United States General Accounting Office

GAO Report to the Ranking Minority Member,

Committee on Commerce, House of

Representatives

December 1995 PESTICIDES

The Phaseout of

Methyl Bromide in the

United States

GAO/RCED-96-16

GAO United States

General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-261602 

December 15, 1995

The Honorable John D. Dingell

Ranking Minority Member

Committee on Commerce

House of Representatives

Dear Mr. Dingell:

Emissions of various chemicals are depleting the stratospheric ozone

layer, which shields the earth from the sun’s harmful ultraviolet rays.1

According to the Environmental Protection Agency (EPA), increased

ultraviolet radiation reaching the earth’s surface can, over time, raise the

incidence of skin cancer and cataracts and weaken the immune system in

humans, as well as damage the environment.

To protect the ozone layer, 24 nations, including the United States, signed

the Montreal Protocol in September 1987, agreeing to place controls on

and perform further assessments of major ozone-depleting substances. In

1990, the Congress amended the Clean Air Act to, among other things,

require EPA to identify ozone-depleting substances and phase out their

production. In December 1993, EPA issued regulations under these

provisions to phase out methyl bromide, a widely used agricultural

pesticide identified by scientists as an ozone-depleting substance. EPA’s

regulations freeze the production and importation of methyl bromide at

1991 levels until January 1, 2001; after this date, the pesticide can no

longer be produced or imported into the United States for domestic use.

The Montreal Protocol—now signed by over 150 countries—freezes

methyl bromide’s production at 1991 levels but does not require a

phaseout.

Methyl bromide has been used in agriculture since the 1930s, principally as

a fumigant to control pests in the soil before planting various crops, to

protect stored agricultural commodities, and to treat commodities being

shipped in international trade.2

 In response to your questions about the

consequences of banning methyl bromide for these purposes, we agreed to

provide you with information on (1) the scientific evidence that emissions

from human uses of methyl bromide are depleting the ozone layer, (2) the

1

There are three types of ultraviolet radiation classified according to their wavelength. UV-C, the most

harmful, does not reach the earth’s surface. UV-B, which is somewhat less harmful, is partially

absorbed by stratospheric ozone. UV-A, the least harmful, reaches the earth with little obstruction.

2

Similarly, methyl bromide is used to fumigate certain commodities shipped between states such as

California and Florida.

Page 1 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

availability of economical and effective alternatives to the pesticide’s

agricultural uses, (3) the effects of banning the pesticide on U.S. trade in

agricultural commodities, and (4) EPA’s authority under the Clean Air Act

to exempt essential uses from the phaseout.

Results in Brief World scientists participating in the United Nations Environment

Programme’s assessment of ozone-depleting substances have concluded

that emissions from human uses of methyl bromide contribute

significantly to ozone depletion and should be controlled. Although some

complex atmospheric processes are not fully understood, scientists know

from laboratory measurements that bromine, a major component of

methyl bromide, is very efficient in destroying ozone.

Various chemical and nonchemical pest-control alternatives are available,

but none is as economical and effective as methyl bromide for its many

uses. Hence, a combination of these alternatives will likely have to replace

methyl bromide. The agricultural community is concerned that federal

research to identify the most cost-effective alternatives or combination of

alternatives is not adequately funded or coordinated. For some uses, such

as treating certain commodities in trade and destroying certain organisms

in the soil that can cause plant diseases, alternatives have not yet been

identified.

If other countries continue to use methyl bromide after it is phased out in

the United States, they may have an unfair advantage in international

markets for the various agricultural commodities produced with the

substance. At the next meeting of the parties to the Montreal Protocol in

November 1995, U.S. officials plan to propose a worldwide phaseout

similar to the U.S. one. The officials believe that the parties are likely to

agree on some additional controls but not to a phaseout. In addition, a U.S.

phaseout could mean that some commodities, which must now be

fumigated with methyl bromide to kill pests that might damage U.S. crops,

could no longer be imported into this country. Other countries have

similar requirements that might affect U.S. exports.

The Clean Air Act does not authorize EPA to grant exemptions from the ban

on producing and importing methyl bromide except for use in medical

devices and for export to developing countries that have signed the

Montreal Protocol. The Clean Air Act would have to be amended before

EPA could grant exemptions from the January 1, 2001, ban for other uses.

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Background During the past decade, both international and national efforts have been

made to control ozone-depleting chemicals. Shortly after the United

Nations Environment Programme (UNEP) developed the Montreal Protocol

on Substances that Deplete the Ozone Layer (Protocol), the Congress

added title VI to the Clean Air Act to supplement the Protocol’s terms and

conditions. Amendments to the Protocol and regulations implementing

title VI have since expanded the restrictions on individual ozone-depleting

chemicals.

An ozone depletion potential (ODP) index is used under the Protocol and

the Clean Air Act to gauge a substance’s relative potential to deplete

stratospheric ozone. This index primarily reflects the substance’s (1) likely

lifetime in the atmosphere and (2) efficiency in destroying ozone

compared with chlorofluorocarbon-11 (CFC-11), a widely used refrigerant

and major ozone depleter that is being phased out under the Protocol and

the Clean Air Act. On the basis of scientific assessments performed in

December 1991 and updated in June 1992, UNEP calculated that methyl

bromide has an ODP of 0.7, or 70 percent of CFC-11’s ozone-depleting

potential.

The Protocol originally placed controls on eight major ozone

depleters—five chlorofluorocarbons (CFC) and three halons—and provided

for technical and scientific assessments of potential ozone-depleting

substances to be undertaken at least every 4 years.3

 In November 1992,

following the update of UNEP’s 1991 assessment, the parties to the Protocol

first imposed controls on methyl bromide. They agreed to accept UNEP’s

calculation of methyl bromide’s ODP as 0.7, and they amended the Protocol

to freeze production of the substance at 1991 levels, beginning in

January 1995.4

 They did, however, create an exemption for the substance’s

preshipment and quarantine uses.5

 The parties also agreed to decide by

January 1, 1996, how the freeze would affect the consumption of methyl

bromide in developing countries. (The Protocol allows methyl bromide

producers to produce 10 percent above 1991 levels for export to

3

Halons have been used primarily as fire extinguishers in ships, planes, and military vehicles, as well as

in computer facilities, telephone switching centers, and other places where materials would be

damaged by the use of water or foam fire extinguishers.

4

The agreement technically froze member countries’ “consumption” levels of methyl bromide, that is,

the amounts produced plus the amounts imported minus the amounts exported.

5

Preshipment use generally refers to the treatment with methyl bromide of commodities being

exported to meet the phytosanitary and sanitary (plant and animal health) requirements of the

importing country. Quarantine use refers to the treatment performed or authorized by a national plant,

animal, environmental protection, or health authority to prevent the introduction, establishment, or

spread of harmful pests that are (1) not yet present or (2) present but not widely distributed and being

officially controlled.

Page 3 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

developing countries.) The parties further agreed to consider imposing

additional controls on methyl bromide at their November 1995 meeting,

after they had reviewed the results of UNEP’s next round of scientific and

technical assessments. These assessments were completed in late 1994.

Title VI of the Clean Air Act identifies many substances that EPA is to list as

ozone depleting and requires the agency to list any others that have an ODP

of 0.2 or that it finds may reasonably be anticipated to cause harm to the

ozone layer. These substances are to be listed as either class I or class II,

depending primarily on their ODP. The title authorizes EPA to add

substances to either list and requires the agency to update both

periodically. Substances that have an ODP of 0.2 or greater are to be listed

as class I, and EPA is to take action to phase out their production no later

than 7 years after they are listed. The schedule for phasing out the less

threatening class II substances is less stringent.

In December 1991, three environmental groups petitioned EPA under the

Clean Air Act to list methyl bromide as a class I substance. EPA concluded,

in large part on the basis of UNEP’s calculation, that methyl bromide has an

ODP of 0.7, well above the act’s 0.2 threshold for listing as a class I

substance. In December 1993, EPA issued a rule first freezing and then

banning the production and importation of methyl bromide. The freeze,

which is at 1991 levels, took effect on January 1, 1994. No further

reduction from 1991 levels is required until January 1, 2001, when the ban

is mandated to begin. EPA imposed no further reductions during this 7-year

period because it recognized that the loss of methyl bromide would be

costly and it wanted to allow as much time as possible for the

development of alternatives. (In promulgating the rule, EPA estimated both

the costs and benefits of phasing out methyl bromide. The U.S.

Department of Agriculture (USDA) and the University of California at

Berkeley and the University of Florida have also estimated the costs of

banning methyl bromide’s agricultural uses. App. I summarizes these

studies.)

Table 1 compares the controls placed on methyl bromide by the Montreal

Protocol and by EPA’s regulation.

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B-261602 

Table 1: Comparison of Controls Placed on Methyl Bromide

Provision Montreal Protocol U.S. regulation

Freeze on production and importation Production and importation were frozen at

1991 levels, effective January 1, 1995.

Production and importation were frozen at

1991 levels, effective January 1, 1994.

Exemptions to the freeze Preshipment and quarantine uses were

exempted.

Methyl bromide producers can generally

exceed their 1991 levels by 10 percent for

export to developing countries. The Protocol

parties are to decide by January 1, 1996,

how the freeze will affect developing

countries.

No exemptions have been granted yet, but

EPA has the authority to grant exemptions

for use in medical devices and for export

to developing countries.

Ban on production and importation No ban has been approved. A ban on production and importation

becomes effective January 1, 2001.

Methyl bromide is a highly effective fumigant used to control a broad

spectrum of pests—insects, nematodes (parasitic worms), weeds,

pathogens (bacteria, fungi, and viruses), and rodents. The agricultural

community today uses it for over 100 crops. U.S. production in 1993 was

over 60 million pounds.6

 About 80 percent is used to fumigate the soil

before planting crops.7

 Another 19 percent is used to fumigate harvested

agricultural commodities during storage—including those being exported

from and imported into the United States—and to fumigate structures

such as food processing plants, warehouses, mills, and grain elevators. A

small amount is used in the production of other chemicals.

According to EPA, methyl bromide is a very toxic substance whose effects

on human health depend on the concentration and duration of the

exposure. Exposure to the pesticide can damage the lungs, eyes, and skin

and, in severe cases, cause the central nervous and respiratory systems to

fail. Gross permanent disabilities or death may result. Agricultural field

workers and structural fumigators have developed respiratory,

gastrointestinal, and neurological problems, including inflammation of

nerves and organs and degeneration of the eyes. EPA officials told us that

exposures to high concentrations have resulted in deaths.

6

Chemical Marketing Reporter, Vol. 245, No. 1 (Jan. 3, 1994).

7

According to a 1994 USDA report, five crops—tomatoes, strawberries, peppers, ornamentals, and

tobacco—account for over 80 percent of the methyl bromide used for soil fumigation.

Page 5 GAO/RCED-96-16 Phaseout of Methyl Bromide
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Scientific Evidence of

Methyl Bromide’s

Role in Ozone

Depletion

UNEP’s scientific assessments of ozone-depleting substances have

concluded that methyl bromide is a significant ozone depleter.8

 Although

some uncertainties are involved in these assessments, the participating

scientists are confident that methyl bromide’s ODP will not drop below the

0.2 level that triggers the phaseout of the pesticide as a class I substance

under the Clean Air Act.

The atmosphere is made up of distinct layers, each of which has its own

composition of gases and natural processes. The troposphere extends

from the earth’s surface up to about 6 miles, and the stratosphere extends

from the troposphere to about 30 miles above the surface. Although ozone

can be harmful in the troposphere—it is a primary constituent of smog—in

the stratosphere it helps protect life on earth from the sun’s ultraviolet

radiation. (See fig. 1.)

8

According to the Montreal Protocol’s 1992 assessment update report, modeling results suggest that

emissions of methyl bromide from human activities could have accounted for about 5 to 10 percent of

the current observed stratospheric ozone loss. The modeling results further suggest that this amount

could grow to about 17 percent by the year 2000 if emissions continue to increase at the present rate of

5 to 6 percent per year.

Page 6 GAO/RCED-96-16 Phaseout of Methyl Bromide
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Figure 1: Ozone in the Earth’s

Atmosphere

Troposphere

In this region, ozone 

can damage lung 

tissue and plants.

Stratosphere

In this region, ozone 

protects life from the 

sun's harmful 

ultraviolet radiation.

Ozone is continuously being produced naturally in the stratosphere by a

photochemical reaction caused by the sun’s rays. It is also continuously

being removed by other chemical reactions. According to scientists

involved in the UNEP assessment, the production and destruction of ozone

are normally in balance. However, as emissions from human uses of

ozone-depleting chemicals reach the stratosphere, more ozone is lost than

is created, and the ozone layer is thinned. Similarly, methyl bromide is

continuously being produced and removed from the atmosphere by

natural processes—scientists estimate that up to 60 percent or more of the

methyl bromide in the atmosphere may be released from the oceans.

Again, the UNEP scientists believe that the amounts produced and removed

by natural processes tend to be in balance. Therefore, their concern about

methyl bromide as an ozone depleter is focused on emissions from human

uses.

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The scientific basis for the Montreal Protocol’s freeze and EPA’s phaseout

was principally a 1992 assessment completed under the auspices of UNEP.

This assessment, which scientists from around the world performed for

the parties to the Montreal Protocol, concluded that the best estimate of

methyl bromide’s ODP was 0.7. The 1994 UNEP scientific assessment found

that the pesticide’s ODP is 0.6.

Producers of methyl bromide and members of the agricultural community

have expressed concern about UNEP’s estimate of the substance’s ODP.

More specifically, they have questioned UNEP’s calculation of methyl

bromide’s “lifetime” in the atmosphere, which the 1994 UNEP assessment

calculated to be about 1 year.9

 This calculation is important because the

less time the substance is in the atmosphere, the less chance it has of

reaching the stratosphere and depleting the ozone layer. UNEP’s calculation

of the pesticide’s lifetime assumes that significant amounts of methyl

bromide are being removed from the atmosphere through chemical

reactions in the troposphere and through interaction with the oceans.

However, some in industry and the agricultural community have suggested

that soil and vegetation may also remove significant amounts of methyl

bromide from the atmosphere. Scientists who participated in the UNEP

assessment believe that the range of uncertainty factored into their

estimates of methyl bromide’s lifetime is sufficient to allow for the

possibility that the substance may be removed by soil and vegetation.

The other major part of the ODP measurement is the relative efficiency of

methyl bromide in destroying ozone. On the basis of laboratory

measurements, the scientists who participated in the UNEP assessment

estimate that bromine, a major component of methyl bromide, is about 50

times more efficient in destroying ozone than the chlorine in

chlorofluorocarbons.

Additional research is addressing the scientific uncertainties currently

involved in calculating methyl bromide’s ODP. At this point, the scientists

associated with the UNEP assessment anticipate only a further refinement

of the ODP calculation. They are confident that the research results will not

bring the ODP below 0.3.

9

Various physical and chemical processes tend to break down and remove chemicals in the

atmosphere. Atmospheric lifetime is a measure of how long a gas stays in the atmosphere before it is

removed by these processes. Atmospheric lifetimes are commonly modeled as e-folding lifetimes,

which means that the concentration of a gas is assumed to decay exponentially.

Page 8 GAO/RCED-96-16 Phaseout of Methyl Bromide
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Availability of

Economical and

Effective Alternatives

EPA, USDA, and industry representatives generally agree that chemical

substitutes and other alternatives are available today to manage many of

the pests currently controlled with methyl bromide. They further agree

that no one substitute or alternative is available for methyl bromide’s

many uses and that research is needed to identify the alternatives or

combinations of alternatives that can economically and effectively replace

the pesticide’s individual uses. USDA and the agricultural community,

however, are less optimistic than EPA that economical and effective

alternatives will be identified by the time the ban on methyl bromide goes

into effect in 2001. EPA, USDA, and industry are sponsoring or conducting

research on alternatives, but it is not clear at this point what this research

will be able to achieve over the next 5 years.

Effectiveness of Efforts to

Identify Replacements Is

Unclear

According to EPA, there are many chemical and nonchemical alternatives

to methyl bromide. These include fumigants that can kill a range of pests

similar to those killed by methyl bromide. Other chemicals—for example,

insecticides, fungicides, and herbicides—with a more limited range are

also available. Nonchemical alternatives include techniques such as

rotating crops to avoid a buildup of pests, using plants that are more

pest-resistant, and using organisms like parasitic bacteria to control weeds

and nematodes.

These alternatives, according to EPA, are technically capable of controlling

many of the pests currently controlled by methyl bromide. (In its 1994

report, UNEP’s Methyl Bromide Technical Options Committee said that it

had identified a technically feasible alternative, either currently available

or at an advanced stage of development, for over 90 percent of the uses

being made of methyl bromide in 1991.10 According to the report,

alternatives were not identified for controlling some soilborne viruses and

other pathogens and for some quarantine procedures.) The key

question—assuming that the alternatives do not pose any unmanageable

health and environmental risks—is which alternative or combination of

alternatives is most effective and economical in a given situation.

According to USDA officials, alternatives are not currently available for

some important uses, such as treating certain quarantined commodities

and responding to certain incidents or emergencies. The officials noted,

for example, that ships carrying infested commodities may dock at U.S.

10The Methyl Bromide Technical Options Committee is one of the technical committees operating

under the Technology and Economic Assessment Panel, which was established under the Montreal

Protocol to perform the technical and economic assessments needed for the parties to consider

controls on ozone-depleting substances.

Page 9 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

ports, military equipment contaminated with soilborne pests may be

brought back to the United States, or a destructive pest, such as the

Mediterranean fruit fly, may be found in an area of California or another

state. In these circumstances, they said, fumigation with methyl bromide is

the only effective way to deal with the pests.

USDA officials also pointed out that numerous scientific, economic, and

environmental variables have to be considered in evaluating potential

replacements. Selecting a replacement can be further complicated because

a use can be quite specific. For example, alternatives for preplant soil

fumigation (a technique for killing pests in the soil before planting) will

need to be selected on the basis of such factors as the crop grown, the

pests present in the soil, the climate, and the geographical location.

Government and industry researchers believe that considerable research

and field testing are needed to define the alternatives’ efficacy,

applicability, and cost-effectiveness in given situations.

To fund research on alternatives to methyl bromide, EPA and USDA spent

about $13.3 million in fiscal year 1995 and, according to agency officials, a

similar amount has been requested for fiscal year 1996. However, the Crop

Protection Coalition11 estimates that about $60 million is needed annually

for this research. According to the Coalition, the public sector has not

mobilized sufficient resources and funds to achieve meaningful results

before 2001 in either preplant or postharvest applications. The Coalition

also believes that this research needs to be more effectively coordinated.

The Coalition, with USDA’s and EPA’s cooperation, is attempting to

consolidate federal and private research activities into a single agenda

reflecting a consensus on priorities. In July 1995, the Coalition issued a

report on the status of research activities to (1) help prioritize projects for

funding, (2) identify gaps in current research, and (3) improve the transfer

of technology to users of methyl bromide.12 According to a USDA official,

the Coalition’s report and research agenda will be discussed at an

international research conference on alternatives and methods for

reducing methyl bromide emissions that the Department is cosponsoring

in November 1995 with the Coalition and EPA.

11A national organization of about 30 fresh fruit and vegetable producers, associations, cooperatives

and related industries. During action on USDA’s fiscal year 1995 appropriation, the Senate

Appropriations Committee expressed its expectation that the Department would work with the

Coalition on directing funds for methyl bromide research (Senate Report 103-290, June 23, 1994, p. 23).

12Status of Methyl Bromide Alternatives Research Activities, Crop Protection Coalition (July 1995).

Page 10 GAO/RCED-96-16 Phaseout of Methyl Bromide
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New Chemical Substitutes

Appear Unlikely

USDA, the Methyl Bromide Working Group—which represents methyl

bromide producers and distributors—and the Crop Protection Coalition

believe that very few new chemical alternatives will be available when the

ban on methyl bromide goes into effect. They said that substantial

development costs, research requiring multiple planting cycles, and

federal/state regulatory reviews are involved in putting a new chemical on

the market. They noted that moving a new pesticide from development to

commercialization can take up to 10 years and cost a manufacturer from

$50 million to $70 million. As part of this process, the manufacturer must

develop the health and safety data that EPA requires to register a pesticide

for use.

Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),

EPA decides whether to register a pesticide after assessing, among other

things, the potential effects on human health and the environment of using

a pesticide product according to the directions on the label. A separate

registration is required for each new chemical, and an existing registration

has to be amended for a new or different use. The registration process can

take many years, depending on the type of substance, the complexity of

the testing needed, the gaps in the data, and the nature of EPA’s findings

from the health and safety data submitted for the agency’s review.

However, EPA recently established an expedited system for reviewing

alternatives to methyl bromide.13 According to EPA, to date, no new

chemicals and only a few new uses of existing chemicals have been

submitted to EPA as potential alternatives to methyl bromide.

Under 1988 amendments to FIFRA, all pesticides registered before

November 1984 must be reviewed for reregistration and the data

supporting their registrations must be brought up to current scientific

standards. Methyl bromide and a number of pesticides that have been

approved for use on pests now controlled by methyl bromide are included

in this group of chemicals. USDA has identified six of these chemicals as

potential alternatives to methyl bromide.14

13In a July 13, 1995, pesticide regulation notice (No. 95-4), EPA explained the expedited review process

and invited the submission of potential alternatives. In this notice, EPA said that if all necessary data

have been submitted, the agency will work to ensure that decisions are made within 6 months on

petitions for new food uses for registered pesticides, within 8 months on applications to register

biological pesticides, and within 12 months on applications to register new active ingredients as

reduced-risk pesticides.

14These chemicals are 1,3-dichloropropene, dazomet, metam-sodium, chloropicrin, phosphine, and

dichlorvos.

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For each of the alternatives identified by USDA, EPA has found potentially

serious environmental and/or health and safety concerns. According to

USDA officials, regulatory actions by EPA to ban or limit the use of these or

other pesticides because of health and environmental concerns could

exacerbate the economic effects of the methyl bromide phaseout by

eliminating potentially effective alternatives. However, EPA officials told us

that, under FIFRA, the agency balances risks and benefits, and if the

benefits of using a pesticide outweigh the potential risks to people and the

environment, then EPA may register or reregister the pesticide. The

officials said that EPA is likely to reregister many of the chemical

alternatives to methyl bromide after adopting appropriate risk mitigation

measures, such as label changes. (App. II lists these and other potential

alternatives to methyl bromide’s agricultural uses and describes various

concerns raised by EPA and others. The appendix also lists recent studies

and reports by EPA, USDA, industry, and environmental groups that provide

additional details on alternatives.)

Reducing Emissions and

Recycling Are Not

Alternatives Under the

Clean Air Act

Some technically proven methods for reducing methyl bromide emissions,

such as better sealing of fumigation enclosures, are available. In addition,

industry is working to develop technology that can recapture and recycle a

very high percentage of the methyl bromide used to fumigate commodities

and structures. According to UNEP’s Methyl Bromide Technical Options

Committee, a few pieces of methyl bromide recovery equipment are

already in use, and prototype systems capable of recycling recaptured gas

for some uses will be evaluated by the end of 1995. Although using these

technologies could substantially reduce emissions, the Clean Air Act does

not exempt production for use in such systems from the ban. However,

using recovery and recycling technology would extend the existing supply

of methyl bromide when the ban on production and importation becomes

effective.

Exemptions for Essential

Uses May Be Necessary

In August 1995, EPA’s Assistant Administrator for Air and Radiation said

that the agency is aware of and understands the agricultural community’s

concern that it does not currently have satisfactory substitutes for all uses

of methyl bromide.15 The Assistant Administrator said that alternatives are

available to effectively control many of the pests on which methyl bromide

is used and that research on additional alternatives is taking place.

According to the Assistant Administrator, the critical issue is whether

15Statement of the Assistant Administrator for Air and Radiation, EPA, before the Subcommittee on

Oversight and Investigations, House Committee on Commerce (Aug. 1, 1995).

Page 12 GAO/RCED-96-16 Phaseout of Methyl Bromide
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adequate alternatives will be available by the time the phaseout deadline

arrives and, if they are not available, the agency will seek an appropriate

solution. According to EPA, alternatives do not need to be identical to

methyl bromide but they must be environmentally acceptable and must

effectively and economically manage those pests that are now being

controlled by the pesticide. (As discussed later, the Clean Air Act would

have to be amended to give EPA the authority to grant exemptions from the

ban.)

Potential Impact of

Banning Methyl

Bromide on U.S.

Trade

Because methyl bromide is an important pesticide worldwide, a ban that

took effect in the United States before similar actions were implemented

in other countries could create an “uneven playing field” in international

trade for U.S. producers of various agricultural commodities. The need to

use more costly and/or less effective alternatives could increase the costs

and reduce the yields for growers of U.S crops. In addition, some countries

require certain U.S. commodities to be treated with methyl bromide as a

condition of entry. These exports would likely be lost unless acceptable

alternatives could be agreed upon with the importing countries. Likewise,

the United States requires treatment with methyl bromide as a condition of

entry for certain imports. The impact of the U.S. ban on agricultural trade,

however, will depend on the controls other countries have placed on

methyl bromide and on the cost-effectiveness of the alternatives available

when the U.S. ban goes into effect in 2001.

Use May Continue in Many

Countries

Although the parties to the Montreal Protocol are to consider placing

additional controls on methyl bromide at their November 1995 meeting,

they may not agree to ban the pesticide. According to U.S. officials, the

United States will propose a ban, but contacts with representatives of

other countries indicate that a wide range of proposals will be made at the

meeting. For example, the technical assessment report prepared for the

parties by UNEP’s Methyl Bromide Technical Options Committee states that

individual committee members estimated feasible reductions in methyl

bromide emissions ranging from 50 percent by 1998 to only a few percent

by 2001.

Even if the parties agree to a ban, they may give developing countries

special consideration. The parties have recognized that these countries

may not have the technical or financial resources to switch to alternatives

or that a change may have a greater economic impact on them than on

more developed countries. For example, in addition to financial and

Page 13 GAO/RCED-96-16 Phaseout of Methyl Bromide
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technical assistance, the Protocol gave these countries a 10-year grace

period to implement the controls on CFCs and halons. The Methyl Bromide

Technical Options Committee is presenting several options for the parties

to consider if additional controls are placed on methyl bromide. One

proposal would establish a 9-year grace period for developing countries,

with reviews every 3 years to determine whether the grace period should

be adjusted. Another option would cap or freeze the quantities used by

developing countries and grant exemptions for preshipment and

quarantine uses.

A few countries have acted independently to control their methyl bromide

emissions. According to EPA, the Netherlands phased out its use of methyl

bromide for soil fumigation in 1992 because of concerns that the pesticide

contaminates groundwater. Germany and Switzerland have also prohibited

its use on soil. Denmark and Sweden plan to phase out the pesticide’s uses

by 1998, as does Italy by 2000, although Italy plans to retain essential uses.

The European Union plans a 25-percent reduction in use by 1998, and

Canada has drafted controls calling for a 25-percent reduction by 1998.

Loss for Soil Fumigation

Could Hurt U.S.

Competitiveness

In response to a 1994 survey by the Methyl Bromide Technical Options

Committee, 39 countries reported information on their use of methyl

bromide for preplant soil fumigation. The committee also obtained

estimates from industry for nine additional countries. Although the use of

methyl bromide in many of these countries is small (developing countries

account for about 18 percent of its use), the crops produced with it are

primarily high-value cash crops, usually for export. Because these

crops—for example, strawberries, tomatoes, peppers, cucumbers, and

various other produce—are similar to those grown in the United States

with methyl bromide, producers in these countries potentially compete

with U.S. growers for both domestic and international markets for these

commodities.

Studies done by USDA and for California and Florida, the two states that are

the largest users of methyl bromide for soil fumigation, have concluded

that alternatives to the substance are less effective in controlling soil pests

and often cost more (see app. I). According to USDA officials, the higher

costs and reduced yields would put U.S. growers at a disadvantage if

growers in other countries could continue to use methyl bromide. For

example, the Florida study stated that the use of methyl bromide is critical

because of the state’s environment. According to the study, producers

faced with substantially reduced revenues would reduce their acreage for

Page 14 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

fresh fruit, vegetable, and fresh citrus crops. The study concluded that the

primary beneficiary would be Mexico, which, the study assumed, would be

given longer, as a developing country, to use methyl bromide under any

future agreement reached under the Montreal Protocol. If Mexico or other

developing countries expand their use of methyl bromide, the

environmental benefits gained by phasing out the pesticide’s use in the

United States would be at least partially offset.

EPA’s Methyl Bromide Program Director told us that the U.S. agricultural

community’s concerns about the uneven playing field may be valid. He

said that Mexico may increase its production of such fruits and vegetables

as tomatoes and strawberries, which are major crops for California and

Florida. He added, however, that additional study would be needed to

determine whether Mexico could realistically market increased amounts

of these commodities in the United States. For example, could

strawberries be shipped to market in time to maintain the necessary

freshness? And would these fruits and vegetables be grown in Mexico at

the same time of year as in the United States?

According to USDA officials, the Florida study and two recent USDA studies

document the competition that the United States faces from developing

countries, especially Mexico, in markets for crops whose production relies

heavily on the use of methyl bromide.16 The officials said, for example,

that such competition occurs in the cucumber market in March and April,

in the bell pepper market from January through March, and in the tomato

market from January through April. The officials also said that Mexico has

supplied nearly all of the strawberries imported into the United States over

the last 5 years.

Treatment With Methyl

Bromide Is Required for

Certain Exports and

Imports

Although less than 1 percent of the methyl bromide produced in the

United States is used to treat quarantined commodities, this use is

important because it permits trade in these commodities. During

quarantine treatments, which are usually done at international borders, the

commodities are fumigated to kill pests that could cross geographical

barriers and infect susceptible crops or commodities. Quarantine

requirements are negotiated between the importing and exporting

countries for individual commodities, and the treatments are governed by

strict regulations that require very high efficacy levels. For example, USDA’s

Animal and Plant Health Inspection Service (APHIS) requires efficacy levels

16The two USDA studies, issued by the Economic Research Service, are Competition in the U.S. Winter

Fresh Vegetable Industry, Agricultural Economic Report No. 691 (July 1994), and The U.S. Strawberry

Industry Statistical Bulletin No. 914 (Jan. 1995).

Page 15 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

of 99.9968 percent for most treatments. To meet these efficacy levels, APHIS

requires that certain imports be treated with methyl bromide because of

its effectiveness, and some other countries, notably Japan, likewise require

this treatment for certain imports from the United States.

APHIS currently requires fumigation with methyl bromide or an alternative

treatment as a condition of entry into the United States for 19 fruits, 14

vegetables, and 7 nuts, seeds, and miscellaneous foods coming from

certain countries (see app. III).17 (APHIS also requires these treatments for

various nonfood imports, including unprocessed seeds and nuts, hays and

straw, cotton products, gums, bagging, and brassware.) About 90 percent

of some U.S. imports, including apricots, nectarines, grapes, peaches,

plums, and yams, are affected by these requirements. According to APHIS

officials, acceptable alternatives are generally not available and the loss of

methyl bromide will lead APHIS to ban imports of many economically

important commodities.18

An April 1993 USDA study of nine imported fruits found that the loss of

imports would reduce supplies and increase prices.19 According to the

study, the higher prices would increase the revenues to U.S. producers by

$3.0 billion to $3.3 billion over 5 years. However, the losses to U.S.

consumers from paying the higher prices would range from $4.7 billion to

$5.0 billion over 5 years. The study further found that many of the

imported items fill an important niche in U.S. supplies. For example, the

study said that apricots, grapes, nectarines, peaches, and plums from Chile

enter the United States during the winter when none or nearly none of

these items are produced domestically.

In addition, U.S. exports worth over $400 million were fumigated with

methyl bromide in 1994 (see app. IV). If the United States bans methyl

bromide, an acceptable alternative treatment must be negotiated with the

receiving countries. According to USDA officials, these negotiations can

take several years and may not be successful, especially if other producers

can continue to use methyl bromide and meet the quarantine

requirements. EPA officials told us that they are more optimistic than USDA

officials that acceptable alternatives will be available for imports and can

be agreed upon for exports.

17According to APHIS officials, the agency will approve alternatives to methyl bromide if the exporting

country can document that the alternatives will meet the required efficacy levels.

18According to USDA officials, import and export requirements may change from year to year.

19The Biologic and Economic Assessment of Methyl Bromide, National Agricultural Pesticide Impact

Assessment Program, USDA (Apr. 1993).

Page 16 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

EPA’s Authority to

Grant Essential Use

Exemptions

On the basis of our review, we have concluded that the Clean Air Act does

not currently authorize EPA to grant exemptions from the ban on methyl

bromide for domestic agricultural uses, including preshipment and

quarantine treatments. Supplies of methyl bromide available when the ban

goes into effect on January 1, 2001, can be used, but no additional amounts

can be produced or imported for domestic uses.

The Congress, in section 604 of the act, specified the conditions under

which EPA may grant exemptions from the production phaseout of class I

ozone-depleting substances, including methyl bromide. This section details

six categories of substances for which exemptions may be granted. For

four of the six categories, the exemptions are restricted to specific

chemicals named in the relevant provisions, none of which is methyl

bromide. For the remaining two categories—chemicals used in medical

devices and exports to developing countries—EPA is authorized to

promulgate exemptions for any class I substance after giving notice and an

opportunity for public comment. Neither section 604 nor any other

provision of title VI grants EPA general authority to issue essential use

exemptions.

We identified no current uses of methyl bromide in medical devices, and it

appears that an exemption for this purpose would not be applicable.

However, methyl bromide could qualify for an exemption under the export

provision of section 604(e). That provision imposes only three limits on

the availability of the exemption: (1) it authorizes the production of only

“limited quantities” (not defined in the provision), (2) the substance may

be exported only to developing countries that are parties to the Montreal

Protocol, and (3) the export may be only for the purpose of “satisfying the

basic domestic needs of such countries.”

Conclusions UNEP’s scientific assessments indicate that emissions from human uses of

methyl bromide cause significant ozone depletion and should be

controlled. However, a phaseout of the substance could adversely affect

some parts of U.S. agriculture and trade unless adequate—that is,

environmentally acceptable, effective, and economical—alternatives are

identified before the ban takes effect in 5 years. More progress in

identifying alternatives is being made for some uses of methyl bromide

than for others. If adequate alternatives are not available by the time the

ban takes effect, exemptions from the ban may be needed for some

domestic uses until alternatives can be developed. However, EPA does not

Page 17 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

currently have the authority to grant exemptions for the continued

production and/or importation of methyl bromide for domestic uses.

Recommendation To provide for an orderly phaseout of methyl bromide, we recommend

that the Administrator, EPA, seek changes to the Clean Air Act to authorize

the agency to grant exemptions from the ban for essential uses. This

authority should provide for EPA to grant exemptions after determining

that adequate alternatives for a particular use are not available and that

the adverse impact of not having methyl bromide for that use outweighs

the negative effects on human health and the environment of further

production and importation.

Agency Comments We provided copies of a draft of this report to EPA and USDA for their

review and comment. On November 3, 1995, we met with USDA officials,

including the Chairman of the USDA Ad Hoc Committee for Alternatives to

Methyl Bromide and the Deputy Director of the National Agricultural

Pesticide Impact Assessment Program. The USDA officials generally agreed

with the report’s findings. The officials said that overall the report is

balanced and presents the important issues and viewpoints associated

with the use of methyl bromide. The officials again stressed their positions

that practical or cost-effective alternatives are not available for many of

methyl bromide’s uses and that a unilateral ban on the pesticide is likely to

hurt U.S. competitiveness in world agricultural markets.

On November 7, 1995, we met with EPA officials, including the Methyl

Bromide Program Director in the Office of Air and Radiation and the

Deputy Director of the Policy and Special Projects Staff in the Office of

Pesticide Programs. The officials described the report’s summarization of

available information on the agricultural, economic, environmental, and

health effects of the planned phaseout of methyl bromide as generally

accurate. However, they expressed concern that the report leaves the

impression that the outlook for finding alternatives to methyl bromide is

more dire than warranted. In their view, the fact that no single chemical or

other alternative is expected to replace methyl bromide for all of its uses

does not mean that viable, economical alternatives will not be available for

most uses by 2001. Furthermore, they added, even though viable,

economical alternatives may not be found for some uses by 2001, current

projections of large losses resulting from the phaseout cannot be relied on

by any means.

Page 18 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

EPA officials indicated that the agency would look at the need for

exemptions and determine whether EPA has the authority to grant them as

the deadline for the ban approaches. The officials stated that the focus

now should be on identifying alternatives.

We believe that our report accurately depicts the availability of

alternatives to methyl bromide at this time. We have made no judgment as

to whether the alternatives will prove to be inadequate for many uses, as

USDA officials have suggested, or for only a few, as EPA officials have

suggested. In either case, we believe that EPA will need authority to grant

exemptions. Although EPA could wait to seek such authority until the

deadline approaches, it will need some lead time to propose changes to

the Clean Air Act, have them approved, and issue implementing

regulations.

EPA and USDA also provided some technical comments on our draft report.

We have revised our report as appropriate in response to these comments.

We conducted our work from November 1994 through November 1995 in

accordance with generally accepted government auditing standards. We

interviewed officials from EPA, USDA, the Executive Office of the President,

and the United Nations Environment Programme. We also interviewed

representatives of the Methyl Bromide Working Group (producers and

distributors) and the Crop Protection Coalition (a broad spectrum of

methyl bromide users). In addition, we reviewed available studies on

methyl bromide’s contribution to the depletion of the ozone layer and

economic and technical assessments of a phaseout. We also reviewed

applicable laws and regulations and public comments during the proposal

stage of EPA’s phaseout regulation. Moreover, we attended conferences on

alternatives to methyl bromide and on the status of scientific knowledge

concerning methyl bromide’s role in ozone depletion. Appendix V more

fully discusses our scope and methodology.

As arranged with your office, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 7 days after the

date of this letter. At that time, we will send copies to the Secretary of

Agriculture, the Administrator of EPA, and other interested parties. We will

make copies available to others upon request.

Page 19 GAO/RCED-96-16 Phaseout of Methyl Bromide
B-261602 

Please call me at (202) 512-6112 if you or your staff have any questions.

Major contributors to this report are listed in appendix VI.

Sincerely yours,

Peter F. Guerrero

Director, Environmental

 Protection Issues

Page 20 GAO/RCED-96-16 Phaseout of Methyl Bromide
Page 21 GAO/RCED-96-16 Phaseout of Methyl Bromide
Contents

Letter 1

Appendix I 

Studies of the

Economic Impact of

Phasing Out Methyl

Bromide for

Agricultural Uses

24

EPA’s Analysis of Costs and Benefits 24

USDA’s National Agricultural Pesticide Impact Assessment

Program Study

25

Study by the University of California at Berkeley 26

Study by the University of Florida 27

Appendix II 

Potential Alternatives

to Methyl Bromide for

Agricultural Uses

29

Descriptions of Potential Alternatives for Methyl Bromide’s

Preplant End Uses

30

Descriptions of Potential Alternatives for Methyl Bromide’s

Postharvest End Uses

33

Sources of Detailed Information on Potential Alternatives 35

Appendix III 

Food Imports

Requiring Fumigation

With Methyl Bromide

or an Alternative

Treatment as a

Condition of Entry

Into the United States

37

Appendix IV 

Value of U.S. Exports

for Which Receiving

Countries Require

Treatment With

Methyl Bromide, 1994

38

Page 22 GAO/RCED-96-16 Phaseout of Methyl Bromide
Contents

Appendix V 

Objectives, Scope,

and Methodology

39

Appendix VI 

Major Contributors to

This Report

41

Tables Table 1: Comparison of Controls Placed on Methyl Bromide 5

Table II.1: Potential Alternatives for Methyl Bromide’s Preplant

End Uses

29

Table II.2: Potential Alternatives for Methyl Bromide’s

Postharvest End Uses

33

Figure Figure 1: Ozone in the Earth’s Atmosphere 7

Abbreviations

APHIS Animal and Plant Health Inspection Service

CFC chlorofluorocarbon

EPA Environmental Protection Agency

ODP ozone depletion potential

UNEP United Nations Environment Programme

USDA U.S. Department of Agriculture

Page 23 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix I 

Studies of the Economic Impact of Phasing

Out Methyl Bromide for Agricultural Uses

Methyl bromide is used primarily for agricultural purposes, principally for

fumigating (1) the soil before planting (preplant soil fumigation) and

(2) commodities after harvesting (commodity fumigation). The costs and

benefits of a ban on these uses were analyzed by the Environmental

Protection Agency (EPA) during the promulgation of its phaseout rule. We

also identified three other studies of the potential economic impact of a

phaseout on agricultural users. The U.S. Department of Agriculture’s

(USDA) National Agricultural Pesticide Impact Assessment Program studied

the effects of a phaseout on 21 crops in six states, and the University of

California at Berkeley and the University of Florida examined the impact

of a phaseout in their states. Each of these studies compared the projected

costs and crop yields for likely replacements with those for methyl

bromide and found that growers would incur significant losses because of

a ban on agricultural uses of methyl bromide. The USDA study also found

that consumers would suffer a loss because supplies would be reduced

and prices would be higher. Each study based its economic estimates on

alternatives available at the time the study was conducted. The economic

impact could change if more effective or less costly alternatives are

identified in the future.

The studies by EPA and USDA arrived at substantially different estimates of

the impact of a ban on methyl bromide. However, these estimates could

not be easily compared because the studies made different assumptions,

differed in their scope, and used different methodologies and cost data.

The California and Florida studies were more limited in their scope than

either the EPA or USDA studies. We did not independently evaluate these

studies.

EPA’s Analysis of

Costs and Benefits

In 1993, EPA reviewed the costs and benefits of its regulatory action to

phase out the production and importation of methyl bromide.1

 This study

included information on the costs and effectiveness of potential new

alternatives by the year 2001 and on the costs and benefits of improving

the use of existing alternatives. On the basis of this study, EPA estimated

that the total costs of a phaseout of methyl bromide between 1994 and

2010 would be $1.7 billion to $2.3 billion.2 EPA’s cost analysis examined the

likely range of costs for the alternatives and coupled these assumptions

with a monte carlo analysis, presenting a set of costs (median, mean,

1

The Cost and Cost-Effectiveness of the Proposed Phaseout of Methyl Bromide, EPA (1993).

2

The year 2010 was chosen as the end point in estimating the costs because the study team believed

that forecasting the course of technological innovation and identifying alternatives to methyl bromide

would be difficult beyond this date.

Page 24 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix I 

Studies of the Economic Impact of Phasing

Out Methyl Bromide for Agricultural Uses

minimum, and maximum) that could be expected with a methyl bromide

phaseout in 2001. The $1.7 billion figure represented the estimated median

cost, and the $2.3 billion figure represented the mean cost. The minimum

and maximum costs were estimated at approximately $7 million and

roughly $16 billion, respectively. According to EPA, some available

alternatives, if used after 2001, may indeed prove to be more expensive

than methyl bromide, and their users may receive lower profits if the

increases cannot be passed on to consumers. However, EPA said that it has

found that the effects of regulatory actions that remove pesticides from

the market are mitigated over time as new pest control technologies are

introduced and adjustments are made to compensate for the loss of the

pesticide through alternative pest control practices.

EPA estimated that the benefits of the phaseout would be between

$244 billion and $952 billion. This estimate was based primarily on avoided

cases of nonmelanoma cancers. According to the study, in the longer term

(until 2160), a total of 2,800 skin cancer fatalities in the United States

would be avoided because of the phaseout. The benefits for the period

from 1994 through 2010 were estimated to be between $14 billion and

$56 billion. The analysis reflected key assumptions about emissions of

methyl bromide from human activities, the impact of bromine on ozone,

and the likely growth in use of methyl bromide without regulations. The

range in values for benefits results from different estimates of the value of

a human life.

EPA recognized but did not calculate the benefits of avoiding other health

and environmental problems caused by increased ultraviolet radiation,

such as damage to plants and animals. EPA also did not consider the

possible adverse effects on humans, plants, and animals of contact with

methyl bromide during its application.

USDA’s National

Agricultural Pesticide

Impact Assessment

Program Study

In 1993, USDA published a study of the effects on U.S. agriculture of

banning methyl bromide, under the National Agricultural Pesticide Impact

Assessment Program.4

 The study showed that actions to ban or restrict

methyl bromide’s use in the United States would be costly because

currently available alternative control practices are less effective or more

expensive than using methyl bromide. The study estimated that the annual

economic loss to producers and consumers from banning the agricultural

uses of methyl bromide included in this study would be about $1.3 billion

4

The Biologic and Economic Assessment of Methyl Bromide, National Agricultural Pesticide Impact

Assessment Program (Apr. 1993).

Page 25 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix I 

Studies of the Economic Impact of Phasing

Out Methyl Bromide for Agricultural Uses

to $1.5 billion. Of this amount, $800 million to $900 million would be

attributed to the loss of methyl bromide for soil fumigation and

$450 million to its loss for the fumigation of quarantine imports. An

additional economic loss of about $200 million would occur if Vorlex—the

alternative identified as having the most potential for succeeding methyl

bromide—were no longer available. (The manufacturer had indicated to

EPA that it planned to stop producing Vorlex because of high reregistration

costs.)

According to the study, a phaseout, rather than an immediate ban, of

methyl bromide would postpone annual losses and provide time for

potential alternatives to be developed and for consumers and producers to

adjust. The study concluded, however, that the likelihood of developing

new, effective fumigant alternatives appears very remote.

The results of USDA’s study were presented to EPA as part of the

Department’s comments on the agency’s proposed phaseout rule.

According to EPA, the study would be a useful analysis if methyl bromide

were being banned immediately, but it does not consider alternatives that

may be developed before the ban goes into effect. EPA also said that the

study considers only alternatives that duplicate methyl bromide’s ability to

kill a wide range of pests and that other alternatives could be used in

combination to achieve similar results. USDA officials believe that no

alternatives are available for many uses.

Study by the

University of

California at Berkeley

A 1993 study by the University of California at Berkeley for the California

Department of Food and Agriculture examined the role of methyl bromide

in the state’s agriculture and the impact on growers of regulatory action to

further restrict or ban its use.5

 The University examined background

information on the patterns and intensity of methyl bromide’s uses for

preplant soil and postharvest fumigation and then used a model to

measure the financial impact on California growers of canceling

agricultural uses of methyl bromide.

According to the University’s report on the study, in the short term, the

loss of methyl bromide for preplant soil fumigation would reduce net farm

income in California by more than $233.8 million annually. The most

significantly affected crops would be strawberries, nursery products (cut

flowers and rose, fruit, vine, nut, and strawberry plants), and grapes, and

5

Economic Impacts of Methyl Bromide Cancellation, Department of Agricultural and Resource

Economics, University of California at Berkeley (Feb. 1993).

Page 26 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix I 

Studies of the Economic Impact of Phasing

Out Methyl Bromide for Agricultural Uses

estimated net annual farm income losses would be $105.8 million,

$71.7 million, and 31.3 million, respectively. Net income losses reflect

differences in production costs from using alternative treatments, which

are more costly for some crops, and lower revenues from reduced yields.

The report also found that the cancellation of methyl bromide for

postharvest applications would have a significant impact on the

profitability of California’s fresh fruit and dried nut crops in the short run

because fumigation by another method would cost more and take longer.

For example, producers of cherries sell their highest-quality fruit on the

export market and receive a premium price. If the cancellation of methyl

bromide diverts all of the cherries previously sold on the export market to

the domestic market, growers will lose $7.3 million annually. Likewise,

walnut producers will have to ship more products to the domestic market

instead of the holiday markets abroad because alternative techniques

could not be used to fumigate the walnuts quickly enough to meet the

holiday markets’ needs. As a result, walnut producers would lose about

$36.8 million annually. However, according to the study, trade negotiations

could, in the long term, remove the requirements for quarantine treatments

for cherries or approve alternative techniques. For walnuts, the expansion

of holiday markets or earlier harvesting could help meet producers’ needs.

Study by the

University of Florida

A University of Florida study of the economic impact of losing methyl

bromide on Florida’s agriculture concluded that the environment that

prevails in the state makes the use of methyl bromide critical to the

competitiveness of the state’s fruit and vegetable crops in U.S. and

international markets.6

 The University surveyed extension specialists in

the production areas and reviewed previous work on methyl bromide to

identify existing production systems and possible alternatives to the use of

methyl bromide. To analyze the economic impact of the ban, the

University developed mathematical models of the North American winter

fresh vegetable market and the world market for Florida grapefruit.

According to the study, the loss of methyl bromide would have a

devastating effect on Florida’s winter fresh vegetable producers. Because

no viable alternatives can be effectively substituted for methyl bromide,

Florida is estimated to lose over $620 million in the value of fresh fruit,

vegetables, and fresh citrus (measured at the time of shipping) worth over

$1 billion in total sales and more than 13,000 jobs. The study concludes

6

The Use of Methyl Bromide and the Economic Impact of Its Proposed Ban in the Florida Fresh Fruit

and Vegetable Industry, Institute of Food and Agricultural Sciences Bulletin No. 898, University of

Florida at Gainesville (Nov. 1995).

Page 27 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix I 

Studies of the Economic Impact of Phasing

Out Methyl Bromide for Agricultural Uses

that producers in the state would reduce the acreage allocated to these

crops by 43 percent, from about 126,000 acres to 71,500 acres. Tomato

production would decline by more than 60 percent, pepper production by

63 percent, and cucumber production by 46 percent without methyl

bromide. The study also predicted that Mexico, in particular, would

expand its production of vegetables, increasing its tomato production by

80 percent and its pepper production by 54 percent because, as a

developing country, it was expected to have longer to use methyl bromide

in producing and marketing its crops.

Page 28 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix II 

Potential Alternatives to Methyl Bromide for

Agricultural Uses

Research is currently being conducted by governmental and academic

institutions, as well as by the private sector, to ensure that alternative

materials and methods will be proven viable and available to the

agricultural community before methyl bromide is phased out. Tables II.1

and II.2, together with the accompanying descriptions, briefly profile

various alternatives to methyl bromide being evaluated by USDA and other

researchers for methyl bromide’s preplant and postharvest end uses and

note various concerns that need to be resolved during the 5 years before

the ban goes into effect.

Table II.1: Potential Alternatives for

Methyl Bromide’s Preplant End Uses Soil use areas

Alternatives

Small fruit and

vegetable farms Nurseries

Orchards and

vineyards

Chemical

1,3-Dichloropropene x x x

Dazomet x x x

Metam-sodium x x x

Sodium

tetrathiocarbonate

x x

Formalin/formaldehyde x x x

Chloropicrin x x x

Nonfumigant

narrow-spectrum

pesticides

x x x

Future and preliminary

research alternatives

x x x

Nonchemical

Steam x x

Solar heating x x x

Hydroponics x x

Organic matter x x x

Plant modification x x x

Crop rotation x

Future and preliminary

research alternatives

x x x

Integrated pest

management

x x x

Source: EPA and USDA studies, conference proceedings, and discussions between GAO and

representatives of government and industry organizations.

Page 29 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix II 

Potential Alternatives to Methyl Bromide for

Agricultural Uses

Descriptions of

Potential Alternatives

for Methyl Bromide’s

Preplant End Uses

1,3-Dichloropropene. A broad-spectrum liquid fumigant comparable to

methyl bromide for controlling most soil pests but less effective for

controlling weeds. A potential groundwater contaminant. Classified by EPA

as a probable human carcinogen. Under special review by EPA because of

concerns about cancer for workers and residents in and around treated

fields. Use permits previously suspended by California because of health

and safety concerns but currently allowed for limited use.

Dazomet. A broad-spectrum granular fumigant comparable to methyl

bromide for controlling most soil pests but can be less effective for

controlling nematodes (parasitic worms). Currently registered for some

food crops, but approval may not be sought for all uses of methyl bromide

(e.g., crops with low production acreage). Small fruit and orchard uses

restricted to the propagation or outplanting of nonbearing berry, vine, fruit

and nut crops and similar nonbearing plants, according to EPA. Concerns

about potential genotoxicity raised by EPA. Releases methyl isothiocyanate

(MITC), a potential groundwater contaminant. Concerns expressed by

United Nations Environment Programme (UNEP) about contamination of

groundwater.

Metam-sodium. A broad-spectrum liquid fumigant comparable to methyl

bromide for controlling most soil pests but may be less effective as a

nematicide. Identified by EPA as a known teratogen (i.e., cause of

developmental malformations). Classified by EPA as a probable human

carcinogen. Efficacy dependent on the availability of water (irrigation) to

ensure even distribution in the soil. Releases methyl isothiocyanate

(MITC), a potential groundwater contaminant. Concerns about

contamination of groundwater expressed by EPA and UNEP.

Sodium tetrathiocarbonate. A broad-spectrum liquid fumigant found

effective for many soilborne pests but not for weeds. Is considered less

effective than methyl bromide for controlling nematodes. Currently

registered for use on grapes and citrus and registration being sought for

almonds, prunes, and peaches. Efficacy dependent on the availability of

water (irrigation) to ensure even distribution in the soil. Concerns about

groundwater contamination expressed by UNEP. Groundwater concerns

addressed by EPA through label restrictions.

Formalin/formaldehyde. A broad-spectrum granular (paraformaldehyde)

or liquid (formalin) fumigant comparable to methyl bromide for

controlling fungi but less effective for controlling nematodes and weeds.

Registration voluntarily canceled because of health, safety, and

Page 30 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix II 

Potential Alternatives to Methyl Bromide for

Agricultural Uses

environmental concerns. Efficacy dependent on the availability of water

(irrigation) to ensure even distribution in the soil and prevent toxicity to

plants.

Chloropicrin. A broad-spectrum liquid fumigant principally used as a

fungicide. Comparable to methyl bromide for controlling many soil pests

but less effective for controlling nematodes and weeds. Also used for tear

gas, has a pungent/noxious odor, and can be very unpleasant or even

hazardous to handle. Concerns about toxicity and effects of exposure on

humans raised by EPA.

Nonfumigant narrow-spectrum pesticides. Include granular or liquid

nonfumigant nematicides, herbicides, and fungicides spread or sprayed on

the soil before or after planting to control specific pests (nematodes,

weeds, insects, fungi, or bacteria). Less effective than methyl bromide.

Registered uses specific to crops and locations, varying from state to state.

Some reregistration concerns raised (e.g., registered nematicides such as

aldicarb, carbofuran, and oxamyl are potential groundwater

contaminants).

Future and preliminary chemical research alternatives. Include new and

modified pesticides (e.g., bromonitromethane and carbonyl sulfide) being

researched. Will require registration and are in varying stages of research.

Will take time to completely develop products and assess their suitability

as replacements.

Steam. Technically feasible for soil applications and can be as effective as

methyl bromide, depending on methods of application and soil

conditions/temperatures. Concerns about viability raised by USDA. May be

impractical for large-scale (more than 2-acre) applications because it is

labor-, equipment-, and energy-intensive and current estimated costs per

acre are about two to five times higher than for methyl bromide. Related

equipment and services may not be readily available. Feasibility dependent

in some areas on availability of energy resources and fuel costs, according

to EPA.

Solar heating. Technically feasible for soil applications, depending on

geographic location and climate. Can be as effective as methyl bromide,

depending on application methods and soil conditions/temperatures.

Requires long treatment periods and may therefore be impractical for

sterilizing soil in areas with short growing seasons (e.g., northern United

Page 31 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix II 

Potential Alternatives to Methyl Bromide for

Agricultural Uses

States). Is likely, for the most part, to be used in combination with other

alternatives (e.g., soil fumigants) rather than by itself.

Hydroponics. Relatively new plant production systems that eliminate

soilborne pests by eliminating soil as the growing medium. Instead,

technology uses water-retaining substrates to deliver nutrients. Cannot be

used for root crops (e.g., carrots), can have high start-up costs, requires

significant support services, and, in the long run, could take many years to

become widely accepted and economical.

Organic matter. Incorporates soil amendments, such as compost, green

waste, straw, sawdust, and animal manure, into the soil to build soil health

and control some soilborne pests (e.g., nematodes and weeds).

Information on efficacy generally lacking. Some amendments as or more

effective than some nonfumigant pesticide alternatives used to control

nematodes and possibly viable for use in combined treatments.

Plant modification. Includes techniques such as crossbreeding plants,

grafting orchard and vineyard rootstocks, and changing plants’ genetic

makeup to obtain high resistance to pests and desirable production

characteristics. Extensive research required to determine potential of

some techniques as alternatives. Considered an important source of viable

alternatives by USDA and as having an already demonstrated potential in

breeding plants for pest resistance.

Crop rotation. Can be effective in suppressing damage by soilborne pests.

Effectiveness can be improved by including plants that produce fungicidal

and nematicidal substances. Limitations include land availability and

required knowledge of pest dynamics, general ecology, and appropriate

rotational crops in specific production areas. Research under way to

address these concerns.

Future and preliminary nonchemical research alternatives. Include

biocontrol methods (e.g., egg-destroying fungi) and genetic engineering

(e.g., altering organisms to control plant pathogens). Registration and

further research required for most. Time needed to complete development

and assess suitability as replacements.

Integrated pest management. Prevents pest populations from reaching

damaging levels through the use of chemical and/or nonchemical

treatments and management practices, as appropriate. Requires strict

monitoring of pest populations and knowledge of soil ecosystem/crop

Page 32 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix II 

Potential Alternatives to Methyl Bromide for

Agricultural Uses

production interactions. For effective implementation, requires intensive

research, training for growers, and use of some chemical control methods

that require regulatory approval and may involve health, safety, and

environmental concerns. Research needed to determine effective

combinations. Choices potentially limited by concerns about registering or

reregistering chemicals.

Table II.2: Potential Alternatives for

Methyl Bromide’s Postharvest End

Uses

Uses

Alternatives

Perishable

commodities

Nonperishable

commodities Quarantine Structures

Chemical

Phosphine x x x

Sulfuryl fluoride x x

Dichlorvos x

Previously

used/limiteduse alternatives

x

Nonchemical

Irradiation x x x

Controlled/

modified

atmosphere

x x x x

Thermotherapy x x x x

Combination

treatments

x x x x

Source: EPA and USDA studies, conference proceedings, and discussions between GAO and

representatives of government and industry organizations.

Descriptions of

Potential Alternatives

for Methyl Bromide’s

Postharvest End Uses

Phosphine. A gas produced when aluminum or magnesium phosphide is

exposed to moisture. Primarily used to fumigate grains but can be used to

control numerous pests on a wide variety of commodities and in some

structures. Commodities include raw agricultural foods (e.g., grains and

almonds), processed foods (e.g., cereal flours), animal feeds, and nonfood

commodities (e.g., tobacco). Structural uses include disinfesting grain

storage facilities, such as silos and grain bins, and other structures that are

not sensitive to phosphine’s highly corrosive properties, which can

damage switches or electronic equipment. Also used as a quarantine

treatment for nonfood commodities, such as tobacco exports and cotton

products. Effectiveness comparable to methyl bromide’s for allowed

treatments. Not suitable for some agricultural commodities (e.g., toxic to

Page 33 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix II 

Potential Alternatives to Methyl Bromide for

Agricultural Uses

fresh fruits and vegetables and can decrease efficiencies when longer

treatment times are required, according to USDA). Poses concerns for EPA

about effects of exposure on workers, mutagenicity, and neurotoxicity.

Risk of corrosion can be reduced and penetration and toxicity can be

enhanced by combining low doses with heat and carbon dioxide,

according to EPA.

Sulfuryl fluoride. Applied as a liquid that converts to a gas and can be used

for some nonfood quarantine treatments and for disinfesting some

structures empty of food and food products. Effectiveness comparable to

methyl bromide’s but poses concerns for EPA about mutagenicity,

carcinogenicity, and reproductive effects.

Dichlorvos. A volatile liquid compound with limited penetrative powers.

Used primarily to control pests in nonperishable foods (e.g., dried fruits

and nuts, grains, and milled products) stored in warehouses, including raw

and processed products. Classified by EPA as a possible human carcinogen

and under special review because of concerns about neurotoxicity and

carcinogenicity.

Previously used/limited-use alternatives. Include ethylene oxide and other

quarantine fumigants (hydrogen cyanide, ethylene dibromide, carbon

disulfide, and ethylene dichloride) that pose concerns about health and

safety. As effective as methyl bromide for quarantine treatments, but may

need emergency-use permits such as USDA formerly obtained to control

specific pests on specified commodities. Also include methyl bromide

recovery systems being researched for quarantine applications, since use

of the recycled chemical is not banned after 2001. Preliminary research

indicates feasibility of designing fumigation chambers to achieve

95-percent recovery. But full development of these systems may extend

beyond 2001 and poses liability concerns involving yet-to-be-established

operational and performance tolerances.

Irradiation. Uses low-level gamma radiation to sterilize or kill pests in

quarantine and nonquarantine applications. Can be used on most foods

and grains and can be equal in effectiveness to methyl bromide. Requires

considerable investment in facilities and equipment, entails additional

costs to dispose of spent cobalt, and poses capacity limitation concerns.

USDA concerned about some commodities’ sensitivity to treatment. Still

requires USDA’s approval for quarantine uses, and public’s acceptance is

uncertain.

Page 34 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix II 

Potential Alternatives to Methyl Bromide for

Agricultural Uses

Controlled/modified atmosphere. Uses decreased amounts of oxygen

and/or increased amounts of carbon dioxide or nitrogen to suffocate pests.

May require sealed facilities. Has most potential for treating nonperishable

commodities. Use in combination with other treatments being evaluated

for improving efficacy levels. Requirements for sealing facilities and long

treatment times can pose cost considerations. Controlled atmospheres and

low temperatures used more cost-effectively than methyl bromide by the

Department of Defense to successfully ship perishables, according to EPA.

Thermotherapy. Can be used to control a broad spectrum of pests

infesting commodities and structures and is comparable in effectiveness to

methyl bromide. Treatments include vapor heat, dry heat, hot water, quick

freeze, and cold. Length of required treatment, treatment facility’s size, and

commodities’ sensitivities to temperature pose limitations.

Experimentation begun with various techniques. Combination treatments

likely to be required for some combinations of pests.

Combination treatments. Chemical and/or nonchemical combinations

potentially usable to control pests on many commodities and in quarantine

treatments. Combinations not yet identified for all commodities or pests.

Chemical and nonchemical pest control combinations indicate the best

potential for controlling pests now managed by methyl bromide, according

to EPA.

Sources of Detailed

Information on

Potential Alternatives

Listed below are recent studies and reports that provide more detailed

information on these and other potential alternatives for methyl bromide’s

many agricultural uses, the status of their availability as viable substitutes,

and research priorities for meeting users’ short-, mid-, and long-term

needs.

• Alternatives to Methyl Bromide: Research Needs for California, California

Department of Food and Agriculture (Sacramento: Sept. 1995).

• Status of Methyl Bromide Alternatives Research Activities, Crop

Protection Coalition (July 1995).

• Alternatives to Methyl Bromide: Ten Case Studies—Soil, Commodity, and

Structural Use, EPA, EPA430-R-95-009 (Washington, D.C.: July 1995).

• Out of the Frying Pan, Avoiding the Fire: Ending the Use of Methyl

Bromide—An Analysis of Methyl Bromide Use in California and the

Alternatives, Ozone Action, Inc. (Washington, D.C.: 1995).

Page 35 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix II 

Potential Alternatives to Methyl Bromide for

Agricultural Uses

• 1994 Report of the Methyl Bromide Technical Options Committee for the

1995 Assessment of the Montreal Protocol on Substances That Deplete the

Ozone Layer, UNEP (Nairobi, Kenya: Nov. 1994).

• Annual International Research Conference on Methyl Bromide

Alternatives and Emissions Reductions, sponsored by Methyl Bromide

Alternatives Outreach (Orlando, Fla.: Nov. 1994).

• Alternatives to Methyl Bromide, ICF Incorporated for EPA (Washington,

D.C.: Sept. 1993).

• Alternatives to Methyl Bromide: Assessment of Research Needs and

Priorities, USDA (Arlington, Va.: June/July 1993).

• Methyl Bromide Substitutes and Alternatives: A Research Agenda for the

1990s, USDA (Arlington, Va.: Jan. 1993).

Page 36 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix III 

Food Imports Requiring Fumigation With

Methyl Bromide or an Alternative Treatment

as a Condition of Entry Into the United

States

Fresh fruits and vegetables Other foods

Apples

Apricots

Asparagus

Avocado

Beans

Blueberries

Cabbage (Brassica Oleraceae)

Cactus (Opuntia)

Cherries

Cipollino

Ethrog

Garlic

Grapes

Grapefruit

Horseradish

Kiwi fruit

Lemons

Lettuce

Limes 

Nectarines

Okra

Oranges

Peaches

Pears

Peas

Pigeon peas

Pineapples

Plums

Quinces

Roselle

Tangerines

Thyme

Yams

Chestnuts, unprocessed or shelled

Citrus, frozen unpeeled or frozen peel

Cucurbit seeds, unprocessed, dried,

roasted, or salted

Cumin, unprocessed,

roasted, or ground

Faba beans, unprocessed

Lentils, unprocessed

Peppers, dried

Source: USDA’s Animal and Plant Health Inspection Service.

Page 37 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix IV 

Value of U.S. Exports for Which Receiving

Countries Require Treatment With Methyl

Bromide, 1994

Dollars in thousands

Commodity Receiving country

Dollar

value

Apples Japan $5,986

Blueberries Mexico 12

Cherries Japan 92,427

Korea 535

Cotton Mexico 198,399

Bangladesh 15,867

Pakistan 36,695

El Salvador 18,536

Guatemala 16,990

Peru 10,869

Oaklogs European Union 21,209

Mexico 4,331

Peaches/nectarines Japan 25

Mexico 6,864

Strawberries Australia 426

Walnuts in shell Japan 1,349

Walnuts, shelled Korea 990

Total $431,510

Source: USDA.

Page 38 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix V 

Objectives, Scope, and Methodology

The Ranking Minority Member of the House Committee on Commerce

asked that we review the concerns of the U.S. Department of Agriculture

and the agricultural community about phasing out the U.S. production and

importation of methyl bromide. Specifically, we agreed to develop

information on (1) the scientific evidence that human uses of methyl

bromide contribute to the depletion of the stratospheric ozone layer,

(2) the availability of economical and effective alternatives to methyl

bromide, (3) the impact of the ban on U.S. trade in agricultural

commodities, and (4) EPA’s authority under the Clean Air Act, as amended,

to grant exemptions to the ban for essential uses. We conducted our work

from November 1994 through November 1995 in accordance with

generally accepted government auditing standards.

To review the scientific evidence, we consulted the reports of the United

Nations Environment Programme (UNEP) on its 1991, 1992 (update of

1991), and 1994 scientific assessments of ozone depletion. We discussed

the results of these studies with the Associate Director of Environment,

Office of Science and Technology Policy in the Executive Office of the

President and with scientists at the National Aeronautics and Space

Administration who participated in the 1994 assessment. We also

discussed the results with officials of USDA and EPA, including EPA’s Methyl

Bromide Program Director. We further discussed the scientific evidence

with the Methyl Bromide Working Group, which was formed by methyl

bromide producers and distributors to address scientific issues related to

the phaseout, and with the Crop Protection Coalition, which represents

methyl bromide users. Finally, we discussed the phaseout with a

representative of the Natural Resources Defense Council, which is

coordinating methyl bromide issues for various environmental groups,

including the Friends of the Earth and the Environmental Defense Fund.

In addition, we reviewed scientific studies, reports, and other information

either prepared by EPA or submitted by others during EPA’s promulgation of

the methyl bromide phaseout rule. Furthermore, we attended the “1995

Methyl Bromide State of the Science Workshop” held in June 1995. At the

conference, which was sponsored by the Methyl Bromide Global Coalition

in cooperation with the National Aeronautics and Space Administration,

various papers were presented on the latest research developments.

At EPA, we discussed concerns about alternatives to methyl bromide with

officials of the Stratospheric Protection Division and Office of Pesticide

Programs. At USDA, we interviewed officials of the Agricultural Research

Service, Economic Research Service, and Animal and Plant Health

Page 39 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix V 

Objectives, Scope, and Methodology

Inspection Service, including the Chair of USDA’s Ad Hoc Committee for

Alternatives to Methyl Bromide. We further discussed substitutes for and

alternatives to methyl bromide with the Methyl Bromide Working Group,

the Crop Protection Coalition, the California Strawberry Commission, and

several strawberry growers in California. In addition, we reviewed studies,

reports, and other information on the availability and suitability of

substitutes and alternatives provided by these officials. We also reviewed

the assessment reports of UNEP’s Technology and Economics Assessment

Panel, Methyl Bromide Technical Options Committee, and Economics

Committee and attended the “Annual International Research Conference

on Methyl Bromide Alternatives and Emissions Reductions,” which was

held in November 1994. Furthermore we reviewed the applicable EPA

supporting documents and the information submitted to the agency during

the promulgation of the phaseout rule.

We discussed the trade implications of the phaseout with officials of

USDA’s Economic Research Service, Agricultural Research Service, and

Animal and Plant Health Inspection Service; EPA’s Methyl Bromide

Program; the Crop Protection Coalition; and the Methyl Bromide Working

Group. In addition, we reviewed studies, reports, and other documents

prepared by these organizations on the phaseout’s effects on trade in

agricultural commodities. We also reviewed the 1994 assessment reports

of UNEP’s Technology and Economics Assessment Panel, Methyl Bromide

Technical Options Committee, and Economics Committee. Finally, we

obtained information from the Animal and Plant Health Inspection Service

on U.S. imports and exports of commodities treated with methyl bromide.

To determine whether the Clean Air Act provides EPA with the authority to

grant essential use exemptions to the phaseout rule, our Office of General

Counsel reviewed the Clean Air Act and its legislative history.

Page 40 GAO/RCED-96-16 Phaseout of Methyl Bromide
Appendix VI 

Major Contributors to This Report

Resources,

Community and

Economic

Development

Division, Washington,

D.C.

Lawrence Dyckman, Associate Director

Edward A. Kratzer, Assistant Director

J. Kevin Donohue, Assistant Director

Raymond H. Smith, Jr., Senior Evaluator

J. Kenneth McDowell, Senior Evaluator

Donald E. Pless, Senior Evaluator

Frank J. Gross, Senior Evaluator

Office of General

Counsel

Richard P. Johnson, Attorney Advisor

(160301) Page 41 GAO/RCED-96-16 Phaseout of Methyl Bromide
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