Reply to MBTOC Comments of February 2010 1

LIST OF QUESTIONS FOR PARTIES ON POST-HARVEST CUN’s: 2010 ROUND

Received from MBTOC February 17 & 18, 2010

UNITED STATES

Commodities

1. MBTOC: We observe that problems achieving pest kill efficacy have been demonstrated with 

SF fumigation at various lower temperatures and depending on pest species. Please indicate if 

research on SF fumigation in combination with heat or other alternative treatments is planned 

and funded for harvest season 2010 and 2011. 

USG Response: Gary Obenauf and Spencer Walse have reported that the California Walnut 

Board, California Date Commission, the California Dried Plum Board, and the California Fig 

Advisory Board have funded research for the 2010 and 2011 calendar years. An effort will be 

made to pair sulfuryl fluoride with a potent ovicide (e.g., PPO) to support the goal of 

circumventing the ovicidal deficiencies of sulfuryl fluoride. Dr. Walse and his laboratory will 

also begin looking at sulfuryl fluoride fumigant mixtures (and synergists) in “stored product 

disinfestations” under tarpaulins in an effort to combat resistance that is likely to develop as 

sulfuryl fluoride is commercially applied at sub-lethal doses. 

Dr. Spencer Walse, USDA-ARS, is providing MBTOC with an excerpt of his study concerning 

the efficacy of sulfuryl fluoride at lower temperatures by pest species (Attachment entitled Walse 

Report). 

2. MBTOC: However, we note that in dried plum and date sector, the request for MB is the 

same this year as was granted by the Parties last year. MBTOC repeats it comment from last 

year that since plums are heat dried, and heat drying also results in disinfestation. The Party 

has not demonstrated a strong seasonal market demand for dried plums and so it is difficult to 

understand why phosphine can not be used if a post-drying infestation occurs. Therefore, upon 

review, and without further substantiation, MBTOC may find the CUN for MB for dried plums to 

be not well-enough supported. 

USG Response: Gary Obenauf reports that the industry acknowledges that dried plums are free 

of insects when they come out of the dryer. However, reinfestation occurs fairly soon thereafter 

and thus the reason for these stored commodity treatments. This industry has already

transitioned to phosphine where possible. Some treatments need to occur around electronic and 

electrical equipment that prevents the industry from using phosphine. To ship insect infested 

dried fruit is prohibited by US food safety standards. 

3. MBTOC: Does the US believe it is no longer able to further transition dried plum and dates 

to alternatives? Have some dried plum and date companies entirely transitioned to alternatives 

and if so how did they accomplish that? 
Reply to MBTOC Comments of February 2010 2

USG Response: The US believes that until viable options with the registered alternatives are 

further developed, the dried fruit industry has reached the maximum adoption of alternatives. 

Obenauf, Keck, and Lindsay, report that phosphine is already used for the majority of “stored 

product disinfestations” which shows a commitment by these California industries to the requests 

of MBTOC regarding reductions in methyl bromide use. In addition, the California dried fruit 

and nut industries continue to financially support research on methyl bromide alternatives for 

postharvest applications, which suggests that alternatives to methyl bromide will be 

commercially utilized when they are technically and economically feasible. At this time, there 

are no technically and economically registered alternatives to methyl bromide for rapid field 

disinfestations below 80°F that are universally effective on the target insects endemic to 

California.

Mr. Keck reports that some of the commodity industries are having difficulties in getting 

permission from their California County Agriculture Commissioner for sulfuryl fluoride

applications. Apparently some counties in the state of California are being more restrictive of 

sulfuryl fluoride. At this time, there is no explanation for the restrictions. Therefore, state and 

country regulatory constraints are also impacting this sector. 

Dry Cured Pork

1. MBTOC: We are concerned that the CUN reports that an unnecessarily high dosage rate of 

MB is sometimes used. We are also concerned that the CUN gives us conflicting information 

about the dosage rate used. The CUN BUNI table states the dosage rate is 13 – 20 g/m3. We 

note this is an unusually wide range and not in keeping with the use of the lowest effective 

dosage rate. The CUN page 5 also discussed MB dosage rates by saying, “concentrations 

lower than 15 g/m3 could be used to achieve 100 % mortality of all life stages for red legged 

beetles and levels less than 8 g/m3 could be used to achieve 100 % mortality in all life stages of 

ham mites at the bench top level (Sekhorn, et al. 2009b; Phillips, 2009).” Additionally, in the 

CUN page 5 also gives conflicting information concerning the dosage rate, “Fumigation levels 

should be tested at the plant level to determine if levels could be decreased from the 24 g/m3 

that is commonly used in the industry”.

USG Response: Dr. Schilling reminds MBTOC that the text information on page 5 is reporting 

recent research results. However, benchtop test results may not correspond to real world 

applications. These studies are still in progress and the researchers have started negotiating with 

some producers to conduct trials in their facilities. However, the researchers would like to 

remind MBTOC that there are many details that needed to be addressed before commercial level 

investigations can begin. The typical rate for commercial applications of methyl bromide is 20 

g/m3. As per the MBTOC request the BUNI will be changed to reflect this rate. 

2. MBTOC: The CUN reports structure volume of 250,000 m3, but ham volume and ham 

stowage factors* have not been reported. Therefore, MBTOC can not calculate how much MB 

might be necessary and in keeping with Decision IX/6. 
Reply to MBTOC Comments of February 2010 3

USG Response: According to Dr. Schilling, hams are stored in aging rooms (hung a couple feet 

apart from each other on racks). Hams can be stored this way from 40 days to one year 

depending on the product and desired flavor. Ham volume and stowage is similar to Spain. The 

U.S. production is approximately 3 to 5 million hams per year that may get fumigated. Hams 

range from 10-12 kg each. The stowage is 150-180 kg/m3. When the middle ranges for weight

and stowage are used the structure volume results in a range of about 200,000 to 250,000 m3. 

3. MBTOC: So, we either need to know ham volume and ham stowage factors (which might be 

difficult information to obtain at this point), or we need to know that Government of United States 

has a program or regulatory or inspection method to ensure that cured pork sector-users of MB 

will make facility improvements to ensure that only the lowest effective dosage will be used. 

(Based on the research cited in the CUN, the lowest effective dosage seems to be 15 g/m3.) In 

other words, we need to know how the Government of the US will ensure that only < 15g/m3 is 

used to treat cured pork hanging in storage facilities. 

USG Response: Dr. Schilling reminds MBTOC that the research cited was conducted on the 

benchtop and needs to be verified at the plant level. The benchtop level efficacy research may 

have very different results than what might happen in a ham aging room. After the commercial 

level tests are conducted, the rate of methyl bromide will be adjusted to reflect the results. 

4. MBTOC: Additionally, we would like to know if the US cured pork research program has 

identified the incidence of the red-legged beetle? This information would impact the amount of 

MB needed because according to the CUN, levels less than 8 g/m3 MB could be used to 

achieve 100 % mortality in all life stages of ham mites.

USG Response: Dr. Schilling: The US cured pork research program has identified the 

incidence of red-legged ham beetle. The incidence of the red legged beetle is approximately 50-

60 % of the plants that have reported infestations. The incidence of mites is approximately 60-

70 %. 

Again, MBTOC should note that the lower amount of methyl bromide for 100% mortality of 

ham mites is from a benchtop laboratory experiment and is not recommended for use in 

commercial level facilities until those investigations are completed. It would not be advisable to 

use less than 20 g/m3 until tests are conducted at the plant level to ensure that lower 

concentrations could be used. The only reports of 8 g/m3 being effective against mites are in 3.7 

L jars with no refugia.

5. MBTOC: Could you please confirm whether the USDA CREES cured pork study is still 

ongoing? 

USG Response: The USDA CSREES cured pork study is still ongoing and an additional 

proposal will be submitted to the USDA. While preliminary results are promising, further 

research is critically needed. 
Reply to MBTOC Comments of February 2010 4

NPMA

1. MBTOC: We are also concerned that no research or results of commercial trials -- directly 

pertinent to the processed food facilities and sector included in this CUN -- has been presented 

for several years. There has been no heat treatment research or trials presented to try to 

resolve the concerns presented about using SF as an alternative. The research presented in the 

CUN detailing the Kansas State Mill trials of MB, heat and SF trials do not seem relevant to the 

facilities included in CUN. If the five-story Kansas State mill is representative of the processed 

food facilities included in this CUN that information should be documented (processed food 

facilities are normally flat constructed). 

USG Response: NPMA reports that the US has invested a substantial amount of money into 

research that is directly “pertinent” to processed food facilities included in this CUN. Within the 

U.S. we are fortunate to have great research institutes, facilities and more importantly individuals 

with the know how to objectively carry out the work. Research by USDA Agriculture Research 

Service and grants funded through USDA National Institute of Food and Agriculture support 

these investigations. Much of the post-harvest research is conducted in Kansas. USDA has their 

Center for Grain and Animal Health located in Manhattan, KS. Many of the university 

researchers that investigate post-harvest issues are now located at Kansas State University

(KSU). Kansas is a major wheat producer in the U.S. and consequently the focus of these 

laboratories tends to focus on wheat and its products. 

However, the fact that most of the research has been carried out in flour mills does not make the 

research irrelevant to food handling facilities in this CUN. It is research that to some degree is 

directly applicable to any food handling facility, whether it is a mill or finished processing 

facility. The biggest difference between the 5 story flour mill at KSU and most food processing 

facilities found in the U.S. is not the height of the structure, but the sanitary design that was 

incorporated into the newly built mill at KSU. Many mills in the U.S. are twice the height of this 

mill, at around 9 to 11 stories high. Warehousing and distribution sections of flour mills are 

typically no more than 1 story tall. Food handling facilities included in this CUN tend to have 

very large 1 to 3 story areas for processing and packaging, but they can also have sections up to 5 

or more stories tall that utilize gravity for moving dry ingredients, very similar in designs used in 

flour mills. (NPMA)

NPMA reports that sanitary design is a critical component for managing stored product pest, and 

is the big challenge for food handling facilities. Some facilities may only have 1 story high 

processing sections, but the ceilings of those areas can be over 30 feet high, with structural 

support systems, processing lines and conveyer systems running throughout that have not been 

designed to be cleaned or accessed. Consequently, research results from KSU's flour mill 

experiments are applicable to all structures, including those of NPMA's CUN. 

2. MBTOC: There is relevant research on facilities for processed foods in this field, for 

example, research on pasta facilities done by Dirk Meier, now at Kansas State but formerly at 

Purdue University. There is also relevant commercial experience which has not been assessed 

for this CUN. In fact, the Kansas State heat treatment workshop (May 2009), included numerous 
Reply to MBTOC Comments of February 2010 5

American participants from pasta and snack food sector who reported successful use of heat 

treatment. 

USG Response: NPMA reports that some food processing facilities have been able to take up 

heat as an alternative, either for the entire facility or as a spot treatment of bins, equipment or 

rooms. Where practical this alternative fits nicely as treatments on a smaller scale can be carried 

out while other parts of the facility are in production. However, not all facilities are candidates 

for this alternative due to structural design and other considerations. Heat can also not be used to 

treat many commodities. Field trials for heat as commodity treatment were carried out at one 

U.S. facility on organic pasta. Heating of the interior of the commodity packaging could not be 

achieved in an effective manner and compromising product integrity was a concern. The trails 

were determined to be unsuccessful. 

3. MBTOC: While we understand that there are no alternatives for infested cheese in storage 

facilities, we need to see reports of research or commercial efforts done to avoid the infestation, 

and other information demonstrating that progress is being made in this sector. 

USG Response: Since the pests of cheese are identical to the pests of dry cure pork products, 

the researchers have included cheese in their research proposal. 

4. MBTOC: In Herb and Spice sector, growing commercial experience with spot heat in other 

regions is an indicator that this alternative needs to be tried and adapted and reported on for 

this CUN. MBTOC has indicated for several years that spot heat should be considered a viable 

alternative for this sector. It is not sufficient to just indicate concerns with alternatives and not 

include written reports documenting that the concerns are justified. 

USG Response: NPMA reports that some food processing facilities have been able to take up 

heat as an alternative, either for the entire facility or as a spot treatment of bins, equipment or 

rooms. Where practical this alternative fits nicely as treatments on a smaller scale can be carried

out while other parts of the facility are in production. However, not all facilities are candidates 

for this alternative due to structural design and other considerations. Heat can also not be 

utilized to treat commodity. Field trials for heat as commodity treatment were carried out at one 

U.S. facility on organic pasta. Heating of the interior of the commodity packaging could not be 

achieved in an effective manner and compromising product integrity was a concern. The trails 

were determined to be unsuccessful. 

5. MBTOC: The facilities in the processing sector are not sufficiently described. For example, 

we do not know how many pasta facilities are included, versus facilities that are largely baked 

processed foods (such as cookies and crackers). We do not know how many facilities are 

included in the CUN, nor their volume. We do not know how many and which types of facilities 

have product warehousing integral to the processing rooms which can not be separated off 

during SF fumigations. The CUN implies that some facilities are insufficiently sealed to allow 

treatment by other means, but this means they should not be MB treated until they are properly 

sealed and improved by other means. 
Reply to MBTOC Comments of February 2010 6

USG Response: Information concerning this industry and its structures was submitted to 

MBTOC in 2005. While the food being produced is not available per facility, the estimates of 

volumes were. Roughly, one third of the facilities have product warehouses that are unable to be 

separated from the production areas and are therefore, not available for sulfuryl fluoride 

fumigation. The CUN reported facilities that could not sufficiently seal between the two areas, 

but since methyl bromide is labeled for "all processed foods" it is legal to expose these food 

products to methyl bromide. The facilities are sealed to retain fumigants and reduce leakage 

from the buildings.

6. MBTOC: This CUN does not report actual MB use in cheese sector, yet previous CUNs 

have indicated that MB fumigation of cheese only takes place upon the demand of government 

inspectors. In that case, we think there would be written documentation of the requirement to 

fumigate, the pests identified and the amount of MB used. 

USG Response: The U.S. food supply is one of the safest in the world. Prevention is the 

keystone of an effective, proactive food defense. Preventive measures must be built in from the 

start of domestic and international food production processes. The Food and Drug 

Administration (FDA) conducts inspections to determine compliance with the Federal Food, 

Drug, and Cosmetic Act (the Act) and implementing regulations contained in Title 21, Code of 

Federal Regulations, Part 133 (21 CFR 133). FDA has food safety oversight of cheese products, 

however, dairy products such as cheese that are part of the US government commodity purchase 

programs are subject to the fee for service grading and inspection service of the Dairy Program 

within the USDA Agricultural Marketing Service. If a plant were to fail an inspection, the 

impact to the producer would be substantial which may even result in the loss of the product. 

The records of failed inspections are not available to the public. 

7. MBTOC: Although our previous reports and correspondence have asked for documentation 

reporting the tarping of commodities to see if that would provide sufficient barrier during SF 

facility fumigations, no documentation has been provided to show that this has been done. 

Additionally, the CUN indicates this sector has an environmental concern with the use of SF. 

Please document this concern with, for example, written customer demands, regulatory 

requirements or other evidence of an inability to use SF on environmental grounds.

USG Response: In the U.S. pesticide re-registration is required every 15 years. Sulfuryl 

fluoride is in the early stages of product re-registration, with a projected completion of the 

process in 5-6 years. At this time it is too early in the process to know what final label language 

will be or what commodities will be listed on the label. Current labeling clarification from the 

US EPA states “that the label would require all finished product and the majority of the bagged 

ingredients to be removed from the premises. NPMA hopes that the future label will allow 

commodities not labeled for direction fumigation could remain in the treated space if they are 

under tarps or otherwise protected by packaging. ”

In the U.S. the pesticide "label is the law" and the sulfuryl fluoride label does not list tarping of 

commodities as an option in a facility under fumigation. However, some food processing 

facilities have transitioned to SF where processing areas can be safely segregated from areas that 
Reply to MBTOC Comments of February 2010 7

contain commodities that cannot be treated. In other facilities the ability to safely segregate

areas is very difficult due to large open oven lines that merge into packaging, warehousing and 

distribution areas. 

Structures – Food Processing Plants

1. MBTOC: We acknowledge that the CUN provided a new flour mill research study conducted 

at the Kansas State flour mill. The Kansas State study reported there were some pest survivors 

in some cages. But, it was also acknowledged that dosage and temperature were inadequate in 

at least one of those studies. In its Progress Report of 2007 (TEAP, May 2007) MBTOC 

reported that both the correct dosage rate and temperature must be achieved to obtain zero 

survivor results in test cages. It is not acceptable to think that a few survivors in a trial means 

that the sulfuryl fluoride is not an effective alternative; with the results of this trial, adjustments 

could be made in dosage rate and temperature to ensure it worked the next time. The need to 

adapt and learn from trials in mills was also emphasized in the May 2007 Progress Report and 

by all commercial experience with alternatives to date. 

USG Response: The North American Millers' Association response is:

The Kansas State University research (KSU) is the ONLY such academic

analysis comparing methyl bromide and sulfuryl fluoride (SF) (and heat) 

in the world, so far as we are aware. We are willing to, and expect to, learn 

from the research. But the research is not yet complete. Therefore we 

believe it is unfair to criticize the milling industry for not having moved 

faster when the research isn’t even finished. It is also unfair to criticize the

milling industry for not adopting whatever research findings that have 

resulted when those findings were not favorable to SF.

It is also unfair to criticize this industry with the dismissive statement that 

all that needs to be done to make SF work better is to correct “the dosage 

rate and temperature to ensure it worked the next time.” The fact that the 

SF dosage rate is highly temperature sensitive, and requires a dosage rate 

more than 400 percent greater than MB is exactly the point we’ve been

trying to explain for years, with little apparent effect.

If the mill needs to be heated up prior to an SF fumigation, that is not a 

head-to-head comparison, since MB fumigation does not require such 

heat. In a legitimate head-to-head comparison, if the mill is heated for one 

treatment, it must be heated for all treatments. In such a situation MB 

would work even better and require even less than is customary.

We have never claimed SF doesn’t kill insects. Of course it does. What we 

have said, and the KSU research supports, is that SF requires far greater 

quantities to do the same job. As an industry we are attempting to 
Reply to MBTOC Comments of February 2010 8

minimize pesticide usage whenever and wherever possible. Sustainability 

goals – ours and those of our customers – require that.

In a MB fumigation, a CT (concentration x time) product of 180 is typical. 

In the KSU SF fumigation in May 2009, a CT of 941 was targeted, a 423 

percent increase. Still, there were surviving insects.

MBTOC must not understand modern food manufacturing demands, 

sustainability or economics when it says it is “unacceptable” to consider 

SF not to be an “effective alternative” when using more than 4x still does 

not give complete control.

There is another critical issue which is not discussed in the MBTOC letter, 

but is relevant to the adoption rate of sulfuryl fluoride – the label wording. 

This has consistently been an impediment since SF was approved. There 

have been multiple label changes, but Dow AgroSciences acknowledges it 

is still deficient and needs further changes. NAMA and other user group 

representatives have met with Dow AS many times to discuss this, as 

recently as January 7, 2010. We discussed how the label could be refined 

to add greater clarity to the conditions under which SF can be legally used. 

Dow AS has agreed to propose even more changes in the label. Until these 

changes are proposed by Dow and approved by EPA, it is unfair to 

criticize the milling industry for not adopting SF more quickly. Apart from 

any economic or technical consideration of SF as a viable alternative, the 

label must remove doubts about the conditions of legal use, not add to 

them as is currently the case. Said another way, regardless of technical 

merit, a potential user will not adopt the compound so long as questions 

remain about legal liability. Any expectation to the contrary is unrealistic.

2. MBTOC: The Kansas State research is not directly pertinent to pet food facilities and rice 

mills. There does not seem to be a research program directly relevant to the pet food and rice 

milling facilities included in this CUN. Pet food facilities and rice milling establishments seem to 

have stalled in their adoption of alternatives, and no new information on trials has been given for 

several years. 

USG Response: Funded research by Kansas State has focused on flour mills for several reasons: 

1) wheat is a very abundant crop in Kansas, 2) flour mills are more numerous than rice mills, and 

3) flour mills use more methyl bromide. Therefore because there are budgetary constraints the 

flour mills are the main focus of research. However, that does not mean that the information 

gleaned in flour mill research is not applicable to rice mills or pet food facilities. 

The US Rice Federation replies: "There have been several trials of rice mills in the last 8 years, 

but the trials were not conducted by USDA or University researchers, so are not publishable. 

That said, USG does have some information on those tests. In 2007, a trial of a 650,000 cu3rice 

mill used sulfuryl fluoride. The effective dosage of sulfuryl fluoride was 1,900 lbs vs 550 lbs of 

methyl bromide. Although the price of methyl bromide and sulfuryl fluoride, pound for pound, 
Reply to MBTOC Comments of February 2010 9

is essentially the same the difference in amount needed is problematic for several businesses. 

Another mill has been alternating between sulfuryl fluoride and methyl bromide trying to gain 

experience and assess effectiveness of the fumigants. Some mills are using sulfuryl fluoride 

when fumigation occurs during the summer. The higher temperatures allow for a volume of 

sulfuryl fluoride to be the same as a methyl bromide fumigation. Unfortunately, not all pest 

infestations and consequently fumigations take place in the summer. 

A rice mill is cooperating with USDA Grain Lab in Kansas in a pheromone trap study. As part 

of another study an "in house" fogging system has been installed. This allows for fogging 

separate, or all, areas within a processing facility. The U.S. Rice industry is attempting this 

approach in an effort to reduce the need for annual structural fumigation. This program began 

approximately 18 months ago and sufficient data are not yet available. 

On a nonstructural note, one rice mill has conducted 4 trials with sulfuryl fluoride on FINISHED 

GOODS in containers. These trials have been jointly conducted with another company and the 

registrant. These trials have discovered that sulfuryl fluoride by itself does not give a successful 

kill on the eggs of rice weevil insects therefore a new trial with a mix of sulfuryl fluoride and 

phosphine is being conducted. The gas application has been completed and the trial insects (all 

three stages of rice weevil and flour beetle) are currently in incubation for 60 days." 

The Pet Food Institute replies: "While the research was not conducted in a pet food facility, the 

evaluation of the efficacy of ProFume is directly relevant to the matter under consideration.

Generally ProFume is a less effective fumigant than methyl bromide in part because it does not

kill insect eggs as readily. What the Kansas State research revealed is the impact of temperature 

on the effectiveness of ProFume. The target temperature for the research within the fumigated 

facility was around 87°F, an unrealistic temperature target for many facilities for much of the 

year unless additional heating equipment is used. In the study the temperature in the facility was 

about ten degrees lower (77°F). The impact of this temperature variance was that insufficient 

ProFume was on hand to successfully fumigate the facility within the target efficacy. A 

significant increase in ProFume would have been needed to achieve anticipated lethality targets.

The Kansas State research documents very real drawbacks of ProFume over methyl bromide

both in terms of efficacy under real world conditions and cost. Certainly portable heaters could

have been used in the test facility, but that would have resulted in a less valid comparison

because of the difference in environmental conditions. Use of heaters in a facility treated with

ProFume would result in increased cost of treatment. However it is worth noting that less methyl 

bromide would be needed in a heated facility, as methyl bromide would become even more 

effective under such conditions."

3. MBTOC: For several years now pet food facilities have been stymied by lack of registration 

for pet foods treated by sulfuryl fluoride. But there has been no documentation submitted which 

shows that the sector is trying to circumvent this problem by trialling and adopting either full-site 

or spot heat, by developing methods to segregate products or other means. Although our 

previous reports and correspondence have asked for documentation reporting the tarping of 

commodities to see if that would provide sufficient barrier during SF facility fumigations, no 

documentation has been provided to show that this has been tried. The CUN discusses 
Reply to MBTOC Comments of February 2010 10

concerns about the logistics and costs of tarping commodity to allow SF fumigation. But what is 

the sector doing to circumvent this problem, other than continuing to rely on methyl bromide? 

Has the sector investigated asking EPA for an exemption for pet foods, tarped off from an SF 

fumigation, as an inadvertent residue as described in FFDCA section 201q (as amended by 

FQPA). Noting the persistent problems reported with SF, it is imperative that the sector show 

progress adopting other alternatives to methyl bromide. 

USG Response: The Pet Food Institute replies: "Use of ProFume in a pet food facility is 

hampered by the need to remove all finished product and a significant portion of ingredients, 

particularly animal by-products and meals. Many pet food plants operate continuously 

throughout the year with little down time for the entire facility. The down time required to halt 

production and to remove finished product and ingredients could be prohibitive, particularly if a 

warehouse adjoins the manufacturing area, as occurs in most efficient manufacturing facilities.

In the U.S. pesticide re-registration is required every 15 years. Sulfuryl fluoride is in the early 

stages of product re-registration, with a projected completion of the process in 5-6 years. At this 

time it is too early in the process to know what final label language will be or what commodities 

will be listed on the label. Current labeling clarification from the US EPA states “that the label 

would require all finished product and the majority of the bagged ingredients to be removed from

the premises. The hope is that the future label will allow commodities not labeled for direction 

fumigation could remain in the treated space if they are under tarps or otherwise protected by 

packaging. ”

In the U.S. the pesticide "label is the law" and the sulfuryl fluoride label does not list tarping of 

commodities as an option in a facility under fumigation. However, some food processing 

facilities have transitioned to SF where processing areas can be safely segregated from areas that 

contain commodities that cannot be treated. In other facilities the ability to safely segregate 

areas is very difficult due to large open oven lines that merge into packaging, warehousing and 

distribution areas. 

Tarping off the manufacturing area may be effective at preventing ProFume from entering the

warehouse area. However this practice poses two problems. First, insects could migrate from

the manufacturing area into the warehouse, making the fumigation less effective. Second, and

perhaps more significant, according to the EPA letter of 2005 (Attachment Letter), ProFume 

cannot be used in the section of a pet food facility where fumigation may be needed most, in a 

warehouse containing finished product. Tarping off finished pet food would defeat the purpose 

of the fumigation. If effective at preventing penetration by ProFume, tarping also would prevent

exposure to insects under the tarp that are on, around or between packages of finished products." 

PFI states: The suggestion that the PFI work with EPA for an exemption of pet food is 

inconsistent with the manner in which uses of pesticides are approved within the United States. 

PFI has no legal standing to request such an exemption. Only Dow AgroSciences, as the owner 

of ProFume, and consequently the owner of its label, has the legal standing to petition EPA for 

an expansion of the approved uses on its label. Dow AgroSciences is well aware of its ProFume 

label problems, and is hopefully working to resolve these issues. 
Reply to MBTOC Comments of February 2010 11

4. MBTOC: Several pet food and rice milling companies have transitioned to alternatives; 

inadequate detail is given to document why the remaining companies can not reduce their MB 

usage. Other pet food and rice milling structures in the US use SF and heat treatments. How do 

they isolate pet food, ingredients, and other food stuffs with no tolerance for SF. Are the 

structures of different vintage, scale, and design so that materials can be isolated and tarped or 

removed from the structure at an "acceptable" cost? 

USG Response: PFI: A vast majority of pet food facilities have transitioned away from use of

methyl bromide as part of their routine pet management program. Companies that have

completed the transition away from methyl bromide either view their pest management programs 

as proprietary or as a competitive advantage, so we are unable to share specifics on those 

alternative programs. We can suppose that such programs utilize techniques such as

microsanitation, spot heat treatment, insect growth inhibitors, and fumigation treatment with

Vapona ULV fogging, phosphine and ProFume. Vapona has limited penetration capabilities, so

its limitations in a pet food facility are significant. Phosphine, as described in CUE submissions,

is highly corrosive to electronic equipment. Pet food facilities widely utilize electronics to 

control and monitor the manufacturing process. Such equipment would have to be protected prior 

to fumigation with phosphine, which reduces its application as a practical alternative to methyl

bromide.

Most often pet food companies seek to use methyl bromide as a final option to eliminate a pest

infestation when other practices have proved ineffective. However the pet food industry is

experiencing difficulty obtaining sufficient quantity of methyl bromide for use in emergency

situations as described.

While the number continues to shrink, there remains a number of older pet food facilities in the

United States for which methyl bromide is an important component of the pet management

program.

US Rice Federation: Since 2005 one company has reduced their MB usage 48% (60% from 

1999) through better cleaning and increased usage of Insect Growth Regulators (IGR) applied in 

space/fog treatments. USG assumes other mills have also improved sanitation and is using 

fogging or space treatments to reduce fumigations. 

US Rice Federation: There are various degrees of rice milling that depend upon the 

market/customer. Some rice facilities mill specifically for pet food. Some companies mill rice 

and bulk ship. Some mills formulate and package processed meals using ingredients they must 

have onsite for that purpose. Most of these finished products are not listed on the sulfuryl 

fluoride label. Some mills may also believe, incorrectly, that they can legally fumigate certain 

ingredients/products, not realizing that these food products are not on the label for sulfuryl 

fluoride. So, some rice mills are using sulfuryl fluoride even though the final product is not on 

the label and other mills continue to fumigate with methyl bromide, but have increased sanitation 

and space treatments do so less often. 

US Rice Federation: Heat treatments at one rice milling company have all been abandoned due

to increase cost (3 times over MB fumigation costs) and stress on facility structures. Regarding 
Reply to MBTOC Comments of February 2010 12

SF fumigations, the company plans to not include areas with ingredients, since they are not on 

the SF label, in future SF fumigations. 

US Rice Federation: Eighty percent of one rice company’s finished product is packaged in 

plastic jars and these plastic jars cannot withstand the heat that they would be subjected to during 

heat treatment. These products and materials would need to be relocated to an outside 

warehouse during the heat treatment at a cost of over $6M per treatment. This cost is in addition 

to the cost to re-skin/re-roof the facility to ensure it will hold the required temperature to achieve 

the kill.

US Rice Federation In some cases a single rice milling structure is of different vintage, scale, and 

design since they are decades old. There is no single design for all mills though, so not every 

mill can cost effectively isolate materials.

Tarping of non-labeled products and ingredients is not listed on the label as an allowed method 

for protection during fumigation. For pesticide products in the U.S., “the label is the law.”

5. MBTOC: There is a complete dearth of information about the need for MB and adoption of 

alternatives in rice mills. Most of rice milling has converted to alternatives and inadequate detail 

is given to document why the remaining companies can not reduce their MB usage. 

USG Response: US Rice Federation responds: "One company reports that MB is easier and 

more cost effective to use than SF. Both fumigants will kill insects, but you have to do much 

more preparation work for SF to be effective and it is much easier to lose the concentration of SF 

gas before it kills the insects than it is with MB. As far as the heat treatment, it tends to be more 

expensive and it warps or ruins various pieces of equipment in the mill when used. 

Another company has a facility that is of metal construction; very old and porous. After 

extensive sealing of joints and visible leak sources, they conducted a fumigation test using 

sulfuryl fluoride. The building leaked too much to maintain the required concentration level. In 

order to effectively use sulfuryl fluoride, the company needs to re-skin/re-roof the facility at a 

cost of over $1 million. The company has not been involved in any other research to identify 

other alternative solutions. Instead, they are planning to relocate to a new and larger facility 

within the next 5 years. Their plan is to build a new facility that can support sulfuryl fluoride 

and possibly heat treatment."

The US Rice Federation disagrees that “most” rice mills have converted to alternatives? Is 

MBTOC referring to companies, individual milling structures, or capacity? One large rice 

company fumigates over 22 million cubic feet of space annually. A fumigation has to be done 

correctly the first time because the cost of redoing a fumigation is extreme. 

6. MBTOC: What percent of US plants in rice mills, pet food formulators, and flour millers are 

covered by this CUN? What are the specific differences between the facilities that have 

converted to alternatives versus the facilities which have not converted? How do those 

differences result in the inability of the remaining facilities to convert to alternatives? 
Reply to MBTOC Comments of February 2010 13

USG Response: The consortia included in this sector: NAMA, PFI and US Rice Federation,

represent the majority of their respective industries, about 85 – 95% of the companies belong. 

As to differences between facilities that can convert to alternatives and those that have not the 

main reason is primarily size. The US Rice Federation reports that the 2-3X dosage of SF 

compared to MB, creates an exponential cost increase. (e.g. A facility that uses 11,000 lbs of 

MB would require a potential 33,000 lbs of SF to fumigate the same space. Cost comparisons 

for material alone would average $88,000 versus $231,000, respectively.) Also of importance in 

transition to alternatives is age. Newer tighter mills with more piping can use SF more 

thoroughly and cost effectively than older mills. Construction design is also important. Wooden 

versus concrete or metal siding, and roofing are all variables to consider.

The US Rice Federation reports that costs are a significant factor in the ability to convert to 

alternatives. Smaller mills with fewer resources are compelled to continue a practice that is 

affordable to their situation and still gets the pests under control.

7. MBTOC: The CUN indicates this sector has an environmental concern with the use of SF. 

MBTOC is aware of the findings regarding the global warming potential of SF. Please 

document the concern with using SF by providing, for example, written customer demands, 

regulatory requirements or other evidence of an inability to use or customer pressure against 

using SF on environmental grounds.

USG Response: According to PFI: In the United States, retailers are putting increased pressure 

on manufacturers to reduce their environmental footprint. For example, on February 25, 2010 

Wal-Mart announced that it wants its suppliers to eliminate “20 million metric tons of 

greenhouse gas emissions by the end of 2015.” Considering that scientists have determined that 

ProFume is 4,800 times more potent a greenhouse gas than carbon dioxide, use of ProFume 

could easily eviscerate any reductions in carbon emissions that pet food makers are able to 

realize (see attachment: article ProFume as a greenhouse gas). In fact use of ProFume could 

potentially expand a company’s carbon footprint. Such a situation is likely to be viewed by 

retailers and consumers with much disapproval.

According to the Rice Federation: The rice industry is currently being market driven by 

international and some national customers that are designing sustainability plans for their own 

needs and sending those down the food supply chain. One of the most basic requirements is to 

reduce the carbon footprint in every step of the chain. Rice producing fields are currently at a 

severe disadvantage for their inability to mass-utilize no-till practices, and the production of 

GHGs. Adding another product in the same supply chain that is a climate change contributor is 

counterintuitive and contrary to customer requirements of reducing the carbon footprint and 

controlling global warming.

8. MBTOC: Our reviewers have also noted dosage rate inconsistencies in the MB request. The 

MB application rate for the millers in the BUNI is given as 13 g/m3for 2011, but as 19 g/m3for 

2012. It is not clear why there is this difference. Also, for 2011 the nomination the rate was 19 

g/m3 when the approved rate was 17g/m3for the flour milling. Why does the dosage rate vary 
Reply to MBTOC Comments of February 2010 14

across sectors and year over year? Why is the dosage rate for rice milling and pet food facilities 

higher than for flour milling? 

USG Response: The BUNI should have been 20 g/m3as the rate for all structural fumigations, 

and should not have changed over the years. The dosage rate should not be higher for rice mills 

and pet food facilities. As per MBTOC's request the BUNI will be changed to reflect their 

request (Appendix A). 

9. MBTOC: In short we find this CUN to be deficient in that the information presented is not 

directly relevant to pet food and rice milling, and the information presented on flour milling does 

not recognize that sulfuryl fluoride can be effective if the dosage and temperature are correct. In 

fact there is considerable commercial use of SF in US flour milling sector already. 

USG Response: USG disagrees with MBTOC. Although the majority of research has been 

conducted in Kansas in flour mills does not mean that the information is not applicable to the 

other structures included in this sector. Research is expensive, and resources are limited, 

especially in these economic times. Many of the post-harvest researchers are at Kansas State 

University and USDA has laboratory facilities located there as well. Kansas is a wheat growing 

state. In addition, flour mills are the bulk of this sector's request for methyl bromide. It makes 

sense to conduct research in this area first. However, that does not imply that members of the pet 

food institute or rice millers are not also pursuing their own solutions to methyl bromide. 

That said, there has been much progress to the alternatives of methyl bromide. Alternatives are 

not only sulfuryl fluoride, but also heat and microsanitation. The use of fogging, space, and 

crack and crevice treatments has greatly decreased the number of times structures are fumigated. 

However many companies desire to retain the ability to utilize methyl bromide in the event of a 

difficult infestation. Eliminating such an infestation is essential to the continued food companies. 

Retailers and consumers would accept their products no other way than pest free.
Reply to MBTOC Comments of February 2010 15

Appendix A. Revised BUNIs

 Processed Foods Spices and Herbs Cheese 

Processing Plants 

 Sector Total / 

Average 

Quantity Requested for 2011: Amount (kgs) 14,498 1,055 1,812 17,365

Quantity Recommended by 

MBTOC/TEAP for 2011 : Amount (kgs) 14,498 1,055 1,812 17,365

Amount (kgs) 14,498 1,055 1,812 17,365

Volume (1000 m3) 1,676 122 91 1,889

Rate 9 9 20 9

Transition from 2011 Baseline 

Adjusted Value

Percentage (%) 0% 0% 0% 0%

Amount (kgs) 14,498 1,055 1,812 17,365

Volume (1000 m3) 725 53 91 868

Rate 20 20 20 20

 Rice Millers Pet Food 

Institute 

 North American 

Millers 

 Sector Total / 

Average 

Quantity Requested for 2011: Amount (kgs) 14,511 13,722 107,066 135,299

Quantity Recommended by 

MBTOC/TEAP for 2011 : Amount (kgs) 14,511 13,722 107,066 135,299

Amount (kgs) 14,511 13,722 107,066 135,299

Volume (1000 m3) 726 745 8,459 9,930

Rate 20 18 13 14

Transition from 2011 Baseline 

Adjusted Value

Percentage (%) 0% 0% 0% 0%

Amount (kgs) 14,511 13,722 107,066 135,299

Volume (1000 m3) 726 686 5,353 6765

Rate 20 20 20 20

SECTOR

NPMA

Quantity Required for 

2012 Nomination:

Quantity Approved by Parties for 

2011:

Quantity Required for 

2012 Nomination:

SECTOR

2012 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

Transition Use Reduction Description Spreadsheet

2012 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

Transition Use Reduction Description Spreadsheet

STRUCTURES

Quantity Approved by Parties for 

2011: