USA CUN11 SOIL Ornamentals Open Field Page 1 of 20 

NOMINATING PARTY: THE UNITED STATES OF AMERICA

FILE NAME: USA CUN11 SOIL ORNAMENTALS Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION: 

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Ornamentals Grown in Open 

Fields (Submitted in 2009 for 2011 Use Season) 

CROP NAME: Ornamentals Open Field

QUANTITY OF METHYL BROMIDE REQUESTED: 

TABLE 1: QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF NOMINATION

Year NOMINATION AMOUNT

2011 70,178 kilograms 

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Hodayah Finman 

Title: Foreign Affairs Officer 

Address: Office of Environmental Policy 

 U.S. Department of State 

 2201 C Street, N.W. Room 2658 

 Washington, D.C. 20520 

 U.S.A. 

Telephone: (202) 647-1123 

Fax: (202) 647-5947 

E-mail: finmanhh@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that the 

specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for 

this use would result in a significant market disruption. ■ Yes  No 

 

Signature Name Date 

Title: 

 (Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat website under 

Decision Ex. I/4(8).) 

This form is to be used by holders of single-year exemptions to reapply for a subsequent year’s exemption (for 

example, a Party holding a single-year exemption for 2005 and/or 2006 seeking further exemptions for 2007). It 

does not replace the format for requesting a critical-use exemption for the first time. 

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on 

which the Party’s first-year exemption was approved, as well as any supplementary information provided by the 

Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not 

re-submit that earlier information. 
USA CUN11 SOIL Ornamentals Open Field Page 2 of 20 

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack E. Housenger 

Title: Director (Acting) 

Address: Biological and Economic 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) 308-8200 

Fax: (703) 308-7042 

E-mail: jack.housenger@epa.gov 

 

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE: 

1. PAPER DOCUMENTS: 

Title of paper documents and appendices 

No. of pages Date sent to Ozone 

Secretariat 

USA CUN11 SOIL ORNAMENTALS Open Field 20 

 

 

 

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: 

*Title of each electronic file (for naming convention see notes above) 

No. of 

kilobytes 

Date sent to Ozone 

Secretariat 

USA CUN11 SOIL ORNAMENTALS Open Field 

 

 

 

* Identical to paper documents 
USA CUN11 SOIL Ornamentals Open Field Page 3 of 20 

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

ORNAMENTALS 

1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE 

This renomination is for methyl bromide for the production of ornamentals. The ornamental 

sector consists of cut flowers, cut greens, and bulbs in California; floriculture in Florida; and 

hybrid anemones and ranunculus in New York. All data comes from the applicants’ requests 

unless otherwise cited. 

California

Ornamental growers in California have a demonstrated critical need for methyl bromide in 2011. 

Alternatives are not available due to regulatory constraints. Iodomethane is not currently 

registered in California, and its future registration status is uncertain. Furthermore, many 

alternative fumigant regimens contain 1,3-dichloropropene and/or chloropicrin; these active 

ingredients are severely restricted by California state and local laws which effectively prevent 

their use as methyl bromide alternatives for ornamental cultivation. Restrictions on chloropicrin 

also means the lowest formulation of methyl bromide used in California is 67:33 (methyl 

bromide: chloropicrin), as rates of chloropicrin higher than 225 kg/ha are prevented by law and 

lower rates are ineffective for pest control. 

Florida

Iodomethane is now a registered pesticide in Florida. Research results indicate that it is as 

efficacious as methyl bromide, facilitating a transition away from methyl bromide. However, 

few long-term trials have been conducted and serious concerns have been raised about 

application techniques and species-specific interactions. For instance, there have been no 

iodomethane trials to treat permanent post-rows using the “hot gas” method, which currently 

uses methyl bromide and chloropicrin (98:2 ratio), and is a common management practice for 

Florida ornamental growers. Until more studies have been done to address these concerns, there 

is a critical need for methyl bromide in 2011 as part of a multi-year transition to alternatives. 

New York 

The applicant in New York has a demonstrated critical needed for methyl bromide in the 2011 

growing season, as many of the alternatives registered for open fields do not have a label 

allowing greenhouse usage, such as Telone (1,3-dichloropropene and chloropicrin) and Vapam 

(metam sodium). Furthermore, iodomethane is not registered in New York, and the possibility 

of its registration in the future is unknown. Steam sterilization appears to be the best pest control

option; however, there is a lack of research and thus efficacy data on methyl bromide alternatives 

for ornamental growers using enclosures. Therefore, methyl bromide is a critical component of a 

multiyear transition process. 
USA CUN11 SOIL Ornamentals Open Field Page 4 of 20 

2. REASONS WHY ALTERNATIVES TO METHYL BROMIDE ARE NOT FEASIBLE 

The adoption of alternatives to methyl bromide by the ornamentals sector is constrained by 

regulatory prohibitions, yield losses, and higher costs. Many of these restrictions vary by state. 

Additionally, some constraints apply to the entire ornamentals industry. A single grower may 

grow dozens of types of species and cultivars, each of which may experience different pest 

pressures. For example, a 2008 study in Florida found a significant difference between the pests 

of two cultivars of Delphinium and their pest loads (Rosskopf et al 2008). These differences may 

result in varying cultivar and species reactions to pest control measures, impacting an 

alternative’s ability to control the entire pest spectrum. 

California 

In addition to federal regulations, the California Department of Pesticide Regulation (DPR) has 

implemented severe restrictions for soil fumigants, including larger buffer zone requirements and 

township caps, which limit the amount of each fumigant can be applied within a 36-mile area 

(Segawa et al 2005). If these restrictions were not in place, the best methyl bromide alternative 

for ornamental growers in California would be 1,3-D plus chloropicrin followed by metam 

sodium (James Gerik, personal communication). A recent study found that this fumigant 

combination was at least as efficacious as methyl bromide (Klose et al 2008). The state buffer 

and township cap regulations currently prevent the use of this alternative. Moreover, another 

recent study found that the most effective alternative treatments contain chloropicrin (Gerik et al 

2002). However, any pesticide combinations including either 1,3-D or chloropicrin are subject 

to prohibitory regulations and cannot be considered currently available alternatives despite any 

proven efficacy. 

Some alternatives that appear effective in research trials are not currently registered, including 

acrolein, DMDS, and iodomethane (Rosskopf et al 2007b). The future registration status of these 

products and other alternatives is unknown. 

Florida 

Iodomethane is now fully registered in Florida and recent research results showed it is at least as 

effective as methyl bromide for pest control in Florida ornamentals (Rosskopf et al 2006, 

Rosskopf et al 2007a, Rosskopf et al 2007b, Kokalis-Burelle et al 2006). However, no studies 

have been conducted on the same fields for more than two years, so long-term efficacy and 

application issues have yet to be fully identified and understood. Moreover, efficacy has varied 

between the species and cultivars tested in research trials; it is impossible to predict how each of 

the many species and cultivars of ornamentals would respond to iodomethane. Additionally, 

research is needed on the compatibility of iodomethane with ‘hot gas’ fumigant application 

currently used for methyl bromide; it is a common management method for ornamental growers. 

The majority of methyl bromide alternatives research for ornamentals has been conducted in 

California (Rosskopf et al 2005). More studies are needed in order to understand the climatespecific constraints faced by Florida ornamental growers. 
USA CUN11 SOIL Ornamentals Open Field Page 5 of 20 

New York 

The critical use nomination for the 2011 growing season is entirely in greenhouse production, 

which has unique constraints for pest control options compared to open field production. Many 

fumigant alternatives currently registered do not have a label for use in greenhouses, including 

1,3-D and metam sodium. Iodomethane is not registered for any uses in New York and its future 

registration status is unknown. 

Moreover, very little research is conducted on the efficacy of methyl bromide alternatives in 

greenhouses. As such, efficacy data obtained from field trials is not translatable into predicting 

how even the same cultivar or species would perform in greenhouse conditions. 

Steam sterilization appears to be the best currently available alternative to methyl bromide for 

greenhouse production. While no regulations prevent the adoption of steam, the small size of the 

grower’s operation necessitates that the margin of error for research testing is very small. 

Methyl bromide is therefore critical in the 2011 growing season to a multi-year transition. 

For a more comprehensive list of methyl bromide alternatives and why they are not feasible for 

use in the ornamental sector due to technical and regulatory constraints, please see Appendix C. 

3. IS THE USE COVERED BY A CERTIFICIATION STANDARD?

Methyl bromide is not used to meet a certification standard for ornamental production. 

4. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, 

INDICATE THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER 

AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO 

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL 

BROMIDE THERE. 

Methyl bromide is only being requested for ornamental crop acreage with demonstrated critical 

need and is not being requested for acreage that has had success with alternatives, such as 

caladiums in Florida. 

Enclosures 

Some ornamental growers using greenhouses have had success controlling pests with substrates. 

Crops successfully grown in soilless media include roses, gerbera, lilies, and tulips. However, 

even substrates are fumigated after multiple cropping seasons to control diseases such as 

Pythium and continue using the substrate, which must be reused in order for the cropping system 

to be cost effective. Certain crops actually experience yield or quality gains when grown in 

substrates, such as roses; however, for most crops there is not such a gain to offset the increased 

costs associated with substrate production. Soilless media systems also require altered watering 

and fertilization management practices, which may incur additional costs. Ultimately, the use of 
USA CUN11 SOIL Ornamentals Open Field Page 6 of 20 

substrates requires greenhouses with benches, as opposed to growing crops in enclosures with 

open bottoms to the soil. 

Steam sterilization has been adopted by some shade house and greenhouse growers to produce 

lilies. While steam is considered effective in controlling pests, there are many costs required to 

set up a steaming system within an existing enclosure structure. The cost of fuel required to heat 

soil beds uniformly also impacts the feasibility of steam sterilization. Some growers who 

attempted transitioning to steam sterilization switched back to fumigation due to application 

issues and additional costs. 

Open Field 

The U.S. does not have information about the proportion of ornamental or floriculture crops 

using alternatives to methyl bromide. It can be presumed that acreage not requesting methyl 

bromide has either transitioned to an alternative pesticide or does not have the same cropping 

practices or pest pressure as the applicants with critical use requests. For example, Easter lily 

growers in California now use 1,3-D and metam sodium applied sequentially instead of methyl 

bromide. However, these crops allow fallow periods between crops of more than 10 years, 

which is not feasible for other specialty growers due to limited land resources. 

5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO 

COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF 

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE 

THIS? 

No, it is not currently feasible to expand the use of alternative pest control measures to address 

the demonstrated critical needs of the ornamentals sector requesting methyl bromide for the 2011 

growing season. Regulatory, technical, and economic barriers prevent their adoption and 

generally vary by state. Research to find efficacious, safe, and cost effective alternatives is 

ongoing. 

California 

State and local regulations would have to change in order for fumigants such as 1,3-D and 

chloropicrin to be adopted as methyl bromide alternatives. Other fumigants currently being 

tested may prove effective in research trials but lack registration in the state of California, such 

as iodomethane (Rosskopf et al 2007a). Furthermore, some fumigants considered effective in 

research trials for use in California lack both federal and state registration, including dimethyl 

disulfide and acrolein (Gerik and Wong 2008). 

Florida 

Research is needed in order to determine the long-term efficacy and cost issues associated with 

iodomethane adoption as a methyl bromide alternative. More research is also needed on 

nonfumigant alternatives. Critical use of methyl bromide could be further reduced by changing 

the label to allow concentrations lower than 98:2 (methyl bromide: chloropicrin) to be applied 

using the ‘hot gas’ method, which is a common management practice. Concentrations as low as 

50:50 (methyl bromide: chloropicrin) have been found to achieved comparable control of 

nematodes and nutsedge as with the 98:2 formula (Noling et al 2001). 
USA CUN11 SOIL Ornamentals Open Field Page 7 of 20 

New York 

Some fumigant alternatives available for open field ornamental growing are not registered for 

greenhouse use and as such cannot be used barring a change in their registration status. Research 

is needed to address the efficacy and cost issues associated with steam sterilization. 

6. SUMMARY OF RECENT RESEARCH 

CALIFORNIA 

Rosskopf, EN; JS Gerik, NK Burelle, G Church, R McSorley. 2007. Status of methyl bromide 

alternatives for ornamental crop production in Florida and California. American 

Phytopathological Society Annual Meeting. 

Midas 50:50 and 33:67 (iodomethane:chloropicrin) provided the best pest control in California. 

FLORIDA 

Rosskopf, Erin and Nancy Kokalis-Burelle. 2008. Area-wide demonstration of chemical 

alternatives to methyl bromide for Florida ornamentals. Proceedings of the Annual 

International Research Conference on Methyl Bromide Alternatives and Emissions 

Reductions. http://mbao.org/2008/028Rosskopf.pdf

No significant difference between methyl bromide and iodomethane efficacy was observed in 

terms of weeds per acre, rogues per acre, labor hours, and number of root-knot nematodes per 

100cc of soil. 

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

Please note that in this study net revenue is calculated as gross revenue minus operating costs. 

This is a good measure as to the direct losses of income that may be suffered by the users. It 

should be noted that net revenue does not represent net income to the users. Net income, which 

indicates profitability of an operation for an enterprise, is gross revenue minus the sum of 

operating and fixed costs. Net income is smaller than the net revenue measured in this study, 

often substantially so. We did not include fixed costs because they are difficult to measure and 

verify. 
USA CUN11 SOIL Ornamentals Open Field Page 8 of 20 

TABLE 2: CALIFORNIA CUT FLOWERS - CALLA LILY & RANUNCULUS - ECONOMIC IMPACTS OF 

METHYL BROMIDE ALTERNATIVES

California Cut Flowers – Calla Lily & Bulbs METHYL 

BROMIDE

1,3-D + Pic Dazomet Metam 

Sodium 

YIELD LOSS (%) 0 25 25 20 

 YIELD PER HECTARE 55,937 41,952 41,952 44,749 

* PRICE PER UNIT (U.S.$) 2.59 2.59 2.59 2.59 

= GROSS REVENUE PER HECTARE (U.S.$) 145,107 108,830 108,830 116,086 

- OPERATING COSTS PER HECTARE (U.S.$) 160,030 160,030 160,030 160,030 

= NET OPERATING REVENUE PER HECTARE (U.S.$) -14,923 -51,200 -51,200 -43,945 

1. LOSS PER HECTARE (U.S.$) 0 36,277 36,277 29,021 

2. LOSS PER KILOGRAM OF METHYL BROMIDE 

(U.S.$) 0 137 137 110 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0 25 25 20 

4. LOSS AS A PERCENTAGE OF NET OPERATING 

REVENUE (%) 0 -243 -243 -194 

TABLE 3: NEW YORK ANEMONES - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES *

NEW YORK CUT FLOWERS – ANEMONES METHYL 

BROMIDE STEAM STEAM STEAM

YIELD LOSS (%) 0 0 10 20 

 YIELD PER HECTARE 247,105 247,105 222,395 197,684 

* PRICE PER UNIT (U.S.$) 3.75 3.75 3.75 3.75 

= GROSS REVENUE PER HECTARE (U.S.$) 926,644 926,644 833,980 741,315 

- OPERATING COSTS PER HECTARE 

(U.S.$) 34,595 115,781 115,781 115,781 

= NET OPERATING REVENUE PER 

HECTARE (U.S.$) 892,050 810,863 718,199 625,534 

1. LOSS PER HECTARE (U.S.$) 0 81,186 173,851 266,515 

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (U.S.$) 0 110,86 237.38 364 

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0 8.8 18.8 29 

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0 9.1 19.5 30 

* Due to a lack of research on steam sterilization as a methyl bromide alternative for pre-plant fumigation for 

ornamentals in enclosures, yield loss estimates do not exist. Scenarios were therefore calculated with 0%, 10%, and 

20% yield loss estimates. 
USA CUN11 SOIL Ornamentals Open Field Page 9 of 20 

TABLE 4: FLORIDA CUT FLOWERS - LILIES - ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES 

Florida Cut Flowers - Lilies METHYL BROMIDE

IODOMETHANE +

PIC (98:2)

YIELD LOSS (%) 0 0 

 YIELD PER HECTARE 31,135 31,135 

* PRICE PER UNIT (U.S.$) 10 10 

= GROSS REVENUE PER HECTARE (U.S.$) 311,353 311,353 

- OPERATING COSTS PER HECTARE (U.S.$) 262,715 262,715 

= NET OPERATING REVENUE PER HECTARE (U.S.$) 48,638 46,908 

1. LOSS PER HECTARE (U.S.$) 0 1,730 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (U.S.$) 0 4 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0 1 

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0 4 

Summary of Economic Feasibility 

The economic analysis evaluated methyl bromide alternative control scenarios for cut flower 

production for California, New York, and Florida by comparing the economic outcomes of 

methyl bromide oriented production systems to those using alternatives. However, due to the 

fact that there are over 100 species of ornamentals grown in all regions of the country, the data 

from these examples are used to derive a proxy estimate for the entire industry. A major factor 

that affected this economic analysis as compared to the past economic analyses was the 

availability of iodomethane (registered in 2008) in Florida, but not in California and New York 

for use in ornamentals. 

The economic factors that most influence the feasibility of methyl bromide alternatives for fresh 

cut flower production are: (1) yield losses, referring to reductions in the quantity produced, (2) 

increased production costs, which may be due to the higher-cost of using an alternative, 

additional pest control requirements, and/or resulting shifts in other production or harvesting 

practices, and (3) missed market windows due to plant back time restrictions, which also affect 

the quantity and price received for the goods. 

 

The economic reviewers analyzed crop budgets for pre-plant sectors to determine the likely 

economic impact if methyl bromide were unavailable. Various measures were used to quantify 

the impacts, including the following: 

(1) Loss per Hectare. For crops, this measure is closely tied to income. It is relatively easy to 

measure, but may be difficult to interpret in isolation. 

(2) Loss per Kilogram of Methyl Bromide. This measure indicates the nominal marginal value 

of methyl bromide to crop production. 

(3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues 

are usually easy to measure, at least over some unit, e.g., a hectare of land or a storage operation. 

However, high value commodities or crops may provide high revenues but may also entail high 
USA CUN11 SOIL Ornamentals Open Field Page 10 of 20 

costs. Losses of even a small percentage of gross revenues could have important impacts on the 

profitability of the activity. 

(4) Loss as a Percentage of Net Operating Revenue. We define net cash revenues as gross 

revenues minus operating costs. This is a very good indicator as to the direct losses of income 

that may be suffered by the owners or operators of an enterprise. However, operating costs can 

often be difficult to measure and verify. 

These measures represent different ways to assess the economic feasibility of methyl bromide 

alternatives for methyl bromide users, who are producers in this case. Because producers 

(suppliers) represent an integral part of any definition of a market, we interpret the threshold of 

significant market disruption to be met if there is a significant impact on commodity suppliers 

using methyl bromide. The economic measures provide the basis for making that determination. 

Several methodological approaches will help interpret the findings. Economic estimates were 

first calculated in pounds and acres and then converted to kilograms and hectares. Costs for 

alternatives are based on market prices for the control products multiplied by the number of 

pounds of active ingredient that would be applied. Baseline costs were based on the average 

number of annual applications necessary to treat cut flowers with methyl bromide. 

Net revenue is calculated as gross revenue minus operating costs. This is a good measure as to 

the direct losses of income that may be suffered by the users. It should be noted that net revenue 

does not represent net income to the users. Net income, which indicates profitability of an 

operation of an enterprise, is gross revenue minus the sum of operating and fixed costs. Net 

income should be smaller than the net revenue measured in this study. Fixed costs were not 

included because they are difficult to measure and verify. 

Loss per hectare measures the value of methyl bromide based on changes in operating costs 

and/or changes in yield. Loss expressed as a percentage of the gross revenue is based on the 

ratio of the revenue loss to the gross revenue, likewise for the loss as a percentage of net revenue. 

Yield loss estimates were based on data from the CUE applications and U.S. EPA data, as well 

as expert opinion. 

Regulatory constraints

California restricts total use of 1,3-d, at the local level (township cap). Nematodes and weeds 

and pathogens are key pests in Florida and California bulb grower and are controlled with methyl 

bromide. Chloropicrin is not as effective in controlling weeds as methyl bromide. Using 

chloropicrin adds to production costs through increased chemical, weeding and labor costs. 

Tables 2 though 4 provide a summary of the estimated economic losses. A measure of net 

revenue loss may not be completely accurate partly because some nurseries are publicly owned 

and seedling prices or production costs are subsidized. Indirect losses arising from shifts in the 

production cycle were not quantified. Changes in production costs arise due to differences 

between the costs of methyl bromide and the alternatives, shifts in the production cycle 
USA CUN11 SOIL Ornamentals Open Field Page 11 of 20 

(increasing the frequency of fumigation or lengthening the fallow period) and additional 

expenses such as supplementary irrigation. These costs vary across regions. 

As shown in Table 2, the alternatives to methyl bromide for California cut flower production 

impose significant economic impacts on the growers. Similarly, for New York anemones 

growers, steam sterilization as an alternative to methyl bromide results in substantial economic 

impacts (Table 3). However, in Florida where iodomethane is available for use in ornamentals, 

economic impacts of using iodomethane as an alternative to methyl bromide are small. 

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES 

The USG has applied an aggressive transition rate which is reflected in the nomination amount 

and detailed in Table 5. 

TABLE 5: NOMINATION AMOUNT

 California Cut 

Flower 

Commission 

 New York 

Ornamentals 

 Florida Cut 

Flowers 

 Sector Total / 

Average 

Quantity Requested for 2010: Amount (kgs) 272 67,946 24,281 92,499 

Quantity Recommended by 

MBTOC/TEAP for 2010 : Amount (kgs) 74 57,963 24,281 82,318 

Amount (kgs) 74 57,963 24,281 82,318 

Area (ha) 0 290 121 411 

Rate 200 200 201 200

Transition from 2010 

Baseline Adjusted Value

Percentage (%) -15% -73% -70% -37%

Amount (kgs) 74 57,963 12,141 70,178 

Area (ha) 0 290 61 351 

Rate 200 200 200 200 

ORNAMENTALS

2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

Transition Use Reduction Description Spreadsheet

SECTOR

Quantity Approved by Parties 

for 2010:

Quantity Required for 

2011 Nomination:
USA CUN11 SOIL Ornamentals Open Field Page 12 of 20 

CITATIONS 

Gerik, JS; CL Elmore, ID Greene. 2002. Alternative soil treatments for field grown 

ornamentals. Proceedings of the Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions. 

http://mbao.org/2002proc/093gerikj%20mbao_2002.pdf

Gerik, James and Dong Wang. 2008. Control of Agrobacterium tumafaciens with soil 

fumigants. Proceedings of the Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions. http://mbao.org/2008/110Gerik.pdf

Gerik, James. Personal communication via telephone. October 28, 2008. 

Klose, Susanne; Jim Gerik, Hussein Ajwa, Cheryl Wilen, Mike Mellano. 2008. Proceedings of 

the Annual International Research Conference on Methyl Bromide Alternatives and 

Emissions Reductions. http://mbao.org/2008/029Klose.pdf

Kokalis-Burelle, Nancy; Erin Rosskopf, Randy Driggers. 2006. Efficacy of Midas for control of 

Meloidognye incognita on Celosia in Florida. Proceedings of the Annual International 

Research Conference on Methyl Bromide Alternatives and Emissions Reductions. 

http://mbao.org/2006/06Proceedings/112BurelleNMBAOAbstractBurelleetal2006.pdf

McSorley, R., Wang, K.H., Church, G. 2004. Fumigant alternatives to methyl bromide for 

managing nematodes and weeds in snapdragon. Proceedings of Florida State Horticulture 

Society. 117:334-337. 

National Agricultural Statistics Service (NASS). 2008. Floriculture Crops 2007 Summary. 

USDA Sp Cr 6-1 (08) 

http://usda.mannlib.cornell.edu/usda/current/FlorCrop/FlorCrop-04-24-2008.pdf 

Noling, J.W; J.P. Gilreath, E.R. Rosskopf. 2001. Alternatives to methyl bromide field research 

efforts for nematode control in Florida. Proceedings of the Annual International Research 

Conference on Methyl Bromide Alternatives and Emissions Reductions. 

http://mbao.org/2001proc/014%20Noling%20JW%20MBAO2-2001.pdf 

Rosskopf, Erin; D.O. Chellemi, N. Kokalis-Burelle, G.T. Church. 2005. Alternatives to methyl 

bromide: a Florida perspective. APSnet Feature June 2005: 

http://www.apsnet.org/online/feature/methylbromide/

Rosskopf, Erin; Nancy Kokalis-Burelle, Randy Driggers. 2006. Evaluation of Midas for 

production of ornamental cockscomb in Florida. Proceedings of the Annual International 

Research Conference on Methyl Bromide Alternatives and Emissions Reductions. 

http://mbao.org/2006/06Proceedings/037Rosskopfetalcelosia2006.pdf

Rosskopf, Erin; Nancy Kokalis-Burelle, and Randy Driggers. 2007a. Reduced rates and 

alternatives to methyl bromide for snapdragon production in Florida. Proceedings of the 
USA CUN11 SOIL Ornamentals Open Field Page 13 of 20 

Annual International Research Conference on Methyl Bromide Alternatives and Emissions 

Reductions. http://mbao.org/2007/Proceedings/106RosskopfEMBAOsnapdragon2007.pdf

Rosskopf, EN; JS Gerik, NK Burelle, G Church, R McSorley. 2007b. Status of methyl bromide 

alternatives for ornamental crop production in Florida and California. American 

Phytopathological Society Annual Meeting. 

Rosskopf, Erin and Nancy Kokalis-Burelle. 2008. Area-wide demonstration of chemical 

alternatives to methyl bromide for Florida ornamentals. Proceedings of the Annual 

International Research Conference on Methyl Bromide Alternatives and Emissions 

Reductions. http://mbao.org/2008/028Rosskopf.pdf

Segawa, Randy. 2005. Methods for developing fumigant regulatory requirements in California. 

Proceedings of the Annual International Research Conference on Methyl Bromide 

Alternatives and Emissions Reductions. 

http://mbao.org/2005/05Proceedings/001%20SegawaR%20mbao_2005_conf_segawa_sum

mary.pdf 

Zinati, Gladis; Herbert Bryan and Merlyn Codallo. 2002. Solarization as a potential approach 

for recycling wastes for potting media and as an alternative to methyl bromide for fieldgrown bedding plants. Proceedings of Florida State Horticulture Society. 115: 123 – 127. 
USA CUN11 SOIL Ornamentals Open Field Page 14 of 20 

APPENDIX A: ORNAMENTAL SPECIES GROWN 

The incredibly large and constantly changing number of species and cultivars grown in the 

ornamentals sector means that compiling a complete list of species and acreage grown is not 

possible. There are hundreds of types of cut flower, foliage, and bulb crops grown each year and 

often several species are grown in the same field simultaneously. However, the U.S. has tried to 

describe the major crops below. Additional information is not available from public or private 

sources. 

California 

APPENDIX B -TABLE 1: CALIFORNIA ORNAMENTALS - PRODUCTION OF MAJOR SPECIES

SPECIES # FLOWER BUNCHES IN 2003 

Alstroemeria 892,789 

Carnations 1,694,870 

Delphinium 3,617,186 

Gladiolus Data not released 

Gerbera 62,638,650 

Iris 5,823,242 

Lilium 6,247,027 

Chrysanthemums 1,273,742 

Pompons 6,350,127 

Roses 7,360,729 

Snapdragons 2,976,219 

APPENDIX B - TABLE 2: CALIFORNIA ORNAMENTALS - PARTIAL LISTING AND ESTIMATE OF CUT FLOWER AND 

FOLIAGE AREA PRODUCED IN CALIFORNIA IN 2002

CROP AREA (USUALLY FIELD) - HA AREA (USUALLY GREENHOUSE) - HA 

Alstroemeria 8 5 

Antirrhinum (snapdragon) 126 17 

Aster 6 

Calla lily 16 

Carnation 30 2 

Chrysanthemum 88 28 

Delphinium 22 

Eucalyptus 54 

Gerbera 21 

Gypsophila 55 

Iris (Dutch) 18 

Larkspur 6 

Lilium 32 21 

Limonium spp. 13 

Lisianthus 13 

Protea 190 

Rose 41 12 

Stock (Matthiola) 26 

Wax flower 317 

Other 791 6 

Greenhouse misc. 70 28 

Field misc. 303 

Cut greens misc. 389 
USA CUN11 SOIL Ornamentals Open Field Page 15 of 20 

CROP AREA (USUALLY FIELD) - HA AREA (USUALLY GREENHOUSE) - HA 

Total 2609 145 ha 

1

 Total does not add due to rounding. 

Florida 

The only three cut flower species identified by the Florida Agricultural Statistics Service are 

gladioli, lilies and snapdragon. These are assumed to have the highest acreage and they have 

been identified by the applicant as using methyl bromide. 

APPENDIX B TABLE 3. FLORIDA ORNAMENTALS - CROP PRODUCTION FOR CERTAIN CUT FLOWER SPECIES2

2001 2002 2003 

CROP

# OF 

PRODUCERS

QUANTITY 

SOLD (1000

SPIKES)

1

# OF 

PRODUCERS

QUANTITY 

SOLD (1000

SPIKES)

1

# OF 

PRODUCERS

QUANTITY 

SOLD (1000

SPIKES) 

Gladioli 4 40,331 4 49,581 4 39,444 

Snapdragons 5 6,806 4 4,415 4 4,757 

Lilies 4 3,031 3 2,257 - - 

1

 Quantity of lilies sold 1000 stems. 

2 This table only includes data for growers with sales over $100,000. 

New York

The nomination is for methyl bromide critical use in New York is for hybrid anemones and 

ranunculus grown in greenhouses. 
USA CUN11 SOIL Ornamentals Open Field Page 16 of 20 

APPENDIX B: KEY TARGET PESTS 

The ornamentals industry is complex; therefore, the following list is not comprehensive but is 

intended to demonstrate the large number of pests affecting ornamental production and creating a 

critical need for methyl bromide in the U.S. for the 2011 growing season. 

APPENDIX B TABLE 1. KEY PESTS

Region where 

methyl 

bromide use 

is requested 

Key disease(s) and weed(s) to 

species and, if known, to level of 

race 

Specific reasons why methyl bromide needed (e.g. 

Effective herbicide available, but not registered for this 

crop; mandatory requirement to meet certification for 

disease tolerance; no host resistance for a specific race) 

A: California 

Cut Flowers, 

Cut Greens 

and 

Perennials 

Verticillium spp., Fusarium spp., 

Pythium spp., Meloidogyne spp., 

Nutsedge (Cyperus spp.), Malva spp., 

Poa spp., and previous crop 

propagules. Specific pest problems 

vary by individual crop and variety. 

The diversity and complexity of the industry, makes it 

difficult to control all root pathogens and weeds with 

currently available pest control methods. Some methyl 

bromide alternatives used for other sectors are not

feasible for floriculture due to high costs, difficulty 

timing applications to allow intercropping, and regulatory 

restrictions including township caps and buffer zone 

requirements. 

B: Florida 

Floriculture 

Soilborne diseases, weeds, and 

nematodes including Fusarium spp., 

Rhizoctonia spp., Phytoplithora, 

Stromatinia, Pythium spp., Erwinia, 

and most soil nematodes e.g. 

Meliodogyne spp., and previous crop 

propagules. Specific pest problems 

vary by individual crop and variety. 

These diseases are common, abundant, and spread via

water, exacerbated by Florida’s regions of tropical and 

sub-tropical climates. Due to the complexity of the

ornamentals sector, alternative pest control measures 

have not been found for all species but research efforts 

are ongoing. Iodomethane is now registered; however, 

other methyl bromide alternatives preliminarily 

considered effective, such as dimethyl disulfide, are not 

currently registered for use. 

C. New York 

Anemones 

Soil borne diseases and pests, 

including Rhizoctonia, Pythium, 

Thielaviopsis, nematodes, 

symphylids, and the Anthracnose 

fungus Colletotrichum

Infected corms from previous cropping cycles must also 

be controlled. Iodomethane is not registered, and other 

alternatives may be cost prohibitive or do not control the 

entire pest spectrum. Several methyl bromide 

alternatives considered effective and registered for open 

field use do not have labels for greenhouse use. 
USA CUN11 SOIL Ornamentals Open Field Page 17 of 20 

APPENDIX C: STATUS OF METHYL BROMIDE ALTERNATIVES 

APPENDIX C TABLE 1. REASON FOR ALTERNATIVES N OT BEING FEASIBLE

NAME OF 

ALTERNATIVE

TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR 

AVAILABLE

1,3-

Dichloropropene 

(1,3-D) 

Technical 

Controls nematodes but will not provide adequate control of diseases and weeds at label rates. 

Regulatory 

Buffer zones limit its use and township caps in Florida and California further restrict its use in 

those states. Mandated plant-back times can be 1 to 2 weeks longer with 1,3-D than with other 

fumigants. 1,3-D is not registered for use in greenhouses. 

Chloropicrin 

Technical 

Weed control is poorer than with methyl bromide Control of the entire pest spectrum cannot be 

achieved with lower use rates, but there are concerns about phytotoxicity to nearby plantings if 

greater than 2% chloropicrin is used in a fumigant combination 

Regulatory 

There is concern over the real or perceived public exposure to higher rates of chloropicrin, 

especially in highly populated urban areas, due to increased worker exposure, offsite 

movement, and smells. 

Metam sodium 

Technical 

Efficacy data is inconsistent, depending on soil type, moisture content, and temperature. 

Regulatory 

Metam sodium is not registered for use in greenhouses. 

Iodomethane 

Technical 

More research needs to be done to understand application and long-term efficacy issues. 

Regulatory 

Iodomethane is not registered for use in California or New York. Large buffer zones may also 

prevent widespread adoption. 

1,3-D + 

chloropicrin 

Technical 

This alternative does not control the entire pest spectrum. 

Regulatory 

In California, 1,3-D + chloropicrin is considered one of tthe best currently available 

alternatives, if label application rates were increased Township caps and buffer zones that exist 

for the individual chemicals also apply for the combination. 

Metam sodium + 

chloropicrin 

Technical 

This combination does not adequately control nematodes and weeds, and performance is 

inconsistent. 

Regulatory 

Restrictions and concerns existing for the individual chemicals also apply for the combination. 

1,3-D + metam 

sodium 

Technical 

Efficacy data is inconsistent. 

Regulatory 

Restrictions for the individual chemicals also apply for the combinations. 
USA CUN11 SOIL Ornamentals Open Field Page 18 of 20 

NAME OF 

ALTERNATIVE

TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR 

AVAILABLE

1,3-D + 

chloropicrin + 

metam sodium 

Technical 

Weed control is incomplete. 

Regulatory 

In California, 1,3-D + chloropicrin is considered the best currently available alternative, if use 

restrictions, such as township caps, were removed. Restrictions existing for the individual 

chemicals also apply for the combinations. 

1,3-D + 

chloropicrin + 

herbicides 

Technical 

None. 

Regulatory 

Restrictions existing for the individual chemicals also apply for combinations. 

Dazomet 

Technical: 

Dazomet does not control the entire pest spectrum unless in combination with 1,3-D, 

chloropicrin, and/or herbicides. 

Regulatory: 

Restrictions on 1,3-D and chloropicrin prevent the use of Dazomet as a methyl bromide 

alternative. 

Metam sodium + 

crop rotation 

Technical 

Treatment does not control the entire pest spectrum. 

Regulatory 

Restrictions existing for metam sodium also apply to its use in combination with other pest 

control measures. 

Steam 

Technical 

Steam sterilization is not feasible in open field production due to the need to remove the steam 

piping after application in order to accommodate cultural management practices. In 

greenhouses, steam has been successfully used in previous decades as a pest control method. 

 

Regulatory 

None. 

Biological control 

agents 

Technical 

No biological controls have been developed to cover all of the pests. 

Regulatory 

None. 

Crop rotation 

Technical: 

Previous crops’ bulbs and corms often contaminate the following crop as volunteer weeds or 

reservoirs for pathogens. 

Regulatory 

None. 

Herbicides 

Technical: 

Crop damage may occur from contact with certain herbicides or in the following crop if soil 

residues remain. 

Regulatory 

Restrictions for registered pesticides vary depending on the active ingredient(s) and individual 

product labels. 
USA CUN11 SOIL Ornamentals Open Field Page 19 of 20 

NAME OF 

ALTERNATIVE

TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR 

AVAILABLE

Biofumigation 

Technica:l 

Biofumigation is still largely in the experimental stages. Specific brassicas as well as specific 

years yield variable amounts of activity. While this alternative may provide some control, the 

control of all target pests is not sufficient. 

Regulatory: 

None. 

Substrates 

Technical: 

The use of substrates is only technically feasible in greenhouses using benches, 

Regulatory 

None. 

Dimethyl 

disulfide 

(DMDS) 

Technical: 

Studies are currently being conducted to test the efficacy of DMDS in ornamentals under an 

Experimental Use Permit. 

Regulatory: 

DMDS is not currently registered, and its future registration status is not known. 

Acrolein 

Technical: 

Studies are currently being conducted to determine the efficacy of acrolein for ornamentals. 

Regulatory: 

Acrolein is currently only registered as an aquatic herbicide and cannot be used on soil for this 

use. Its future registration status is unknown.

Propargyl 

bromide 

Technical: 

More research is needed to understand its efficacy as a methyl bromide alternative. 

Regulatory: 

This alternative is not currently registered and its future regulatory status is unknown. 

Sodium azide 

Technical: 

More research is needed to understand its efficacy.

Regulatory: 

This alternative is not currently registered and its future regulatory status is unknown. 

Muscador albus 

Strain QST 

20779 

Technical: 

No commercially available formulation. 

Regulatory: 

None. 

Ethane dinitrile 

(Cyanogen) 

Technical: 

Considered a viable alternative in Australia, no studies have been conducted in the U.S. 

comparing efficacy with methyl bromide and other alternatives. 

Regulatory: 

This product is not currently registered in the U.S. and its future registration status is unknown. 

Acidic 

electrolyzed 

oxidizing (EO) 

water 

Technical: 

EO water only controls foliar fungal diseases in greenhouse ornamentals. No research has been 

conducted on this product as a pre-plant pesticide in at least 6 years. 

Regulatory: 

There is no commercial development or planned registration of this product currently. 
USA CUN11 SOIL Ornamentals Open Field Page 20 of 20 

NAME OF 

ALTERNATIVE

TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR 

AVAILABLE

Solarization 

Technical: 

Efficacy data is inconsistent between research trials. Regional subclimates with significant 

cloud cover or cooler annual temperatures will not receive enough degrees for solarization to be 

a feasible pest control option. 

Regulatory: 

None. 

Furfural 

Technical: 

It does not control the entire pest spectrum. 

Regulatory: 

Furfural has a federal registration for ornamentals and non-food commodities for greenhouse 

soil use only. However, it does not have state registrations currently, and its future registration 

status is unknown.. 

Regulatory reasons include local restrictions (e.g. occupational health and safety, local environmental regulations) 

and lack of registration.