USA CUN 14 POST HARVEST

-- Dry, Cured Pork Products Page 1



### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR POST

HARVEST

-- DRY CURED PORK PRODUCTS

NOMINATING PARTY : The United States of America

FILE NAME USA CUN 1 4 POST HARVEST

-- DRY, CURED PORK PROD UCTS

BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methyl Bromide Critical Use Nomination for Post Harvest Use on Dry Cured Pork Products (Submitted in 20 1 1 for 201 4 Use Season)

STRUCTURE, COMMODITY OR OBJECT TREATED:
This sector is for the production of cured meat products, such as country hams. These a re produced primarily in the southern U.S. This sector has no known viable alternative currently

available.

QUANTITY OF METHYL B ROMIDE REQUESTED IN EACH YEAR OF

NOMINATION:

T ABLE 1 : Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION

Y EAR N OMINATION A MOUNT ( KILOGRAMS )

201 4 3,730 kg

(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).)

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.

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

Following the requirements of Decision IX/6 paragraph (a)(1) United States of America has determi ned 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  NoUSA CUN 14 POST HARVEST

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Signature Name Date

Title:

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger

Title: Division Director

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: Housenger.jack@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

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 CUN1 4 Post Harvest Ham

* Identical to paper documentsUSA CUN 14 POST HARVEST

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### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR POST

HARVEST

-- DRY CURED PORK PRODUCTS

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

Currently there are no viable alternatives to methyl bromide for the dried meat industry: heat would alter the product , and phosphine has failed to control mites, a major pest . Sulfuryl

fluoride rec eived federal registration and has be en tested for efficacy against the mites and oth er pests of cured meat products

. Although mortality of the red

- legged ham beetle occurred at levels below maximum rates of sulfuryl fluoride, the same cannot be said for the ham mites (Phillips, et al., 2008 ). Control of the ham mites took three times the legal limits of sulfuryl fluoride (Phillips, et al., 2008). At the time of this nomination

, there are no known registered alternatives for use on hams in the U.S. that provide the same level of mite contro l as methyl bromide.

This industry is cooperating with university researchers to find technically and economically feasible alternatives to methyl bromide. Dry, cured pork producers no longer fumigate with methyl bromide on a monthly schedule , but monito r and fumigate when pests are detected

. Many producers use pheromone traps to monitor for pests (Arthur and Phillips, 2003). Producers improved sanitation in their curing facilities . Producers have modified their buildings to make them more gas

- tight

, not only to try to exclude pests

, but also to retain methyl bromide better

. Some companies eliminated grass, trees, and shrubs from their buildings and replacing them with gravel, as suggested by researchers in 2008 , to reduced harborage for pests outside their aging

houses

. These efforts have reduced their use of methyl bromide, but have not eliminated the need to disinfest their dry, cured pork products.

This industry currently has no viable chemical or non

- chemical alternative available. Although

s ome measures , listed in the above paragraph, have reduced the number of times fumigation is needed in some facilities, it has not eliminated the need for fumigation. Therefore, methyl bromide remains critical to this industry.USA CUN 14 POST HARVEST

-- Dry, Cured Pork Products Page 4

T ABLE 2

. N OMINATION A MO UNT

2. SUMMARIZE WHY ALTERNATIVES ARE NOT FEASIBLE

This industry currently has no viable chemical or non

- chemical alternative available . Although

its IPM measures has reduced the number of times fumigation is needed, it has not eliminated the need for fumigation. Therefore, methyl bromide remains critical to this industry.

3. UPDATE OF RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES

R esearchers are actively investigating the control of arthropod pests that infest dry cured pork products during the aging process

.

Research Results

Fumigation trials were conducted in May, October, and November 2011 in 1000

- cubic meter shipping containers intended to simulat e dry cured aging ham houses at phosphine concentrations ranging between 1000

- 2000 ppm and exposure times of 48 or more hours. Temperature was measured in the ham houses during fumigation and twenty Tyrophagus putrescentiae (ham mites) bioassay jars and t en Necrobia rufipes (red

- legged ham beetles) jars were placed in each shipping container for each trial. Ten dry cured hams were hung from racks in shipping containers to simulate dry cured aging conditions. Five of these hams were used for

mite inoculat ion and the other 5 hams were used for sensory analysis and phosphine residue testing. The lean portion of the dry cured hams (that were used for inoculation) was also inoculated with a mixed culture of approximately 1000 mites. Phosphine gas was produce d in the shipping containers using magnesium phosphide cells that reached target fumigation doses atUSA CUN 14 POST HARVEST

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between 8 to 12 hours after the fumigation was started. Phosphine concentration was measured in the shipping containers using both Dräger tubes and a cali brated UV

- VIS detector.

The post

- embryonic mite mortality was 99.8 % in the bioassa ys at two weeks post fumigation when 2000 ppm phosphine was achieved, but the eggs on either the hams or in the bioassays

w ere not controlled, even at concentrations as great as 2000 ppm. The next phase of the study

will be to fumigate in spring 2012 at 2000 ppm for 72 hours to determine if greater control of ham mite eggs can be reached with a longer exposure time when the temperatu re is greater than

20 o C. A trial fumigation of 72 hrs in November 2011 had been planned; however, the ambient temperature was already too cold (<15 o C) to achieve successful control of ham mites in this follow up trial. (Schilling & Phillips, personal co mmunication)

Earlier investigations presented at 2010 MBAO, demonstrated that a t temperatures of 20 o C or greater, all life stages of Necrobia rufipes (red legged ham) beetles were controlled in all phosphine fumigation trials. Variations in test conditi ons indicated that temperatures and exposure times need to be optimized for fumigation since 48 hours was not long enough to control ham mites at 2000 ppm and ambient temperatures below 15 o C decreased the effectiveness of the fumigation against both ham m ites and red legged beetles. Sensory tests indicated that trained panelists could not determine differences between phosphine treated dry

cured hams and non

- fumigated hams. In addition, r esidual phosphine concentration s w ere below the legal limit of 0.01 ppm in ham slices that were taken from phosphine fumigated hams. Thus maintenance of post

- treatment market quality and food safety support continued research on efficacy of phosphine fumigation for hams. (Phillips, et al. 200 8)

Previous USG nominations described the failure of sulfuryl fluoride, carbon dioxide, and ozone to control ham mites and red legged ham beetles. USG previously reported the results of low pressure and low oxygen concentrations on ham mites under labora tory settings , which took too long to be a viable option at this time

.

There is still no technical alternative for methyl bromide for the dry cured ham industry at this point in time. Research is still ongoing with phosphine, but more research and comm ercial applications need to be conducted before a ny treatment can be considered an alternative to methyl bromide for treatment of ham (mold) mites.

Funding

In the spring of 2007

, a proposal was submitted to the USDA Integrated Research, Education, and Extension Competitive Grants Program

- Methyl Bromide Transitions (CSREES

- MBT) by

several meat scientists and one entomologist. A no

- cost extension was granted for 2010

- 2011, and additional funding has been provided thr ough the Southern R egions I ntegrated P est

M anagement Center to continue research efforts for 2010 and 2011.

The researchers successfully competed for a USDA

- MBT grant to support their investigations. The new funding is for 2011

- 2013, with a potential n o

- cost extension into 2014. This research will start in January 2012 and is a collaborative effort between Mississippi State University, Kansas State University, and Oklahoma State University . In addition, all th e research projectsUSA CUN 14 POST HARVEST

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are being conducted in conjunction with the National Country Ham Association, The American Association of Meat Processors, individual ham producers, and fumigant companies.

4. REGISTRATION UPDATE

No new chemicals have been registered or de

- registered since the last nomination.

5. ECONOMIC INFEASIBILITY OF ALTERNATIVES

An economic analysis was not conducted because this sector has no technically feasible

alternatives at this time

.

CITATIONS

Phillips, T.W. Hasan, M.M., Aikens, M.J., Schilling, M.W. 2008. Efficacy of sulfuryl fluoride

to control ham mites and red

- legged ham beetles. Annual International Research Conference on Methyl Bromide Alternatives and Emission Reduction, Orlando, FL,

November 11 th

- 14 th

Schilling, W. and T. W. Phillips, 2011 . Personal Communication.