USG Responses to MBTOC QSC Page 1



### Structures (mills)

1. We note that there is no decrease in MB use planned between 2010 and 2011 for rice milling and pet foods. These sectors had previously ma d e year o ve r year decreases in their MB use. Could you please provide the explanation(s) for th e inability of these

sectors to continue to decrease MB use?

US G Response

In the judgment of USG no further transition is possible at this point for either rice mills or pet food facilities d ue to regulatory barriers

. T he remaining pet food facilities p roduce products that include elements not on the sulfuryl fluoride ( SF ) label (which also does not include a registered category “pet food”) limiting further uptake of SF unless there is a change in the registration of SF or the registration of another alt ernative,

. Pet food manufacturers have reduced the frequency of methyl bromide fumigations so as to minimize the use of methyl bromide as much as technically feasible and now the average frequency is once every 3

- 5 years

. R educing the frequency further i s not possible with

current alternatives.

In the case of rice mills, further reduction of methyl bromide use is not economically feasible. In order to obtain a complete kill of all life stages it is necessary to have either much higher rates of sulfuryl fluoride use (in some cases to levels that exceed label rates) or a facility temperature of approximately 140 0 

### F (approximately 125 0 

### C). In warm areas, where facility temperatures average 85 0 

### F, heating the facility can be accomplished at moderate expense. In colder areas where the facility temperature may average 40 o 

### F, the cost of heating the facility to obtain a complete kill is prohibitive. See table six below outlining the economic infeasibility of further reductions in thee particular portions of the

s ector

.

2. We understand the current regulatory situation for sulfuryl fluoride does not allow the treatment of some foods, such as pet foods and that this regulatory situation makes the use of SF difficult in some facilities. This may also be a problem fo r some rice and flour

millers. However, in the MBTOC text box for 2008 , we suggest that ways of segregating the food during facility fumigation be researched and assessed

. (See text excerpt below.) Can USG tell us if trials of these methods have been condu cted and the results of those investigations?

Excerpt of MBTOC/TEAP, April 2008 text box for US CUN structures provided for ease of reference: “Pet food facilities could, however, expand use of full site or spot heat treatment, utilizing appropriate pest barrier methods to prevent pest escape from spot heat treatments.” And, “The three sectors included in this CUN are expected to work to improve treatment logistics that improve product segregation so that more adoption of alternatives can be accomplished even if regulatory barriers to the use of SF persist. When conducting SF fumigations where food mixes are present, the applicant could trial tarping off the food under positive pressure or removing food ingredients and mixes to

non

- fumigated areas or seal ing off stored product warehouses to allow SF treatment of facility while ensuring that food is not exposed.”

USG ResponseUSG Responses to MBTOC QSC Page 2



### Both the P et Food I nstitute and the National Pest M anagement Association are considering test ing these strategies but have not ye t done so , in part because of recent budgetary concerns

. They are discussing this option with their fumigators to determine its potential. We will keep the MBTOC informed of further developments when they

occur.

3. We are having difficulty understandi ng the headings on the economic assessment

tables 5, 6, and 7

. I f the heading 7°F means the cost of raising the facility’s temperature by 7°F what would the heading 29°F mean? The CUN notes that mill temperature averages 29.44°C . If an additional 7°C is a dded, the resulting temp would be 36.44°C, which is insufficient for a heat treatment (50°C is required)

.

US G Response

On all structures assessments (rice mills, flour mills, and pet food), the 7oC and 29oC in the headings were incorrect but this will not change the costs in the assessment. The assessment was originally conducted on the Fahrenheit scale and then converted to Celsius. The temperature of an average facility (called a “warm facility” in the column heading) was assumed to be around 85oF ( 29.4oC). The temperature of a cold facility was assumed to be around 40oF (4.4oC). To heat the warm facility from 85o to 130oF (the temperature needed for total kill) required a 45oF increase in temperature which was converted to 7oC but a 7o change in t emperature on the Celsius scale does not reflect a 45o change in temperature on the Fahrenheit scale, hence the 7o was not the correct value to enter in the heading. Instead it should have reflected the change from 85oF to 130oF in

terms of Celsius so it should have read “Heat: 25oC” or the difference between 29.4oC

and 54.4oC.

The prices in the table, however, will remain unchanged. A heat treatment needs to warm the facility to 130o

- 140oF (54o

- 60oC) for total kill. So the assessment for a warm facilit y (i.e., a facility with an indoor temperature of 85oF) simply used a reasonable estimate of costs provided by a heat treatment company. The company that we contacted provided a cost range of $0.02 to $0.15 per cubic foot with $0.07 being the average and $0.15 being a worst case scenario (i.e., extreme cold and a lot of building partitions).

The cost of a heat treatment for warm facility (85oF or 29.4oC) assumed a cost of $0.07/cu ft to raise the temperature 45oF to reach 130oF. The cost of a heat trea tment for a cold facility (40oF or 4.4oC) assumed the worst

- case scenario and set the cost at $0.15/cu ft for heat treatment. The cost of the combination of SF + Heat treatment used the cost of SF from the second column plus $0.07/cu ft for heat. The dif ference between

29.4oC and 54.4oC is the same as the different between 4.4oC and 29.4oC. This would be an example where a very cold facility used heat to boost the efficacy of an SF treatment.

The column headings are corrected in the revised Table 6. ( See below)

Mills and NPMA

4. Why is the implicit per kg price for MB and SF $42.48 for Pet Food while the price per kg is $13.22 for MB and SF in Rice Mills and NAMA? Implicit price is calculated by dividing fumigant cost (i.e. gas) per year by quantit y of fumigant per year.USG Responses to MBTOC QSC Page 3



### US G Response

The calculations for kgs per facility, fumigant cost, and other fumigation costs were incorrect in the pet food table. The total fumigation costs, however, are unchanged.

Total fumigation costs were derived from information provided in the application and the average cost of SF ($6/lb) used throughout the assessment. The application states that a rate of 1.15 lbs/1,000 cu ft is needed to treat a pet food facility and that each facility is treated one time every 3

- 5 yrs or approximately 0.25x/yr. The annual cost of fumigation provided by the applicant in Worksheet 2

- D is $38,450 but this appears to actually reflect the cost of one MB fumigation, not the “annual” cost which would be the cost of a single fumigation spread over four years.

The calculations are corrected in the revised Table 6. (See below)USG Responses to MBTOC QSC Page 4

T ABLE 6 : A NNUAL E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES FOR P ET F OOD I NSTITUTE

Pet Food 1 Units MeBr 2 SF 2 Warm Facility:

Heat from 29.4 o C

to 54.4 oC Cold Facility:

Heat from 4.4 o C

to 54.4 oC Cold Facility: SF

+ Heat from 4.4 o C

to 29.4oC

Gross Revenue $/year $ 33,176,000 $ 33,176,000 $ 33,176,000 $ 33,060,000 $ 33,176,000

Total Operating Costs $/year na na na na n a

Total Fumigation/Heat Costs $/year $ 9,61 3 $ 11,63 8 $ 17,500 $ 37,500 $ 29,13 8 Quantity of Fumigant (0.25 treatment per year ) Kgs/facility

/ treatment 522 1,134 na na n a

Fumigant cost (i.e., gas) $/year $ 1,725 $ 3,750 na na $ 3,750 Other fumigation costs (i.e., labor, equip

., etc.) $/year $ 7,888 $ 7,888 $ 17,500 $ 37,500 $ 25,388

Other Operating Costs $/year na na na na na

Time Lost days 0 0 0 1 0

Total Loss (MeBr to alt) $/year $

- $ 2,025 $ 7,88 8 $ 27,88 8 $ 19,525 Average Facility Loss per Kg MeBr Requested $/kg MB requested $

- $ 1 10 $ 428 $ 1,51 4 $ 1,060

Loss as % of GR with MeBr 0% 0.01% 0.02% 0.08% 0.06%

1 Analysis for a 28,317 cubic meter ( 1,000,000 cubic foot ) facility

2 Temperature 29.44 degrees C (85 degrees F)USG Responses to MBTOC QSC Page 5



### 5

. MBTOC is trying to clarify the use of MB in flour milling and food processing in North

Amer ica through a better understanding of industry sector structure . Some mills included in the flour milling CUN also seem to be producers of bakery and cereal mixes and other processed foods

. Yet, processed foods manufacturers are included in NPMA. Last year USG indicated that about 58% of mills do not prepare bakery mixes. Can USG provide further clarification of percentage breakdown available, showing for example, the percentage of mills which only mill grain, the percentage which both mill grain and also

p repare bakery and cereal mixes, and also the percentage which also produce prepared foods?

USG Response

USG believes that 58% of mills mi l l grain but do not produce bakery mixes and so are eligible to use sulfuryl fluoride assuming that such use is econ omically feasible. The remaining 42% of mills both mill grains and produce bakery mixes so that until another product is registered, there is a change in the sulfuryl label, or some means of segregating inputs and product from the fumigation, these facili ties will be unable to transition.

Cured Pork Products and Facilities

6

. We note, with interest, the multi

- university research program for control of pests in this sector. We are aware of the results with sulfuryl fluoride. However the research

program has five different objectives; results obtained with the other alternatives have not been reported. If any of these studies are completed between now and September
2009, we request that USG send the results to MBTOC

.

US G Response

USG will share results a s they become available. However, t he multi

- university research program is funded for 3 years with a possible extension of 2 more years. The research is continuing.

7

. The CUN reports that heat would alter the product. The MBTOC text box (October,

20 08) makes a suggestion about a heat treatment that might effectively control pests in this commodity. What method was used in the US to test the effect of heat treatment

which resulted in the conclusion in the CUN? Was the method MBTOC suggested

tested? A re there plans to test the method MBTOC suggested?

Excerpt of MBTOC/TEAP October 2008 US cured pork products text box provided for ease of reference. “MBTOC recommends a CUE of 4.465 tonnes for specific cured (air

dried) pork products in 2010. This CUN h as decreased by 14.533 tonnes over the amount granted by the Parties for 2009. The USG is in the second of a three year multi

disciplinary research program to try to find non

- MB methods to control mites in this traditional cured pork product and associated storage houses. No chemical alternatives are registered for pest control in these products. Although MBTOC does not know of methods that have been published as effective for this situation. In the interest of contributing to research ideas, we can suggest : low oxygen controlled atmosphere; or dipping the hams in oil and lard at 90oC as practised in Spain with a similar product.USG Responses to MBTOC QSC Page 6



### MBTOC comments on economics: No economic data given. This is a minor use and there is little economic incentive to develop alterna tives”

US G Response

At this time, neither the industry nor the researchers have investigated these techniques. However, at the 2008 MBAO conference, the researchers informed us that they are planning on investigating these alternative techniques. When the researchers are ready to start these investigations they do intend to contact MBTOC for more specific

information

.