# MONTREAL PROTOCOL

ON SUBSTANCES THAT DEPLETE

THE OZONE LAYER



# UNEP

R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC 

# A SSESSMENT 

# P ANEL



# V OLUME 

# 3

MAY 

# 2014

E VALUATION OF 

# 2014 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE



# I NTERIM 

# R EPORT

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 iii 

# UNEP

MAY 

# 2014 R EPORT OF TH E



# T ECHNOLOGY AND 

# E CONOMIC



# A SSESSMENT 

# P ANEL



# E VALUATION OF 

# 2014 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE



# I NTERIM 

# R EPORT

# iv MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# Montreal Protocol

On Substances that Deplete the Ozone Layer



# Report of the

UNEP Technology and Economic Assessment Panel

May 2014

E VALUATION OF 

# 2014 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE

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

Co

- ordination: Methyl Bromide Technical Options Committee

Composition of the report: Co

- chairs Ian Porter, Marta Pizano, Moha m med Besri

Reproduction: UNON Nairobi

Date: May 2014

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

UNITED NATIONS ENVIRONMENT PROGRAMME

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

This document is also available in portab le document format from

http://ozone.unep.org/new_site/en/assessment_panels_main.php

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

acknowledgement of the sourc e of the material.

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 v



# 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, a nd 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 disp osal 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 amon g 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 accu racy, 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, envi ronmental 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, associati on, 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 Techn ical 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 an d do not reflect the reviews of any sponsoring

or supporting organisation.

The TEAP thanks the UN Multilateral Fund Secretariat in Montreal, Canada, for hosting the

TEAP meeting, 5

- 9 May 2014, where the final elements for this report were discussed and

dec isions were taken how to finalise the report.

Methyl Bromide Technical Options Committee:

MBTOC Co

- Chairs : Mohammed Besri (Morocco), Marta Pizano (Colombia), Ian Porter (Australia).

MBTOC Technical Members : Jonathan Banks (Australia); Chris Bell (UK); F red Bergwerff

(Netherlands); Aocheng Cao (China); Peter Caulkins (USA); Ricardo Deang (Philippines); Raquel

Ghini (Brazil); Ken Glassey (New Zealand); Alfredo Gonzalez (Philippines); Michelle Marcotte

(Canada ); Takashi Misumi (Japan); David Okioga (Kenya) ; Christoph Reichmuth; (Germany); Jordi

Riudavets (Spain); John Sansone (USA); Sally Schneider (USA); Johannes (Stappies) Staphorst

(South Africa); Akio Tateya (Japan); Robert Taylor (UK); Alejandro Valeiro (Argentina); Ken Vick

(USA); Nick Vink (South Africa) ; Chris Watson (UK); Jim Wells (USA); Eduardo Willink

(Argentina);.Suat Yilmaz (Turkey)

# vi MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# Foreword

The May 2014 TEAP Report

The May 2014 TEAP Report consists of six volumes:

Volume 1 : May 2014 TEAP Progress Report

Volume 2 : May 2014 TEA P Essential Use Nominations Report

Volume 3 : May 2014 TEAP Critical Use Nominations Report

Volume 4 : TEAP XXV/5 Task Force Report on information on alternatives to ODS

Volume 5 : TEAP XXV/6 Report on TOC appointment processes, future configurations and the

streamlining of annual (progress) reports

Volume 6 : TEAP XXV/8 Task Force on the funding requirement for the 2015

- 2017 replenishment of

the Multilateral Fund for the Implementation of the Montreal Protocol

 Volume 1 contains the TOC progres s reports and a chapter “Other TEAP matters”, discussing the

status of (re

- ) nominations and challenges to the participation of experts, as well as an annex with

the list of TEAP and TOC members, status May 2014

 Volume 2 contains the assessment of the 201 4 essential use nominations by the CTOC and the

MTOC

 Volume 3 contains the assessment of the 2014 critical use nominations by the MBTOC

 Volume 4 is the report of the TEAP Task Force responding to Decision XXV/5 on information on

alternatives to ODS in the refrigeration and air conditioning, foams, medical uses, fire protection

and solvent sectors

 Volume 5 contains a description by the TEAP on the TOC appointment processes and their future

configurations and the streamlining of the annual (progress) reports in response to Decision

XXV/6

 Volume 6 is the report of the TEAP Task Force responding to Decidion XXV/8 on the funding

requirement for the 2015

- 2017 replenishment of the Multilateral Fund for the Implementation of

the Montreal Protocol.

This is Volume 3 on the assessment of critical use nominations by the MBTOC.

The UNEP Technology and Economic Assessment Panel (TEAP):

Lambert Kuijpers, co

- chair NL Jose Pons

- Pons VEN

Bella Maranion, co

- chair USA Ian Porter AUS

Marta Pizano, co

- chair COL Miguel Quinter o COL

Paul Ashford UK Helen Tope AUS

Moham m ed Besri MOR Dan Verdonik USA

David Catchpole UK Ashley Woodcock UK

Marco Gonzalez CR Masaaki Yamabe J

Sergey Kopylov RF Shiqiu Zhang PRC

Kei

- ichi Ohnishi J Jianjung Zhang PRC

Roberto Peixoto BRA

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 vii 

# M A Y 

# 2014 R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC



# A SSESSMENT 

# P ANEL



# E VALUATIONS OF 

# 2014 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE



# I NTERIM 

# R EPORT

# viii MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# UNEP

M AY 

# 2014 R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC



# A SSESSMENT 

# P ANEL



# MBTOC INTERIM CUN R EPORT



# – MAY 2014

Common Acronyms

1,3

- D 1,3

- dichloropropene

A5 Article 5 Party

ASD Anaerobic soil disinfestation

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

MITC Methyl isothiocyanate

MOP Meeting of the Parties

MS Metam sodium

OEWG Open Ended Working Group

Pic Chloropicrin

QPS Quarantine and Pre

- shipment

SF S ulfuryl fluoride

TEAP Technology and Economics Assessment Panel

TIF Totally Impermeable Film

VIF Virtually Impermeable Film

VOC Volatile Organic Compounds

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 ix



# 2014 Evaluations of Critical Use Nominations for Methyl Bromide and

Related Matters

– Interim R eport

Table of Contents

1.1 SCOPE OF THE REPORT

................................ ................................ ................................ .............. 1

1.2. CRITICAL USE NOMINAT IONS FOR METHYL BROM IDE

................................ ................ 1

1.2.1. M ANDATE



# ................................ ................................ ................................ ................................ .. 1

1.2.2 F ULFILMENT OF 

# D ECISI ON 

# IX/6

................................ ................................ ................................ .. 2

1.2.3 R EPORTING OF 

# MB C ONSUMPTION FOR 

# C RITICAL 

# U SE



# ................................ ............................... 2

1.2.4 T RENDS IN 

# M ETHYL 

# B ROMIDE 

# U SE FOR 

# CUE S SINCE 

# 2005

................................ ........................ 3

1.2.5 D ISCLOSURE OF 

# I NTEREST



# ................................ ................................ ................................ .......... 3

1.2.6 A RTICLE 

# 5 ISSUES



# ................................ ................................ ................................ ...................... 3

1.2.7 C ONSIDERATION OF 

# S TOCKS



# , D ECISION 

# E X 

# .1/4 (9 F 

# )

................................ ................................ ... 4

1.3 EVALUATIONS OF CUNS

– 2014 ROUND FOR 2015 AND 2016 EXEMPTIONS

................. 10

1.3.1 C RITICAL 

# U SE 

# N OMINATIONS 

# R EVIEW



# ................................ ................................ ...................... 11

1.3.2 A CHIEVING 

# C ONSENSUS



# ................................ ................................ ................................ ............ 11

1.4 MBTOC SOILS: INTERIM EVALUATIONS OF 2014 CRITICAL USE NOMINATIONS FOR

METHYL BROMIDE FOR 2 015 AND 20 16

................................ ................................ ...... 11

1.4.1 C RITICAL 

# U SE 

# N OMINATION 

# A SSESSMENT



# ................................ ................................ ................ 11

1.4.2 I SSUES 

# R ELATED TO 

# CUN A SSESSMENT FOR 

# P REPLANT 

# S OIL 

# U SE



# ................................ ........... 12

1.4.3 G ENERAL 

# C OMMENTS ON THE 

# A SSESSMENT FOR 

# P REPLANT 

# S OIL 

# U SE



# ................................ ..... 13

1.4.4 R EGISTRATION OF 

# A LTERNATIVES FOR 

# P REPLANT 

# U SES



# - D ECISION 

# E X 

# I/4 (9 I 

# ) AND 

# (9 J 

# )

......... 13

1.4.5. D ECISION 

# XXV/4

................................ ................................ ................................ ..................... 13

1.4.5.1 Regulations impact ing use of alternatives by country

................................ .......................... 13

1.4.5.2 Health effects of MB use and environmental acceptability

................................ .................. 14

1.4.6 S USTAINABLE 

# A LTERNATIVES FOR 

# P REPLANT 

# U SES



# ................................ ................................ . 15

1 .4.7 S TANDARD 

# P RESUMPTIONS 

# U SED IN 

# A SSESSMENT OF 

# N OMINATED 

# Q UANTITIES



# . ..................... 15

1.4.8 A DJUSTMENTS FOR 

# S TANDARD 

# D OSAGE 

# R ATES USING 

# MB/P IC 

# F ORMULATIONS



# ..................... 17

1.4.9 U SE 

# /E MISSION 

# R EDUCTION 

# T ECHNOLOGIES



# - L OW PERMEABILITY BARR IER FILMS AND

DOSAGE REDUCTION



# ................................ ................................ ................................ ................ 17

1.5. INTERIM EVALUA TION OF CUNS: STRUCT URES AND COMMODITIES

......................... 36

1.5.1 S TANDARD RATE PRESUMP TIONS



# ................................ ................................ .............................. 36

1.5.2. D ETAILS OF THE EVALUA TION



# ................................ ................................ ................................ .. 36

1.6 REFERENCES:

................................ ................................ ................................ ................................ 39

ANNEX 1: DECISION I X/6

................................ ................................ ................................ ...................... 44

ANNEX II

- PART A: HISTORIC TRE NDS IN PREPLANT SOIL NOMINATIONS AND

EXEMPTIONS FOR M B USE

................................ ................................ ............................ 45

ANNEX III

– PART B: HISTORIC TRE NDS IN STRUCTURAL AN D COMMODITY

NOMINATIONS AND EXEM PTIONS FOR MB USE

................................ .................... 52

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 1



# 2014 Evaluation of Critical Use Nominations for Methyl Bromide and

Related Matters

1.1 Scope of the Report

The 2014 interim report provides evaluations by MBTOC of Critical Use Nominations (CUNs)

submitted for methyl bromide (MB) for 2015 and 2016 by six Parties: three non

- A5 (Australia,

Canada and USA) and three A5 (Argentina , China and Mexico). One additional A5 Party (Malaysia)

submitted a CUN, but later informed the Ozone Secretariat and MBTOC that it was withdrawing the

nomination. As per provisions set out in Decision IX/6 (Annex I, MOP16), CUNs were submitted by

the Part ies to the Ozone Secretariat in accordance with the timetable shown in paragraph 1 of Annex I,

Decision XVI/4. Given that January 1 st 

# , 2015 is the deadline for phasing

- out methyl bromide in A5

Parties, these Parties are now able to submit CUNs according to provisions set out in the Protocol.

This report also provides 1) interim recommendations for the CUNs for which the Parties provided

information as per the timelines set at the 25 th 

# Meeting of the Parties; 2) information from Parties on

stocks (Decision E x.1/4 (9f)); 3) partial information on actual MB consumption for critical uses (in

accordance with Decision XVII/9) and 4) apparent adoption rates of alternatives, as evidenced by

trend lines on reduction of MB CUNs (in accordance with Decisions XIX/9, XX/ 5). It is noted that

trend lines on adoption may not necessarily indicate true adoption rates for alternatives, as the use of

stocks of MB that may have been available to the same sector or areas of production may have

increased or fallen within the sector due to a range of circumstances. MBTOC notes that stock

volumes have significantly decreased in recent years.

Standard presumptions used in the 2014 round were the same as those used in the 2013 evaluations of

the CUNs. These standard presumptions are s ubject to continual review. However, any changes

proposed by MBTOC are required to be approved by the Party’s in the MOP preceding the year of

assessment based on a draft Decision presented to the MOP in accordance with paragraph 2 in Annex

1 to the repor t of MOP16.



# 1.2. Critical Use Nominations for Methyl Bromide

1.2.1. Mandate

Under Article 2H of the Montreal Protocol, Parties not operating under Article 5(1) are required to

phase

- out all production and consumption (defined as production plus impor ts minus exports) of MB

after 1 January 2005. The same requirements apply to Parties operating under Article 5(1) after 1

January 2015. 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 (see Annex 1 of this report) of

the Protocol, which all critical uses need to meet in order to qualify for an exemption. TEAP and its

MBTOC have provided guidance to the Parties on recommendations regarding critica l use exemptions

in accordance with Decisions IX/6, Annex I of Decision XVI/2 and a number of subsequent decisions

( XVI/2 ; XVII/9 , XVIII/13, XIX/9, XX/5, XXI/11, XXII/6, XXIII/4, XXIV/5 and XXV/4).

Decision XXIV/5 differed from past decisions in that it reinforced that Parties ‘take all reasonable

steps to explore furthe r the possibility of transitioning to technically and economically feasible

alternatives... and to ensure that the Methyl Bromide Technical Options Committee is fully aware of

these efforts ’

.

Decision XXV/4 requests Australia and Canada to submit, by the 36 th 

# OEWG, the available results of

their research programmes on alternatives to MB to the TEAP for its consideration. It is anticipated

that TEAP will consider the progress by Parties to this decision when making its final

recommendations. This same Decision further requests TEAP to analyse the impact of national,

subnational and local regulations and law on the potential use of methyl bromide alternatives, to

report annually on the status of re

- registration and review of methyl bromide uses for the applicati ons

reflected in the CUNs, including any information on health effects and environmental acceptability

# 2 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# and 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.

MBTOC considers that any chemical or product registered for a particular use has been through the

rigours of the national local regulatory authorities and accepts that these fall within guidelines for

health effects and environmental acceptability. MBTOC particularly takes note of those products,

which are generally listed in any CUN application.



# 1.2.2 Fulfilment of Decision IX/6

Decision XVI/2 and Decision XXI/11 directed MBTOC to indi cate whether all CUNs fully met the

requirements of Decision IX/6. When the requirements of Decision IX/6 are met, MBTOC can

recommend critical uses of MB. Where some of the conditions are not fully met, MBTOC can

recommend a decreased amount depending on its technical and economic evaluation, or determine the

CUN as “unable to assess” and request further information from the Party. When the information is

submitted, MBTOC is required to re

- assess the nomination, following the procedures defined in

Annex 1 of the Sixteenth Meeting of the Parties.

MBTOC recommended less methyl bromide that requested in a CUN when technically and

economically feasible alternatives were considered to be available or, when the Party failed to show

that there was no technical ly and economically feasible alternative. In this round, MBTOC did not

recommend two nominations as important information essential to the assessment had not been

supplied and the nomination did not meet the requirements of Decision IX/6. Also, in this round of

CUNs, as in previous rounds, MBTOC considered all information provided by the Parties, including

answers to questions requested by MBTOC up to the date of the evaluation.

Now that technically and economically feasible alternatives have been ident ified for virtually all

applications of methyl bromide, regulations on the use of these alternatives often determine their

availability to the end users. In addition, comparative information on the economic

feasibility/infeasibility of the use of alternat ives compared to MB is critical to the outcomes of present

and future CUNs. In particular, MBTOC needs annual updates of the economics information

evaluating the costs of alternatives.



# 1.2.3 Reporting of MB Consumption for Critical Use

A number of decisio ns ( Ex. I/3(5) ; XVI/2(4) ; XVII/9(5) ), XVIII/13(6), XIX/9(7), XX/5(7),

XXI/11(6), XXII/6(5), XXIII/4(4), XXIV/5 and XXV/4 set out provisions which request Parties to

submit by 1 st 

# February each year information on how criteria in IX/6(1) is met when licensing

permitting or authorizing CUEs. Decision 

# XVII/9 of the 17 th 

# MOP specifically requests TEAP

and its MBTOC to “ report for 2005 and annually thereafter, for each agreed critical use

category, the amount of methyl bromide nomin ated 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 tables of the historic amounts of

MB nominated and ag reed for each critical use (Annexes III and IV). Additionally Parties provide

accounting frameworks on amounts used for critical uses and stocks as required under Dec Ex.1/4

(9f). (Table 1

- 3).

In 2013, the Meeting of the Parties authorised Australia to use 29.760 tonnes of MB for strawberry

runners and 1.187 t for use on rice. The Party exempted 32.134 tonnes and 31.521 t was reportedly

used for the critical uses in 2013. For Canada, the Meeting of the Parties in 2013 authorised 13.109

tonnes for strawberr y runners. In the accounting framework the party reported that 12.867 t was used

for critical uses in 2013. For the United States, the MOP authorised 562.326 tonnes for a wide range

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 3



# of crops and commodities in 2013 (Annex III and IV). In their allocation regulation for 2013 critical

uses, the Party reported that 562.326 tonnes had been approved for pre

- plant soil uses and postharvest

uses (Federal Register 78, July 22, 2013).

This is the first year that A5 Parties are able to submit CUNs. Under Decision E x1/4. (9f) those A5

Parties which are granted critical use will need to provide accounting frameworks for these uses in

forthcoming years.



# 1.2.4 Trends in Methyl Bromide Use for CUEs since 2005

The nominated amounts and the apparent rate of reduction in M B or adoption of alternatives achieved

by Parties are shown in Table 1

- 5, as well as Figures 1

- 1 and 1

- 2. It is noted that for those non

- A5

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 adoption of alternatives since pre

- 2005 stocks

may have been used (or may still be used) in the same sectors. Tables 1

- 9 and 1

- 11 in particular show

the amounts nominated by Parties for soil uses, and structures and commo dity uses and the final

recommendations for ‘Critical Use’ in 2015 and 2016.

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

Parties (Fig 1

- 1 and Fig 1

- 2, Annexes III and IV). Since 2005, there has been a progressive trend in

the reduction of methyl bromide for CUNs by all Parties for both soil and post

- harvest uses, although

this has occurred at different rates. Figs 1

- 1 and 1

- 2 show reduction trends in amounts

approved/nominated by Parties for ‘Critical Use’ from 2005 to 2016 for all the remaining soil and

structures and commodity uses. The complete trends in phase out of MB by country, as indicated by

change in CUE, are shown in Annexes III and IV.



# 1.2.5 Disclosure of Interest

As in past reports, MBTO C members were requested to update their disclosure of interest forms

relating specifically to their level of national, regional or enterprise involvement for the 2014 CUN

process. The Disclosure of Interest declarations for 2014, updated in March 2014 can be found on the

internet at http://ozone.unep.org/new_site/en/disclosure_of_interest.php?body_id=6&committee_id=6

and a list of members in Annex I to the 2014 TEAP Report, Volume One. As in previous rounds,

some members withdrew from or abstained to participate in a particular CUN assessment or only

provided technical advice on request, for those nominations where a potential conflict of interest was

decl ared.

MBTOC co

- chairs further briefed members of recent updates introduced by the Parties to the Terms

of Reference (TOR) of the TEAP/TOC, as per recent Decisions XXIV/8 and XXV/6.



# 1.2.6 Article 5 issues

Methyl bromide is due to be fully phased out i n A5 Parties by January 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, approximately 85% of the controlled consumption in A5 Parties has been phased out, ahead

of the 2015 deadline. This has been achieved largely as a result of inv estment projects implemented

by the Montreal Protocol agencies, with MLF funding, bilateral cooperation and also national

funding. The large majority of A5 Parties still consuming MB have agreements in place with the

Executive Committee for full phaseout o f methyl bromide by 1 st 

# January 2015 at the latest, sometimes

earlier. These are usually accompanied by a commitment from the Party in question to put in place

policy packages to restrict consumption of MB for controlled uses after the phase

- out. MBTOC not es

that all A5 Parties submitting CUNs in this round have received funding from the MLF for complete

phaseout of MB in their countries by 1 st 

# January 2015 at the latest, sometimes earlier.

# 4 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# Article 5 Parties may submit nominations for Critical Use Exemption s (CUEs) for uses they consider

appropriate for the year 2015 and possibly subsequently. The first CUNs by non

- A5 Parties were

made in 2003 for CUEs to be in place in 2005. Four A5 Parties submitted CUNs in this round for

extended use of MB in 2015; one o f these

– Malaysia

– later withdrew its CUN.



# 1.2.7 Consideration of Stocks, Decision Ex.1/4 (9f)

One criterion for granting a critical use is that MB “ is not available in sufficient quantity and quality

from existing stocks of banked or recycled methyl b romide ” (paragraph 1 (b) (ii) of Decision IX/6).

Parties nominating critical use exemptions are requested under decision Ex.I/4(9f) to submit an

accounting framework with the information on stocks. MBTOC has not reduced its recommended

amount of methyl b romide in consideration of stocks held by the Party and has instead relied on

Parties to take this into consideration when approving the amounts recommended by TEAP for each

nomination. To assist the Parties with their consideration of stocks, and in acc ordance with Decision

XVIII/13(7), a summary of the data on stocks as reported by the Parties in the first year for accounting

in 2006, and then reports submitted in 2012 and 2013 are summarized in Tables 1

- 1 to 1

- 3 below.

Parties may wish to consider th is information in the light of Decision IX/6 1(b) (ii) when authorising

methyl bromide for critical uses.

Efficient functioning of commerce requires a certain level of available stocks and additional stocks to

respond to emergencies. Additionally, stocks may be held on behalf of other Parties or for exempt

uses (feedstock and QPS uses). The correct or optimal level of stocks for virtually every input to

production is not zero. In addition, stocks are privately owned and may not be readily available for

c ritical uses, or there may be national regulations preventing the transfer of stocks. Despite these

restrictions, Parties may wish to ensure that stocks are used wherever possible in order to minimize

the quantity of MB that need to be produced each year for critical uses. Tables 1

- 1 to 1

- 3 report the

quantities of MB ‘on hand’ at the beginning and end respectively of 2005, 2012 and 2013 as required

under Decision XVI/6. The earlier CUN reports identified stocks for the other years.

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 5



# Table 1

- 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 4 43

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 1

- 2. Quantities of MB ‘on hand’ at the beginning and end of 2012, as reported by Part ies in

2012 under Decision XVI/6.

Party Critical use

exemption

authorized by

MOP for 2012 Quantity of MB as reported by Parties (metric tonnes)

Amount

on hand

at start of

2012 Quantity

acquired for

CUEs in

2012

(production

+imports) Amount

available

for use in

2012 Quantity

used for

CUEs in

2012 Amount

on hand

at the

end of

2012

Australia 33.413 0 32.593 32.593 32.593 0

Canada 16.281 1.455 12.186 13.641 12.725 0.916

Japan 219.609 9.726 155.902 165.628 174.708 

# 2.709

USA 1023

[760 t

authorization an d

263 t critical stock

allowances] ? (c)



# 1249(a) 759 2008 759 ? (c)



# 627(b)

(a) Amount of pre

- 2005 stocks available at the start of 2012

(b) Amount of pre

- 2005 stocks available at the end of 2012

(c) Amount of post 2005 stocks are not reported.

# 6 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# Table 1

- 3. Quantities of MB ‘on hand’ at the beginning and end of 2013, as reported by Parties in

2013 under Decision XVI/6.

Party Critical use

exemption

authorized by

MOP for 2013 Quantity of MB as reported by Parties (metric tonnes)

Amount

on hand

a t start

of 2013 Quantity

acquired for

CUEs in 2013

(production

+imports) Amount

available

for use in

2013 Quantity

used for

CUEs in

2013 Amount

on hand at

the end of

2013

Australia 32.134 0 31.521 31.521 31.521 0

Canada 13.109 0.916 11.951 12.867 11.460 1.407

Japan 3.317 0.816 1.190 2.006 1.667 0.339

USA 562 ? (c)



# 627 (a) 

# 562 1189 562 ? (c)



# 357 (b)



# (a) Amount of pre

- 2005 stocks available at the start of 2013

(b) Amount of pre

- 2005 stocks available at the end of 2013

(c) Amount of post 2005 stocks ar e not reported

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 7



# Figure 1

- 1. Amounts of MB nominated and exempted for CUE uses in nominated preplant soil

sectors from 2005 to 2016. Blue lines indicate the trend in CUN MB nominated and

the red lines the amount of CUE MB approved by the Parties

# 8 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# Figure 1

- 2. Amounts of MB nominated and exempted for CUE uses in dry cure pork (smokehouse

hams) from 2005 to 2016. Blue lines indicate the trend in the CUN MB nominated and the red

lines the amount of CUE MB approved by the Parties

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 9



# Table 1

- 4. Summary of Critical Use Nominations and Exemptions of Methyl Bromide (tonnes)

Quantities Nominated Quantities Approved Interim

rec.

Party 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2005

(1ExMOP

and

16MOP) 2006

(16MOP+

2ExMOP+

17MOP) 2007

(17MOP +

18MOP) 2008

(18MOP

+ 19MOP) 2009

(19MOP) 2010

(20MOP

+ 21MOP) 2011

(21MOP) 2012

(22MOP) 2013

(23MOP) 2014

(24MOP) 2015

(25 MOP) 2016

Australia 206.950 81.250 52.145 52.900 3 8.990 37.610 35.450 34.660 32.164 30.947 29.79 29.79 146.600 75.100 48.517 48.450 37.610 36.440 28.710 31.708 32.134 30.947 29.79  29.79 

Canada 61.992 53.897 46.745 42.241 39.115 35.080 19.368

+3.529 16.281 13.444 10.305 5.261 5.261 61.792 53.897 52.874 36.112 39.020 30.340

+3.529 19.368 16.281 13.109 10.305 5.261  5.261 

EC 1

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

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

Japan 748.000 741.400 651.700 589.600 508.900 288.500 249.420 221.104 3.317 0 0 0 748.000 741.400 636.172 443.775 305.380 267.000 239.746 219.609 3.317 0 0 0

New

Zealand

53.085 53.085 32.573 0 0 0 0 0 0 0 0 0

50.000 42.000 18.234 0 0 0 0 0 0 0 0 0

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

USA 10753.997 9386.229 7417.999 6415.153 4958.034 3299.490 2388.128 1181.779

+ 6.339 691.608 442.337 377.170 234.78 9552.879 8081.753 6749.060 5355.976 4261.974 3232.856

+2.018 2055.200 993.706 562.328 442.337 377.170  234.780 

Argentina

- - - - - - - - - - 245

- - - - - - - - - - [0]

China

- - - - - - - - - -- 120

- - - - - - - - - - [114]

Mexico

- - - - - - - - - - 140

- - - - - - - - - - [84.957]

TOTALS 18704.241 15617.837 10677.552 8297.739 6244.487 4044.380 2928.142 1460.163 740.533 483.589 917.191 266.561 16050.089 13418.200 9160.714 6990.039 5,254.838 3572.183 2343.024 1261.304 610.888 483.589 412.221 +

[ 198.957] [ 266.561]



## * 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

# 10 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# 1.3 Evaluations of CUNs

– 2014 round for 2015 and 2016 exemptions

Parties requesting CUNs in 2014 sent information to the Ozone Secretariat generally by the January

24, deadline. The Secretariat forwarded them to MBTOC co

- chairs, who in turn provided the

information to MBTOC for their consideration for preliminary assessment to ensure information had

been provided as per Decision IX/6 and Annex 1 of the 16 th 

# MOP. Where some evidence was missing,

MBTOC requested further information of t he Parties prior to the interim assessment. Detailed interim

assessments of all CUNs were made by MBTOC at a meeting in Stellenbosch (South Africa) from

March 31 to April 4 2014. The meeting was attended by twenty MBTOC members with expertise in

soils, SC and QPS applications of methyl bromide. MBTOC worked as a single body, not i n sub

committees. The three co

- chairs appointed working groups to address the different tasks assigned to

MBTOC including CUNs, but also others as included in its Progress Report. Recommendations were

discussed and signed off in plenary and by consensus. Comments made by members not attending the

meeting were considered during evaluations. This scheme allowed members with specific expertise

to make contributions where they were mo st useful and for all the committee to fully participate in the

decision making process.

During the meeting, MBTOC held a teleconference with the US delegation with participation of

experts from the USA on alternatives for the ham sector. MBTOC also condu cted a field visit to the

Dept. Agriculture, Forestry and Fisheries Quarantine Station in Stellenbosch and two commercial

field producers (a strawberry producer and a vegetable farm) who were still using methyl bromide.

Pest control applicators and commer cial growers that attended the meetings were surprised to hear

that South Africa was reporting zero consumption and was concerned that this situation be rectified

with the regulatory authorities in South Africa.

For soils CUNs, Australia and Canada submit ted similar amounts to the previous rounds highlighting

difficulties with phase out of MB for the strawberry runners sector in particular. In the USA the only

soil CUN submitted was for strawberry fruit production.

With respect to A5 Parties, Argentina s ubmitted CUNs for the strawberry fruit (open field), tomato

and pepper sectors (protected), China for both protected and field production of ginger and Mexico

for raspberry and strawberry runners produced in the open field.

For the postharvest sector only one CUN was received from the USA, for dry cure pork. Malaysia

initially submitted a CUN for structures concerning flourmills, ship holds and aircraft fumigation, but

later withdrew this nomination.

The total nominated amount for all countries for 2015 wa s 917.191 tonnes; of these, 412.191 t by non

A5 Parties (representing a 14.8% reduction with respect to the nominated amount in 2013 for 2015)

and 505 tonnes by A5 Parties. For 2016, non

- A5 Parties have nominated 315.005 tonnes, a reduction

of 34.6% with r espect to the previous year. MBTOC has recommended 198.957 tonnes for A5 Parties

for 2015 and 266.561 tonnes for non

- A5 Parties for 2016. The grounds used for these

recommendations are given in detail for the relevant CUNs in Tables 1

- 9, 1

- 10 and 1

- 11.

I n general the CUNs were submitted due to the following alleged issues: regulatory restrictions that

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

- up of alternatives and that all

alternatives were considered uneconomical, insu fficiently effective and/or were unavailable. In

paragraph 20 of Annex 1 referred to in Decision XVI/4, Parties specifically requested that MBTOC

explicitly state the specific basis for the Party’s economic statement relating to CUNs. Tables 1

- 9,

1.10 and 1

- 11 provide this information for each CUN as prepared by the MBTOC economist.

MBTOC notes the economic information supplied by the nominating Parties continued to improve in

this round.

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 11



# 1.3.1 Critical Use Nominations Review

The meeting was held as requir ed in accordance with the time schedule for the consideration of CUNs

provided in Annex I referred to in Decision XVI/4. In considering the CUNs submitted in 2014, as in

previous rounds, MBTOC applied as much as possible the standards contained in Annex I of the final

report of 16 MOP, and, where relevant, the standard presumptions given below. In particular,

MBTOC sought to provide consistent treatment of CUNs within and between Parties while at the

same time taking local circumstances into consideration. The most recent CUE approved by the

Parties for a particular CUN was used as baseline for consideration of continuing nominations, except

in the case of A5 Parties, this being the first time that they have submitted CUNs. In that case,

however, historical MB use provided with the nomination, was taken into account. In evaluating the

CUNs for soil treatments, MBTOC assumed that the presence of a technically feasible alternative to

MB would need to provide sufficient pest and/or weed control for continued pr oduction 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. The outcome of evaluations of CUNs

for the soil and structural treatments are presented in Table 1.9, 1.10 and 1.11 below.



# 1.3.2 Achieving Consensus

In accordance with decision XX/5(9) and simi lar subsequent decisions (XXI/11(4), XXII/6(4) and

XXIII/4(3)) and XXIV/5 and 8 the Parties have indicated that MBTOC ‘ should ensure that it develops

its recommendations in a consensus process that includes full discussion among all available

members of th e Committee and should ensure that members with relevant expertise are involved in

developing its recommendations’

.

In keeping with recent Decisions as well as the new working scheme put in place by the co

- chairs, all

members were given access to the infor mation and were able to discuss issues related to all

nominations (either in person or by electronic means), but only those members able to physically

participate in the meeting formed consensus. All views were discussed fully in plenary and issues

debated until a consensus position was reached. No minority positions arose during the meeting

Several members recused from recommendations on nominations as required by MBTOC’s working

procedures. These included Jim Wells (US Strawberry Fruit, Mexican strawber ry and raspberry

runners, Argentina strawberry fruit and tomato and peppers), Alejandro Valeiro (Argentina strawberry

fruit and tomato and pepper), Aocheng Cao (China ginger), Eduardo Willink (Argentina strawberry

fruit and tomato and pepper) and Ian Porte r (Australian Strawberry nurseries). The recusals took

place either as a result of a member’s disclosure as per MBTOC's guidelines or members may have

chosen to self

- recuse to avoid any perceived conflict of interest.



# 1. 4 MBTOC Soils: Interim Evalua tions of 2014 Critical Use Nominations for

Methyl Bromide for 2015 and 2016

1.4.1 Critical Use Nomination Assessment

Table 1.5 identifies the quantities recommended by MBTOC after consideration of all the information

provided by the Parties. I n summary, the Australian, Canadian and US nominations were

recommended in full as the Parties gave sufficient substantiation that alternatives were economically

infeasible or impacted by regulatory issues. The USA has indicated this will be the last year they will

submit a CUN for strawberry fruit. The Argentinean nominations were not recommended because

MBTOC believes that alternatives, which are available and effective, could be used for the

nominations and the Party did not provide information demonstra ting that this is not the case under

the particular circumstances of these nominations. The CUNs submitted by China and Mexico were

only partially recommended after adjustments related to MBCTOC’s standard presumptions or

# 12 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# because MBTOC believes that altern atives are available and effective for part of the nominations. In

one case, the committee considered that contingency amounts were being requested for a future

scenario and this was not supported. The detailed descriptions can be found in Table 1

- 5.

Table 1

- 5. Summary of the interim recommendations (in square brackets) for CUE’s for preplant

uses of MB (tonnes) submitted in 2014 for 2015 and 2016

Country and Sector Article 5 Parties Non A5 Parties

Nomination

by Party for

2015 Interim

Recommendation

for 2015 Nomination

by the Party

for 2016 Interim

Recommendation

for 2016

1. Australia

Strawberry runners 29.760 [29.760]

2. Canada

Strawberry runners 5.261 [5.261]

3. USA

Strawberry fruit 231.540 [231.540]

4. Argentina

Tomato and pep per

Strawberry fruit 145

100 [0]

[0]

5. China

Ginger, open field

Ginger, protected 90

30 [90]

[24]

6. Mexico

Strawberry runners

Raspberry runners 70

70 [43.539]

[41.418]

TOTAL 505 [198.957] 266.561 [266.561 ]



# 1.4.2 Issues Rel

ated to CUN Assessment for Preplant Soil Use

Key issues which influenced assessment and the need for MB for preplant soil use of MB in the 2014

round were:

i) An increase in the chloropicrin dosage rate allowed in California was a key issue related to

the fur ther reduction made in the US nomination.

ii) Continued adoption of a new formulation of 1,3

- D/Pic (‘ Pic

- Clor 60’ ) in the USA, which

increases the area that may be treated with 1,3

- D in regions affected by township caps in

California.

iii) More effective disease control obtained with shank applied fumigants than drip applied

fumigants will influence the practices being adopted for existing and future CUE sector.

iv) The USA has indicated that this will be the last year that they will submit a CUN for

strawberry fruit. Canada noted that it intends that 2016 is the final year for use of methyl

bromide for strawberry runner production .

v) The Mexican raspberry and strawberry runner sectors developed recently and were

incorporated into the MB phase

- out project at a late sta ge. Only preliminary results from

trials with alternatives are thus available at this time.

vi) The only chemical alternative available in China for ginger is chloropicrin. Initial results with

this fumigant are encouraging, but time is needed to implement int egrated control programs

for the key pathogen Ralstonia solanacearum

.

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 13



# MBTOC has noted more specific issues related to requests for CUNs below and also in the CUN text

boxes (Table 1.9).



# 1.4.3 General Comments on the Assessment for Preplant Soil Use

MBTOC continues to encourage Parties to consider a review of regulations covering the registration,

use and adoption of alternatives, particularly those regarding barrier films to reduce dosage rates of

MB and its alternatives, and associated emissions. MBTOC is aware that regulations now allow high

barrier films (VIF) to be used with MB in California. MBTOC also notes that a large proportion of

MB has been nominated for uses where regulations or legislation prevent reductions of MB dosage.

For several cases, t he mandatory use of MB is specified at a high dosage, in some cases for treatment

of certified propagation material. Also regulations on the use of alternatives or lack of registration of

them, are preventing their uptake for a substantial proportion of th e remaining CUNs for preplant soil

use.



# 1.4.4 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 sub stitutes for

methyl bromide, with particular emphasis on possible regulatory actions that will increase or

decrease dependence on methyl bromide”.

Where these have impacted a nomination, the party or MBTOC may have adjusted quantities to allow

for effectiv e use of the alternative. A description of any changes has been made available in the CUN

text boxes (Tables 1.9 and 1.11).

Any future nominations submitted by Australia, Canada and the US should include information on

expected rates of adoption of altern atives following registration, in accordance with paragraphs 34

- 35

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



# 1.4.5. Decision XXV/4

In response to Decision XXV/4 from the 25th MOP, MBTOC notes that a ll of the non

- A5

nominations contained a discussion of national, subnational or local regulations impacting the

potential use of alternatives to MB. In addition, both Non

- A5 and A5 nominations contained

information on the status of the registration of alt ernatives and substitutes for MB. These comments

are summarized below for each Party.

1.4.5.1 Regulations impacting use of alternatives by country

 Australia: Methyl iodide has been withdrawn by the registrant from Australia and is no longer

available to the strawberry runner industry. BOC/Linde ceased funding research on

Ethanedinitrile (EDN) for strawberry runners. Future development of EDN is uncertain. Nordiko

is no longer pursuing registration of recaptured methyl bromide due to inconsistency o f

formulation. Meanwhile trials to generate registration data for an 80:20 mix of chloropicrin/1,3

- D

are underway. Australia has a certification program in place to assure the sanitation of strawberry

runners. Only certain fumigants and rates are approve d for use by the authorities. Three years of

studies have not demonstrated bioiequivalency between 20g/m 2 

# of MB and standard rates of

25g/m 2 

# , so registration of the lower rate is not proceeding. PicPlus®, while registered in Australia

and part of an activ e research program, is not approved for use for certified runners at this time.

 Canada: Strawberry runners produced on Prince Edward Island are primarily exported to North

Carolina in the USA. The runners must meet the phytosanitary requirements of Canad a, the

United States government and the North Carolina Department of Agriculture. Chloropicrin is still

not permitted on Prince Edward Island and so is not available for use in strawberry runner

production there. A protocol has been developed for a chlor opicrin groundwater study.

# 14 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# Depending on the results of the study, chloropicrin may be allowed for use on PEI in the future.

1,3

- D was de

- registered in Canada after December 31, 2011. Re

- evaluation of MITC generators

is ongoing. A groundwater warning st atement is currently on Canadian labels, which prevents the

use of these products on PEI.

 USA: Allyl isothiocyanate (AITC) is registered as a preplant soil fumigant for several crops in the

US in September, 2013.The registrant has expressed interest in re gistering AITC products in

California, but has yet to submit an application. In accordance with California Department of

Pesticide Regulation (CDPR) policy, a full risk assessment will be conducted prior to the

registration of any new fumigants in Califor nia. CDPR has announced that there will no longer be

exceptions to the 90,250 lb. township cap for 1,3

- D products in high use strawberry townships,

until the completion of an on

- going risk assessment of 1,3

- D, at which time a decision will be

made whether to further limit or expand 1,3

- D use in California.

 China: The only registered alternative to MB for ginger in China is chloropicrin and there are no

mixtures of fumigants with chloropicrin registered, including MB.

 Argentina: Chloropicrin is not registe red as a stand

- alone product in Argentina, but combinations

of 1,3

- D/pic products are registered. Dazomet is not registered for edible crops.

 Mexico: Chloropicrin alone, 1,3

- D/Chloropicrin mixtures, metham sodium and dazomet are

registered in Mexico. Di methyl disulfide (DMDS) is not registered in Mexico at this time.

1.4.5.2 Health effects of MB use and environmental acceptability

Over the past two decades numerous studies have characterized the health hazards resulting from

exposure to methyl bromide . Its acute and chronic toxicities are very high and in many countries it is

classified as “toxicity class I”. It is known as a developmental, neurologic and respiratory toxin

(Gemill et al ., 2013, de Souza et al ., 2013, Bulathsinghala et al. , 2014). Other known target organs are

the heart, adrenal glands, liver, kidneys and testis (Gemill et al ., 2013).

Accidental exposure to high concentrations of MB has been reported in many instances including

fumigation of museums in Japan (Yamano and Nakadate, 2006), when handling the fumigant in a

manufacturing facility in India (de Souza et al ., 2013) and when opening imported freight containers

(Baur et al ., 2010).

Recent research findings suggest links between exposure to MB and health problems, including

increas ed risk of developing prostate cancer, derived from occupational and community exposure

(Budnik et al ., 2012, Alavanja et al ., 2013, Cockburn et al., 2011). In another study (Gemill et al

., 2013), a correlation was found between impaired foetal growth duri ng the third trimester and

exposure to methyl bromide in residential areas

Risk of exposure is especially high when small disposable canisters (i.e. 500 to 750g) are used for MB

fumigation for pre plant soil under plastic sheets (Yamano et al ., 2001). Cani ster applications have

been eliminated for soil use in all non

- Article 5 and in many A5 countries as this application is

considered to be less efficient than other methods for the control of soil borne pathogens. Besides, this

treatment is considered to be more dangerous to workers than injection methods, because trained

contractors are not generally involved in MB application. This practice is not considered as effective

for pathogens’ control as use of MB/Pic mixtures and also can lead to high emissions o f methyl

bromide as the gas is released immediately beneath the plastic sheets. MBTOC notes with concern

that canister use is still allowed for preplant use and quarantine uses in a number of A5 countries e.g.

China, Egypt Jordan, Mexico.

The environmenta l acceptability of methyl bromide is handled by national regulatory authorities in

each country

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 15



# 1.4.6 Sustainable Alternatives for Preplant Uses

MBTOC urges Parties to consider the long term sustainability of treatments adopted as alternatives to

MB. The combination of chemical and non

- chemical alternatives in an IPM program provides

excellent results in the longer term. Decision IX/6 1(a)(ii) refers to alternatives that are ‘ acceptable

from the standpoint of environment and health’ . MBTOC has visited var ious regions where successful

non

- chemical alternatives e.g. soil less culture, grafting, solarisation, steam, biodisinfestation and

anaerobic soil disinfestation, are used as sustainable alternatives to MB. Several Parties consider these

techniques as via ble alternatives, particularly when an integrated approach that combines different

options is adopted.

MBTOC recognizes the potential benefit of the recent establishment of a California DPR “Strawberry

Non Fumigant Workgroup” to evaluate and adopt further chemical and non

- chemical technologies

such as: anaerobic soil disinfestation; soilless substrate systems and steam (CalDPR, 2013).



# 1.4.7 Standard Presumptions Used in Assessment of Nominated Quantities.

The tables below (Tables 1

- 6 and 1

- 7) provide the s tandard presumptions applied by MBTOC 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 17 th 

# MOP. Studies and reports to

support them hav e been provided in previous reports and were revised for some sectors after

consideration by the Parties at the 19 th 

# MOP. The rates and practices adopted by MBTOC as standard

presumptions are based on maximum rates considered acceptable by published litera ture 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, MBT OC continues to accept a maximum rate of 200 kg/ ha (20 g/m 2 

# ) in MB/Pic

formulations with high Pic

- containing mixtures with or without 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/m 2 

# ) 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. MBTOC also notes tha t certified runner production may involve regulations which

specify the mandatory use of a fumigant such as MB or an alternative, in order for the runners to be

“certified runners”.

The indicative rates used by MBTOC were maximum guideline rates, for the p urpose 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.

# 16 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# Tabl e 1

- 6. Standard Presumptions Used in Assessment of CUNs for Preplant Soil Use of MB

Comment CUN adjustment Exceptions

1. Dosage rates Maximum guideline rates for

MB:Pic 98:2 are 25 to 35 g/m 2 

## with

barrier films (VIF or equivalent); for

mixtures of MB/P ic are 12.5 to 17.5

g MB/m 2 

## for pathogens and

nutsedge respectively, under barrier

films depending on the sector. All

rates are on a ‘per treated hectare’

basis. Amount adjusted to maximum

guideline rates. Maximum rates

set dependent on formulation and

so il 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 re duced

proportionately to conform to

barrier film use. Where barrier film

prohibited or restricted by

legislative or regulatory

reasons

3. MB/Pic

Formulation:

Pathogens

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/Pi c

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 a djusted for

use with MB/Pic 67:33 (or

similar). Where Pic or Pic

- containing

mixtures are not registered

5. Strip vs.

Broadacre Fumigation with MB and mixtures

to be carried out under strip Where rates were shown in broad

acre hectares, the CUN was

adjust ed 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

regul ations on MB, or

open field production

of high health

propagative material



# Table 1

- 7. Maximum dosage rates for preplant soil use of MB by sector used since 2009 (standard

presumptions).

Film Type Maximum MB Dosage Rate (g/m 2 

# ) in MB/Pic mixtures (67:33 , 50:50)

considered effective for:

Strawberries and

Vegetables Plant

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

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 17



# 1.4.8 Adjustments for Standard Dosage Rates using MB/Pic Formulations

As in previous assessments, one key transitional strategy to reduce MB dosage has been the adoption

of M B/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) (P orter et al., 2006; Santos et al

., 2007; Hamill et al., 2004; Hanson et al., 2006). MBTOC notes that reported use of MB/Pic

formulations in the US shows that formulations with greater amounts of MB (CalDPR, 2012a) are still

being used in California and th e Party is urged to consider even lower dosage rates of MB for the

remaining CUN. This includes rates as low as 75 kg/ha (7.5 g/m 2 

# ) with mixtures of 30:70 or 33:67

mixtures (at 250 kg/ha or 25 g/m 2 

# ) or 100 kg/ha (10 g/m 2 

# ) of MB in 250 kg/ha (25 g/m 2 

# ) of 50 :50

MB/Pic mixtures in conjunction with barrier films (Table 1

- 8).

Table 1

- 8. 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

(kg/ha) of MB/Pic

formulation MB/Pic formulation (dose of MB in g/m 2 

# )

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 (previous CUN reports) show that a dosage of 10g/m 2 

# (e.g. MB/Pic 50:50 a t

200kg/ha with low permeability barrier Films) is technically feasible for many situations and equivalent to the

standard dosage of >20g/m 2 

# using standard PE films



# 1.4.9 Use/Emission Reduction Technologies

- Low permeability barrier films and dosage

redu ction

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 or other

mitigation strategies such as high moisture sea ling and the 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., 2009). These latter technologies have not been reported

or ad opted widely by Parties.

In southeast USA the reported use of barrier films in vegetable crops, which expanded rapidly to over

20,000 hectares in 2009 has continued to increase. A recent change in the regulations

– presently

allowing use of VIF in Califor nia

- should lead to an increase in the adoption of barrier films in that

State. MBTOC notes that barrier films particularly more recently developed totally impermeable

(TIF) films can be used with alternatives and this is consistently improving the perfor mance of

alternatives at lower dosage rates (Driver et al . 2011; Fennimore and Ajwa, 2011)]. Effectiveness at

lower dosages can allow for greater areas to be treated with 1,3

- D under township cap regulations.

# 18 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# As of December 1, 2012, EPA issued new set of soil fumigant product label changes, implementing

important new protections for workers and bystanders. In the frame of these changes, the State of

California now allows the use of VIF films for fumigation with MB, which were formerly prohibited

(Cal DPR, 2012b & c; EPA, 2013). MBTOC is at this time unclear on the impact this change could

have in terms of potential reduction of dose rates of MB and emission control. Studies continue to

show the advantages of barrier films and other technologies for reducin g emissions and improving

efficacy of alternatives as well as MB (Quin et al . 2013; Chellemi et al . 2013).

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 19 

# Table 1

- 9. Interim evaluation of CUNs from non A5 Parties for preplant soil use submitted in 2014 for 2016

Country Industry CUE for

2005 1 

## CUE for

2006 2 

## CUE for

2007 3 

## CUE for

2008 4 

## CUE for

2009 5 

## CUE for

2010 6 

## CUE for

2011 7 

## CUE for

2012 8 

## CUE for

2013 9 

## CUE for

2014 10 

## CUE for

2015 11 

## CUN for

2016 MBTOC

interim

rec for

2016

Australia Strawberry

runners 35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.760 29.760 29.760 29.760 29.760 [29.760]

MBTOC interim recommendation for 2016:

MBTOC recommends 29.760 tonnes for MB use in this sector in 2016. This is on the understanding that funding for research has been restored and efforts to find alternative s continue. MBTOC notes that mixtures of existing fumigants, and new formulations of fumigants with PIC (i.e.TF80 and TF60), ar e being trialled, and if effective, expect these to be

adopted and registered.

Nomination by the Party for 2016:

The quantity re quested for this CUN is 29.760 tonnes, an amount that has remained unchanged for this industry since 2009.

Circumstances of the nomination by the Party:

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

, Agrostistenuis sp, Raphanus spp

., Poa annua, Cyperus spp ). The nomination is based on a particular soil and temperature situation: very high clay and organic matter content

soils requiring fumigation treatments under cold temperatures.

In its CUN the Party argues that runner production in these kind of conditions, treated with MB:Pic (50:50 at a MB dose of 25 g/m 2 

## ) is needed to meet the certification standards.

The Victorian runner indust ry only produces runners in soils treated with MB:Pic, and is not using any other methods other than substrates for the found ation stock production

stage . Some non

- chemical alternatives are not feasible. Plant resistance is unreliable as an alternative to MB:Pic for delivering certified runners (Fang et al . 2012). Integrated soil

disinfestation with combinations of existing, registered fumigants is now considered the most likely and quickest approach fo r delivering a viable alternative to MB for the runne r

industry.

Although MB rates used exceeds MBTOC’s standard presumption of 20 g/m 2 

## , the lower rate is still unregistered in Australia. According to the Party, three years of trials with lower

MB rates do not support bioequivalency of these rates.

The Part y insists that soil

- less systems are not yet technically and economically feasible for adoption into generations beyond the foundation stock.

A significant change since the last nomination is the fact that in December 2013, the federal government agency, H orticulture Australia Limited, confirmed co

- funding for a new 3

- year research program into MB alternatives for strawberry runners.

MBTOC interim assessment for MB use in this sector in 2016:

MBTOC acknowledges that the Party has provided an economic analys is supporting their assertion that the expansion of the use of soilless substrates beyond the foundation

stock is not economically feasible.

# 20 MBTOC 2014 CUNs: Interim Recommendations

– May 2014 Country Industry CUE for

2005 1 

## CUE for

2006 2 

## CUE for

2007 3 

## CUE for

2008 4 

## CUE for

2009 5 

## CUE for

2010 6 

## CUE for

2011 7 

## CUE for

2012 8 

## CUE for

2013 9 

## CUE for

2014 10 

## CUE for

2015 11 

## CUN for

2016 MBTOC

interim

rec for

2016

The nomination indicates that funding for the R&D program has been confirmed in 2013, so the Party is back in acco rdance with Decision IX/6 (b) (i) and (iii). MBTOC notes that

t he Party is required to report the available results of its research programme to the Technology and Economic Assessment Pane l for its consideration to the 36th OEWG as per

Decision XXV/4. Whi le MBTOC once more recognizes the Party’s past efforts in research and development of MB alternatives (Mattner, 2012), these efforts have not resulted in

significant commercial uptake of alternatives. Furthermore, there have been essentially no significan t reductions made for this production region since 2005 and no reduction in

use rate as this is regulated by certification rules.

MBTOC is aware that soilless production is technically suitable for at least some part of the nomination, as it is in other p arts of the world i.e. Belgium (Robe 1997, 1998), Poland

(Trader et al

. 2007), France (Hennion et a l. 1997) and A5 countries e.g. Brazil (Janisch et al . 2012, Oliveira et a l. 2010), Uruguay (Giménez et al . 2008), and Paraguay

(Nacimiento and Lopez

- Medina, 2009). The nomination ratifies that industry does not consider further expansion of soil

- less systems for the production of mother and certified

runners as it is considered economically infeasible and reports technical problems on the foundation generatio n.

MBTOC still considers that soil

- less culture is a technique used widely throughout the world for production of strawberry runners and is technically and econ omically suitable for

some of the certified nursery production system as well as stock plants resulting in healthy nursery material (López

- Galarza et al ., 2010, Rodríguez

- Delfín, 2012).

MBTOC notes that after more than eleven years there is no action plan to phase out MB for this sector.

MBTOC comments on economics in 2014 for 2016:

 A comprehensiv e economic analysis shows that while foundation stock can be done in a soil

- less system, Mother and Certified stock cannot. The selling prices of Mother and

Certified stock would have to increase almost 7 fold (from A$0.34 per runner to A$2.03 and A$2.00 p er runner respectively to break even.

 Both operating and capital costs are about five times higher with a soilless system than open field production.

 The main reason is the capital cost of setting up the soilless system and a yield loss of around 18%. Pric es are assumed to stay the same for the two procedures.

 These differences do not include the compliance costs with municipal regulations, or the costs of waste treatment, but note t hat the costs of use of methyl bromide do not

include the real cost of dama ge to the ozone layer.

 Soilless systems are more labour intensive, and labour costs in Australia are very high. With MB/Pic pre

- plant soil treatment harvesting is done by machine, while with a

soilless system it will be done by hand. The additional labour cost is already included in the operating costs and is a large reason for the difference in operating costs.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission Reduction : No, but the Party states that standard films perform the same as VI F for the reduction of emissions in the cold temperatures and

heavy wet soils typical for strawberry runner production in Victoria. Party also states that use of VIF did not improve the e fficacy of reduced rates of MB to an

acceptable level for the strawbe rry runner industry.

 Dec. IX/6 b(iii) Research Program : An approved and funded research program is currently in place at the time of this nomination.

 Dec. IX/6 b(iii) Appropriate Effort : Research effort is adequate

- funded research program currently in place at the time of this nomination

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 21 Country Industry CUE for

2005 1 

## CUE for

2006 2 

## CUE for

2007 3 

## CUE for

2008 4 

## CUE for

2009 5 

## CUE for

2010 6 

## CUE for

2011 7 

## CUE for

2012 8 

## CUE for

2013 9 

## CUE for

2014 10 

## CUE for

2015 11 

## CUN for

2016 CUE for

2016

Canada Straw berr y

runners (PEI) 6.840 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.261 5.261 5.261 5.261 [5.261]

MBTOC interim recommendation for 2016:

MBTOC recommends the nominated amount of 5.261 tonnes for use in this sector in 2016. MBTOC notes that the Party i n its response to questions noted that it intends that 2016

is the final year for use of methyl bromide for strawberry runner production in Prince Edward Island, although this might dep end on the outcomes of the Pic 100 groundwater study.

Nomination by the Party for 2016:

The Party has nominated 5.261 t of MB, which was similar to the CUE granted for 2015 and the previous year’s CUEs since 2011. It is for use for multiplication on runners on

26.3ha of land, which includes the two final stages of multiplicat ion of plants exported from PEI. The nomination is based on a reduced rate of MB of 20 g/m2 under high barrier

films for the entire fumigated area (26.3 ha) which is consistent with MBTOC’s standard presumptions.

Circumstances of the nomination by the Pa rty :

The Party has attempted to replace MB with 1,3

- D in the past, but it was banned for use in Prince Edward Island in January 2003 due to ground water contamination. Chloropic rin

(PIC 100) is registered, but the PEI authorities have denied a permit for i ts use until further groundwater testing has been conducted. Long awaited studies on potential

groundwater contamination of Pic 100 have finally been commenced in December 2013 and are anticipated to continue for two yea rs. The Party is however required t o report

preliminary results to the 36 th 

## OEWG as per Decision XXV/4. The company at PEI has tested organic production from 2006

- 2009 with different varieties, but found that significant

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

500 kg/ha is the only formulation and rate registered for use in strawberry runners in PEI, and although this 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. The CUN for 2016 is based entirely on a red uced rate for MB of 200 kg/ha for the entire critical area (26.3 ha).

The Party noted that at this time greatest effort is concentrated on the groundwater study with chloropicrin, as it is curren tly considered the most feasible alternative for the grower.

The Party has also sought advice on soilless systems to reduce dependency on chemical fumigants.

MBTOC interim assessment for MB use in this sector in 2016:

After thorough review of the information provided by the Party, MBTOC now understands that the us e of micro

- propagated plants from USA and the scale up into soilless

substrates for the first stage of multiplication of runners at PEI to produce approximately 60,000 runners have replaced or a voided the use of methyl bromide in stages for which

MBTOC bel ieves there are effective alternatives. The nomination is requesting MB for the final two multiplication stages. Canada con siders the first stage of this field production

and multiplication as foundation stock, however this is different nomenclature to o ther countries and this has caused some confusion in past years. Whilst soilless production is

technically feasible for the later stages of production, MBTOC agrees from the information on economics that the use of soill ess culture for the remaining runner s is uneconomical

and impractical. For this reason MBTOC agrees with the Party that the focus should be to find suitable alternatives for soil disinfestation and urges the Party to complete the

groundwater studies to adopt chloropicrin either alone or in combination with other alternatives as soon as possible. MBTOC notes that metam sodium, metam potassium and

# 22 MBTOC 2014 CUNs: Interim Recommendations

– May 2014 Country Industry CUE for

2005 1 

## CUE for

2006 2 

## CUE for

2007 3 

## CUE for

2008 4 

## CUE for

2009 5 

## CUE for

2010 6 

## CUE for

2011 7 

## CUE for

2012 8 

## CUE for

2013 9 

## CUE for

2014 10 

## CUE for

2015 11 

## CUN for

2016 CUE for

2016

dazomet are also registered in Canada and could be considered for use in PEI under permit. MBTOC suggests that future progra ms for runners at PEI consider these alternatives

as it is unclear from the nomination whether these products are being considered as replacements to MB at PEI. MBTOC requeste d a copy of the review conducted by Canada on

soilless production systems, but this has not been provid ed. This is important, particularly as soilless systems are evolving rapidly and future systems may be more economical.

MBTOC also notes that MB formulations containing Pic (67:33) are used in PEI under permit without groundwater contamination a pparently occurring and suggests a similar

situation should be possible for Pic alone, which is not currently permitted.

MBTOC comments on economics in 2014 for 2016:

While the CUN is submitted on technical grounds, an economic argument is provided in response to M BTOC ́s recommendation of a 50% transition to soilless culture as

a technically feasible alternative. Such a transition would imply high capital costs, but at a very small reduction (8%) in t he required amount of MB. Production cost under

the current practi ce is $0.135 per second generation plants. Total cost under a soilless system is $0.425 per second generation plant. Revenue s stay the same as the

price is the same (no improvement in quality is expected) and yields are not assumed to decline (unlike the Australian case). While MBTOC has recommended a cheaper

soilless system, the party finds that the Australian alternative recommended by MBTOC is three times more expensive than the Haygrove system analysed in the CUN

and therefore is still uneconomic.

Com ments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission Reduction: Yes, uses barrier films with a reduced application rate of MB conforming to MBTOC’s presumptions

 Dec. IX/6 b(iii) Research Program: A research program is proposed based on groundwat er studies for Pic, a review has been conducted on the evaluation of soilless

methods to improve feasibility and consideration of improvements in the production processes.

 Dec. IX/6 b(iii) Appropriate Effort: The Party has demonstrated now that it is engag ed in an active research program and is implementing groundwater studies. The

party has also engaged a consultant to assist with full evaluation of any potential alternatives to MB.

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 23 Country Industry CUE for

2005 1 

## CUE for

2006 2 

## CUE for

2007 3 

## CUE for

2008 4 

## CUE for

2009 5 

## CUE for

2010 6 

## CUE for

2011 7 

## CUE for

2012 8 

## CUE for

2013 9 

## CUE for

2014 10 

## CUE for

2015 11 

## CUN for

2016 CUE for

2016

United

States Strawberry

(field) 2052.846 1730.828 1476.019 1349.575 12 69.32 1007.477 812.709 678.004 461.186 415.067 373.660 231.540 [231.540]

MBTOC interim recommendation for 2016:

MBTOC recommends the nominated amount of 231.540 tonnes for use in this sector for 2016. MBTOC acknowledges that the Party r educed the nomin ation by 38% from the

amount approved for 2015. MBTOC also acknowledges the Party ́s statements, which align with Decision XXV/4, that this will be the final nomination for this sector in order to

complete its intended transition from critical uses for met hyl bromide by the end of 2016.

Nomination by the Party for 2016:

The Party nominated 231.540 t of MB for use in 2016 on 1,362 ha at a dosage rate of 170 kg/ha. The Party indicated that the p roportion of total crop area to be treated with MB

was 9.0%.

C ircumstances of the nomination by the Party:

The CUN requests MB specifically for areas: 1) where a transition period is needed for the use of broadcast 100% chloropicrin in fields with high pest pressure, in particular, with

Macrophomina and Fusarium and 2) where 1,3

- dichloropropene (1,3

- D) is limited by township caps.

MBTOC interim assessment for MB use in this sector in 2016:

MBTOC agrees with the Party that alternatives are available for this nomination and respectfully acknowledges the Party has s tat ed that this is the final year for transition. MBTOC

endorses that alternatives are available for 100% of the nomination and notes that a recent meta

- analysis in this sector supports this and previous findings (Belova et al ., 2013,

Porter et al ., 2006). MBTOC also acknowledges the industries push to find more sustainable non chemical alternatives as reported recently by Fennim ore et al ., 2013. Key

chemical alternatives include shank applied 1,3

- D/Pic as well as other similar Pic mixtures, Pic alone or Pi c in sequential application with MITC generators (KPam, Vapam,

Dazomet) coupled with disease tolerant varieties of strawberries would be suitable to address a significant proportion of one or more of the 3 issues raised by the Party as a

reason for the nom ination ( Belova et al ., 2013, Medina

- Minguez 2012, Noling and Cody 2011, Porter et al. , 2006, Zveibel et al. , 2012). MBTOC also notes that formulations with

chloropicrin are the key chemical alternative effectively adopted in other regions of the world. M BTOC notes that the Party has accepted that the technical expertise required for

application of 100% chloropicrin already exists in California and uptake of this method will be feasible by the end of 2016.

MBTOC also notes that as of December 1, 2012, a new set of label changes went into effect for soil fumigant products, fully implementing important new protection for workers

and bystanders. In light of these changes, the State of California now allows the use of barrier films (VIF and TIF) for MB f umiga tion, which was formerly prohibited (Cal DPR,

2012b & c; EPA, 2013). Studies continue to show the advantages of barrier films and other technologies for reducing emissions and improving efficacy of alternatives as well as

MB (Qin et al., 2013; Chellemi et al., 2013; Luo et al. , 2013) and anticipate that the Party will continue to consider their adoption where feasible for this sector, either with th e

remaining MB use or with alternatives to minimise the environmental and health effects of their use as requi red in Decision XXV/4.

# 24 MBTOC 2014 CUNs: Interim Recommendations

– May 2014 Country Industry CUE for

2005 1 

## CUE for

2006 2 

## CUE for

2007 3 

## CUE for

2008 4 

## CUE for

2009 5 

## CUE for

2010 6 

## CUE for

2011 7 

## CUE for

2012 8 

## CUE for

2013 9 

## CUE for

2014 10 

## CUE for

2015 11 

## CUN for

2016 CUE for

2016

MBTOC comments on economics in 2013 for 2015:

 The CUN is based on the need for a transition period to move to 100% chloropicrin and regulatory (township cap) issues.

 Economic data are provided and show that steam and chloropicr in b0oth result in net revenues that are slightly higher than that of methyl bromide application

 Total phase

- out is planned for the 2017 season

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission Reduction: In California (high barrier) fil ms are now allowed for use with MB and with alternatives and although they appear not to be used with MB,

rates are below MBTOC’s standard presumptions. Further emission reduction may be possible with their adoption for any remain ing uses of MB.

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

 Dec. IX/6 b(iii) Appropriate Effort: California has extensive research programs being conducted and continual regulatory rev iews on the use of MB and other fumigant

alternatives in the State. MBTOC is unaware from the CUN application what efforts are being made to register some alternative s registered and being used in other areas of

the USA (eg. Pic

- Clor 60 and 80, DMDS in com bination with Pic).

1 

## 1ExMOP and 16MOP; 2 

## 16MOP+2ExMOP+17MOP; 3 

## MOP17+MOP18; 4 

## MOP18+MOP19; 5 

## MOP19+MOP20; 6 

## MOP20+MOP21; 7 

## MOP21+MOP22; 8 

## MOP22, 9 

## MOP23, 10 

## MOP24, 11 

## MOP25

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 25 Table 1

- 10 Interim evaluation of CUNs from A5 Parties for preplant soil use submitted in 2014 for 2015.

Country Industry CUN

for

2015 MBTOC interim

recommendation for

2015

Argentina Tomato and

Pepper 145 [0]

MBTOC interim recommendation for 2015:

MBTOC does not recommend this nomination for 2015.

Nomination by the Pa rty for 2015:

MBTOC does not recommend 145 tonnes of methyl bromide nominated by Argentina for critical uses for tomato and pepper producti on in protected cultivation in the critical

regions of Mar del Plata and La Plata. MBTOC requested disaggregation of this CUN (separate nominations for tomatoes and peppers) but the Party explained that this is not

possible as these two crops are grown simultaneously or sequentially on the same land and fumigation applies to both. The key pests are nematodes, fungi ( Rhiz octonia,

Sclerotinia, Phytophthora spp. ), and weeds ( Cynodon and Cyperus spp .). Rates of MB vary between 350 kg/ha to 500 kg/ha and MB/Pic70:30 formulations are used.

Circumstances of the nomination by the Party:

The Party states that 1,3

- D/Pic does not p rovide sufficient control of key pests in the critical areas, mainly due to soil types, which are heavy clay soils and soil t emperatures (5 to

23C). Chloropicrin is not registered alone and does not control weeds. Metam sodium shows erratic and insufficien t performance for weed and disease control most possibly also

due to soil type and weather conditions. Dazomet is not registered for edible crops and does not control nematodes. Steam boi lers are not commercially available and are costly.

Steam was trialle d as an alternative through the MLF funded projects and found to be efficient but economically infeasible.

MBTOC interim assessment for MB use in this sector in 2015:

The Party has not provided substantiation to support its claim that 1,3

- D/Pic or other a lternatives (ie metam sodium) are not effective under the particular circumstances of the

nomination. 1,3

- D/Pic is reported as a successful alternative in some regions of Argentina (Agüero y Borquez 2007; Adlercreutz, E.G.A. y A. Szczesny, 2010), however n o evidence of its lack of efficacy in the critical areas relating to the nomination was provided. MBTOC was unable to recommend without this information. Trials and results showing

that non

- chemical alternatives are not technically or economically feasible have also not been provided. MB also notes that the dose rate used by the Party appears to be 24.5 to

35.0 g/m 2 

## (350 to 500 kg/ha) and this exceeds MBTOC’s standard presumptions for these crops.

MBTOC notes that the Party has been supported by the MLF wi th 2 demonstration and 4 technical assistance projects since 1997 and that many alternatives have been trialled

(MLF, 2014a). The funding received from the MLF also supported two investment projects (one consisting of six tranches), which committed the Pa rty to phase out its whole MB

consumption for controlled uses by the end of 2014 (MLF 2014 ab).

Different types of alternatives have been adopted to replace MB in tomatoes and peppers in many developed and developing coun tries around the world, in differen t climates and

soil types. For example, grafting tomatoes and peppers onto resistant rootstocks is effective and in use in many A5 countries such as China, Egypt, Lebanon, Mexico, Morocco,

Romania, Tunisia and Turkey (MBTOC, 2011). The Party acknowledges t hat grafting is a promising alternative and has conducted preliminary trials with excellent results, when

combining grafted plants and biofumigation (Garbi et al . 2013). 1,3

- D/Pic is reported to provide excellent results and has been adopted as a key alte rnative in many countries

(MBTOC, 2011). The performance of metam sodium has been shown to be enhanced when applied with a spading machine (Slusarski et al., 2012)

# 26 MBTOC 2014 CUNs: Interim Recommendations

– May 2014 Country Industry CUN

for

2015 MBTOC interim

recommendation for

2015

MBTOC comments on economics in 2014 for 2015:

The CUN assumes a substantial yield reduction in both tomatoes and peppers while prices and costs remain the same for both treatments (MB and the alternative) for both cro ps.

Revenue reduction of 28% results from the use of alternatives. The reduction in revenue is partly due to a smaller drop in y i eld on the early crop, but mostly due to the

impossibility of a late crop because of the waiting time between applications and planting.

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

 Dec. IX/6 b(i) Emission Reduction: Low impermeable films are not adopted bu t have been trialled through the projects

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alternatives: Trials and research have been conducted through the MLF projects implemented in Argentina and also

directly by INTA (Argentinean Institute of Agri culture) and various universities. No reference related to the research in Argentina was provided with the nomination.

Dec. IX/6 b(iii) Appropriate Effort: MBTOC assumed considerable research has been conducted during the MLF funded projects but was una ble to assess the research effort

as no references or reports were provided of local R and D.

Argentina Strawberry

Fruit 100 [0]

MBTOC interim recommendation for 2015:

MBTOC does not recommend this nomination.

Nomination by the Party f or 2015:

The Party nominated 110 tonnes of methyl bromide for a critical use for strawberry fruit on 1,000 ha, which represents a MB r ate of 110 Kg/ha. This rate is lower that the reported

used rates (350

- 500 Kg/ha) in three key production regions, (Lules, Mar del Plata, Buenos Aires). The key pests are fungi ( Phytophthora

, Verticillium

, Fusarium) , and weeds

( Cyperus)

. MB rates vary between 350 kg/ha to 500 kg/ha and a 70/30 formulation is used

.

Circumstances of the nomination by the Party :

The Party sta tes that 1,3

- D/Pic does not control the entire pest spectrum and that metam sodium provides erratic results. According to the Party, chall enges to the adoption of

alternatives are mainly related to low soil temperatures and heavy rainfall at the time when fumigation needs to be performed. Chloropicrin alone is not registered and does not

control weeds. Dazomet is not registered for edible crops. Steam was evaluated as an alternative through various projects and was found to be technically effective but unsu itable

for large, open field areas and economically infeasible

.

MBTOC interim assessment for MB use in this sector in 2015:

MBTOC requested clarification from the Party on soil temperatures and these were provided. In the absence of further informa tion f rom the Party, the range of temperatures

provided, 6

- 23o C, are not considered by MBTOC low enough to impact performance of fumigants such as 1,3

- D/Pic. Further, the Party has not provided any additional information

to substantiate that 1,3

- D/Pic or other alternatives (ie metham sodium) are ineffective under the particular circumstances of the nominated areas. MBTOC was unable to

# MBTOC 2014 CUNs: Interim Recommendations

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recommend without this information. 1,3

- D/Pic is reported as a successful alternative for strawberry in other regions of Argentin a (Del Huerto

- Sordo, 2013). No evidence of lack of

effectiveness in the critical areas related to the nomination was provided, however MBTOC found references indicating positiv e results with alternatives such as metam

ammonium, 1,3

- D/Pic, metam sodium and metam potassium in the critical regions (Jaldo et al., 2007; INTA, 2008; 2007; Bórquez et al., 2007; Aguero and Bórquez, 2007; Bórquez

y Mollinedo, 2009, 2010; Adlercreutz and Szczesny, 2008, 2010). Trials with soil

- less culture in the same sector have show n encouraging results in Tucuman (Villagra et al

., 2012). MBTOC is unclear why these results have not been transferred to the regions nominated. MBTOC notes that the Party has been supported by the MLF with 2

demonstration and 4 technical assistance projec ts since 1999 and that many alternatives have been trialled (MLF, 2014a). The funding received from the MLF also supported two

investment projects (one consisting of six tranches), which committed the Party to phase out its whole MB consumption for con tro lled uses by the end of 2014 (MLF, 2014b).

MBTOC comments on economics in 2014 for 2015:

For the Mar del Plata region:

 Assumes a yield reduction from 93 to 62 t/ha using 1.3

- D + Pic because of heavy clay soils and low soil temperatures.

 From the yield redu ction calculates a decline in gross revenue of one third as prices are assumed to be the same for the two treatments.

 Argues that operating costs for the two treatments are similar, but these are not shown. However, the CUN then contradicts an d argues tha t weed control costs of 1.3

- D Pic

would be greater than for methyl bromide, as will conversion to a one year production system. In this case yields are still a ssumed to be lower (15

- 20%) and the costs of

fumigants, tarps and transplants will be higher. How ever, these costs are not given.

For the Lules region:

 Provides data on the movement in prices from the early harvest to late harvest. Prices start at $6/kg and end at <$1.

 Argues that weed control is insufficient with 1.3

- D Pic, that the planting time i s short because of soil temperature and rainy conditions and prolonged plant back time. As a

result, the strawberries miss the market window and are sold at the high

- season price rather than the early

- season price.

 In this case, yield is expected to incre ase with 1.3

- D Pic, but despite this, the fall in prices results in a loss in revenue of around 50%.

 The “with methyl bromide” price is taken as $1.69/kg and the “with 1.3

- D Pic” as $0.72/kg.

 Again, costs of production are expected to be similar for the tw o treatments, in this case without the caveats.

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

 Dec. IX/6 b(i) Emission Reduction: Low impermeable films are available and have been trialled through the projects but are not yet adopted. A reference to lack of

registration of TIF is made

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alternatives: Trials and research have been conducted through the MLF projects implemented in Argentina and also

directly by INTA (Argentinean Institute of Agriculture) and v arious universities. No reference related to the research conducted in Argentina was provided with the nomination.

 Dec. IX/6 b(iii) Appropriate Effort: MBTOC assumed considerable research has been conducted during the MLF funded projects but was unable t o assess the research

effort as no references or reports were provided by the Party of local R and D.

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China Ginger Open 90 90

MBTOC recommendation for 2015:

MBTO C recommends the requested amount of 90 tonnes of MB for this use in 2015.

Nomination by the Party for 2015:

China nominated 90 tonnes of methyl bromide for critical uses for open air ginger production on 229.59 ha at the rate of 40g/ m 2 

## for use in 2015 . The target pests are, Ralstonia

solanacearum

, Pythium spp. Meloidogyne spp and Cyperus rotundus . MB is used in regions where soil

- borne pathogen pressure is high and this only represents a small

percentage (0.29%) of the total ginger area. The request is only for ginger grown in the Shandong region where ginger is grown continuously and where pressure from the target

pests is high.

Circumstances of the nomination by the Party :

China is using small disposable canisters of MB (681 g/canister), using standar d polyethylene films. MB is applied in canisters (98:2), as cold gas at a rate of 400 kg/ha, which is

below the rate registered in China. According to the Party, chloropicrin is the only chemical alternative registered in China for this sector. Chloropicr in did not provide effective

control of Meloidogyne spp and Cyperus rotundus. In addition, chloropicrin causes phytotoxicity and needs longer fumigation time obliging farmers to postpone the planting tim e

which affects yield, quality and marketing. Howeve r a recent study confirms that chloropicrin is a promising alternative with good efficacy against Ralstonia solanacearum , which

can be used successfully in integrated pest management programmes in China (Mao et al ., 2014).

In spite of their proven efficacy , the other chemical alternatives, 1,3

- dichloropropene, dazomet, iodomethane, metam sodium, dimethyl disulfide and sulfuryl fluoride are not

registered for use on soilborne pathogens in this sector in China. SF however has been shown to control root

- knot nematodes and to reduce the levels of key soil pathogens in

research trials (Aocheng et al . 2014). Chloropicrin and 1,3 D have been formulated in capsules for trial work. Trials with Pic are encouraging (Mao et al ., 2014). The tested 1,3

- D/Pic capsule form ulation provides a promising method for soil pest and disease control and reducing environmental emissions and potential huma n exposure in greenhouse

vegetable cultivation (XiaoXue et al. , 2013). Telone C

- 35 is an excellent MB alternative and has provided acceptable weed control efficacy (XiaoXue et al ., 2013), but this

formulation is not registered.

According to the Party, non chemical alternatives (crop rotation, bio

- fumigation, solarization, steaming) are not technically and economically feasible. Barrie r films (VIF and TIF)

are produced in China, but are not used for ginger production due to their high cost and low efficacy under low temperatures. MB is applied every year during early spring or late

autumn.

MBTOC interim assessment for MB use in this sec tor in 2015:

MBTOC accepted the Party ́s information that alternatives are not available for this nomination, particularly as 1,3

- D is unavailable for use in China. MBTOC however notes that

other countries which applied MB using canisters on a small scale basis have phased out for this sector (eg Japan). In China the registered MB application rate varies between

500 and 750 kg/ha (Aocheng, 2014). Although the amount requested is based on a use rate of 40g/m 2 

## (without VIF or TIF), the application is based o n the use of canisters of MB

which are less efficient than soil injection methods and thus the rate proposed is considered appropriate. This rate is high er than the rates used for ginger before in Japan , but the

target pests in China, also include Ralsto nia and nutgrass ( Cyperus ), which are more difficult to control. MBTOC considers that in the absence of effective alternatives MB/Pic

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50:50 can be suitable for this sector, but China would need to develop technology to formulate and apply this formulation . MBTOC considers that barrier films should be used in

future and urges the Party to consider accessing these films. MBTOC is also aware that chloropicrin combined with dimethyldis ulphide or chloropicrin with fosthiazate have shown

promising results (Aoche ng, pers. comm.).

MBTOC notes that the Party has been supported by the MLF with one demonstration project, three project preparation grants and one investment project con sisting of eight

tranches since 1994 and that many alternatives have been trialled. Th e funding received from the MLF was support for investment projects and committed the Party to phase out

its whole MB consumption for controlled uses by the end of 2014 (MLF, 2014 ab).

MB canisters are used because they provide small

- scale farmers with an easy application method and the ability to apply targeted amounts of MB to small areas where injection

machinery may be difficult to use (TEAP 2008). However, they have been eliminated for soil use in many Article 5 countries as this application is conside red to be less efficient for

the control of soil

- borne pathogens than injection methods. Use of canisters is also considered to be more dangerous to workers because trained c ontractors are not involved in its

application. This practice also leads to high e missions of MB.

Even though the Party did not present any management strategy, it stated that they hoped to register more alternatives for gi nger by 2018 to possibly be able to phase out by

2018. According to reports presented to the ExCom, satisfactory p est and disease control has been obtained in ginger crops with the combination of high dosages of chloropicrin,

improved application methods of this fumigant and dazomet, and use of other chemicals and biological nematicides, in an IPM a pproach. PIC is us ed for soil fumigation in areas

where the main ginger soil

- borne pathogens Pythium spp. and Ralstonia solanacerum are main pests.

MBTOC comments on economics in 2014 for 2015:

 Ginger prices have been increasing, so more farmers wish to produce it. Chlorop icrin is the only registered alternative, but requires a long fumigation period and damages the

ginger when applied in low temperatures. Besides, it does not control root

- knot nematodes. With chloropicrin, planting time must therefore be postponed, and thi s affects

yields, quality and time to market, resulting in a significant loss in net revenue.

 Non

- chemical alternatives include crop rotation, but land in China is scarce. Soilless systems require capital investment and tr ained farmers. Steam, is expensiv e. Other

alternatives (soil disinfection, bio

- fumigation) are technically infeasible given the particular growing conditions.

 The Party argues that the price of ginger will be lower with chloropicrin (Methyl bromide: $9.02/ kg ; chloropicrin: $6.89/ kg ) because of the root

- knot nematodes impact on the

product quality

 Yield with methyl bromide is 96.45 tonne/ha, while with chloropicrin is 86.22 tonne/ha, again because of the effect of root

- knot nematodes.

 Gross revenue with chloro picrin is 44% less than that of Methyl Bromide (because of the yield and price difference)

 Net revenue is 25% of that of methyl bromide; put another way, net revenue has declined by well over two thirds.

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

 Dec. IX/6 b(i) Emission Reduction: VIF and TIF are produced in China, but are not used for ginger production due to very high cost and low efficacy under low

temperatures. MB is applied every year during early spring or late autumn.

 Dec. IX/6 b(iii) MLF Assistanc e/Adoption of Effective Alternatives: Research has been conducted on chemical alternatives (chloropicrin + DMDS, chloropicrin +

fosthiazate and chloropicrin + avermectins). It is expected that some chemicals will be registered by 2018. China is trying a lso to develop the flame sterilization technology.

 Dec. IX/6 b(iii) Appropriate Effort: Yes considered appropriate as experiments are being conducted to register chemical alternatives by 2018.

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China Ginger

Protected 30 [24]

MBTOC recommendation for 2015:

MBTOC recommends a reduced amount of 24 tonnes of MB for this use in 2015.

MBTOC considers that the same rate of 40g/m 2 

## that is used for open field production of ginger in China should be feasible for ginger production in protected cropping as the pests

are identical. MBTOC also considers that China produces and has trialled barrier films and that these films may be available in the future to further reduced dosage rates, and

urges the Party to consider their adoption. China’s current position i s that these films do not provide an advantage in the cool soils used for ginger production in the Shandong

region, however the barrier films do offer a means to further reduce emissions.

Nomination by the Party for 2015:

China nominated 30 tonnes of MB fo r Ginger production in protected cultivation (61.2 ha) at the rate of 50g/m 2 

## for use in 2015

. This represents 12.24 % of the total ginger

protected area. MB is applied annually. T he target pests are similar to the open field production, i.e. Ralstonia sola nacearum, Pythium spp. Meloidogyne spp and Cyperus

rotundus

. The request is only for ginger grown in the Shandong region where ginger is grown continuously and thus pressure from the tar get pests is high.

Circumstances of the nomination by the Party :

Chin a is using small disposable canisters of MB (681 g/canister) for this use, using standard polyethylene films. It is applied as a cold gas (98:2), at a rate of 500 kg/ha. In China

the registered MB application rate for canister use varies between 500 and 7 50 kg/ha (Aocheng, 2014). According to the Party, chloropicrin is the only chemical alternative

registered in China for this sector. Chloropicrin did not provide effective control of Meloidogyne spp and Cyperus rotundus, . In addition, chloropicrin causes phytotoxicity and needs

longer fumigation time obliging farmers to postpone the planting time which affects yield, quality and marketing. However, a recent study confirms that it is a promising alternative

with good efficacy against Ralstonia solanacearum , which can be used successfully in integrated pest management programmes in China (Mao et al ., 2014)

In spite of their proven efficiency, the other chemical alternatives 1,3

- dichloropropene, dazomet, iodomethane, metam sodium and dimethyl disulfide and su lfuryl fluoride are not

registered in China. S ulfuryl fluoride can be used as a soil fumigant to control root

- knot nematodes and to reduce the levels of key soil pathogens (Ao cheng et al . 2014).

Chloropicrin and 1,3 D have been formulated in capsules, wi th Pic providing encouraging results (Mao et al ., 2014) The tested 1,3

- D/CP gel cap formulation provides a promising

method for soil pest and disease control and reducing environmental emissions and potential human exposure in greenhouse vege table cultivat ion ( XiaoXue et al ., 2013). Telone

C

- 35 is an excellent MB alternative and has provided acceptable weed control efficacy (XiaoXue et al ., 2013).

According to the Party, most of the reported n on

- chemical alternatives (crop rotation, bio

- fumigation, solariza tion, steaming) are not technically and economically feasible.

VIF and TIF are produced in China, but are not used for ginger production due to very high cost and low efficacy under low te mperatures. MB is applied every year during early

spring or late aut umn.

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MBTOC interim assessment for MB use in this sector in 2015:

MBTOC accepted the Parties information that alternatives are not available for this nomination, particularly as 1,3

- D is unavailable for use in China. MBTOC however notes that

other countri es which applied MB using canisters on a small scale use have phased out for this sector and have identified alternatives (eg Japan). MBTOC considered that a use

rate should be brought in line with the outdoor ginger production as the target pests are simi lar i.e. 40g/m 2 

## (without VIF or TIF). MBTOC notes that the rate is higher than the rates

used for MB applied by canisters for ginger in Japan before they phased out MB. MBTOC considers that in the absence of effect ive alternatives MB/Pic 50:50 would be sui table for

this sector, but China would need to develop technology to formulate and apply this MB/Pic formulation. MB considers that bar rier films should be used in future for this use and

urge the Party to consider accessing these films. MBTOC is also awar e that chloropicrin combined with dimethyl disulphide or chloropicrin with fosthiazate have shown promising

results (Aocheng, pers. comm.).

MBTOC notes that the Party has been supported by the MLF with one demonstration project, three project preparation g rants and one investment project consisting of eight

tranches since 1994 and that many alternatives have been trialled (MLF, 2014a). The funding received from the MLF was support for investment projects and was committed to

phase out its whole MB consumpt ion for controlled uses by the end of 2014 (MLF, 2014b).

As noted for the ginger open field nomination, use of canisters of MB have been eliminated for soil use in many Article 5 cou ntries as this application is considered to be less

efficient for the cont rol of soil

- borne pathogens than injection methods. Use of canisters is also considered to be more dangerous to workers because trained c ontractors are not

involved in its application. This practice leads also to high emissions of MB. Canisters are used be cause they provide small

- scale farmers with an easy application method and the

ability to apply targeted amounts of MB to small areas where injection machinery may be difficult to use (TEAP 2008).

Even though the Party did not present any management strat egy, the Party stated that they hoped to register more alternatives for ginger by 2018 to possibly be able to phase out

by 2018. According to reports presented to the ExCom , satisfactory pest and disease control has been obtained in ginger crop s with the combination of high dosages of

chloropicrin, improved application methods of this fumigant and of dazomet and use of other chemicals and biological nematici des, and IPM. PIC is used for soil fumigation in

areas where the main ginger soil

- borne pathogens Pythium spp. and Ralstonia solanacerum

. In many countries, soil less culture has proven to be an excellent alternative to MB

for ginger in protected cultivation e;g. Hawaii, USA (Maine), Mauritus and India (Hayden et al ., 2004, Hepperly et al . 2004, Kra tky 1998, Mamta and Shraddha 2013, Sato 1999,

Sayed 1984, Singh and Singh 2012, Suhaimi et a l. 2012). MBTOC considers that this alternative should be considered in China for areas where MB is used for in ginger,

especially in protected cultivation. The in itial capital investment is not considered to be high because greenhouses are already available. Ginger farmers may also have available

locally the basic systems of plastic bags, local substrate and adequate fertigation/ irrigation systems for setup of the se systems. Training for a centralized region is also

considered not to be prohibitive. During the MBTOC meeting an overview of soil less culture for ginger production was present ed and is available to the Party.

MBTOC comments on economics in 2014 for 20 15:

 Ginger prices have been increasing, so more farmers wish to produce it. Chloropicrin is the only registered alternative, but requires a longer period for fumigation time, and

damages the ginger when applied in low temperatures and does not control root

- knot nematodes. With chloropicrin, planting time must therefore be postponed, and this

affects yields, quality and time to market, resulting in a significant loss in net revenue.

 Non

- chemical alternatives include crop rotation, but land is scarce and ging er is profitable, or soilless, which requires capital investment and more experienced farmers; or

steam, which is expensive. Other alternatives (soil disinfection, bio

- fumigation) are technically infeasible given the particular growing conditions.

 Argues t hat the price of ginger will be lower with chloropicrin (Methyl bromide: $9.02/ kg ; chloropicrin: $6.89/ kg because of the quality impact of root

- knot nematodes.

 Yield with methyl bromide is 96.45 t/ha, while with chloropicrin it is 86.22 t/ha, again because of the effect of root

- knot nematodes.

 Gross revenue with chloropicrin is 44% tha t of Methyl Bromide (because of the yield and price difference.

 Net revenue is 25% of that of methyl bromide; put another way, net revenue has declined by well over two thirds.

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

 Dec. IX/6 b(i) Emission Reduction: VIF and TIF are produced in China, but are not used for ginger production due to very high cost and low efficacy under low

temperatures. MB is applied every year during early spring or late autumn.

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alt ernatives: Research trials within the MLF

- funded investment project commenced in this sector in 2008 and will

be completed in 2014. Promising results have been obtained. Additionally, active research is being conducted on chemical a lternatives (chloropi crin + DMDS, chloropicrin

+ fosthiazate and chloropicrin + avermectin). It is expected that some chemicals will be registered by 2018. China is trying also to develop the flame sterilization technology.

 Dec. IX/6 b(iii) Appropriate Effort : Yes, considered appropriate as experiments are being conducted to register chemical alternatives by 2018

Mexico Raspberries 70 [41.418]

MBTOC interim recommendation for 2015:

MBTOC recommends 41.418 t tonnes of MB for use in raspberry nurseries for 2015. This amount does not allow for the contingency amount requested for projected growth of the

industry in 2015. MBTOC based the decision on the actual amount of MB reportedly consumed in the most recent full year of co nsumption in 2012 as 2013 data has not been

reported. MBTOC acknowledges that past historic data may not have been complete as only two out of three growers reported th eir use of MB in 2012. This recommendation has

been made as trials have only recently been initiated and there is reportedly insufficient data provided to the Party to evaluate the performance of alternatives for this relatively new

industry. MBTOC considers that if results show feasibility that rapid adoption will follow.

Nomination by the Party for 2015:

The quantity requested for this CUN is 70 tonnes, for use in raspberry nursery stock production in the Jalisco and Michoacan States. MB formulation s applied are 50:50,

broadacre, in dosages of 200 kg/ha, once a year and normally not under VIF. This rate however conforms with MBTOCs standard presumption for nursery material.

Circumstances of the nomination by the Party:

The raspberry nursery industry in Mexico is evolving, and small low/medium technology production systems now coexist with lar ge “professional” nursery producers similar to

those found in California. The industry previously sourced transplants from California for many raspberry growers in Mexico. The transition includes confronting many of the same

challenges facing California and the EU to produce raspberry nur sery stock that meets the high health standards demanded by the marketplace. Trials of methyl bromide

alternatives were recently initiated in 2012.

This new industry is growing rapidly and the land area requiring methyl bromide is expected to continue to increase while the additional field trials are on

- going. The party is

requesting increased methyl bromide in anticipation of the expanded acreage for this industry.

The Party states that the key pests affecting strawberry runner production are the fu ngi Phytophthora, Pythium, Fusarium

, Rhizoctonia, Verticillium, Colletotrichum, and weeds

such as Cyperus spp and Malva neglecta

.

Available alternatives

- according to the nomination

- cannot control target pests adequately to meet “market standards”, altho ugh no certification thresholds are established or

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required by regulation. However, a research program was put in place in 2012 and showed promising results especially with 1,3D + chloropicrin; and chloropicrin + metam sodium,

followed by metam sodium alon e. A new round of trials began in 2013/14 to obtain additional data about the efficacy of the alternatives (López Aranda et al .; 2012; Cotero et al

., 2013; SEMARNAT

– UNIDO; 2013 ). The Party anticipates that soilless systems would be expensive and require a significant investment as infrastructure does not exist.

MBTOC interim assessment for MB use in this sector in 2015:

MBTOC acknowledges that an active research program was recently initiated and recognizes that additional time is needed to c onduct tri als to gain confidence in the efficacy of

the alternatives under Mexican conditions.

MBTOC accepts that a quantity of MB is required for this industry at present and has used the most recent usage for the recom mendation. MBTOC however considers the

requ est for increased methyl bromide in anticipation of a potential increase in acreage to be a contingency request, rather than a request based on the current circumstances of

the nomination. MBTOC does not recommend contingency requests. MBTOC notes that s ome parties have adopted a policy that they will not nominate methyl bromide for the

purpose of increasing the acreage of a specific industry. MBTOC encourages this party to consider adopting a similar policy.

MBTOC notes that the Party has been supported by the MLF with 2 demonstration and 2 technical assistance projects plus 4 project preparation grants, and one investment

project also funded bilaterally by Italy and Canada since 1998, and that many alternatives have been trialled across a range of secto rs (MLF, 2014a), although trials for this sector

started only recently (SEMARNAT

- UNIDO, 2014). The funding has been received from the MLF to support Mexico with the phase out its whole MB consumption for controlled

uses by the end of 2013 (MLF, 2014b).

MB TOC comments on economics in 2014 for 2015:

 Because Methyl bromide alternatives are not yet used commercially for raspberry nurseries in Mexico, there is still limited i nformation on their cost and feasibility, especially

because nursery production require s cleaner plants than fruiting fields.

 Data on the production costs with methyl bromide are however provided for future comparison.

 For strawberries the cost of application of chloropicrin and 1.3D

- Pic is roughly comparable to that of methyl bromide, whi le application of metam sodium is around a third of

the cost

 For raspberries only the cost of methyl bromide application is available.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission Reduction: Most growers do not use barrier films (VIF or TIF), although some growers are beginning to try it. The research program includes low

permeability films. The formulation of MB/Pic is 50:50, which contributes to emission reduction.

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alternatives : Trials in an MLF project commenced in this sector in 2011/2012 and will be completed in 2014.

Promising results have been obtained.



#  Dec. IX/6 b(iii) Appropriate Effort: Research effort is adequate.

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Mexico Strawberries 70 [43.539]

MBTOC Recommendation for 2015:

MBTOC recommends 43.539 t of MB for use in strawberry nurseries for 2015. This amount does not allow for the contingency amo unt requested for projected growth of the

industry in 2015, and has based the decision on the actual amou nt of MB reportedly consumed in 2013. MBTOC also notes that some Parties have adopted a policy that they will

not nominate MB for the purpose of increasing the acreage of a specific industry. Also, that the use for strawberry nurserie s commenced after 20 05 when consumption was

capped at 80%. A recommendation has been proposed, as trials have only recently been initiated and there is reportedly insuff icient data provided to the Party to evaluate the

performance of alternatives for this relatively new indus try. MBTOC considers that if results show feasibility that rapid adoption of alternatives will follow.

Nomination by the Party for 2015:

The quantity requested for this CUN is 70 tonnes, for use in strawberry runner production in the Jalisco and Michoaca n States. MB formulations applied are 50:50, broad acre, in

dosages of 200 kg/ha, once a year and normally not under VIF.

Circumstances of the nomination by the Party:

The strawberry nursery industry in Mexico is evolving, and small low/medium technology p roduction systems now coexist with large “professional” nursery producers similar to

those found in Spain and California that were previously the source of transplants for many berry growers in Mexico. This tr ansition includes confronting many of the same

challenges facing Spain, California, Australia, and Canada to produce strawberry runners that meet the high health standards demanded by the marketplace. Trials of methyl

bromide alternatives were recently initiated in 2012.

This new industry is growi ng rapidly and the land area requiring methyl bromide is expected to continue to increase while the additional trials are ong oing. The party is requesting

increased methyl bromide in anticipation of the expanded acreage for this industry.

The Party stat es that the key pests affecting strawberry runner production are the fungi Phytophthora, Pythium, Fusarium

, Rhizoctonia, Verticillium, Colletotrichum, and weeds

such as Cyperus spp and Malva neglecta . Nematodes and Macrophomina were specifically excluded a s problems, for the moment, in the Party ́s responses to MBTOC.

Available alternatives

- according to the nomination

- cannot control target pests adequately to meet “market standards”, although no certification thresholds are established or

required by regul ations. However, a research program was put in place in 2012 and showed promising results especially with 1,3D + chloropicrin; and chloropicrin + metam

sodium, followed by metam sodium alone. A new round of trials began in 2013/14 to obtain additional dat a on the efficacy of the alternatives (López Aranda et al .; 2012; Cotero et

al ., 2013; SEMARNAT

– UNIDO, 2013 ). The Party anticipates that soilless systems would be expensive and require a significant investment as infrastructure does not exist.

MBTOC int erim assessment for MB use in this sector in 2015:

MBTOC acknowledges that the active research program was recently initiated and recognizes that additional time is needed to c onduct trials to determine the efficacy of

alternatives under Mexican conditions

. MBTOC notes that although the nominating industry is recent and uses more sophisticated management approaches, there are traditional

nurseries in the country that do not use MB fumigation at all (INIFAP; 2011).

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MBTOC considers the request for increased methyl bromide in anticipation of a potential increase in acreage to be a contingency request, rather than a request based on the

current circumstances of the nomination. MBTOC does not recommend contingency requests and has adjusted the recommendation t o remove the contingency amount of methyl

bromide. MBTOC notes that some Parties have adopted a policy that they will not nominate methyl bromide for the purpose of i ncreasing the acreage of a specific industry.

MBTOC notes that the Party has been suppor ted by the MLF with 2 demonstration and 2 technical assistance projects plus 4 project preparation grants, and one investment

project also funded bilaterally by Italy and Canada since 1998, and that many alternatives have been trialled across a range of se ctors (MLF, 2014a), although trials for this sector

started only recently (SEMARNAT

- UNIDO, 2014). The funding has been received from the MLF to support Mexico with the phase out its whole MB consumption for controlled

uses by the end of 2013 (MLF, 2014b).

MBTOC comments on economics in 2014 for 2015:

The nomination was not based on economic arguments.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission Reduction : Most growers do not use VIF or TIF, although some growers are beginning to try it. The research program includes low permeability

films. Formulation is 50:50 which contributes to emission reduction.

 Dec. IX/6 b(ii) MLF Assistance/Adoption of Effective Alternatives: Trials in an MLF project commenced in this sector in 2011/2012 an d will be completed in 2014.

Promising results have been obtained.

 Dec. IX/6 b(iii) Appropriate Efforts: Research effort is adequate.

# 36 May 2011 TEAP Report on 2011 CUNs: Interim Report



# 1.5 Interim evaluation of CUNs: Structures and Commodities

A group of MBTOC members, appointed by the co

- chairs, assessed the single remaining CUN in the

SC sector submitted in 2014 for 2016 (US dry cure pork). Discussion was later held in plenary to

discuss the proposed recommendation and reach consensus. Information provided during the bilateral

discussion held via teleconference with the US delegation and experts on alternatives to MB for cured

ham were considered in the course of the assessment.



# 1.5.1 Standard rate presumptions

MBTOC assessed the SC CUN for appropriate MB dosage rates and deployment of MB emissi on/use

reduction technologies, such as appropriate sealing techniques.

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

feasible steps have been taken to minimise the critical use and any associated e mission of methyl

bromide ’. Decision Ex.II/1 also mentions emission minimisation techniques, requesting Parties “... to

ensure, wherever methyl bromide is authorised for critical

- use exemptions, the use of emission

minimisation techniques that improve gas ti ghtness or the use equipment that captures, destroys

and/or reuses the methyl bromide and other techniques that promote environmental protection,

whenever technically and economically feasible. ”

With the beginning of the CUN process in 2005, MBTOC publis hed its standard presumptions for

structures (20g m

- 3 

# ) and indicated that the European Plant Protection Organization’s (EPPO)

published dosage rates for commodities should be considered standard best practice for fumigation

worldwide. Since that time all P arties submitting CUNs stated their adherence to those practices. The

EPPO dosage rates for commodity treatment vary by commodity, sorption rate and environmental

conditions. They can be found in annexes to the MBTOC 2006 Assessment Report (MBTOC, 2007).

W here possible, reduced dosages, combined with longer exposure periods, can reduce MB

consumption, while maintaining efficacy (MBTOC 2007).



# 1.5.2. Details of the evaluation

The total MB volume nominated in 2014 for post

- harvest uses in 2016 was 3.240 tonnes . MBTOC

recommended 3.240 tonnes (Table 1.11 and 1.12). Table 1

- 12 provides the MBTOC

- SC interim

recommendation for the CUN submitted.

Table 1

- 11. Summary of the interim recommendations for a CUE for postharvest uses

of MB (tonnes) for 2016 submitted i n the 2014 round.

Country and Sector Nominated in 2014 (tonnes) Recommended for 2016

(tonnes)

United States

- Dry cure pork 3.240 [3.240]

Total 3.240 [3.240]

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 37 Table 1

- 12. Interim evaluation of CUNs from non A5 Parties for structures and commodities submitted in 2014 for 2016

Country Industry CUE for

2005 1 

## CUE for

2006 2 

## CUE for

2007 3 

## CUE for

2008 4 

## CUE for

2009 5 

## CUE for

2010 6 

## CUE for

2011 7 

## CUE for

2012 8 

## CUE for

2013 9 

## CUE

for

2014 10 

## CUE

for

2015 11 

## CUN for

2016 MBTOC

Rec. for

2016

United

States Dry Cu re

Pork 67.907 40.854 18.998 19.669 18.998 4.465 3.73 3.730 3.730 3.730 3.240 3.240 [3.240]

MBTOC interim recommendation for 2016:

MBTOC recommends 3.240 tonnes, the amount nominated by the Party for use in US Southern dry cure pork in long storage in 20 16.

Nomination by the Party for 2016:

The Party nominated 3.240 tonnes, the same amount granted by the Parties for this use in 2015.

Circumstances of the nomination:

Presently, there is still no commercially effective and economically feasible alternati ves to methyl bromide for the specialised disinfestation of ham houses containing

Southern dry cure pork, a unique regional, traditional product, that is stored (cured) for long periods. Previous reductions in methyl bromide consumption have been

achieved through improvements in fumigation practice, reduced curing time and reduced frequency of fumigation. The nomination states t hat there is no further scope for

reduction through similar changes. The pests of this product are the red

- legged ham beetle ( Necro bia rufipes ) and the ham mite ( Tyrophagus putrescentiae ), with the mite

being particularly difficult to control to US food hygiene standards (nil tolerance on inspection). Many ham houses using sho rt curing times do not now use methyl bromide

fumigation.

T here is an ongoing multi

- university, multi

- state research program which is focused on improving processing sanitation, IPM and pest control through a variety of possib le

fumigants and physical processes (Amoah et al ., 2012; Phillips, 2013a, b). The Party has previously reported processors and researchers were trying steam cleaning, use

of approved disinfectants with acaricidal properties, dips and coatings, to protect hams in store. The results of investigations with various alternative fumigants and

nonch emical treatments on the ham mite Tyrophagus putrescentiae have not yet been fully successful (e.g. Abbar et al ., 2012; 2013; Zhao et al ., 2012a, b). Recently, a

commercial trial was carried out with phosphine applied as magnesium phosphide for mite contro l (Phillips, 2013c). While this was successful in controlling the mites,

corrosion damage to exposed electronics in the houses was unacceptable.

Southern dry cure pork processors only fumigate when the pests, or signs of the pests, are present.

MBTOC in terim assessment for MB Use in this sector in 2016:

The US has a continuing and robust research program into methyl bromide replacement for this specific situation and commodity . A number of promising lines of

investigation have been identified. These incl ude various dips, some insecticide formulations and sulfuryl fluoride fumigation with added heat. No effective and viable

replacements on a commercial scale have been identified at this time, though use of phosphine appears most promising with som e modific ations in application technique.

MBTOC notes that there are well

- known techniques for preventing phosphine

- related corrosion, including sealing and other protection of the susceptible components.

# 38 MBTOC 2014 CUNs: Interim Recommendations

– May 2014 Country Industry CUE for

2005 1 

## CUE for

2006 2 

## CUE for

2007 3 

## CUE for

2008 4 

## CUE for

2009 5 

## CUE for

2010 6 

## CUE for

2011 7 

## CUE for

2012 8 

## CUE for

2013 9 

## CUE

for

2014 10 

## CUE

for

2015 11 

## CUN for

2016 MBTOC

Rec. for

2016

There appears to be scope for further reduction in frequency of treatment through better pest monitoring and fumigation techniques. MBTOC notes that recapture is not

currently used for reduction of emissions in the absence of alternatives and that there are recapture units commercially avai lable.

MBTOC comments on economics in 2014 for 2016:

The CUN rests on technical infeasibility, so no economic analysis was conducted.

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

 Dec. IX/6 b(i) Emission Reduction : The CUN states that improvements in sealing and fumigant containment have been made.

 Dec. IX/6 b(iii) Research Program : There is an ongoing program testing and trialling promising alternatives

 Dec. IX/6 b(iii) Appropriate Effort : see above

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 39



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XiaoXue J., Kang Q , Sa D, HongYan W , XiaoMing X.,, Wang KaiYun W 2013. Effects of 1,3

- dichloropropene

plus chloropicrin on weed see d germination. Crop Protection; 2013. 45:1

- 5.

Yamano, Y., T. Nakadate 2006. Three occupationally exposed cases of severe methyl bromide poisoning: Accident

caused by a gas leak during the fumigation of a folklore museum. J. Occup. Health 48: 129

- 133

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 43

Y amano, Y., J. Kagawa, S. Ishizu and O. Harayama, 2001. Three cases of acute methyl bromide poisoning in a

seedling farm family. Industrial Health 39: 353

- 358

Yates, S., Papierknik S., Chellemi, D., Wang, D., Gao, S., Hanson, B., Ajwa, H., Browne, G., Klu epfel, 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

Zhao, Y., Phillips, T. W., Aikins, M. J ., Mikel, W. B., Schilling, M. W. 2012a. Sensory evaluation and pest mortality

of dry cured ham fumigated with phosphine in a simulated ham aging house. In: Obenauf, G. (ed.),

Annual International Research Conference on Methyl Bromide Alternatives and Emis sions

Reductions, MBAO conference. 

# www.mbao.org , 78

- 1

- 78

- 3.

Zhao, Y., Phillips, T. W., Abbar, S., Mikel, W. B., Schilling, M. W. 2012b. Effects of various food

- grade coatings on

mite mortality and sensory quality of dry cured ham. In: Obenauf, G. (ed.), Annual International

Research Conference on Methyl Bromide Alternatives and Emissions Reductions, MBAO

conference. 

# www.mbao.org , 77

- 1

- 77

- 3.

Zveibil, A., Mor, N., Gnayem, N., 2012 Survival, Host

– Pathogen Interaction, and Management of Macrophomina

phaseolina on Strawberry in Israel. Plant Disease 96, pp. 265

- 272

# 44 MBTOC 2014 CUNs: Interim Recommendations

– May 2014



# 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 brom ide 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 suita ble 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

critica l 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, eval uating, 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. Th at 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 o f

“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).

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 45 

# ANNEX II

- Part A: Historic Trends in Preplant Soil Nominatio ns and Exemptions for MB Use

List of nominated (2005

– 2015) and exempted (2005

– 2014) amounts of MB granted by Parties under the CUE process for each crop.

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Australia Cut Flowers

–

field 40.000 22.350 18.375 22.350

Australia Cut flowers

–

protected 20.000 10.425

Australia Cu t 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 29.79 0 29.790 29.760 29.760 29.760 35.750 37.500 35.750 35.750 29.790 29.790 23.840+

5.95 29.760 29.760 29.760

Belgium Asparagus 0.630 0.225 0.630 0.225

Belgium Chicory 0.600 0.180 0.180 0.180

Belg ium 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 1.6 40

Belgium Endive (sep from

lettuce) 1.650 1.650

Belgium Leek & onion

seeds 1.220 0.155 0.660

# 46 MBTOC 2014 CUNs: Interim Re commendations

– May 2014 Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Belgium Lettuce(&

endive) 42.250 22.425 2 5.190

Belgium Nursery Not

Predictabl

e 0.384 0.900 0.384

Belgium Orchard pome &

berry 1.350 0.621 1.350 0.621

Belgium Ornamental

plants 5.660 0.000

Belgium Pepper & egg

plant 5.270 1.350 3.000 1.350

Belgium Strawberry

runners 3.400 0.900 3.400 0.900

Belgium Tomato

(protected) 17.170 4.500 5.700 4.500

Belg ium 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 5.596 5.261 5.261 (a)14.792 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.261 5.261

Canada Strawberry r unners (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

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 47 Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

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

Franc e Pepper Incl

in.tomato

cun 27.500 6.000 27.500 6.000

France Strawberry fruit 90.000 86.000 34.000 90.000 86.000

France Strawberry

runners 40.000 4.000 35.000 40.000 40.000 28.000

France Tomato (and

eggplant for

2005 only) 150(all

solanaceo

us) 60.500 33.250 125.000 48.400

France Eggplant 27.500 33.250 48.400

Greece Cucurbits 30.000 19.200 30.000 1 9.200

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 2 8.554

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

# 48 MBTOC 2014 CUNs: Interim Re commendations

– May 2014 Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Isr ael 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 (Shar on &

Ghaza) 57.063

Israel Strawberry

runners (Sharon) 35.000 35.000 20.000 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

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 49 Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

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 1030.00 418.000 871.000 697.000 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 22.9 00 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

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

New

Zealand Strawberry fruit 42.000 42.000 24.78 42.000 34.000 12.000

# 50 MBTOC 2014 CUNs: Interim Re commendations

– May 2014 Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

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

20.000 15.000 43.490

(+Andaluci

a) (+Andaluc

ia)

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 6.0 50

UK Ornamental tree

nursery 12.000 6.000 6.000 6.000

UK Strawberry (&

raspberry in

2005) 80.000 63.600 68.000 54.500

UK Raspberry

nursery 4.400 4.400 54.500

USA Chrys.

Cuttings/roses 29.412 29.412 0

USA Cucurbits

– field 1187.8 747.839 598.927 588.949 411.757 340.405 218.032 59.500 11.899 1187.800 747.839 592.891 486.757 407.091 302.974 195.698 59.500

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 51 Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

USA E ggplant

– field 76.761 101.245 96.48 79.546 62.789 34.732 21.561 6.904 1.381 76.721 82.167 85.363 66.018 48.691 32.820 19.725 6.904

USA Forest nursery

seedlings 192.515 157.694 152.629 133.140 125.758 120.853 106.043 192.515 157.694 122.032 131.208 122.060 117.826 93.547

USA Ginger 9.2 9.2 0

USA Orchard replant 706.176 827.994 405.415 405.666 314.007 226.021 203.591 18.324 6.230 706.176 527.600 405.400 393.720 292.756 215.800 183.232 18.324

USA Or namentals 210.949 162.817 149.965 138.538 137.776 95.204 70.178 48.164 48.164 154.000 148.483 137.835 138.538 107.136 84.617 64.307 48.164

USA Nursery stock

-

fruit trees,

raspberries, roses 45.789 64.528 12.684 51.102 27.663 17.954 7.955 1.591 0. 541 45.800 64.528 28.275 51.102 25.326 17.363 7.955 1.591

USA Peppers

– field 1094.782 1498.53 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 2468.87 3 1918.40 1733.901 1604.669 1336.754 1103.422 1023.471 753.974 531.737 415.067 373.660 2052.846 1730.828 1476.019 1349.575 1269.321 1007.477 812.709 678.004 415.067 415.06

7

USA Strawberry

runners 54.988 56.291 4.483 8.838 8.837 7.381 7.381 3.752 3.752 54.988 56.291 4.483 8.838 7.944 4.690 +

2.018 6.036 3.752

USA Tomato

– field 2876.046 2844.985 2334.047 1840.1 1406.484 994.582 336.191 54.423 10.741 737.584 2476.365 2065.246 1406.484 1003.876 737.584 292.751 54.423

USA Turfgrass 352.194 1 31.600 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

USA Research 2.768 2.768

# 52 MBTOC 2014 CUNs: Interim Re commendations

– May 2014 

# ANNEX III

– Part B: Historic Trends in Structural and Commodity Nominations and Exemptions for MB Use

List of nominated (2005

- 2015) and exempted (2005

- 2014) amounts of MB granted by Parties under the CUE process for each commodity.

Party Industry Total CUN MB Quantities Total CUE Quantitie s

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Australia Almonds 1.900 2.100 1.900 2.100

Australia Rice

consumer

packs 12.300 12.300 10.225 9.200 9.2 7.82 5.66 3.653 2.374 1.187 1.187 6.150 6.150 9.205 9.200 7.820 6.650 4.870 3.653 1.187 1.187

+1.8

Belgium Artefacts and

structures 0.600 0.307 0.590 0.307

Belgium Antique

structure &

furniture 0.750 0.1 99 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 0.2 00 0.200 0.200

Belgium Food

processing

facilities 0.300 0.300 0.300 0.300

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 53

Party Industry Total CUN MB Quantities Total CUE Quantitie s

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Belgium Food

Processing

premises 0.030 0.030 0.030 0.030

Belgium Food storage

(dry) st ructure 0.120 0.120 0.120 0

Belgium Old buildings 7.000 0 .306 1.150 0.306

Belgium Old buildings

and objects 0.450 0.282 0 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 7.848 5.044 5.044 (a)47 34.774 30.167 28.65 26.913 22.878 14.107 11.020 5.044 5.044

Canada Pasta

manufacturing

facilities (a ) 10.457 6.757 6.067 4.740 4.740 2.084 (a) 10.457 6.757 6.067 4.740 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

Fran ce 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 Artefa cts 0.250 0.100 0.250 0.100

# 54 MBTOC 2014 CUNs: Interim Re commendations

– May 2014

Party Industry Total CUN MB Quantities Total CUE Quantitie s

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

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 0.450

Greece Mills and

Proces sors 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 0.6500

Israel Dates (post

harvest) 3.444 3.444 2.200 1.800 2.100 3.444 2.755 2.200 1.800 2.100 1.040

Israel Flour mills

(machinery &

storage) 2.140 1.490 1.490 0.800 0.300 2.140 1.490 1.040 0.312 0.300

Israel Furniture

–

imported 1.4220 1.4220 2.0420 1.4220 0

Italy Artefacts 5.500 5.500 5.000 5.225 0 5.000

Italy Mills and

Processors 160.000 130.000 25.000 160.000 65.000 25.00 0

Japan Chestnuts 7.100 6.500 6.500 6.300 5.800 5.400 5.350 3.489 3.317 7.100 6.800 6.500 6.300 5.800 5.400 5.350 3.489

Latvia Grains 2.502 2.502

Netherlands Strawberry runners post

harvest 0.120 0.1 20 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

# MBTOC 2014 CUNs: Interim Recommendations

– May 2014 

# 55

Party Industry Total CUN MB Quantities Total CUE Quantitie s

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

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 10.1 95 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

a nd nuts)

Whitworths 2.400 1.256 2.400 1.256

UK Herbs and

spices 0.035 0.037 0.030 0.035 0.037

UK Mills and

Processors

(biscuits) 2.525 1.787 0.479 2.525 1.787

UK Spices

structural

equip. 1.728 1.728 0 0.479

UK Spices stored 0.030 0.030 0

UK Structures

buildings

(herbs and

spices) 3.000 1.872 0.908 3.000 1.872 0.908

# 56 MBTOC 2014 CUNs: Interim Re commendations

– May 2014

Party Industry Total CUN MB Quantities Total CUE Quantitie s

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

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 2.419 0.822 0.740 0.310 89.166 87.719 78.983 58.921 45.623 19.242 5.000 2.419 0.740 0.740

USA Dry

commodities/

structures

(coco a 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 1 7.365 0.200 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 3.730 3.730 3.730 67.907 81.708 18.998 19.699 18.998 4.465 3.73 0 3.730 3.730 3.730

USA Mills and

Processors 536.328 505.982 401.889 362.952 291.418 173.023 135.299 74.51 25.334 22.800 483.000 461.758 401.889 348.237 291.418 173.023 135.29

9 74.510 22.80

0 22.80

0

USA Research 0.159 0.159