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NOMINATING PARTY : The United States of America

DATE: MARCH 2 7 , 201 3

FILE NAME: USA CUE15 HAM FACILITIES

BRIEF DESCRIPTIVE TI TLE : U.S. Response to M BTOC February 14, 2013 Questions on

Ham Facilities

SITE NAME (OPEN FIEL D): Dry Cured Meat Products

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Foreign Affairs Officer

Address: Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2657 Washington, D.C. 20520 U.S.A. Telephone: (202) 647

- 3819

Fax: (202) 647

- 1052

E

- mail: SanMartiniFM@state.gov

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:
Contact/Expert Person: Mark Hartman

Title: Acting Director

Address: Biological and Economi c Analysis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcode 7503P Washington, D.C. 20460 U.S.A. Telephone: (703) 308

- 0 734

Fax: (703) 308

- 7042

E

- mail: Hartman.Mark@epa.gov

BACKGROUND The United States government nomination is for 3,240 kilograms of methyl bromide to fumigate aged country hams in 27 facilities. The pest of concern is Tyrophagus putrescentiae

, the ham mite (also called cheese mite and mold mite), which infests the aging hams and renders them unsalable in the United States. No alternatives have been identified to control this pest under

U.S. conditions.

MBTOC Question 1

. This CUN is complet ely silent on MBTOC’s most pressing need for information: why do some facilities fumigate 5x/yr when other facilities fumigate 2x/yr? This was the key concern of MBTOC last year when our recommendation was that each facilityPage 2

improve gastightness, IPM, and take other measures to reduce frequency of fumigation by one fumigation per year (except those which already fumigate only twice per year.)

U.S. Reply The frequency of fumigation is based on the biology of the pests, in this case primarily mites, Tyrophag us putrescentiae

. If a processor visually sees mites , or signs of mites, on his hams and ham racks, he will schedule a fumigation with methyl bromide within 2 weeks to make sure that the mites do not cause damage to the hams. The processors do not fumigate except when they need to reduce pest infestations

. According to U.S. federal regulations, hams sold in the United States must be free of mites ( 21 U.S.C ode 601(m)(3),

9 C ode of F ederal R egulations 416.2(a) ).

A thorough unde rstanding of the biology of this pest, especially in relation to the

environment

, is under investigation by Dr. Phillips , but not completely elucidated. However, like all biological systems, this is greatly affected by the environment , both

biotic and abi otic. For instance, s ome locales have higher pest pressure than others, and some have higher rates of re

- infestations than others. For instance, t emperature and humidity clearly play a role , as does the fat and protein content of the food sources

. However effects of other factors have yet to be described. One factor that appears to play a major influence i s the age of the hams (see also the U.S. reply to question 3 below)

.

The basic generation time of T. putrescentiae

, under optimal conditions, is about 9.5 days (25°C and 85% RH). Under these optimal conditions, longevity of females ranges from 66 to 99 days (Boczek, 1991). A female mite can lay up to 500 eggs (Boczek, 1991). Therefore, this arthropod has more than 36 overlapping generations p er year in these country ham aging rooms.

Aging hams have both high fat and protein content needed by T. putrescentiae . In addition country hams in the U nited S tates provide nearly optimal temperature and humidity ( 26 C, 75% RH) for maximum reproduction and longevity of mites

. Data, from Schilling (see

T able 1 below), indicate that t he longer hams are aged, the greater the likelihood for mite

infestations.

While there is research into IPM strategies for this industry

, currently none have been identified to control mite populations. Sanitation is already being practiced at all facilities

. F urther understanding of the parameters of this biological system is critical to developing more strategies.

MBTOC Question 2

. The CUN page 11 Table 3, indicates that the US request for MB was based on the standard dose plus 10% for contingency. The CUN suggests that this was how MBTOC calculated its recommendation last year. But the US is missing a key element of this

recommenda tion which was that

– in the absence of any technically valid justification for a high frequency of fumigation

– MBTOC recommended a reduction of one fumigation per year for all facilities (except those already only fumigating twice a year). We then added 10% for contingency in the total amount to take into consideration possible adverse weather issues etc. The 10% contingency was not to be considered an allowable additional dosage rate.Page 3

(Two pertinent excerpts of the 2012 MBTOC Final report text box on c ured pork have been added as an appendix to this letter for ease of reference.)

MBTOC has used a standard MB dosage of 20g/m3 for all MB fumigations for all the years it has been reviewing MB use and making recommendations. That standard dosage has not

cha nged and MBTOC has not seen any technical valid argument to change the standard dosage

rate.

We clearly need receive information from USG containing the technical justification for the wide differences in frequency of fumigation by facilities.

U.S. Reply The United States recognizes the standard presumptions identified in the Handbook on

Critical Use Nominations for Methyl Bromide , including the dosage rate of 20 g/m 3 for structural fumigations, and agrees with MBTOC’s 10% contingency for extenuating

ci rcumstances, such as adverse weather issues. However, w e disagree with MBTOC for arbitrarily limiting the number of fumigations.

The number of fumigations is dictated by the presence of mites on hams within the facility

. As described above ( Q 1)

, the environmental conditions of the aging rooms are optimal for mite development. The hams themselves are an optimal source of protein and fat for maximum longevity and reproduction. And researchers have observed that the longer hams are aged, the more often they need to be fumigated to meet the U.S. regulations for unadulterated food products (see table below Q3)

. Since there are no technically and economically feasible alternatives, t he industry needs to fumigate for mites when populations

are observe d. The costs of conducting the fumigation itself as well as associated

inconvenience and lost time for the facility are a strong disincentive for fumigations to take place except when they are needed.

MBTOC Question 3

. I note that during last year’s OEWG meeting, USDA’s Dr. Ann Bartuska gave me a table which correlates frequency of fumigation to length of storage time of the cured pork. I am concerned, however, that this was not given to us officially. If the US wishes to provide that table (and expla in the data source of the information), and/or similar information, to us it might be a significant contribution to our understanding. It is certainly one of the pieces of

information that we could use.

MBTOC is mindful of two facts: one is that our recomm endation was not accepted by Parties last year and the second is that Parties demand that we do a diligent and technically correct evaluation of a requested use of methyl bromide. We can only do so if Parties provide needed

information. Therefore we ask U S to correct the oversight of this needed information in its

CUN.

Questions concerning volume of facilities fumigated:

U.S. Reply

The United States appreciates MBTOC’s follow

- up question on the graph presented informally i n November , 2012 . Attached is Figure 1 , “Number of fumigations per year basedPage 4

on age of dry cured hams that are produced by various dry

‐ cured pork plants in the

Sou theastern United States. ” This is the figure provided by Dr. Bartuska to a member of MBTOC last year. The information in the figure is the result of industry feedback in 2008 to a request for information from Dr. Wes Schilling of Mississippi State University. Because the figure may be difficult to interpret, we are also providing the data used to generate the figure. Table 1 shows the direct relationship between months of aging for dry

cured hams to the number of fumigations to address ham mite infestations

. This data clearly

shows that t he longer a ham undergoes curing in storage, the more frequently fumigations

with meth yl bromide are required. Hams aged less than three months do not require any fumigation. Increasing the aging time to three months results in a majority (87%) of the hams requiring a single fumigation. In contrast, h ams aged more than 6 months can requir e 5 to 6 fumigations. Fumigations are ordered only when mite outbreaks are observed on ham

racks and the hams themselves.

Table 1. Number of fumigations compared to age of hams, percent of total

Maximum

Number of Fumigations per Year Age of Hams (months )

< 3 3 4 5 to 6 6 to 12 18 to 24

0 100 % 14 % 0 0 0 0

1 0 87 % 33 % 0 0 0

2 0 0 33 % 0 17% 0

3 0 0 33 % 100 % 0 0

4 0 0 0 0 50 % 0

5 0 0 0 0 0 0

6 0 0 0 0 33 % 100 % Based on 27 facilities. Information collected by Dr. W Schilling, 2008

.

The United States would like to note that this information is consistent with previous research. Rentfrow et al. (2006) found that aging times of longer than 5 months causes an increased risk for infestation with mites and beetles. However, aging for shor ter times than 5 months does not assure processors that infestation problems will not occur, and long aging times (> 6 months) are often necessary to obtain desired flavour and product quality that

meets niche markets.

MBTOC Question 4

. In May 2012, MBTOC asked the US to supply the following information: a total true volume of the aging rooms which are fumigated in each facility, irrespective of the number of fumigations. In other words, if one of the applicants’ aging rooms is fumigate d 3x/yr we did not want them to multiply the volume of their aging room 3x and then report that as the volume. We then noted that we needed to know the average of how often each aging room is fumigated annually by each applicant.

U.S. Reply In August 2012 the United States provided, on a per facility basis, the maximum methyl bromide used, aging room size, and the maximum number of fumigations per year. ThisPage 5

information was also included in the U.S. critical use nomination submitted on January 24, 2013 (s ee table 3 of the U.S. critical use nomination).

While each facility may be composed of multiple aging rooms, typically all the rooms get

outbreaks of mites at about the same time. Aging rooms may be composed of wood, concrete, or cinder blocks with co nnections, such as electrical conduits and underground pipes and drains. While m ites may be introduced into rooms when the doors are opened or closed, or on workers clothing

, the openings between the aging rooms also allow mites to infest the neighboring rooms. When mites are observed in one aging room it is not long before they are found in other nearby aging rooms; therefore a fumigation will involve the entire aging room complex , or facility

.

While the table (Table 3 of the US CU N ) listed separate facilities, each row represented the

rooms that are fumigated together. P roducers often have multiple small aging rooms in facilities separate from the offices. As a practical matter, all aging rooms are fumigated simultaneously as mite infestation in on e room inevitably lead s to infestations in adjoining aging rooms since ham mites, like dust mites, can be carried in air currents. In fact, professional applicators wil l often tarp (or tent or wrap) the entire building for a fumigation. Regarding the num ber of times an aging room might be fumigated, again please refer to

Table 1.

MBTOC Question 5

. Although the US then supplied information about the number of fumigations at each company, the requested information about the volume of the aging rooms

and the number of times each aging room is fumigated has not yet been supplied. This

information is needed to determine the correct amount of MB needed.

U.S. Reply

A ll aging rooms within a facility are fumigated simultaneously (See reply to Q4)

.

MBTOC Ques tion 6

. The CUN pages 7

- 8 indicates the planned research on MB alternatives for cured pork. However, we believe the CUN was written several months ago. Could the US please confirm if this research has indeed started and if there have been any addition s or deletions to the program of planned research?

U.S. Reply

The CUN research update was written 201 2 and is still current with one update regarding the testing of mesh screens

.

Schilling and Phillips add ed research areas which include: Effect of temperatures between

20 ° C and 40 ° C on mite growth on ham cubes ; Development of food grade gels to cover the

surfaces o f ham and inhibit infestations; and e valuation of mesh coating and barrier bags for their potential to prevent mite infestations.

Dr. Phillips writes:Page 6

“ We will test the efficacy of 30 m (micrometer) mesh nylon for preventing mite infestation of ham pieces. We already have good results on "food

- safe" coatings and dips, but these will need fie ld validation. ”

MBTOC Question 7

. Additionally, in its text boxes and previous correspondence, MBTOC suggested incorporating fine, mite

- proof gauze into the system of preparing and storing cured pork. This suggestion does not seem to have been taken into account by the Party and is not

m entioned in the CUN. Could the USG explain its views, and the intentions of its researchers and cured pork facilities, towards this technical recommendation?

U.S. Reply Dr. Phillips reports:

“ We will test the efficacy of 30 m (micrometer) mesh nylo n for preventing mite infestation of ham pieces. We already have good results on "food

- safe" coatings and dips, but these will need fie ld validation. ”

Questions on phase out of MB for cured pork in the US:

MBTOC Question 8

. Noting that European producers of similar cured pork products do not use methyl bromide for pest control, and noting the continuing use of MB in the US, MBTOC asks how the Party intends to phase out MB in this sector.

U.S. Reply

Researchers in the Unit ed States have conducted research on methyl bromide alternatives for

many years and we continue to have a robust research program . Currently there are no technically and economically feasible alternatives for control of pests on U.S. dry

- cured pork produc ts . We hope that in the future alternatives will be developed that are technically and economically feasible for use in this sector.

References:

Boczek, J. 1991. Mite pests in stored food. In: JR Gorham, ed. Ecology, Management of Food

Industry Pests. FDA Technical Bulletin 4. Association of Official Analytical Chemists, Arlington, VA. Pp 57

- 79.

Rentfrow, G., Hanson,D.J., Schilling, M.W., Mikel, W.B. (2006) Methyl bromide use to combat mite infestation in dry

- cured ham during production

. http://mbao.org/2006/06Proceedings/108SchillingMMethylbromideusetocombatmiteinfestationin %20dry.pdf

.