)

Country CUE approved at 

21st MOP 

CUN for 2013 MBTOC-S final 

Recommendation

2012 2013 2013

Australia

 29.760 29.760 [29.760] 

Canada 5.261 5.596 [5.261]

Israel 224.497 0

Japan 216.120 0

USA 913.31 620.118

Revised

610.339

[532.442]

Total 1164.452 645.695 [567.463]

* Figures do not include research nominations from the USA as they were withdrawn

Table 3-3. Summary of the final recommendations by MBTOC-S (in square brackets) for 

CUE’s for preplant uses of MB (tonnes) submitted in 2011 for 2012 and 2013

* The Party revised (rev.) the nominated amounts for some sectors as shown in the table

Country and Sector Final Nomination by the 

Party for 2103

Final Recommendation 

for 2013

1. Australia

1. Strawberry runners 29.760 [29.760]

2. Canada

1. Strawberry runners 5.596 [5.261]

3. USA*

1. Cucurbits

 2. Eggplants (field) 

3. Nursery stock

4. Ornamentals

5. Orchard Replant

6. Pepper (field)

7. Strawberry (field)

8. Strawberry runners

 9. Tomatoes (field)

(11.899) rev. [3.887]

[1.381]

(0.541) rev. [0.476]

[48.164]

[6.230]

(5.673) rev. [5.604]

[531.737]

[3.752]

(10.741) rev. [9.107]

[3.887]

[1.381]

[0.476]

[40.818]

[6.230]

[5.604]

[461.186]

[3.752]

[9.107]

Sub total USA [610.339] [532.442]

TOTAL [645.695] [567.463]
16 October 2011 MBTOC Report on 2011 CUNs: Final Report

3.3. 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 of methyl iodide (MI or iodomethane) with barrier films and 

registration in most states of the USA that use MB in mid 2008 or December 2010 

(California). This has led to commercial adoption on large sale areas in the US and 

substantial reduction in the US nominations in SE US 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. 

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 („Pichlor 60‟) in the USA which 

increases the area that may be treated with 1,3-D in regions 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 data and acceptance in specific sectors that alternatives exist, e.g. orchard 

replant in heavy soils, and nursery industries.

In 2011, the US indicated it no longer sought nominations for the forest nursery, and sweet 

potato sectors. It was unclear whether this was due to uptake of alternatives or –at least in part 

–to reclassification to QPS. Israel and Japan no longer sought any methyl bromide under 

critical use for preplant soil use, thus respecting their phase out notified to the Parties in 2010.

In the 2011 round as in past rounds, MBTOC also used adoption data of alternatives in specific 

regions where it was available, such as the Californian Department of Pesticide Regulation –

Pesticide Use Report data to help with identifying historic use of MB within regions 

assessment, particularly the largest strawberry fruit nomination.

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 previous years, Parties found 

alternatives more difficult to adopt for propagation materials, such as strawberry runners and 

nurseries. For some Parties, there is a lack of research 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 undertake research in these sectors. The impact of reviews of volatile organic compound 

(VOC) emissions in California (http://www.epa.gov/iaq/voc.html) 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. For instance, current 

restrictions on dose rate for methyl iodide in California prevent the Party and MBTOC 

accepting it as a suitable alternative for all uses. MBTOC urges the Parties to align their local 

policies and regulations with internationally accepted methodologies and to allow use of MB 

alternatives.
October 2011 TEAP Report on 2011 CUNs: Final Report 17

3.3.1. 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”.

Iodomethane (MI) is registered for more than 28 crops in all US states except Washington and 

New York and this has greatly assisted phase out of MB in SE States of the USA including 

field-grown ornamentals, peppers, strawberries and tomatoes. In California approval was 

granted for iodomethane in December 2010, however use rates approved may be restrictive for 

certain uses according to the Party, however in combination with Pic the dosage rates are 

considered effective for most uses by MBTOC. It is a requisite under Decision IX/6 that Parties 

provide data and references to demonstrate the ineffectiveness of these formulations for a 

specific use. where a CUN is sought. MI has also gained registration in a number of Article 5 

countries and non Article 5 countries, such as New Zealand, Mexico, Turkey and Japan and this 

has assisted phase out of MB for preplant uses in these countries. Registration of MI is pending 

in Australia and this alternative is indicated by the Party to be a main alternative which could 

assist phase out for MB in strawberry runners. To ensure that the mitigation measures for MI 

will be consistent with the measures being required for the other fumigants, the label 

requirements are presently being re-examined in the USA. 1,3-dichloropropene, may be subject 

to similar provisions when the soil fumigants are evaluated together again in 2013.

The EU 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.

3.3.2. Update on rates of adoption of alternatives for preplant uses - Dec.XIX/9

From 2010 onwards, 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‟.

Previous reports (see references in Table 3-7, Porter et al., 2006, MBTOC 2011) show that 

technical alternatives exist for almost all uses requesting CUNs, but the uptake of alternatives 

varied between countries, crops and the pest pressure. In general, similar alternatives are being 

adopted by the same sectors in a number of countries, although the rate of adoption has varied 

depending on regulatory restrictions on use, differences in registration rates between countries 

and other market forces. In this round as in previous rounds of CUNs, MBTOC has recognised 

that a limited period of time is needed to allow the market penetration of alternatives, based on 

logistical, training, imports of alternatives and other information provided in the nomination by 

the Party (paragraph 35 in Annex 1 of the 16th Meeting of the Parties). 

Figures 2-1 to 2-4 in this report show the apparent reduction rates for MB use achieved by 

many Parties in a number of key sectors. As noted above, the actual reduction and adoption 
18 October 2011 MBTOC Report on 2011 CUNs: Final Report

rates may vary from the rate of change of CUN/CUE because of factors such as use of stocks 

(some Parties use stocks instead of „freshly produced‟ methyl bromide from CUEs), and/or a 

transfer of MB between sectors of use, which occurs in some Parties. The CUN reviews 

presented in Tables 3-7 and 4-2 also provide detail of some of the key alternatives that Parties 

have and may 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, in accordance with paragraphs 34-35 of 

Annex 1 of the MOP16, as this information would assist MBTOC in evaluation of CUNs in 

future. 

3.3.3. 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 some regions of 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 the sustainability of the alternative. 

In the past, MBTOC visited flower growers in Southern Spain who have successfully adopted 

biodisinfestation as an efficient and sustainable alternative to MB.

3.3.4. Standard presumptions used in assessment of nominated quantities.

The tables below (Tables 3-4 and 3-5) provide the standard presumptions applied by MBTOC-S 

for this round of CUNs for preplant soil uses. 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 prescribe lower or higher rates. However, MBTOC notes that studies have shown 

that rates of 200 kg/ha (20g/m2) or less of MB: Pic 50:50 are effective with barrier films for 

production of „certified‟ nursery material and urge Parties to consider regulations which permit 

these lower rates. 

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. 
October 2011 TEAP Report on 2011 CUNs: Final Report 19

Table 3-4. Standard presumptions used in assessment of CUNs for the 2009 and later 

assessments – 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/m2for 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 Piccontaining 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 3-5. Maximum dosage rates for preplant soil use of MB by sector used in the 2009 and 

later assessments (standard presumptions).

Film Type

Maximum MB Dosage Rate (g/m2) in MB/Pic mixtures (67:33, 

50:50) 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
20 October 2011 MBTOC Report on 2011 CUNs: Final Report

3.3.5. 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, 33:67 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 2006; Melgarejo 

et al., 2001; Santos et al., 2007; Hamill et al., 2004; 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 25 g/m2) or 100 

kg/ha (10 g/m2) of MB in 250 kg/ha (25 g/m2) of 50:50 MB/Pic mixtures in conjunction with 

barrier films (Table 3.6).

Table 3-6. 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.

Commercial 

application 

rates of 

formulation

MB/Pic formulation (dose of MB in g/m2)

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 
October 2011 TEAP Report on 2011 CUNs: Final Report 21

3.3.6. 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, Yates et al., 2009). These latter technologies have not been reported or 

adopted widely by Parties and need to be evaluated more widely.

In southeast 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). 

MBTOC notes that barrier films can be used with alternatives and this is are consistently 

improving the performance of alternatives at lower dosage rates. Effectiveness at lower dosages 

can allow for greater areas to be treated with 1,3-D under township cap regulations or increase 

the likelihood of Pic being applied at dosage rates below the 125 or 200 lbs/acre restrictions 

presently imposed in California. 

3.4. Minority report

One signed Minority Report with technical justification was submitted by MBTOC members on 

the nomination from the United States of America for the use of methyl bromide for strawberry 

fruit production in California in 2013. The full text of the minority report is shown below. 

3.4.1. US Strawberry fruit CUN - Minority viewpoint

The following MBTOC members disagree with MBTOC‟s recommendation of 461.186 tonnes: 

Michelle Marcotte, James Schaub, Sally Schneider, Abraham Gamliel, Andrea Minuto and Ken 

Vick. Instead, these MBTOC members note that the Party has authoritatively and credibly 

substantiated its nomination and the recommended amount for strawberry fruit in California 

should be 531.737 tonnes for 2013. 

Background for the October MBTOC deliberations

At the May meeting in 2011, and after listening to the majority and minority points of views, 

TEAP agreed to support a part of the nominated amount which was not questioned by the 

majority and the minority positions of MBTOC (i.e., 461.186 t). Additionally, TEAP indicated 

that the additional amount, 70.551 tonnes, required further substantiation of the critical area not 

able to use the alternatives (1,3-D and Pic and their combinations). The Party was invited to 

provide information for further evaluation by MBTOC for any amount above the minority 

recommendation up to the nominated amount (TEAP, 2011).

Additional information from the Party

In August and October, the Party provided MBTOC with a statement to clarify the area in 

Ventura County that could not use alternatives. The Party maintains that 40% of the strawberry 

hectares in Ventura County was either underreported or mis-categorized in the California 

Department of Pesticide Regulation Pesticide Use Report (PUR) data. The Party explained that 

there is a significant mis-categorization of strawberry hectares as „soil fumigation/preplant‟ in 

the PUR data and that 85% of this aspect of the PUR data should have been counted as 

strawberry hectares (according to the Ventura County Agriculture Commissioner – the 

government office with pesticide use regulatory authority). The Party also stated that in 

determining the hectares requiring methyl bromide, it took into account areas where 

Macrophomina and Fusarium are not controlled by rates of chloropicrin (that can legally be 
22 October 2011 MBTOC Report on 2011 CUNs: Final Report

used) and areas where proximity to sensitive sites prevent the use of effective rates of 

chloropicrin. The USG has informed MBTOC that 100% of the area nominated in Ventura 

County is affected by these two plant diseases. Expansion of the use of chloropicrin and 1,3D 

as broadacre fumigants to control these diseases seems unlikely because of regulatory 

restrictions on the quantities of fumigants used and in the application methods allowed in 

regulation.

As a result of these aspects, the Party reaffirmed that 894 hectares in Ventura County cannot 

use alternatives. MBTOC, in continuing to recommend its May interim amount of 461.186 

tonnes, has not accepted any of the new, substantive and authoritative information provided by 

the Party. 

Assessment

It was the view of the MBTOC members named above that the Party had substantiated their 

nomination sufficiently. The Party has corrected the number of hectares which had been 

miscategorised. The Party also substantiated the need for MB on area affected by 

Macrophomina and Fusarium or which cannot use Pic due to regulatory constraints. Therefore 

these members assessed that the Party had demonstrated the general conditions for a Critical 

Use Exemption and credibly and authoritatively addressed TEAP‟s May 2011 request for 

further substantiation. As a result, these members hold a viewpoint inconsistent with that of the 

majority of MBTOC members, and recommended the amount of MB nominated by the Party 

for use in California strawberry fruit in 2013 (531.737 tonnes). 
October 2011 TEAP Report on 2011 CUNs: Final Report 23

Table 3-7. Final evaluations of CUNs for preplant soil use submitted in 2011 for 2013

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

Australia Strawberry 

runners

35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.760 - 29.760 - 29.760

MBTOC recommendation for 2013:

MBTOC recommends a CUE of 29.760 tonnes for 2013. There has only been minor reductions made in last 5 CUEs submitted and no reduction in use rate as this is 

regulated by certification rules. 

The Party states that the key pests affecting strawberry runner production are fungi (Phytophthora, Pythium, Rhizoctonia and Verticillium spp.) and weeds (S. arvensis, 

Agrostis tenuis, Raphanus spp., Poa annua, Cyperus spp). The Party also states that MB:Pic 50:50 at a MB dose of 25 g/m2is required to meet certification standards. 

Although this quantity exceeds MBTOC’s standard presumption of 20 g/m2, the lower rate is unregistered. The Party’s first 2-year effort using a reduced rate of 18.75 g/m2

resulted in unsatisfactory results in the second year of testing. The Party initiated another 2-year study using MB/Pic (50/50) @ 400 kg/ha [20g/m2] and the standard rate 

MB/Pic (50/50) at 500 kg/ha [i.e. MB at 25g/m2]. Yields from the plot treated with MB/PIC [20g/m2] were 25% less than the yields from the standard rate. Two additional 

commercial trials were initiated in 2010/2011 using the lower rate of 20g/m2as APVMA requires 2 years of trials before approving a reduced rate. The Party states that the 

most promising alternative, MI/Pic, has been demonstrated in commercial scale field trials to compare with the efficacy to MB:Pic. The registrant has indicated that additional 

data has been requested by APVMA which will be submitted this year and should lead to registration in late 2011. While more data has been submitted to support the 

registration of EDN, the Party indicates that the registration status is still highly uncertain. A key alternative, 1,3-D:Pic, is considered ineffective due to phytotoxicity and 

doubling of plant back times in the heavy and wet soil conditions in the high elevation regions. The Party also indicates that the Victorian Strawberry Certification Authority 

(VSICA) completed the second year of a 2-year development program for soil-less systems for production of foundation stock strawberry runners. Results indicated that the 

productivity of the soil-less system is similar to the current method of production in MB:Pic fumigated soils, and the economics of the soil-less system compares favourably 

with the current method of production. VSICA plans to establish a commercial facility by 2012 which, if successful, would eliminate VSICA’s need for MB for foundation stock 

in 2011/2012.

MBTOC requires that the Party: (1) report the results with reduced rates of 20 g/m2of MB with its next CUN submission as well as the decision on whether to register the 

reduced rates; (2) provide a comprehensive update of the registration status of MI and EDN, (3) provide the results from the new trials using recaptured MB & Pic as well as 

a comprehensive plan for commercialization and (4) since the production of 60,000 foundation generation has been found to be economically feasible, the Party needs to 

provide the economic analysis that supports their assertion that any further expansion is not economically feasible. Although this nomination provides results of extensive 

research results with highly promising alternatives MBTOC expects significant adoption of these in any future nominations.

MBTOC comments on economics 2011:

The nomination was not based on economic arguments

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission control: No, but standard films are claimed by the Party to perform the same as VIF in the cold temperatures and heavy wet soils typical for 

strawberry runner production.

 Dec. IX/6 b(iii) Research program: On going research is being conducted in (a) supporting reduced application rates of MB:Pic, (b) supporting the registration of 

MI; unknown for EDN; (c) use of recaptured MB & Pic;

 Dec. IX/6 b(iii) Appropriate effort: research effort is adequate but commercialization is confronted with regulatory obstacles.
24 October 2011 MBTOC Report on 2011 CUNs: Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

Canada Strawberry 

runners (PEI)

6.840 6.840 7.995 7.462 7.462 7.462 5.261 5.261 - 5.596 - 5.261

MBTOC recommendation for 2013:

MBTOC recommends a reduced CUE of 5.261 tonnes for this use in 2013. In 2012 the requested amount was 5.261 t. In this round, the Party stated that the nomination had 

been reduced by 25%, but as it increased, MBTOC only recommends the quantity approved in 2012. The CUN for 2013 is based on a reduced rate for MB of 20 g/m2, and 

MBTOC acknowledges the Party’s reduction in 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 in Prince Edward Island in January 2003 due to ground water contamination. Chloropicrin

(PIC 100) has been registered by PMRA, but the PEI authorities have denied a permit for its use until further groundwater testing has been conducted. MI registrant has not 

applied for registration in Canada. The company has been testing organic production from 2006 - 2009 with different varieties and has found that they obtained significant 

reductions in yield ranging from 40% to 70%. Only one variety using the organic production system compared favourably to conventional production. While MB:Pic 67:33 at 

500 kg/ha is the only use rate registered for strawberry runners, which exceeds MBTOC’s standard presumption of 200 kg/ha, the grower petitioned PMRA to use a lower 

rate under barrier films. PMRA, in the absence of a formal label amendment, granted permission 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% & 30% lower rates under barrier films and expanded the area tested in 2009. The results were comparable using the 

reduced rates with barrier films. The CUN for 2013 is based entirely on a reduced rate for MB of 200 kg/ha for the entire area to be fumigated. 

For any future nominations, MBTOC suggests the Party (1) complete the necessary ground water studies to obtain the PIC 100 permit which was indicted by the Party to 

commence in 2008 and (2) test the adoption of soilless cultures for at least part of the production cycle, 3) provide an update on barriers to adoption of other key alternatives 

(especially methyl iodide/chloropicrin). MBTOC requests greater substantiation of effort (i.e. trial data) is provided to support any future nominations as required in Decision 

IX/6.

MBTOC comments on economics 2011:

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 presumptions

 Dec. IX/6 b(iii) Research program: No recent research; previous focus has been on organic production testing; registrant for Midas has not submitted any registration 

application materials at this time.

 Dec. IX/6 b(iii) Appropriate effort: The Party has not demonstrated an active research program on its most critical issue since it has been unable to obtain assistance to 

do the necessary GW testing required by PEI authorities before approving the use of PIC100 in PEI.
October 2011 TEAP Report on 2011 CUNs: Final Report 25

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

United 

States 

Cucurbits 1187.800 747.839 592.891 486.757 407.091 302.974 195.698 59.500 - 11.899

revised 

to 3.887

- 3.887

MBTOC recommendation for 2013:

MBTOC recommends an amount of 3.887 t of MB, which was the adjusted nomination by the Party as of July 2011. This was for small-scale (less than 4ha) cucurbit 

production in Georgia in 2013, allocated as 0.815 t for squash, 0.657 t for cucumber and 2.415 t for melon. 

Nomination by the Party

MBTOC noted that the amount reduced by the Party (8.012 t) was a 66% reduction from the interim amount of 11.899 t recommended by MBTOC. This is 93% less than the 

quantity (59.494 t) approved by the Parties in 2012. The Party informed MBTOC that the nomination is for one final year to allow time for some small-scale growers of 

cucurbits in Georgia to adopt available alternatives. 

In its July 2011 response to questions from MBTOC, the Party informed MBTOC that it had withdrawn its previous 2013 nominations for the critical uses of methyl bromide in 

Maryland and Delaware (0.348 t) and South East US (7.664 t, Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee and 

Virginia), leaving the critical use of MB for the production of cucurbits by producers with less than 4ha in Georgia. The target pests were reported to be mainly nutsedge, 

nematodes and Fusarium wilt. The Party stated a rate of 150 kg MB/ha would be used for both pathogen and nutsedge control. This rate conforms to MBTOC’s standard 

presumptions for application of MB under VIF for the control of nutsedge (150 kg/ha) and pathogens (125 kg/ha).

Circumstances of the nomination

The Party reported that farmers needed a period of time to transition to available alternatives and that these small-scale producers do not have much experience with the 

alternatives and need to convert their equipment to utilize the 3-Way method (1, 3-dichloropropene plus chloropicrin plus metham sodium) (US pers comm to MBTOC 14 

July 2011). The nomination was therefore based on financial considerations and time for the adoption of alternatives.

The Party stated that “Decision IX/6(1)(a) is applicable because the US has determined that the specific use detailed in this CUN is critical because the lack of availability of 

methyl bromide for this use would result in a significant market disruption”. The Party reported that it had reduced nominations for the critical uses of methyl bromide for 

fruiting vegetables by 99% over the past nine years. However, MBTOC was uncertain that the unavailability of this relatively small amount of methyl bromide for vegetable 

production could result in a significant market disruption. 

The Party nominated on the basis that small-scale growers needed a period of time to adopt alternatives, as required in paragraphs 35 and 36 of Annex 1 to the Sixteenth 

Meeting of the Parties, by providing financial information for small-scale tomato growers in Georgia. MBTOC accepted that this was equivalent because of similar production 

systems for tomatoes and cucurbits in Georgia.

The Party stated that there are currently no commercial fumigation/applicators for small-scale growers in Georgia, so growers must perform these applications themselves.

MBTOC review and assessment

MBTOC noted that the information provided was insufficient to determine whether the request for critical uses of methyl bromide complied fully with Decision IX/6 and other
26 October 2011 MBTOC Report on 2011 CUNs: Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

relevant criteria, as:

 The Party only provided financial information on the cost of converting the 3-Way system and not other chemical alternatives such as DMDS, MS, DMDS and PIC, 

DMDS and MS, PIC/ MS which are registered and available;

 The Party provided financial information relevant to tomato and not for cucurbit production.

In the circumstances of this nomination, and in light of the decision of the Party to not consume MB for critical uses after 2013 for the production of cucurbits, the lack of some 

information did not prevent MBTOC from making a recommendation on this nomination. 

MBTOC Comments on economics 2011:

The CUN is based on economic and other arguments (see MBTOC review and assessment above).

Comments requested in Dec. XXI/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: There was no information in the nomination about the use of VIF or equivalent film. However, a dosage rate of 150 kg/ha MB 

proposed in the nomination was consistent with the use of barrier films for nutsedge. The amount proposed for use in 2013 was 93% less than the amount 

approved by the Parties for use in 2012.

 Dec. IX/6 b(iii) Research program: The Party demonstrated that a research program was in place several years ago.

 Dec. IX/6 b(iii) Appropriate effort: The Party demonstrated that an appropriate effort has been made to evaluate and commercialise alternatives and substitutes.
October 2011 TEAP Report on 2011 CUNs: Final Report 27

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

United 

States 

Eggplant 76.721 82.167 85.363 66.018 48.691 32.820 19.725 6.904 - 1.381 - 1.381

MBTOC recommendation for 2013

MBTOC recommends 1.381 tonnes of MB for small-scale (less than 4ha) eggplant production in Georgia (0.612 t) and Florida (0.769). MBTOC noted that the quantity (1.381 

t) nominated by the Party was 80% less than the quantity (6.904 t) approved by the Parties in 2012.

Nomination by the Party

The Party informed MBTOC that the nomination is for one final year. The critical uses of methyl bromide allows time for some small-scale eggplant growers in Georgia and 

Florida to transition to available alternatives, with the remaining US producers of eggplant transitioning to alternatives in 2012 or previously. The Party stated a rate of 150 

kg MB/ha would be used for soil borne fungi (Phytophthora capsici, Fusarium spp, Pythium spp, Sclerotium rolfsii), nematodes (Meloidogyne spp) and nutsedge control. This 

rate conforms to MBTOC’s standard presumptions for application of MB under VIF for the control of nutsedge (150 kg/ha) and pathogens (125 kg/ha).

Circumstances of the nomination

The Party reported that farmers needed a period of time to transition to available alternatives. These small-scale growers do not have much experience with the alternatives 

and need to convert their equipment to utilize the 3-Way method (1, 3-dichloropropene plus chloropicrin plus metham sodium) (US pers comm to MBTOC 14 July 2011). The 

nomination was therefore based on financial considerations and time for the adoption of alternatives.

The Party stated that “Decision IX/6(1)(a) is applicable because the US has determined that the specific use detailed in this CUN is critical because the lack of availability of 

methyl bromide for this use would result in a significant market disruption”. The Party reported that it had reduced nominations for the critical uses of methyl bromide for 

fruiting vegetables by 99% over the past nine years. However, MBTOC was uncertain that the unavailability of this relatively small amount methyl bromide for vegetable 

production could result in a significant market disruption. 

The Party nominated on the basis that small-scale growers needed a period of time to adopt alternatives, as required in paragraphs 35 and 36 of Annex 1 to the Sixteenth 

Meeting of the Parties, by providing financial information for small-scale tomato growers in Georgia. MBTOC accepted that this was equivalent because of similar production 

systems for tomatoes and eggplants in Georgia and Florida. 

The Party stated that there are currently no commercial fumigation/applicators for small-scale growers in Georgia and Florida, so growers must perform these applications 

themselves. 

MBTOC review and assessment

MBTOC noted that the information provided was insufficient to determine whether the request for critical uses of methyl bromide complied fully with Decision IX/6 and other 

relevant criteria, as:

 The Party only provided financial information on the cost of converting the 3-Way system and not other chemical alternatives such as DMDS, MS, DMDS and PIC, 

DMDS and MS, PIC/ MS which are registered and available;

 The Party provided financial information relevant to tomato production in Georgia and not for eggplant production in Georgia and Florida;
28 October 2011 MBTOC Report on 2011 CUNs: Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

 A survey of famers using alternatives did not report any impact for eggplant producers of using alternatives on yield loss, cost increase or longer plant back interval 

(US pers comm to MBTOC 14 July 2011, Table 4p4)

In the circumstances of this nomination, and in light of the decision of the Party to not consume methyl bromide for critical uses after 2013 for the production of eggplant, the 

lack of some information did not prevent MBTOC from making a recommendation on this nomination.

MBTOC Comments on economics 2011:

The CUN is based on economic and other arguments (see MBTOC review and assessment above).

Comments requested in Dec. XXI/11 (para 9)

 Dec. IX/6 b(i)- Emission Reduction: There was no information in the nomination about the use of VIF or equivalent film. However, a dosage rate of 150 kg/ha MB 

proposed in the nomination was consistent with the use of barrier films for nutsedge. The amount proposed for use in 2013 was 93% less than the amount approved by the 

Parties for use in 2012. 

 Dec. IX/6-b(iii)-Research program: This research is on going. However, specific studies known to MBTOC that have been conducted or are in progress were not cited in 

the nomination.

 Dec. IX/6-b(iii)-Appropriate effort: The Party demonstrated that an appropriate effort has been made to evaluate and commercialise alternatives and substitutes such 

as the 3-Way system and methyl iodide.
October 2011 TEAP Report on 2011 CUNs: Final Report 29

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

United 

States 

Nurseries 

stock (fruit, 

nut, flower)

45.800 64.528 28.275 51.102 25.326 17.363 7.955 1.591 - 0.541

Revise

d

0.476

- 0.476

MBTOC recommendation for 2013:

MBTOC recommends 0.476 tonnes of MB for this use in 2013. This represents a reduction of 81% from previous amounts. 

The Party states that the requested amount is for those crops that require certification but do not move across controlled boundaries e.g. counties and cannot use the 

preferred alternatives such as 1,3-D due to township caps or on specific soil conditions. The treatment for crops such as fruit and nut trees and rose nurseries are required to 

meet certification standards for a crop that is in the ground for two years. Some portions of the crops in this sector are now produced in substrates and alternatives are used 

wherever possible. The target pest for certification is nematodes, but control of soilborne pathogens and weeds also impacts product quality.

MBTOC comments on economics 2011:

The same economic information is provided as in the previous year. CUN is not based on economic arguments

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 standard presumptions.

 Dec. IX/6 b(iii) Research program: Yes, An area wide program is evaluating the key alternatives, including methyl iodide/Pic.

 Dec. IX/6 b(iii) Appropriate effort: A range of alternatives are being considered and commercialized.
30 October 2011 MBTOC Report on 2011 CUNs: Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

United 

States 

Orchard 

replant

706.176 527.600 405.400 393.720 292.756 215.800 183.232 18.324 - 6.230 - 6.230

MBTOC recommendation for 2013:

MBTOC recommends 6.230 tonnes for this use in 2013. This includes 4.318 t for stone fruit, 0.213 t for raisins, 0.627 t for walnuts, 0.564 t for almond and 0.508 t for wine 

grapes. The CUN is for orchard/vineyard replant disorder of unknown etiology for a portion of replant sites in California where alternatives are not suitable or available (1,3-D) 

or where the data on the effectiveness of lower rates of methyl iodide (MI which is currently registered in California) are still being collected and effectiveness is not yet 

known. 

The Party states that alternatives are not available because of regulatory restrictions or physical characteristics such as unacceptable soil type, moisture or topography. The 

CUN is for heavy soils or soils which cannot be effectively treated to a sufficient depth to effectively use the reduced rates of 1,3-D now allowed in California. Regulatory 

constraints (maximum labelled rates) prevent the use of 1,3-D at the rates needed for effective kill of old roots and the associated pathogens in deeper soil. Although methyl 

iodide has been registered in California since December 2010 for replant, successful trials have only been reported with rates higher than registered (Browne et. al., 2010; 

Schneider et. al, 2005). Trials at the registered, lower, rates have been initiated. The best alternatives for orchard replant that have been identified are 1,3-D or 1,3-D with 

chloropicrin, and/or metham-sodium, especially in coarse-textured soils. Under certain soil and moisture conditions (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 majority of orchard and vineyard sites. 

MBTOC acknowledges that the CUN is for a substantially smaller amount that is 34 % of the previously approved CUN. The Party confirms that MB/Pic 67:33 formulation is 

used for California stone fruit, raisin grapes, and wine grapes, and now as well for almond and walnut at a dose rate of 20g/m2. 

MBTOC comments on economics 2011:

The same economic information is provided as in the previous year. CUN is not based on economic arguments.

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: No, high barrier films cannot be used in California due to regulatory constraints. Rates conform to the standard 

presumptions without barrier films. Rates conform to the standard presumptions with barrier films.

 Dec IX/6 b(iii) Research program: Yes, research effort has been conducted on alternatives.

 Dec. IX/6 b(iii) Appropriate effort: Substantial reduction indicates appropriate efforts. 
October 2011 TEAP Report on 2011 CUNs: Final Report 31

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

United 

States 

Ornamentals 154.000 148.483 137.835 138.538 107.136 84.617 64.307 48.164 - 48.164 - 40.818

MBTOC recommendation for 2013:

MBTOC recommends a reduced amount of 40.818 tonnes for this use in 2013. This includes 39.907 t for California (15% reduction from nominated amount) and 0.911 t for 

Florida (25% reduction from nominated amount). The 25% reduction for Florida recommended by MBTOC in its interim report of May 2011 was accepted by the Party. This 

was based on implementation of substrates, steam and uptake and improvement in MI technologies by 2013 and the registration time (and rate) for MI. 

The Party requested reassessment of MBTOC’s recommended reduction for California by 15%, however MBTOC consider alternatives are available for this portion of the 

nomination and confirms the recommended 15% reduction for California

The Party states that the nomination is for a large number of species, mostly grown in the field rather than in protected cropping. In Florida, the main species using MB are 

gladioli, lilies and snapdragon. Additional species using MB in California include alstroemeria, carnations, delphinium, gerbera, chrysanthemums, pompons, rose and others. 

There are several types of cut flower, foliage, and bulb crops grown each year and often several species are grown in the same field simultaneously. MB is needed to control 

diseases (e.g., Fusarium spp., Pythium spp., Phytophthora spp., and Rhizoctonia spp.), plant parasitic nematodes (e.g., root knot, root lesion, stunt and dagger), weeds (e.g. 

Cyperus spp., Portulaca, Ambrosia and others), and previous crop propagules. Methyl iodide (MI) was registered in Florida in 2009 and is in commercial use although some 

concerns on its applicability for widespread use on certain soil conditions remain (Kokalis-Burelle et al., 2010; Rosskopf et al., 2010 ab). The major issue with MI is the 

potential cultivar sensitivity and this requires more research with the many cultivars and flower crops produced. MBTOC considers other alternatives are available in Florida, 

such as 1,3-D/Pic or solarisation with chemicals (McSorley et al., 2006 ab; McSorley et al., 2008). 

MI was registered in California in December 2010. Recent preliminary studies in California indicate that low rates of methyl iodide are effective when used alone or in 

combination with consecutive application of other fumigants, such as metham sodium (Gerik, 2010) or metham potassium with or without VIF (Klose, et al 2007 ab; Klose et 

al 2008ab). Other studies with other chemicals, e.g. 1,3_D/Pic, metham sodium (Gerik et al, 2006; 2009; Klose et al, 2008ab; Elmore et al, 2007) also show efficient results. 

MBTOC considers that further uptake of non-chemical alternatives such as steam, solarisation and a combination of both (Gerik et al, 2010; Rainbolt et al, 2010; Fennimore, 

2008; Fennimore and Goodhue, 2009; Gilbert et al, 2008; Samtani et al, 2010) is also possible. Steaming systems and application methods were evaluated in California and 

provided pest control statistically similar to hot-gas MB (Gilbert et al., 2009; Rainbolt et al., 2010). An IPM approach has been developed for ornamentals and is 

recommended by researchers in California (Elmore et al, 2007). MBTOC considers that all of the above alternatives can be used at least for part of the nomination and 

together can account for the proposed 15% reduction. Economic assessment of the costs of adoption of steam and other alternatives are needed to support this nomination.

MBTOC comments on economics 2011:

The same economic information is provided as in the previous year. CUN is not based on economic arguments.

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 cannot be used in California 

due to 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 effort: The nomination indicates significant efforts have been made to switch to alternatives. Substantial reduction indicates 

appropriate efforts particularly in Florida. In California, efforts have been made within the constraints imposed by regulations.
32 October 2011 MBTOC Report on 2011 CUNs: Final Report

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for 

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2012 (addtl 

or new)

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United 

States 

Peppers 

(field)

1094.782 1243.542 1106.753 756.339 548.984 463.282 206.234 28.366 - 5.673

revised 

to 5.604

- 5.604

MBTOC recommendation for 2013:

MBTOC recommends 5.604 t of MB which was the nomination adjusted by the Party in July 2011. This was for small-scale (less than 4ha) peppers production in Georgia 

(0.189 t) and Florida (5.415 t) in 2013. MBTOC noted that this total quantity (5.604 t) was slightly less than the interim amount (5.673 t) recommended by MBTOC (TEAP 

May 2011) and in the nomination submitted in January 2011 for 2013. This quantity (5.604 t) was also 80% less than the quantity (28.365 t) approved by the Parties in 2012.

Nomination by the Party

The Party informed MBTOC that the nomination is for one final year. The critical uses of MB allow time for some small-scale pepper growers in Georgia and Florida to 

transition to available alternatives, with the remaining US pepper producers transitioning to alternatives in 2012 or previously. 

In its July 2011 response to questions from MBTOC, the Party informed MBTOC that it had withdrawn its previous 2013 nominations for the critical uses of methyl bromide in 

South East US (0.068 t, Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee and Virginia), leaving the critical use of methyl 

bromide for the production of peppers by producers with less than 4ha located only in Georgia and Florida. The target pests were reported to be mainly nutsedge and 

nematodes. The Party stated a rate of 150 kg MB/ha would be used for both pathogen and nutsedge control. This rate conforms to MBTOC’s standard presumptions for 

application of MB under VIF for the control of nutsedge (150 kg/ha) and pathogens (125 kg/ha).

Circumstances of the nomination

The Party reported that farmers needed a period of time to transition to available alternatives. These small-scale growers do not have much experience with the alternatives 

and need to convert their equipment to utilize the 3-Way method (US pers comm to MBTOC 14 July 2011) (1, 3-dichloropropene plus chloropicrin plus metham sodium). The 

nomination was therefore based on financial considerations and time for the adoption of alternatives.

The Party stated that “Decision IX/6(1)(a) is applicable because the US has determined that the specific use detailed in this CUN is critical because the lack of availability of 

methyl bromide for this use would result in a significant market disruption”. The Party reported that it had reduced nominations for the critical uses of methyl bromide for 

fruiting vegetables by 99% over the past nine years. However, MBTOC was uncertain that the unavailability of this relatively small amount methyl bromide for vegetable 

production could result in a significant market disruption. 

The Party nominated on the basis that small-scale growers needed a period of time to adopt alternatives, as required in paragraphs 35 and 36 of Annex 1 to the Sixteenth 

Meeting of the Parties, by providing financial information for small-scale tomato growers in Georgia. MBTOC accepted that this was equivalent because of similar production 

systems for tomatoes and peppers in Georgia and Florida.

The Party stated that there are currently no commercial fumigation/applicators for small-scale growers in Georgia and Florida, so growers must perform these applications 

themselves. 

MBTOC review and assessment

MBTOC noted that the information provided was insufficient to determine whether the request for critical uses of methyl bromide complied fully with Decision IX/6 and other 
October 2011 TEAP Report on 2011 CUNs: Final Report 33

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20117

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2012 

(addtl or 

new)

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for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

relevant criteria, as:

 The Party only provided financial information on the cost of converting the 3-Way system and not other chemical alternatives such as DMDS, MS, DMDS and PIC, 

DMDS and MS, PIC/ MS which are registered and available;

 The Party provided financial information relevant to tomato production in Georgia but not for pepper production in Georgia and Florida;

 The Party reported the results of a survey of the impact (as measured by any yield loss, cost increase or longer plant back interval) of using alternatives to methyl 

bromide on pepper producers in Florida of -9% (US pers comm to MBTOC 14 July 2011, Table 7p7), which is within MBTOC’s financial feasibility range for 

alternatives. MBTOC considers “...alternatives leading to decreases in gross margins of around 15 to 20 per cent or more as not financially feasible” (MBTOC 2010 

Assessment).

In the circumstances of this nomination, and in light of the decision of the Party to not consume methyl bromide for critical uses after 2013 for the production of peppers, the 

lack of some information did not prevent MBTOC from making a recommendation on this nomination.

MBTOC Comments on economics 2011:

The CUN is based on economic and other arguments (see MBTOC review and assessment above).

Comments requested in Decision XXI/11 (para 9)

 Dec. IX/6 b(i) Emission Reduction: There was no information in the nomination about the use of VIF or equivalent film. However, a dosage rate of 150 kg/ha MB 

proposed in the nomination was consistent with the use of barrier films for nutsedge. The amount proposed for use in 2013 was 80% less than the amount 

approved by the Parties for use in 2012.

 Dec. IX/6 b(ii) Research Program: This research is on going. However, specific studies known to MBTOC that have been conducted or are in progress were not 

cited in the nomination.

 Dec. IX/6 b(iii) Appropriate Efforts: The Party demonstrated that an appropriate effort has been made to evaluate and commercialise alternatives and substitutes 

such as the 3-Way system and methyl iodide.
34 October 2011 MBTOC Report on 2011 CUNs: Final Report

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for 

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rec. for 

2012 (addtl 

or new)

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2013 (new)

United 

States 

Strawberry 

(field)

2052.846 1730.828 1476.019 1349.575 1269.32 1007.47

7

812.709 678.004 - 531.737 - 461.186

MBTOC recommendation for 2013:

MBTOC recommends a reduced amount of 461.186 tonnes for strawberry fruit in California for 2013. After reconsideration of further information from the Party, alternatives 

(1,3-D/Pic and Pic alone with or without barrier films), not restricted by regulations, are considered available to replace MB for specific uses, including Macrophomina and 

Fusarium in specific counties. MBTOC could not support an increase of its interim recommendation.

Nomination by the Party

The Party nominated 531.737 t on 3128 ha at a dosage rate of 170 kg/ha. The Party made a 21% reduction for uptake of methyl iodide on the amount approved at the MOP 

in 2012,

Review process after OEWG

At the 2011 OEWG, the interim MBTOC recommendation included an amount of 461.186 t that had been agreed by all MBTOC members. It was suggested by TEAP that 

MBTOC seek additional information from the Party to substantiate the additional 70.551 tonnes not able to use alternatives (1,3-D and Pic and their combinations). After the 

2011 OEWG and at the request of the Party, MBTOC submitted to the Party the database with historical data on MB use and that of alternatives in the key strawberry 

growing regions of California. 

At the OEWG, MBTOC also requested the Party to provide further substantiation of the area not able to use alternatives, particularly in Ventura county where the MBTOC 

data did not correspond with those of the Party. In response, the Party identified that this was due to under-estimation of the reported MB use acreage (20 - 40% for MB use 

in Ventura, above the California PUR data) and to an increase in pressure due to diseases caused by Macrophomina and Fusarium, which according to the Party are not 

being controlled effectively with the available alternatives. Subsequently in response to 3 rounds of further questions from MBTOC, the Party provided further information by 

email and during a bilateral discussion via teleconference during MBTOC’s second meeting in Holland. This information indicated that alternatives, which are not affected by 

regulations, were not effective on diseases caused by Macrophomina and Fusarium.

MBTOC Assessment

In subsequent review at its second meeting in The Netherlands, MBTOC concluded that it had already accounted for under reporting in its previous recommendations (CUE 

2012 and interim recommendation for 2013) where it had increased the area needing MB by 13% above data reported in PUR. This was consistent with the calculated level 

of under reporting of fumigant use in the PUR database for all strawberry fruit growing counties in California. 

On the issue of diseases, MBTOC consulted further with the Party during the MBTOC meeting and concluded that 1,3-D/Pic and Pic may still be adopted further for some of 

the discrepancy in the area as the Party stated township caps were not maximised. Control of Macrophomina and Fusarium at the permitted dose rates for Pic has been 

shown to be adequate (http://ceventura.ucdavis.edu/Com_Ag/comveg/Strawberry/Diseases_741/
October 2011 TEAP Report on 2011 CUNs: Final Report 35

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20117

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2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

http://ceventura.ucdavis.edu/Com_Ag/comveg/Strawberry/Recent_Meetings/Fumigants_4_11/?i=1, Koike, 2009, Koike et al, 2011a; Koike et al, 2011b; Koike et al, 2011c).

In view of this, MBTOC cannot recommend additional MB for the part of the nomination related to Ventura. MBTOC considers the Party has not adequately described what 

chemical control efforts are being taken to address the Macrophomina and Fusarium issues. MBTOC will consider further information to substantiate any under reporting by 

growers in California that could be provided if the Party wishes to submit a supplementary nomination.

It was the view of one MBTOC member present at MBTOC’s second meeting that the Party had supported its nomination sufficiently, by correcting the number of hectares 

which had been mis-categorised and by substantiating the need for MB on area affected by Macrophomina and Fusarium, or which cannot use Pic due to regulatory 

constraints. Therefore this member held a different viewpoint. 

MBTOC Details of Assessment

In California, the three major strawberry producing districts for which MB is nominated are Oxnard, Watsonville/Salinas and Santa Maria, which report in 2011 strawberry fruit 

production areas of, respectively, almost 4526 ha, 5882 ha and 4121 ha (CSC survey). The most recent PUR data (2003-2009) show that alternatives, namely 1,3-D, Pic and 

metham have been widely adopted in two of these production districts (i.e. excellent and sustained transition has occurred in Oxnard, some transition has occurred in 

Watsonville/Salinas and Santa Maria). State-wide in California, the MB use area has dropped to 5471 ha in 2009, down from 8806 ha in 2003. In California,1,3-D use has 

more than doubled from 2,001 ha (2003) to 4,184 ha (2009), and Pic straight use from 1021 ha (2003) to 1705 ha (2009). In addition, the organic production acreage grew 

from 245 ha (2003) to 719 ha (2009). 

MBTOC considers that alternatives are available and effective, but understands that regulatory restrictions affect the use. Alternatives are implemented in areas with 

township caps in Ventura county. In this county, the production season is significantly shorter than that of Monterey county. In Monterey, drip application of 1,3-D and Pic, an 

alternative adopted in southern counties, results in incomplete protection against soil-borne diseases over the long production season due to unevenness of fumigant 

movement during application. MBTOC reiterates its 2010 suggestion that shank injection of 1,3-D/Pic by strip or broadcast application would result in improved disease 

control, but that township cap regulations impose a penalty on shank injection. MBTOC continues to urge the Party to reconsider the evidence that led to this regulation. The 

registration process of MI/Pic in California was completed successfully in December 2010, however MI/Pic use is restricted by buffer zones and dosage rate restrictions.

Regulations in California allow the use of barrier films with alternatives but prohibit the use of VIF films with MB application, and therefore discourage reduction of MB dose 

rates as well as emission control through use of VIF. PUR use data for 2009 indicate that MB:Pic 57:43 formulations are used on 73% of the MB fumigated acreage, and that 

50:50 formulations are used on 5% of the California use area. The Party has adopted a dose rate of 170 kg MB/ha in its CUN for 2013 which meets the standard 

presumptions. MBTOC encourages wider use of 50:50 formulations, which still allow for complying with regulatory restrictions on Pic use.

MBTOC and the Party calculations of the critical area needing MB were similar for all strawberry fruit growing counties in California, except for Ventura, and this was the key 

difference in the amounts under consideration. Strip application of alternative fumigants in combination with varietal tolerance is as effective as MB for control of 

Macrophomina and Fusarium (Koike, 2009; Koike et al, 2011a; Koike et al, 2011b; Koike et al, 2011c). 

MBTOC notes and commends the withdrawal of MB for this use in Florida and Eastern USA, where full transition to alternatives has been completed.
36 October 2011 MBTOC Report on 2011 CUNs: Final Report

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2013 (new)

MBTOC continues to urge the Party to develop an action plan for California, particularly addressing the restrictions on the use of alternatives adopted elsewhere in the USA, 

and showing stepwise reductions to effectively progress the transition to MB alternatives. 

MBTOC comments on economics 2011:

CUN includes a partial budget for the use of iodomethane by California strawberry producers, in addition to Pic+MB and 1,3D+Pic as in the previous year. CUN shows that 

the gross margin (termed net revenue in the CUN) declines from $688 per hectare using methyl bromide to a loss of $3889 per hectare using iodomethane and $8042 using 

1,3D+Pic, the latter two as a result of a yield loss 14% respectively. MBTOC cannot verify the accuracy of the data, but notes that UC Davis estimates the return to 

strawberry production in California as $6,700 per acre, or more than $16,500 per hectare (http://coststudies.ucdavis.edu/current.php).

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: In California VIF is not used with MB but is available for use with alternatives;

 Dec. IX/6 b(iii) Research program: Yes, there is an on going research program, but specific data justifying CUN requests need to be provided.

 Dec. IX/6 b(iii) Appropriate efforts: In California there is varying effort in the different production districts.
October 2011 TEAP Report on 2011 CUNs: Final Report 37

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2012 

(addtl or 

new)

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for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

United 

States 

Strawberry 

runners 

54.988 56.291 4.483 8.838 7.944 4.690+

2.018

6.036 3.752 - 3.752 - 3.752

MBTOC recommendation for 2013:

MBTOC recommends 3.752 tonnes for this use in 2013, This CUE recommendation is based on an area of approximately 19 ha at a rate of 20 g/m2in California. 

The Party stated that the amount applied for is lower than those required by the nematode certification program which specifies rates of 22.4 to 33.6 g/m2 MB used on sandy 

and clay loam soils according to the of California Dept of Agriculture Nursery Inspection Procedures Manual No. 7. Studies in other nursery industries have shown that MI in 

combination with Pic and metham has given equivalent effectiveness for nematodes at rates of 336 kg/ha. Methyl iodide has been approved for nursery certification 

purposes, but the present rates required for certification (26 g/m2) are greater than those presently registered in California (10 g/m2). A major proportion (99%) of the 

hectares are exempted under QPS. The key pests previously stated as affecting strawberry runners are weeds (purple and yellow nutsedge), fungi (Rhizoctonia and Pythium 

spp in SE, Phytophthora, Verticillium in California), nematodes (root-knot, sting in CA). Alternatives evaluated in research trials over the past several years showed that 1,3-

D/chloropicrin, 1,3-D/chloropicrin + metham-sodium, 1,3-D and metham-sodium, and dazomet as a follow-up application to 1,3-D/chloropicrin or chloropicrin (Fennimore et 

al., 2008b) were very effective. These formulations have been shown to give similar pathogen control in soils and will meet requirements of certification (Kabir et al., 2005; 

Fennimore et al. 2007, 2008; MBAO). However, regulations in California on the use of 1,3-D and chloropicrin restrict key alternatives used in some locations. 

MBTOC acknowledges that trials are now underway to evaluate efficacy of the lower registered rates for certified nursery use and approval and expect future nominations to 

update on trials with these products. Transition rates to MI have not been considered by the Party for this CUE. The CUN does not specify regions for use. MBTOC requests 

that a full review of trials with feasible alternatives (especially MI/Pic) be provided with future nominations as required under Decision IX/6.

MBTOC comments on economics 2011:

The same economic information is provided as in the previous year. CUN is not based on economic arguments

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission control: Yes in Florida and Eastern states, with use of VIF; No in California where VIF is not used; Rates conform to standard 

 Dec. IX/6 b(iii) Research program: Yes, on going research is being conducted showing that MI/Pic especially is effective, but it is not yet registered at rates 

suitable for certification in California.

 Dec. IX/6 b(iii) Appropriate effort: No, trials have not been provided showing use of MI/Pic at lower rates. MI has qualified for certification use by CFDA, however it 

is not yet registered at suitable rates.
38 October 2011 MBTOC Report on 2011 CUNs: Final Report

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new)

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for 

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rec. for 

2012 (addtl 

or new)

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2013 (new)

United 

States 

Tomatoes 

(field)

2876.046 2476.365 2065.246 1406.484 1003.876 737.584 292.751 54.423 - 10.741

revised 

to 9.107

- 9.107

MBTOC recommendation for 2013:

MBTOC recommends 9.107 tonnes of MB which was the nomination adjusted by the Party in July 2011. This was for small-scale (less than 4ha) tomato production in 

Georgia (0.776 t) and Florida (8.331 t) in 2013. MBTOC noted that the amount (1.634 t) reduced by the Party was a 15.6% reduction from than the interim amount 

recommended by MBTOC (TEAP May 2011) and the nomination submitted in January 2011 for 2013. This quantity (9.107 t) was also 83% less than the quantity (54.423 t) 

of methyl bromide approved by the Parties in 2012.

Nomination by the Party

The Party informed MBTOC that the nomination is for one final year. The critical uses of methyl bromide allows time for some small-scale tomato growers in Georgia and 

Florida to transition to available alternatives, with the remaining US tomato producers transitioning to alternatives in 2012 or previously. 

In its July 2011 response to questions from MBTOC, the Party informed MBTOC that it had withdrawn its previous 2013 nominations for the critical uses of methyl bromide in 

Maryland (0.015 t) and Delaware (0.129t) and in the South East US (1.633 t, Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, 

Tennessee and Virginia), leaving the critical use of methyl bromide for the production of tomatoes by producers with less than 4ha only in Georgia and Florida. The target 

pests were reported to be mainly nutsedge, nematodes and Fusarium wilt. The Party stated a rate of 150 kg MB/ha would be used for both pathogens and nutsedge control. 

This rate conforms to MBTOC’s standard presumptions for application of MB under VIF for the control of nutsedge (150 kg/ha) and pathogens (125 kg/ha).

Circumstances of the nomination

The Party reported that farmers needed a period of time to transition to available alternatives. These small-scale growers do not have as much experience with the 

alternatives and need to convert their equipment to utilize the 3-Way method (US pers comm to MBTOC 14 July 2011) (1, 3-dichloropropene plus chloropicrin plus metham 

sodium). The nomination was therefore based on financial considerations and time for the adoption of alternatives.

The Party stated that “Decision IX/6(1)(a) is applicable because the US has determined that the specific use detailed in this CUN is critical because the lack of availability of 

methyl bromide for this use would result in a significant market disruption”. The Party reported that it had reduced nominations for the critical uses of methyl bromide for 

fruiting vegetables by 99% over the past nine years. However, MBTOC was uncertain that the unavailability of this relatively small amount methyl bromide for vegetable 

production could result in a significant market disruption. 

The Party supported the nomination on the basis of the need for a period of time for the adoption of alternatives by small-scale growers, as required in paragraphs 35 and 36 

of Annex 1 to the Sixteenth Meeting of the Parties, by providing financial information for small-scale tomato growers in Georgia. MBTOC accepted that this was equivalent 

because of similar production systems for tomatoes in Georgia and Florida.

The Party stated that there are currently no commercial fumigation/applicators for small-scale growers in Georgia and Florida, so growers must perform these applications 

themselves. 
October 2011 TEAP Report on 2011 CUNs: Final Report 39

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2012 

(addtl or 

new)

CUN 

for 

2013

MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

MBTOC review and assessment

MBTOC noted that the information provided was insufficient to determine whether the request for critical uses of methyl bromide complied fully with Decision IX/6 and other 

relevant criteria, as:

 The Party only provided financial information on the cost of converting the 3-Way system and not other chemical alternatives such as DMDS, MS, DMDS and PIC, 

DMDS and MS, PIC/ MS which are registered and available;

 The Party provided financial information relevant to tomato production in Georgia and not for tomato production in Florida;

 The Party reported the results of a survey of the impact (as measured by any yield loss, cost increase or longer plant back interval) of using alternatives to methyl 

bromide on tomato producers in Florida of -8% (US pers comm to MBTOC 14 July 2011, Table 7p7), which is within MBTOC’s financial feasibility range for 

alternatives. MBTOC considers “...alternatives leading to decreases in gross margins of around 15 to 20 per cent or more as not financially feasible” (MBTOC 2010 

Assessment).

In the circumstances of this nomination, and in light of the decision of the Party to not consume methyl bromide for critical uses after 2013 for the production of tomatoes, the 

lack of some information did not prevent MBTOC from making a recommendation on this nomination.

MBTOC Comments on economics 2011:

The CUN is based on economic and other arguments (see MBTOC review and assessment above).

Comments requested in Dec. XXI/11 (para 9)

 Dec. IX/6 b(i) Emission reduction: There was no information in the nomination about the use of VIF or equivalent film. However, a dosage rate of 150 kg/ha MB 

proposed in the nomination was consistent with the use of barrier films for nutsedge. The amount proposed for use in 2013 was 93% less than the amount 

approved by the Parties for use in 2012.

 Dec. IX/6 b(iii) Research program: The Party demonstrated that a research program was in place several years ago.

Dec. IX/6 b(iii) Appropriate effort: The Party demonstrated that an appropriate effort has been made to evaluate and commercialise alternatives and substitutes.

Country Industry CUE for 

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(addtl or 

new)

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for 

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MBTOC 

rec. for 

2012 (addtl 

or new)

MBTOC rec. for 

2013 (new)

United 

States 

Research

(Both Soils & 

Commodities)

7.445 7.537 Withdrawn Withdrawn

MBTOC recommendation for 2013:

The nomination was withdrawn in full by the Party

1

1ExMOP and 16MOP; 216MOP+2ExMOP+17MOP; 3MOP17+MOP18; 4MOP18+MOP19; 5MOP19+MOP20; 6MOP20+MOP21; 7MOP21+MOP22; 8MOP22
40 October 2011 MBTOC Report on 2011 CUNs: Final Report

4 Final CUN Report – Issues specific to MBTOC-Structures and 

Commodities

At the Open Ended Working Group in Montreal, in August 2011, MBTOC (SC) held bilateral 

meetings with Canada and the United States. The purpose was to discuss Parties‟ views 

concerning MBTOC SC‟s interim CUN recommendations, receive and provide additional 

information and discuss outstanding technical and economic questions. In the May TEAP 

report, MBTOC SC had been unable to assess one CUN for cured pork pending the receipt of 

research results. Additionally, MBTOC SC had been unable to assess some postharvest aspects 

of the US research CUN pending receipt of additional information. MBTOC SC indicated that it

would conduct re-reviews of CUN decisions if Parties requested and provided additional 

information. 

At the OEWG meeting and subsequent to it, the US indicated its request that MBTOC SC rereview its cured pork CUN, and provided new information about the timing of expected 

research. Later, additional information was sent to clarify the intended research for which the 

US was requesting MB. As a result, MBTOC SC was originally asked to re-review applications 

for the critical uses of MB for: US cured pork for 2013, US cured pork research for 2013, US 

research on postharvest emission control methods for 2012 and 2013; and US research on 

alternatives to QPS MB use for 2012 and 2013. 

4.1. New process used by MBTOC SC to conduct CUN re-reviews

Following direction from TEAP advising that improvements in MBTOC processes were 

indicated, MBTOC Co-Chairs polled all MBTOC members in August asking them to indicate 

which CUNs they wanted to review, and reminding members that with that request comes the 

responsibility to review and be involved in much discussion and work as part of the review. As 

a result, one additional MBTOC QPS members also indicated an intention to be involved with 

the review of postharvest CUNs. (In addition to the four MBTOC QPS members also already 

involved in MBTOC SC.) 

In its October 2010 TEAP report MBTOC SC indicated funding difficulties with members and 

because of that said MBTOC SC would hold only one meeting in 2011. This comment was 

repeated in the May 2011 TEAP report. As most MBTOC SC members continue to be 

inadequately funded for MBTOC travel, and knowing that a second meeting had not been 

planned in 2011, MBTOC SC agreed to conduct the re-reviews by email. 

Accordingly, in August, after review and discussion amongst MBTOC members, the following 

process and timelines were agreed:

1. Prepare a situation analysis of the CUN re-reviews required in autumn 2011 (Aug 24).

2. Members to volunteer as CUN Review Team Leaders for each CUN. That person will 

update the B form if required with the new information from the Party. 

3. Prepare a list of CUN documents available and send to members. This will include the 

CUN, B forms, situation analysis, correspondence to and from MBTOC, pertinent etc. 

Any member may contribute pertinent documents. (Aug 28)

4. Send the documents to any member who wishes to receive them. (Aug 29)

5. Ask members to send comments and propose recommendations on the CUNs. 

Consideration should be confined to technical and economic matters and should not 

stray into policy matters outside the direct instructions of TEAP and the Parties. All 

emails will be copied to all MBTOC members who have indicated they want to be 

involved in the SC CUNs. (begins Aug 29 – ends Sept 13) 
October 2011 TEAP Report on 2011 CUNs: Final Report 41

6. Ask Review Team leader to propose the recommendation and the text box. (by 

September 19)

7. Circulate to all members and ask for sign off (Sept 20). 

8. All members have to indicate in writing if they agree or not or if they propose changes 

to the text box. (Members were notified that if they did not respond in writing, the CoChair may call them at home.) Consensus will be defined as agreement or agreement to 

not block consensus. (by Sept 30)

9. In the instance of significant agreement but non-consensing members, MBTOC SC CoChair will attempt to obtain a compromise and/or will invite the member to prepare a 

minority report. (By Oct 5)

Following MBTOC SC‟s agreement to this process and timelines, the process was sent to the 

Ozone Secretariat and the USG since it was only their CUNs, which were being re-reviewed. 

USG agreed it was a reasonable and transparent process.

Two MBTOC members volunteered as review team leaders, documents from the Party were 

distributed, and situation analyses were prepared and sent out on time. Discussion amongst 

members was extensive and detailed. Draft recommendations and text boxes were then 

prepared and circulated to MBTOC SC on August 17. During the review period three members 

suggested text improvements which were agreed to by the other members and the pertinent 

review team leader. 

When the text boxes were circulated, members were asked to indicate, in writing, whether they 

would agree, disagree or agree not to withhold consensus. By August 29, 13 of 15 members had 

indicated their agreement with the all the text boxes. Two members had not responded as of that 

time, but were still within allocated deadlines.

Then, on September 29 and within the time period for comment, one member made numerous 

comments, suggested changes and asked a question. On this date, another member asked a 

similar question which required an official regulatory interpretation from the US. A letter was 

sent to the US with the question. 

On October 3, some changes to the text boxes were incorporated. With the exception of the text 

box awaiting the regulatory response from the US, the text boxes were circulated again, asking 

members to indicate whether they agreed, did not agree or agreed not to withhold consensus. 

Members started to respond. One MBTOC SC member, who had originally indicated his 

intention to review the CUNs, wrote at this time to say that because of a recent diagnosis of 

illness and the resulting need for treatment he would not be able review the CUNs after all.

Consequently, he was not counted. 

On October 5th the US government informed MBTOC that it now withdrew all its research 

CUN nominations.

Subsequently, MBTOC SC circulated the one remaining re-reviewed CUN and asked members 

to indicate whether they agreed, did not agree or agreed to withhold consensus. By October 7, 

14 of 15 members had again sent written agreement to the text box. One member did not agree 

and indicated he would withhold consensus. That member was asked to draft a minority report. 

4.1.1. Resourcing issues in 2011 and in coming years

Under Decision XV I/4 Annex 1, MBTOC was instructed to meet twice a year when making

CUN recommendations to ensure it has full information and to allow Parties seeking CUEs to 

provide information after MBTOCs first review. At the time of that Decision, twice annual 

meetings were considered necessary to allow MBTOC to conduct re-reviews or to complete 
42 October 2011 MBTOC Report on 2011 CUNs: Final Report

reviews of CUNs. Parties can request a re-review if they disagree with MBTOC‟s first-review 

recommendations, and by providing additional information supporting their CUN. 

However, when MBTOC has not been preparing an Assessment report and when Parties rereviews have been few, MBTOC has occasionally met only once per year. Aside from those 

factors, the ability of MBTOC to meet is limited by the on-going lack of availability of funds 

for members‟ travel and subsistence. MBTOC SC met only once in 2011, and instead 

conducted its re-review by email. This was necessitated because of lack of funding by members, 

but also because just a few CUNs required re-review. 

MBTOC draws the attention of the Parties to that the requirement that MBTOC meet twice a 

year in Decision XVI/4 Annex 16, may require further clarification in light of the reductions of 

CUNs, lack of funding of members, and that now, seven years after MOP 16, meetings can take 

place electronically. 

In recent years, the number of CUNs has been reducing steadily, but it is unclear if this trend 

will continue if A 5 Parties begin to submit CUNs in 2013. Another unknown factor that will 

affect resourcing is that initial CUN submissions take more time to review; Parties in their 

initial submissions, have difficulty understanding the information requirements for critical use 

nominations and necessary information may not be available. MBTOC may be unfamiliar with 

the specific circumstances of the CUN. 

If several new CUNs are submitted, and if there are difficulties understanding requirements and 

sourcing information, MBTOC will require two meetings a year. Furthermore, more MBTOC 

members will need funding to attend the OEWG meeting for discussions with Parties that seek 

any clarification on the interim recommendation by MBTOC. 

If, on the other hand, few CUNs are submitted, MBTOC may only need to meet once per year 

or conduct their reviews entirely by email. It may also happen that very few CUNs are 

submitted in 2012, with an increase in 2013 and 2014 if A 5 Parties start to submit CUNs. 

Parties may need to change resourcing for MBTOC and its members during this upcoming time 

period. 

4.2. Details of evaluations

In January of 2011, Parties submitted six CUNs for the use of MB in structures and 

commodities in 2011. In addition, three aspects of the US research CUN pertained to 

postharvest uses of MB; one for cured pork, one for emissions control research and one on 

alternatives to QPS treatments. Each of the research CUNs were requested for both 2012 and 

2013. 

In the May TEAP report, MBTOC SC evaluated the six CUNs, giving recommendations for 

five of the CUNs and recommending one part of the US research CUN. Specifically, in May, 

MBTOC was unable to assess the 2013 cured pork CUN because commercial scale trials with 

phosphine were being conducted and MBTOC thought the research results might be available in 

the summer. However, the US informed MBTOC that data collection would continue until late 

in 2010, and MBTOC found this to be consistent with its understanding and prior investigation 

of the long processing and storage required of this processed meat. Additionally, in May, 

although MBTOC was able to recommend the 2012 cured pork research CUN, it was unable to 

assess the remaining postharvest aspects of the US research CUN because further information 

from the US was pending. 
October 2011 TEAP Report on 2011 CUNs: Final Report 43

However, in October 2011, the US informed MBTOC that it was withdrawing its entire US 

research CUN (pre-plant and post-harvest aspects), including the cured pork research aspect 

recommended in May. 

The final total MB volume nominated in 2011 for post-harvest uses, (and excluding the US 

research CUN which was withdrawn by USG), was 43.425 tonnes. Of nominations in 2011 for 

2013, MBTOC recommended 43.425 tonnes (Table 4-1) 

Table 4-2 provides the MBTOC-SC interim recommendations for the CUNs submitted.

4.3. Minority report USA nomination for the critical use of MB for cured pork

Signed by Tom Batchelor. 

The US submitted a nomination for 3.730 tonnes of methyl bromide for critical uses in cured 

pork facilities in 2013. Methyl bromide is used in this sector to control pests such as beetles 

and mites “... that infest and feed on meat, especially deep inside the meat along the bone, as it 

cures and ages. Food commodities that exceed the US Food and Drug Administration’s 

maximum limits for live or dead insects or insect parts that may be present in stored food 

products are considered adulterated and unfit for human consumption.”

3

 

Availability of alternatives

The Party reported in its 2006 nomination that of more than 1,650 pork production facilities in 

the United States approximately 850 of them required the use of methyl bromide to fumigate 

dry cured pork products4. The Party reported in its 2007 nomination that 45 facilities required 

the use of methyl bromide, which is about 5% (45/850) of the facilities that previously required 

this fumigant. The reduction in use was attributed by the Party to modifications to the curing 

facilities and their surroundings5, sanitation improvements and IPM measures6. In the 2011 the 

Party stated that the cured pork sector “... has no known chemical alternative available to 

eliminate the use of methyl bromide” and as a result “the need for fumigation has not been 

eliminated”

7

. 

The Party did not provide information in 2011 on the infeasibility of the implementation of nonchemical alternatives in about 5% of the cured pork facilities over the past 4 years. A chemical 

alternative, while potentially useful, is therefore not necessary to replace methyl bromide as 

non-chemical alternatives have replaced its use in about 95% of the facilities. 

The Party did not provide information in 2011 to demonstrate that there are no technically and 

feasible alternatives or substitutes available to the user that are acceptable from the standpoint 

of environment and health and that are suitable to the circumstances of the nomination, as 

required by paragraph 1(a) of Decision IX/6.

Minimisation of use and emissions of methyl bromide 

The dosage of methyl bromide proposed by the Party for use in cured pork facilities in 2013 of 

20 gm-3 was much higher than minimum dosages of 11-13 gm-3that were provided in previous 

nominations8. In addition, the Party did not provide sufficient information on gas tightness of 

cured pork facilities in 2011 or earlier nominations. When considering the use of potential 

 

3

ExI/4(3): The US National Management Strategy (2009). Page 13 

4

2006 Nomination, page 9

5

2008 Nomination, page 9

6

2008 Nomination page 7; 2011 nomination page 4

7

2011 Nomination, page 4

8

2006 nomination
44 October 2011 MBTOC Report on 2011 CUNs: Final Report

alternatives in existing facilities, the Party stated that “...structures are not air tight” (which 

would also apply to the use of methyl bromide) and that “several companies have modified their 

buildings to make them more gas-tight”. 

The Party did not demonstrate that all technically and economically feasible steps have been 

taken to minimise the use (dosage) and emissions (gas tightness) of critical uses of methyl 

bromide, as required by paragraph 1(b) of Decision IX/6.

Deployment of alternatives and substitutes 

The Party reported in 2011 that the 3-year research programme on alternatives to methyl 

bromide was due to end in 2010, but it had been extended at no additional cost by one year to 

2011 mainly because of the need to undertake further trials on phosphine. In addition, research 

on “the effectiveness of using phosphine in dry cured ham facilities is planned for the future (if 

funding is obtained)”. The Party reported uncertainty with further funding after 2011, and 

therefore did not demonstrate that a research programme is in place to deploy alternatives and 

substitutes, as required by paragraph 1(b) of Decision IX/6.

Treatment of products with methyl bromide that contain fat

The US reported that cured pork is fumigated one to five times per year depending on pest 

pressure in the cured pork facility9. 

In general methyl bromide is readily absorbed by lipid materials and care should be taken to 

avoid contamination of high fat content foods such as butter, cheese, margarine and meat10. 

The US does not recommend methyl bromide fumigation of products containing butter, lard or 

fats11. Residual methyl bromide normally desorbs relatively quickly from non-fat products, but 

it is not readily desorbed from fat products. Previous research showed that methyl bromide can 

be detected up to 3 months after fumigation in refrigerated storage12. Methyl bromide is an 

alkylating and mutagenic agent. India has banned the use of methyl bromide on butter, lard or 

fats13. 

The use of methyl bromide should not be recommended by MBTOC and TEAP for use on 

cured pork which is a product that contains fat. 

Categorisation as “Unable to Assess”

The 2011 nomination by the US for the critical use of methyl bromide for cured pork in 2013 

was categorised as “Unable to Assess” when initially assessed in 2011 by MBTOC (TEAP May 

2011).

TEAP is requested to retain the categorisation of “Unable to Assess” as insufficient information 

was provided in 2011 to make a final assessment14. Where information was provided, the 

nomination did not “... adhere with each criterion set out in Decision IX/6(1)(a)(ii) and (b)(i) 

and (b)(iii) and other relevant decisions of the Parties, as required by Dec XXI/11(9). Methyl 

bromide requested for this purpose should therefore not be considered as „critical‟ as it does not 

 

9

2007 Nomination, page 18

10 Bond. 1984. Manual of fumigation for insect control. FAO Plant Production and Protection Paper No 54. FAO Website.

11 US. 2010. USDA-PPQ-Treatment Manual. 2-9 Chemical Treatment--Fumigants--Methyl Bromide--Closed-door Container 

Fumigation 

12 Rhodes et al. 1975. Exposure of meat to methyl bromide during refrigerated-store pest control; residues in beef and lamb 

and effect on quality. J. Food Sci. of Food and Agric., 26(9): 1375-1380.

13 Government of India. 2005. Quarantine treatment and application procedures: I. Methyl bromide fumigation. NSPM 11. 

Fumigation Forbidden commodities. Pp18-19.

14 Annex to Decision XVI/4 (Annex 1 of the Report of MOP16)
October 2011 TEAP Report on 2011 CUNs: Final Report 45

comply with the criteria that have been defined by the Parties for the „critical uses of methyl 

bromide‟. 

Table 4-1. Summary of the final recommendations by MBTOC-SC (in square brackets) for 

CUE’s for postharvest uses of MB (tonnes) for 2013 submitted in the 2011 round.

Country and Sector MBTOC Recommendation 

(tonnes)

Australia. Packaged rice [2.374]

Canada. Mills [7.848]

Japan. Fresh chestnuts [3.317]

USA

1. Commodities

2. Mills and food processing structures

3. Cured pork

[0.822]

[25.334]

[3.730]

Total [43.425]
46 October 2011 MBTOC Report on 2011 CUNs: Final Report

Table 4-2. Final evaluations of CUNs for structures and commodities submitted in 2011 for 2013

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

Australia Rice 6.150 6.150 .205 9.200 7.820 6.650 4.87 3.653 - 2.374 - 2.374

MBTOC comments 2011:

MBTOC recommends 2.374 tonnes of MB, the amount nominated by the Party, for use on packaged rice in 2013. This represents an approximate 35% 

decrease over the amount of MB granted by the Parties for this use in 2012. MBTOC had until that point noted that the Australian rice applicant had not 

adopted alternatives in spite of the availability and use of technically effective alternatives in Australia and worldwide. MBTOC notes, however, that the 

treatment of packaged rice with sulfuryl fluoride, one of the alternatives in use elsewhere, is not registered in Australia. 

The Party indicates that the applicant is pursuing the adoption of phosphine. In mid-2010, Australia submitted a new CUN and phase out plan nominating a 

25% reduction for its 2010 submission and also for each following year with the result that in 2015, there would be no further MB CUN nomination. The Party 

indicated that regardless of the volumes of rice harvested or the continuation of drought, this phase out plan would be required of its rice applicant. MBTOC 

continues to note that it does not seem that the applicant has adopted alternatives, but with the recent improvement of water availability in the growing region, 

rice harvests for 2011 are expected to improve significantly and that therefore it seems likely that alternatives will be adopted. 

The Party has noted some difficulties in achieving the level of technical efficacy required by its applicant; MBTOC has volunteered to assist by providing a 

summary of research of efficacy of sulfuryl fluoride for the pest species of concern. MBTOC’s summary of pertinent research of interest to Australia and any 

Party with similar concern can be found in the MBTOC/TEAP Progress Report of May 2011. 

Emission Reduction: Yes. The applicant now sends the majority of its MB-fumigated rice through MB recapture equipment. 

Research Program: Trials with sulfuryl fluoride are ongoing; the applicant says further work is needed to see if results can be improved. MBTOC notes, 

however, that there is already extensive research available on the efficacy of SF against the pests of concern and has provided a summary in the Progress 

Report. A research project in 2009 was interrupted due to the unfortunate death of the scientist in charge. 

Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol nominations has control 

over pesticide registration. This applicant has not made appropriate efforts to adopt alternatives, since no alternatives have been adopted in spite of registration 

of technically effective and affordable alternatives being available. MBTOC agrees with the Party that its new phase out plan will likely result in the applicant 

adopting alternatives soon as harvest quantities are expected to increase and MB availability has decreased.

MBTOC comments on economics 2011:

Applicant argues that phosphine fumigation, following milling but before packaging, is the best technical and economical alternative, and is therefore gearing up 

to transition to phosphine.
October 2011 TEAP Report on 2011 CUNs: Final Report 47

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

Canada Mills 47 

(included 

mills and 

pasta)

34.774 30.167 28.650 26.913 22.878 14.107 11.020 - 7.848 - 7.848

MBTOC comments 2011:

MBTOC recommends 7.848 tonnes, the amount nominated by the Party for use in mills in 2013. This is an approximate 29% decrease over the amount 

granted by the Parties for 2012. The Party advises that mills that are producers of durum semolina or have integrated/contiguous bakery mix plants and those 

that are particularly large structures are the remaining methyl bromide users. The CUN states that the amount requested is only sufficient for a single treatment 

of 7-8 of the 17-18 mills in the application, so most mills would not be fumigated in 2013. As per Canadian regulation, mills which are listed in the CUN may, if 

necessary, share some of the total CUN amount granted so that is why more mills are listed than will actually be fumigated. The 2011 CUN includes at least 

one less mill than in 2010, due to adoption to alternative treatments such as heat.

Evaluation of alternatives to methyl bromide in progress include: heat treatments; the just recently registered ECO2Fume formula (carbon dioxide and 

phosphine mixed in gas cylinders), sulfuryl fluoride (SF) (but only if there is no food contact); plus integrated pest management programs alone or in 

combination with heat treatments and fumigations with the aforementioned alternative fumigants. 

Current research is directed towards practical trials with heat and other IPM upgrades, and SF. The results of current trials on a principal alternative, SF, have 

indicated poorer than expected efficacy, probably because adequate temperatures are not being maintained and the vulnerability of concentration level 

maintenance in windy conditions. Additionally, SF, at the applied dose, has been found to be less effective for the eggs of red flour beetle than for confused 

flour beetle. This is significant because red flour beetle is the pest of most concern in Canadian mills yet confused flour beetle is the most commonly used 

species in trials. 

For all alternatives, the recent tightening of food safety regulations in Canada has increased the pressure to raise the already high efficacy levels of treatments 

to eliminate pests. Mills have to operate according to a “Required efficacy” standard which in Canada means no live insects, including eggs, in milled grain 

product fractions leaving the mill for customer destinations. There is intensifying regulatory pressure in North America to improve food safety by eliminating all 

human pathogens, contaminants and stored product pests from food ingredients and processed foods. 

The Party advised MBTOC that a number of mills are acquiring heat treatment equipment in 2010 and 2011 with the expectation to completely phase out MB 

use by 2012. Other mills are still having difficulty in achieving the required efficacy through use of alternatives. Until problems can be resolved commercial 

adoption of SF will be delayed, even if registration is eventually extended beyond empty structures. There is registration of SF for empty facilities but the 

widening of this registration originally expected in the summer of 2009 was not achieved as of March 2011. 

Heat treatments may also be somewhat less successful than conventional MB fumigations, particularly as the size of the structure increases. Some areas of 

each structure act as “heat sinks” that absorb large amounts of heat, rendering them difficult to heat to the temperature and for the duration required to kill all 

life stages of insect pests. Complete evaluation of the heating requirements for any single milling facility is a process of trial and error, unique to each site and 

one that takes time to complete. 
48 October 2011 MBTOC Report on 2011 CUNs: Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

The CUN summarizes that, treatment with SF or the heat and phosphine combination treatment (phosphine, heat and carbon dioxide) controlled insect 

populations in flour mills for over 18 weeks. In the nine treatments, only once did the next fumigation need to be scheduled earlier expected (Fields, 2007).

Emission control: The majority of mills are now not even fumigated annually, which reduces emissions.

On going research: – Excellent research multi-mill, multi-stakeholder research program in past with several full reports submitted to MBTOC (SF, heat and 

DE, SF and elevated temperature, phosphine + CO2, etc.). Research has not been reported in past two years; MBTOC is not convinced that further research in 

this field is absolutely necessary. When mills are not MB fumigated, they are being heat treated and all are now in enhanced IPM. 

Appropriate effort in the CUN: Full registration of SF has not been achieved; there is still no food tolerance for F residues from SF treatment of mills. This 

action has been delayed for several years and hinders ability to fully adopt SF as an alternative treatment. Neither the millers nor the Party can affect fumigant 

registration. In spite of delay in achieving full registration, the mills are continuing to make progress. 

MBTOC comments on economics 2011:

CUN states that the transition to heat treatment or enabling structural modifications such as replacement of wooden floors and exterior wall cladding and 

insulation to reduce insect harbourage, which require capital investment, is negatively affected by the economic downturn. However, the purpose of the phaseout is to permit a gradual economic adjustment in the absence of federal or provincial government financial assistance programs.
October 2011 TEAP Report on 2011 CUNs: Final Report 49

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

Japan Chestnuts 7.100 6.800 6.500 6.300 5.800 5.400 5.35 3.489 - 3.317 - 3.317

MBTOC comments 2011:

MBTOC recommends 3.317 tonnes of MB, the amount nominated by the Party for fresh chestnuts in 2013. This is a 5% reduction over the amount of MB 

granted by the Party for this use in 2012. 

As a result of its research program, Japan determined that methyl iodide (MI) would be an effective alternative to the use of MB in fresh chestnuts. It was 

registered in 2009 and an MRL for methyl iodide residues in food was later established (0.5ppm), which allowed for the use of MI. However, the registration did 

not result in the immediate commercial availability of the fumigant. The registrant of MI in Japan has a product stewardship program which requires more 

stringent and modern application methods for MI than are required for MB, which was an older process. The registrant had to first design filling and packaging 

systems to make the fumigant available for its different applications. The registrant then investigated current fumigation practises as a prerequisite to beginning 

training in the safe use of the fumigant according to multinational standards of fumigation practise. 

The additional stringency has resulted in the requirements for the building of better containment fumigation chambers, among other things. These more 

stringent requirements for the safe use of MI, plus the training requirement, have resulted in the need for more time to complete the adoption. The Party is still 

establishing technically effective methods to use MI in fumigation consistent with their requirements for 2 hour fumigation times required in periods of peak 

harvest. 

The CUN notes that Japan will have completely transitioned this use to MI by the end of 2014. The amount of MB requested by the Party is consistent with the 

phase out plan leading to zero use of methyl bromide in 2015. MBTOC asks if Japan has established an MRL for iodide. 

Emission reduction: To date regular reductions in MB use through logistical improvements. Consolidation of fumigation loads also reduces emissions.

Research program in past 12 months: Extensive research program has been completed, no further research needed other than to see if reduced dosage of 

MI can be achieved, and that is optional. There is established efficacy of MI for this purpose in Japan and it has been registered.

Appropriate effort:? Registration for methyl iodide proceeded as per normal and was registered after appropriate review. Now extensive effort is required to 

change logistics and treatment facilities to allow the safe use of methyl iodide as per multi-national fumigation standards.

MBTOC comments on economics 2011:

The nomination was not based on economic arguments.
50 October 2011 MBTOC Report on 2011 CUNs: Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

United 

States

Commodities 89.166 87.719 78.983 58.921 45.623 19.242 5.000 2.419 - 0.822 - 0.822

MBTOC comments 2011:

MBTOC recommends 0.822 tonnes, the amount nominated by the Party for MB treatment of dried fruit, walnuts and dates in 2013. This represents a 66% 

reduction over the amount granted by the Parties for use in 2012. The USG has nominated a very challenging decrease in MB use for this sector, which 

MBTOC supports. If it were to be provided, a phase out plan would inform MBTOC and Parties of the continued timing of its transition to alternatives. 

MBTOC notes that logistical improvements and investments may be needed which could lead to the adoption of cold storage for the post-drying processing of 

dried fruits which could assist this sector to phase out of MB entirely. We would expect that any further commodities CUN would not include dried plums since 

they should be protected from post-process re-infestation with treatments other than MB. 

Additionally, MBTOC notes that controlled atmosphere treatment would provide an effective non-chemical treatment for all the commodities in this CUN. Parties 

may find the section on controlled atmosphere treatment and associated tables found in the Structures and Commodities Chapter of the MBTOC Assessment 

Report to be helpful in understanding controlled atmosphere. Transition to controlled atmosphere might be additionally useful given the US Environmental 

Protection Agency regulation which proposes to phase out the use of SF for food contact. This is particularly significant given that the CUN, which was 

prepared before the announcement of the proposed regulation, reports that the sector is moving to SF. If the US government phases out the use of SF on 

foods, it may delay the transition to alternatives, since the use of SF has assisted this transition. 

Emissions reduction: This sector has very considerably reduced use of MB, and therefore emissions. Fumigation takes place in chambers or suitable 

enclosures.

Research effort: Research on dates is ongoing but focused on the use of sulfuryl fluoride. The US Environmental Protection Agency has proposed phasing out 

the use of SF for foods and so MBTOC does not know if this proposed regulation will affect research or adoption of alternatives. 

Appropriate effort: Several alternatives are already registered. Also controlled atmosphere could be used.

MBTOC comments on economics 2011:

Walnuts: The CUN provides a detailed financial analysis in the form of a partial budget of the cost of fumigating walnuts with methyl bromide, with sulfuryl 

fluoride, and with phosphine. SF results in an increase in gross margin because the price per unit is lower, even though the dosages applied are higher. 

Phosphine requires capital investment in fumigation chambers in the first year because of the longer fumigation time and the danger of missing a market 

window, but thereafter is cheaper to use as the unit cost is lower than that of methyl bromide. The full cost of the fumigation chambers is charged in the first 

year.

Dried fruit: The CUN shows that treatment with SF results in a higher gross margin, and that treatment with phosphine, while resulting in a lower gross margin 

in the first year because of the need to provide fumigation chambers, will in later years also lead to a higher gross margin.

Dates: SF is the only technically feasible alternative in dates, and the CUN shows that its use results in an increase in gross margin.

The CUN is not based on economic arguments, but on the need for a phase-out period. 
October 2011 TEAP Report on 2011 CUNs: Final Report 51

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

United 

States

Mills and 

processors

483.000 461.758 401.889 348.237 291.418 291.418 173.023 74.510 - 25.334 - 25.334

MBTOC comments 2011

MBTOC recommends 25.334 tonnes, the amount recommended by the Party for use in food processing structures in 2013. This represents a 66% reduction in 

the amount granted by the Parties in 2012. This CUN includes amounts for three sectors and the recommendation is divided as follows: for rice milling, 2.467 t; 

for pet food facilities .004665 t; for mills 18.201 t. The USG has nominated a very challenging decrease in MB use for this sector, which MBTOC supports. If it 

were to be provided, a phase out plan would inform MBTOC and Parties of the continued timing of its transition to alternatives. 

This nomination is for facilities, or portions of facilities, that are unsuitable for the alternatives, or where the alternatives are not economically feasible. USG is 

requesting methyl bromide for this sector to allow time for the industry to purchase equipment, modify structures, and/or practice using alternatives. 

The lethal effects of sulfuryl fluoride (SF) are highly dependent upon temperature. The Party reported that, should a facility need fumigation during cold 

temperatures, this chemical may not be a cost-effective solution because of the requirement to use supplemental heat and additional dosage. SF requires 

higher dosages to kill the eggs of structural pests than for other life stages. Phosphine, although it is used in combination with heat and CO2 in some Canadian 

mills, can be corrosive to many metals that are present in facilities, especially in the computers and other electronic process control instrumentation. 

There is some confusion as to the commodities that may be directly fumigated with SF. According to the SF label in the US, pet food is not listed as a material 

approved for direct treatment. If not on the label the commodity can not be treated, leaving the question of incidental fumigation if the structure is treated with 

SF. This “incidental” fumigation of commodities inside a food processing structure has resulted in problems with label interpretation. Some companies insist 

that all pet food products would need to be removed from treatment areas or sufficiently protected to prevent the formation of residues of SF and fluoride ion on 

the pet food products. This is also a factor for mills that produce mixes with multiple ingredients (e.g. cake mixes, muffin mixes, etc.). 

The industry reports that complete removal of non-sulfuryl fluoride treatable ingredients and product from the target facility would present significant logistical 

challenges, including multiple forklifts and forklift drivers, plus rented truck trailers onto which the ingredients could be loaded. These trailers would then be 

removed from the facility, most likely to available space in the parking lot. This process that would add labour and trailer rental costs as well as costs 

associated with additional downtime needed to accomplish the ingredient removal task. 

Heat is dependent on several parameters: the structural composition, as different building components expand and contract at different rates; the building 

design/layout factors, which affect the ability to evenly distribute heated air; and the availability of convenient and economical sources of heat. Facilities 

constructed primarily from wood, which the CUN reports comprise about 25 per cent of the flourmills in the U.S., may not be able to use heat because of 

warping of the wood. Some areas of each structure act as “heat sinks” that absorb large amounts of heat, rendering them difficult to heat to the temperature 

and for the duration required to kill all life stages of insect pests. In addition, heat may not be a viable option for structures where a variety of heat-sensitive 

food products or commodities are also present. There is also a high initial investment to purchase explosion-proof heaters, modify sprinkler systems, and 

educate personal on heat treatments. 
52 October 2011 MBTOC Report on 2011 CUNs: Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

In spite of the availability of heat treatment methods, the US structural sector has largely relied on transition to SF as it reduced MB use. The current 

registration of SF remains unchanged in the US for the uses in this nomination. Greater transition to the use of heat treatment might be useful given the US 

Environmental Protection Agency regulation which proposes to eventually phase out the use of SF for food processing structures. If the US government phases 

out the use of SF for food processing structures, it may delay the transition to alternatives, since the use of SF has assisted this transition. 

Emission reduction: The sector has widely adopted SF which requires greater attention to sealing and so if MB is also used emissions would be reduced.

Research effort: No new research reported, but research is not needed. Instead trials and adaptation of known methods are needed at the individual mill sites. 

Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol nominations has control 

over pesticide registration. Many of the companies formerly associated with this CUN have switched to alternatives and/or decreased their use of MB. 

MBTOC comments on economics 2011:

Pet food facilities: The CUN provides a partial budget that shows that heat treatment in the first year will result in a decline in the gross margin of 0.05%. In 

the years after the initial investment the result will be an increase in the gross margin of 0.02%. In the budget provided, the capital cost is charged to the year of 

investment. 

Mills and other food processors: The CUN identifies SF and heat treatment as the best technical alternatives, and provides a partial budget showing the 

economic impact of these two alternatives. In the case of heat treatment, the capital costs are again charged to the first year. The use of SF results in a decline 

of 0.01% in gross margin, while heat treatment, taking into account the capital costs, results in a decline of 0.13%. Once the capital costs have been charged, 

gross margin increases by 0.14%.

The CUN is not based on economic arguments, but on the need for a phase-out period.
October 2011 TEAP Report on 2011 CUNs: Final Report 53

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

United 

States

Cured pork 67.907 40.854 18.998 19.669 18.998 4.465 3.73 3.730 - 3.730 - 3.730

MBTOC comments 2011

MBTOC recommends the nominated amount of 3.730 tonnes, for use in the cured pork sector in 2013. This is the same amount granted by the Parties for this 

use in 2012. 

In May 2011 (TEAP, May 2011) MBTOC had been unable to assess the USG cured pork CUN for 2013, pending the receipt of research results. However, USG 

has now indicated the research timeline, followed by the regulatory requirements; MBTOC has also reviewed the production cycle for Southern cured pork with 

its very long storage requirements. As a result of this new information and analysis, MBTOC can recommend the nominated amount. The cured pork sector 

has been improving the gas tightness of its fumigated pork storage facilities; as with all MB CUN uses, MBTOC reminds Parties that MB can only be used in 

fumigation rooms of good gas tightness and using best fumigation practises. 

The CUN reported that investigators achieved 100 % mortality of all life stages of red-legged ham beetles and ham mites with 48 hours exposure of 400 and 

1000 ppm of phosphine, respectively (Phillips, 2009). In addition, residual phosphine concentrations in dry cured hams that were fumigated for 48 hrs at 1000 

ppm were below 0.01 ppm, the legal residual limit in stored food products (Sekhon, et al. 2009b; Sekhon et al., 2010c), and consumer panellists could not 

detect differences between control and phosphine fumigated samples at 1000 ppm (Sekhon et al. 2009b; Sekhon et al., 2010c). Therefore, phosphine can be 

regarded as a potential alternative to methyl bromide for controlling arthropod pests of southern dry cured hams. 

Further testing with a greater number of mites has indicated that with heavy mite infestations, phosphine at 1000 ppm over 48 h does not achieve complete 

control. A programme of tests to scale up the proposed phosphine treatment to nearly commercial scale is being conducted summer and autumn of 2011 (and 

likely in 2012) to determine the efficacy of using phosphine at the plant level. The CUN noted that the effectiveness of phosphine will next be evaluated through 

the use of both bioassays (with ham present) and on hanging hams in a simulated dry cured ham aging room. This research will include the economic analysis 

of using phosphine in comparison to methyl bromide, with respect to its efficacy in eradicating mites. The Party reports that researchers will not complete data 

collection until November or December of 2011, with analysis to continue into early 2012. Additional items that will be researched in the future (if funding is 

obtained) include the effect of multiple fumigations on the sensory quality and residual concentration of phosphine in ham, and the effectiveness of using 

phosphine in dry cured ham facilities. Many processors have indicated that they would be willing to help evaluate the efficacy of phosphine (at controlling ham 

mite infestations) in their plant as part of a research project, which demonstrates the willingness of the industry to do everything that they can to help determine 

if potential alternatives to methyl bromide exist.

MBTOC notes that earlier research (Bowley and Bell, 1981) has indicated that better results may be obtained by conducting two fumigations with phosphine 

separated by an interval dependent of ambient temperature. This allows tolerant eggs to resume development and hatch before the second exposure. USG is 

also encouraged to investigate other treatment options should the phosphine research not be successful. 

The USG has indicated in correspondence that phosphine is registered for use on processed meats, which would include cured pork. MBTOC notes the 

Degesch America Phostoxin® (aluminium phosphide) and Fumicel® (magnesium phosphide) labels in the US lists processed meats if maximum residue limits 

do not exceed 0.01ppm. The Horn Diluphos Fosfoquim label also lists processed meats with the same maximum residue limits. 
54 October 2011 MBTOC Report on 2011 CUNs: Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUN for 

2012 

(Addtl or 

new)

CUN for

2013

MBTOC 

rec. for 

2012 

(addtl 

or new)

MBTOC 

rec. for 

2013 

(new)

Emissions reduction: Over the years the applicants have made facility improvements to improve gas tightness but this is a traditional meat curing process 

and some of the facilities are older and unusual. The research program continues to work with the applicants to improve gas tightness, IPM and other process 

improvements which reduce the need for fumigation and result in decreased use of MB. This work needs to continue. 

Research effort: Research effort is now extended to examine phosphine effectiveness on a commercial scale. A multi-state, multi-university research program 

is on going and full reports of research have been made available to MBTOC. 

Registration issues: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol nominations has control

over pesticide registration. Phosphine is registered for use on processed meats such as cured pork. 

MBTOC comments on economics 2011:

CUN states that an economic analysis was not conducted because currently there are no technically feasible alternatives.

1

1ExMOP and 16MOP; 216MOP+2ExMOP+17MOP; 3MOP17+MOP18; 4MOP18+MOP19; 5MOP19+MOP20; 6MOP20+MOP21; 7MOP21+MOP22; 8MOP22
October 2011 TEAP Report on 2011 CUNs: Final Report 55

5 Activity report for 2011 and work plan for 2012

5.1. Membership and procedural issues

In response to instructions from TEAP as contained in the TEAP May 2011 Progress Report 

(Chapter 11), MBTOC endeavoured to conduct its second meeting in such a manner as to allow 

all members to participate in discussions on each topic necessary to contribute to an informed 

decision when evaluating CUEs.

5.2. Activity report for 2011

 Initial summarization of the CUNs (initial sorting and recording carried out by the 

Secretariat).

 Preparation of questions for Parties. Assessment of responses received from Parties. 

 First meeting of MBTOC sub committees in March 2011 on the assessment of the 

CUNs: MBTOC met in full (all three sub-committees) in Antalya, Turkey. . Bilateral 

meetings were held by MBTOC-S and MBTOC SC with USA.

 Interim recommendations and preparation of the CUN Interim and Progress reports for 

consideration by the 31st OEWG

 Site visits: MBTOC-S conducted a field trip to observe alternatives adopted by 

vegetable and flower growers in the regions around Antalya. MBTOC-SC conducted a 

site visit to Taris, a large Turkish exporter of dried fruit and others who uses 

alternatives to MB for post-harvest uses and to the quarantine division of the Ministry 

of Agriculture in Izmir. 

 31

st OEWG (Geneva, 1-6 August, 2011). Bilateral meetings with USA and the 

California Strawberry Commission (USA) and Canada. 

 MBTOC SC conducted its re-reviews by an agreed email process.

 MBTOC met October 10 – 12, 2011 in Leusden, The Netherlands to assess soils CUNs 

from the USA and for which new or revised information was submitted. A bilateral was 

held via teleconference with the USG. 

 MBTOC-S and MBTOC-SC prepared the final report on the CUNs for consideration by 

the Parties at their 22nd Meeting.

The following “Actions” and “Indicative Completion Dates” are the “Working procedures of 

MBTOC relating to the evaluation of nominations for critical uses of methyl bromide”, as 

described in Annex 1 of the 16th Meeting of the Parties. The annual work plan is required to be 

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

shall submit it to the Meeting of the Parties each year
56 October 2011 MBTOC Final Report on 2011 CUNs

5.3. Work plan and indicative budget for 2012

Table 5-1. MBTOC work plan and indicative budget: 2012

Tasks and actions Indicative budget 

needs where 

applicable

Indicative 

completion date

Dates of meetings

1. Parties submit their nominations for 

critical-use exemptions to the Secretariat

- 24 January 2012

2. The nominations are forwarded to 

MBTOC co-chairs for distribution to the 

subgroups of appointed members

- 7 February 2012

3. Nominations in full are assessed by 

the subgroups of appointed members. 

The initial findings of the subgroups, and 

any requests for additional information 

are forwarded to the MBTOC co-chairs 

for clearance

- 28 February 2012

4. MBTOC co-chairs forward the 

cleared advice on initial findings and 

may request additional information on to 

the nominating Party concerned and 

consult with the Party on the possible 

presumption therein

- 21 February 2012

5. Nominating Party develops and 

submits its response to the MBTOC cochairs

- 7 March 2012

6. MBTOC Meeting No 1 

 Meets as usual to assess 

nominations, including any 

additional information provided by 

the nominating Party prior to the 

MBTOC meeting under action 5 and 

any additional information provided 

by nominating Party through prearranged teleconference, or through 

meetings with national experts, in 

accordance with paragraph 3.4 of 

the terms of reference of TEAP (see 

Annex I of MOP16, Dec XVI/4) 

 Bilateral meetings

 To discuss and finalise the CUN 

evaluation process proposed by the 

cochairs and commented by the 

MBTOC members

 To discussed any new or standard

presumptions that MBTOC seeks to 

apply in its future assessment of 

critical-use nominations, for 

approval by the Meeting of the 

Parties

 Any administrative changes to 

improve the operations of the 

Committee, within the scope of 

Decisions that have been agreed by 

the Parties

 Draft the 2012 Progress Report

Funds for travel of 1

non-A5 members: 

US$3,000 

Meeting Costs 

$3,000

March 2012 China, first half of 

March 2012 

(tentative)

8. MBTOC provides its draft 

recommendations on the CUNs to TEAP

April, 2012
October 2011 TEAP Report on 2011 CUNs: Final Report 57

Tasks and actions Indicative budget 

needs where 

applicable

Indicative 

completion date

Dates of meetings

9- TEAP Meeting: To assess the 

MBTOC report on critical-use 

nominations and submits the finalised 

interim report on recommendations and 

findings to the Secretariat.

April 2012 TBD

10. The Secretariat posts the finalised 

report on its web site and circulates it to 

the Parties

- May 2012

11. OEWG Bilateral Discussions: 

Nominating Party has the opportunity to 

consult with MBTOC on a bilateral basis 

in conjunction with the Open-ended 

Working Group meetings

June - August 

2012 (TBD)

TBD

12. The nominating Party submits 

further clarification for the critical-use 

nomination requested by MBTOC or if 

requested to do so by the Open-ended 

Working Group, and provides additional 

information should it wish to appeal 

against a critical-use nomination 

recommendation by MBTOC/TEAP

-

Late June 2012 

depending on 

OEWG date

13. MBTOC Meeting No 2:

 Meets to reassess only those criticaluse nominations in the “unable to 

assess” category, those where 

additional information has been 

submitted by the nominating Party 

and any critical-use nominations for 

which additional information has 

been requested by the Open-ended

Working Group (see Annex I of 

MOP16, Dec XVI/4)

 finalise the report, including notice 

of any proposed new standard 

presumptions to be applied by 

MBTOC

 conduct any bilateral consultations 

requested by Parties

 draft work plan and budget for 

MBTOC for 2012

Funds for travel of 1 

non-A5 members: 

US$3,000

Meeting costs: $US 

3,000

SeptemberOctober 2012TBD. 

14. MBTOC draft final report 

considered by TEAP, finalised and made 

available to Parties through the 

Secretariat

- Middle October 

2012

15. 22nd Meeting of the Parties November 2012

Total budget: US $: 12,000*

US$ 6,000 (Travel 

of Non Article 5 

member)

Meeting Costs 

$6,000 

* Travel funds for non A5 members have been requested in the past but not granted
58 October 2011 MBTOC Final Report on 2011 CUNs

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CA, November 10th-13th

Sekhon, R.K., Schilling, M.W., Phillips, Hasan, M.M., Aikens, M.J, Mikel, W.B. (2009). Chemical composition 

of dry cured hams fumigated with phosphine. Annual International Research Conference on 

Methyl Bromide Alternatives and Emission Reduction, San Diego, CA, November 10th-13th

TEAP, (2010). Report of the Technology and Economic Assessment Panel, May.2010 - Volume 2 Progress 

Report. UNEP, Nairobi, Kenya. 279 pp.

TEAP, (2011) .Report of the Technology and Economic Assessment Panel, May.2011 - Volume 2 Progress 

Report. UNEP, Nairobi, Kenya. 

UC Davis. (2011). University of California, Davis. Strawberry Diseases. 

http://ceventura.ucdavis.edu/Com_Ag/comveg/Strawberry/Diseases_741/

http://ceventura.ucdavis.edu/Com_Ag/comveg/Strawberry/Recent_Meetings/Fumigants_4_11/?i=1

USG (2011). United States Government. Methyl Bromide Critical Use Nomination for 2013, U.S. Replies to 

MBTOC Report (Submitted in 2011 for 2013 Use Season. Cucurbits, Eggplant, Ornamentals, 

Peppers, Rose Nursery, Strawberry Fruit, Tomato and Dried Meat Products 15 pp.

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

Yates, S, Papierknik S., Chellemi D, Wang D, Gao S, Hanson B, Ajwa H, Browne G, Kluepfel D. (2009). 

Update of film permeability measurements for USDA-ARS area-wide research project. In 

‘Annual International Research Conference on MB Alternatives and Emissions 

Reductions’Nov 10-13,San Diego, 2009.
October 2011 TEAP Report on 2011 CUNs: Final Report 61

ANNEX 1 - 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. Non-Article 5 

Parties must demonstrate that research programmes are in place to develop and 

deploy alternatives and substitutes. Article 5 Parties must demonstrate that 

feasible alternatives shall be adopted as soon as they are confirmed as suitable 

to the Party’s specific conditions and/or that they have applied to the 

Multilateral Fund or other 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).
62 October 2011 MBTOC Final Report on 2011 CUNs

ANNEX II - 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.
October 2011 TEAP Report on 2011 CUNs: Final Report 63

ANNEX III - Part A: Historical Trend in MB Preplant Soil Nominations and Exemptions

List of nominated (2005 – 2012 in part) and exempted (2005 – 2011 in part) amounts of MB granted by Parties under the CUE process for each crop or 

commodity. 

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2008 2009 2010 2011

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 3.500

Australia 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 35.750 29.790 29.790 23.840

Belgium 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

Belgium Nursery Not 

Predictable

0.384 0.900 0.384
64 October 2011 MBTOC Report on 2011 CUNs: Final Report

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2008 2009 2010 2011

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 7.462 7.462 7.462 5.261

Canada 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

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
October 2011 TEAP Report on 2011 CUNs: Final Report 65

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2008 2009 2010 2011

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 

solanaceou

s)

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 12.500 250.000 250.000 125.000 12.500

Israel Cucumber - protected new 2007 25.000 18.750 18.750 12.500 25.000 18.750 - 15.937

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 44.750 34.698 28.554

Israel Cut flowers – protected 303.000 303.000 321.330 163.400 113.821 72.266 52.955 303.000 240.000 220.185 114.450 85.431 63.464

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 87.500 87.500 70.000

Israel Potato 239.000 231.000 137.500 93.750 75.000 239.000 165.000 137.500 93.750 75.000

Israel Seed production 56.000 50.000 22.400 56.000 28.000 NR

Israel Strawberries – fruit (Sharon) 196.000 196.000 176.200 64.125 52.250 47.500 28.500 196.000 196.000 93.000 105.960 42.750

Israel Strawberries – fruit (Sharon & 

Ghaza)

57.063
66 October 2011 MBTOC Report on 2011 CUNs: Final Report

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2008 2009 2010 2011

Israel Strawberry runners (Sharon) 35.000 35.000 20 15.800 13.570 13.500 35.000 35.000 28.000 31.900 15.825

Israel Strawberry runners and fruit Ghaza 87.875 67.500 67.500 34.000 47.250

Israel Strawberry runners (Sharon & 

Ghaza)

22.320

Israel Tomatoes 90.000 22.750

Israel Sweet potato 95.000 20.000 20.000 111.500 95.000 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

Japan Cucumber 88.300 88.800 72.400 68.600 61.400 34.100 29.120 26.162 88.300 88.800 72.400 51.450 34.300 30.690 27.621

Japan Ginger – field 119.400 119.400 112.200 112.100 102.200 53.400 47.450 42.235 119.400 119.400 109.701 84.075 63.056 53.400 47.450

Japan Ginger – protected 22.900 22.900 14.800 14.800 12.900 8.300 7.770 6.558 22.900 22.900 14.471 11.100 8.325 8.300 7.036

Japan Melon 194.100 203.900 182.200 182.200 168.000 90.800 77.600 67.936 194.100 203.900 182.200 136.650 91.100 81.720 73.548

Japan Peppers (green and hot) 189.900 200.700 169.400 162.300 134.400 81.100 68.260 61.101 187.200 200.700 156.700 121.725 81.149 72.990 65.691

Japan Watermelon 126.300 96.200 94.200 43.300 23.700 15.400 13.870 12.075 129.000 98.900 94.200 32.475 21.650 14.500 13.050
October 2011 TEAP Report on 2011 CUNs: Final Report 67

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2008 2009 2010 2011

Malta 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

(+Andalu

cia)

20.000 15.000 43.490

(+Andalu

cia)

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
68 October 2011 MBTOC Report on 2011 CUNs: Final Report

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2008 2009 2010 2011

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 1187.800 747.839 592.891 486.757 407.091 302.974 195.698

USA Eggplant – field 76.761 101.245 96.480 79.546 62.789 34.732 21.561 6.904 76.721 82.167 85.363 66.018 48.691 32.820 19.725

USA Forest nursery seedlings 192.515 157.694 152.629 133.140 125.758 120.853 106.043 34.230 192.515 157.694 122.032 131.208 122.060 117.826 93.547

USA Ginger 9.200 9.200 0.000

USA Orchard replant 706.176 827.994 405.415 405.666 314.007 226.021 203.591 18.324 706.176 527.600 405.400 393.720 292.756 215.800 183.232

USA Ornamentals 210.949 162.817 149.965 138.538 137.776 95.204 70.178 48.164 154.000 148.483 137.835 138.538 107.136 84.617 64.307

USA 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 51.102 25.326 17.363 7.955

USA Peppers – field 1094.782 1498.530 1151.751 919.006 783.821 463.282 212.775 28.366 1094.782 1243.542 1106.753 756.339 548.984 463.282 206.234

USA 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 1349.575 1269.321 1007.47

7

812.709

USA Strawberry runners 54.988 56.291 4.483 8.838 8.837 7.381 7.381 3.752 54.988 56.291 4.483 8.838 7.944 4.690 + 

2.018

6.036

USA Tomato – field 2876.046 2844.985 2334.047 1840.100 1406.484 994.582 336.191 54.423 737.584 2476.365 2065.246 1406.484 1003.876 737.584 292.751

USA 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 18.144 18.144 14.515 11.612
October 2011 TEAP Report on 2011 CUNs: Final Report 69

ANNEX IV – Part B: Historical Trend in MB Structural and Commodity Nominations and Exemptions 

List of nominated (2005 – 2012 in part) and exempted (2005 – 2011 in part) amounts of MB granted by Parties under the CUE process for each crop or 

commodity. 

Party Industry Total CUN MB Quantities Total CUE MB Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2005 2006 2007 2008 2009 2010 2011

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 9.200 7.820 6.650 4.870

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

Belgium Food storage (dry) structure 0.120 0.120 0.120 0.000
70 October 2011 MBTOC Report on 2011 CUNs: Final Report

Party Industry Total CUN MB Quantities Total CUE MB Quantities

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 30.167 28.650 26.913 22.878 14.107

Canada Pasta manufacturing facilities (a) 10.457 6.757 6.067 4.740 4.7400 3.529 (a) 10.457 6.757 6.067 4.7400 3.529

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

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 1.800 2.100 1.04

Israel Flour mills (machinery & 2.140 1.490 1.490 0.800 0.300 2.140 1.490 1.040 0.312 0.300
October 2011 TEAP Report on 2011 CUNs: Final Report 71

Party Industry Total CUN MB Quantities Total CUE MB Quantities

storage)

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 25.000

Japan Chestnuts 7.100 6.500 6.500 6.300 5.800 5.400 5.350 4.984 7.100 6.800 6.500 6.300 5.800 5.400 5.350

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 1.800

Poland Coffee, cocoa beans (a) 2.160 2.000 0.500 2.160 1.420 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

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
72 October 2011 MBTOC Report on 2011 CUNs: Final Report

Party Industry Total CUN MB Quantities Total CUE MB Quantities

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 78.983 58.921 45.623 19.242 5.000

USA Dry commodities/ structures 

(cocoa beans) 

61.519 61.519 64.028 52.256 51.002 61.519 55.367 64.082 53.188

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 82.771 69.208 54.606 37.778 17.365

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 18.998 19.699 18.998 4.465 3.730

USA Mills and Processors 536.328 505.982 401.889 362.952 291.418 173.023 135.299 135.299 483.000 461.758 401.889 348.237 291.418 173.023 135.299