MBTOC questions for USG Page 1 

## United Nations Environment Programme Methyl Bromide Technical Options Committee Quarantine, Structures and Commodities (QSC)

Co-Chair: Ms Michelle Marcotte (Canada) email: marcotteconsulting@comcast.net

February 15, 2009
Marco Gonzalez Executive Secretary UNEP/Ozone Secretariat
and Ms Hodayah Finman Foreign Affairs Officer Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2658 Washington, D.C. 20520 U.S.A.

Dear Ms Finman and Mr. Gonzalez, MBTOC QSC and economists have completed its first level review of the US CUNs for post harvest uses. The review teams have posed a few questions which are organized below according to the application. 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 made year over year decreases in their MB use. Could you please provide the explanation(s) for the inability of these sectors to continue to decrease MB use? 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 for 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 conducted 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 ofMBTOC questions for USG Page 2 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 sealing off stored product warehouses to allow SF treatment of facility while ensuring that food is not exposed.”

3. We are having difficulty understanding the headings on the economic assessment tables 5, 6, and 7. If 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 added, the resulting temp would be 36.44°C, which is insufficient for a heat treatment (50°C is required).

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 quantity of fumigant per year. 5. MBTOC is trying to clarify the use of MB in flour milling and food processing in North America 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 prepare bakery and cereal mixes, and also the percentage which also produce prepared foods?

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. 7. The CUN reports that heat would alter the product. The MBTOC text box (October, 2008) 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? Are there plans to test the method MBTOC suggested? Excerpt of MBTOC/TEAP October 2008 US cured pork products text box provided forease of reference. “MBTOC recommends a CUE of 4.465 tonnes for specific cured (airdried) pork products in 2010. This CUN has decreased by 14.533 tonnes over theamount granted by the Parties for 2009. The USG is in the second of a three year multidisciplinary 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.MBTOC questions for USG Page 3 MBTOC comments on economics: No economic data given. This is a minor use and there is little economic incentive to develop alternatives”

MBTOC QSC, and all three MBTOC economists, will meet in Rotterdam, Netherlands April 20- 24 th . If it is possible, we would appreciate receiving your answers before our meeting.

Thank you,

Michelle Marcotte MBTOC Co-Chair