## United Nations Environment Programme Methyl Bromide Technical Options Committee

Structures and Commodities (SC)

MBTOC Co

- Chair:

Ms Michelle Marcotte (Canada) email: marcotteconsulting@co geco.ca

February 1 4 , 2013

Mr. Marco Gonzalez Executive Secretary

UNEP Ozone Secretariat

And

Dr. Federico San Martini, Ph.D. Foreign Af fairs Officer Office of Environmental Policy

U .S. Department of State 2201 C Street, N.W. Room 2657 Washington, D.C. 20520

U.S.A. SanMartiniFM@state.gov

Dear Marco and Dear Frederico San Martini and colleag ues,

MBTOC SC has completed its first level review of the US cured pork CUN. During this period some questions have been raised as described below. Part of the reason that MBTOC corresponds with Parties prior to making its recommendation is to ensure tran sparency and ensure the Party understands our trend of thought ahead of our report. Our letters are the result of a consensus process.

All sections of MBTOC will meet in London in early April and if you could deliver the answers to these questions ahead of that meeting we would appreciate it.

If any of our questions are unclear, or if you would like further information, please contact me. I will then confer with my colleagues and prepare an answer for you.

Questions concerning frequency of fumigatio n:

This CUN is completely 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 facility 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.)

T he CUN page 11 Table 3, indicate s 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 recommendation which

was that

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

– MBTOC recommended a reduction of one fumigation per year for all facilities (except thosealready only fumigating twice a year). We then added 10% for contingency in the total amount to

take into consideration possible adverse weather i ssues etc. The 10% contingency was not to be considered an allowable additional dosage rate.

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

MBTOC has used a standard MB dosage of 20g/m 3 for all MB fumigations for all the years it has been reviewing MB use and making recommendations. That standard dosage has not changed and MBTOC has not seen any technical valid argument to change the standard dosage rat e.

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

I note that during last year’ s OEWG meeting, USDA’s Dr. Ann Bartuska gave me a table which

correla tes 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 explain 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 recommendation was not accepted by Parties last year and the second is t hat 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 US to correct the oversight of this needed information in its CUN.

Questions concerning volume of facilities fumigated:

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 fumigated 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 fumigate d annually by each applicant.

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 su pplied. This information is needed to determine the correct

amount of MB needed.

Questions concerning current and planned research:

The CUN p ages 7

- 8 indicates the planned research on MB alternatives for cured pork. However,

we believe the CUN was writ ten several months ago. Could the US please confirm if this research has indeed started and if there have been any additions or deletions to the program of planned

research?

Additionally, in its text boxes and previous correspondence, MBTOC suggested in corporating

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 mentioned in the CUN. Could the USG explain its views

, and the intentions of its r esearchers and cured pork facilities

, towards

this technical recommendation?Questions on phase out of MB for cured pork in the US:

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

Thank you for your consideration of our information request.

Yours sincerely,

Michelle Marcotte

MBTOC Co

- Chair

(see also attached appendix)Appendi x

– Excerpts from the 2012 MBTOC Final Report text box on cured pork

Specifically, the 2012 MBTOC Final Report text box on cured pork said, “These factors led MBTOC to recommend a reduced nomination as explained by the following: one fewer fumigation

per year at each facility (except for those already only fumigating twice a year) with a dosage of 20 g/m3, plus a 10% allowance for occasional unforeseen requirement for additional MB due to inclement weather or the sudden need for an extra treatment at a pa rticular facility or possibly for one or two facilities not included in, or responding in time to, the survey, summed up as 10% for contingency measures. “

The September 2012 MBTOC Final Report text box on cured pork also said, “ The MBTOC standard presum ption is a dosage rate of 20g/m3. MBTOC acknowledges that occasionally during a fumigation, extenuating weather circumstances require the use of additional fumigant, but in a sufficiently gastight facility the use of a higher dosage rate should not be the norm. The Party, in its August 2012 response to MBTOC noted that, “The amount of methyl bromide listed includes additional gas added to adjust for any loss to ensure the required CT (Concentration Time) is maintained during treatment.” This indicates to MB TOC that the requirement for additional gas may be more frequent than should be required in a sufficiently gastight facility as is required for good practise.”