United Nations Environment Programme

Methyl Bromide Technical Options Committee

 Structures and Commodities (SC)

 

 MBTOC Co-Chair:

 

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

February 14, 2013

Mr. Marco Gonzalez

Executive Secretary

UNEP Ozone Secretariat

And

Dr. Federico San Martini, Ph.D.

Foreign Affairs 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 colleagues,

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 transparency 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 fumigation:

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.)

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 recommendation 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. 

(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/m3 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 rate. 

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 

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 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 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 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 fumigated 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 supplied. This information is needed to determine the correct 

amount of MB needed. 

Questions concerning current and planned research:

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 additions or deletions to the program of planned 

research? 

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 mentioned in the CUN. Could 

the USG explain its views, and the intentions of its researchers 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 the 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)
Appendix – 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 particular 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 presumption 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 MBTOC 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.”