MONTREAL PROTOCOL

ON SUBSTANCES THAT DEPLETE

THE OZONE LAYER

UNEP

REPORT OF THE

TECHNOLOGY AND ECONOMIC ASSESSMENT PANEL

SEPTEMBER 2013

EVALUATION OF 2013 CRITICAL USE NOMINATIONS FOR METHYL 

BROMIDE AND RELATED MATTERS

FINAL REPORT
ii MBTOC 2013 CUNs: Final Recommendations - September2013

UNEP

SEPTEMBER 2013 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATION OF 2013 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

FINAL REPORT
MBTOC 2013 CUNs: Final Recommendations - September2013 iii

Montreal Protocol

On Substances that Deplete the Ozone Layer

Report of the

UNEP Technology and Economic Assessment Panel

September 2013

EVALUATIONS OF 2013 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

The text of this report is composed in Times New Roman.

Co-ordination: Methyl Bromide Technical Options Committee

Composition of the report: MBTOC Soils: Co-chairs Ian Porter, Mohamed Besri

MBTOC SC: Co-chair Michelle Marcotte 

MBTOC QPS: Co-chair Marta Pizano

Reproduction: UNON Nairobi

Date: September 2013

Under certain conditions, printed copies of this report are available from:

UNITED NATIONS ENVIRONMENT PROGRAMME

Ozone Secretariat, P.O. Box 30552, Nairobi, Kenya

Normally from SMI Distribution Service Ltd., Stevenage, Hertfordshire, UK, fax: + 44 1438 

748844

This document is also available in portable document format from

http://www.unep.org/ozone/teap/Reports/TEAP_Reports/

No copyright involved. This publication may be freely copied, abstracted and cited, with 

acknowledgement of the source of the material.

ISBN: 978-9966-20-018-1
iv MBTOC 2013 CUNs: Final Recommendations - September2013

Disclaimer

The United Nations Environment Programme (UNEP), the Technology and Economic 

Assessment Panel (TEAP) Co-Chairs and members, and the Methyl Bromide Technical 

Options Committee (MBTOC) Co-Chairs and members, and the companies and organisations 

that employ them do not endorse the performance, worker safety, or environmental 

acceptability of any of the technical options discussed. Every industrial operation requires 

consideration of worker safety and proper disposal of contaminants and waste products. 

Moreover, as work continues - including additional toxicity evaluation - more information on 

health, environmental and safety effects of alternatives and replacements will become 

available for use in selecting among the options discussed in this document.

UNEP, TEAP Co-Chairs and members, and the MBTOC Co-Chairs and members, in 

furnishing or distributing this information, do not make any warranty or representation, either 

express or implied, with respect to the accuracy, completeness, or utility; nor do they assume 

any liability of any kind whatsoever resulting from the use or reliance upon any information, 

material, or procedure contained herein, including but not limited to any claims regarding 

health, safety, environmental effect or fate, efficacy, or performance, made by the source of 

information.

Mention of any company, association, or product in this document is for information purposes 

only and does not constitute a recommendation of any such company, association, or product, 

either express or implied by UNEP, TEAP Co-Chairs and members, and the MBTOC CoChairs and members or the companies or organisations that employ them.

Acknowledgement

The Technology and Economic Assessment Panel and its Methyl Bromide Technical Options 

Committee acknowledge with thanks the outstanding contributions from all of the individuals 

and organisations who provided support to Panel and Committee Co-Chairs and members. 

The opinions expressed are those of the Panel and the Committee and do not reflect the 

reviews of any sponsoring or supporting organisation.

Methyl Bromide Technical Options Committee:

MBTOC Soils (S) Co-Chairs: Ian Porter (Australia). Mohamed Besri (Morocco) Members 

of MBTOC S: Aocheng Cao (China); Peter Caulkins (USA); Raquel Ghini (Brazil); George 

Lazarovits (Canada); Marta Pizano (Colombia); Sally Schneider (USA); JL (Stappies) 

Staphorst (South Africa); Akio Tateya (Japan); Alejandro Valeiro (Argentina); Jim Wells 

(USA); Suat Yilmaz (Turkey)

MBTOC Structures and Commodities (SC) Chair: Michelle Marcotte (Canada) Members 

of MBTOC SC Fred Bergwerff (Netherlands); Chris Bell (UK); Ricardo Deang 

(Philippines); Alfredo Gonzalez (Philippines); Darka Hamel (Croatia); Christoph Reichmuth 

(Germany); Jordi Riudavets (Spain); John Sansone (USA); Robert Taylor (UK); Chris 

Watson (UK)

MBTOC Quarantine and Preshipment Chair: Marta Pizano (Colombia), Members of 

MBTOC QPS Jonathan Banks (Australia); Ken Glassey (New Zealand); Takashi Misumi 

(Japan); David Okioga (Kenya); Ian Porter (Australia); Ken Vick (USA) and Eduardo Willink 

(Argentina).

MBTOC Economist: Nick Vink (South Africa)
MBTOC 2013 CUNs: Final Recommendations - September2013 v

SEPTEMBER 2013 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATIONS OF 2013 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

FINAL REPORT
vi MBTOC 2013 CUNs: Final Recommendations - September2013

UNEP

SEPTEMBER 2013 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

MBTOC FINALCUN REPORT – SEPTEMBER 2013

Common Acronyms

1,3-D 1,3-dichloropropene

A5 Article 5 Party

ASD Anaerobic soil disinfestation

CUE Critical Use Exemption

CUN Critical Use Nomination

DOI Disclosure of Interest

EC European Community

EMOP Extraordinary Meeting of the Parties

EPA Environmental Protection Agency

EPPO European Plant Protection Organisation

IM Iodomethane

IPM Integrated Pest Management

IPPC International Plant Protection Convention

ISPM International Standard Phytosanitary Measure

LPBF Low Permeability Barrier Film (including VIF films)

MB Methyl Bromide

MBTOC Methyl Bromide Technical Options Committee

MBTOC QPS Methyl Bromide Technical Options Committee, Quarantine and Preshipment Subcommittee
MBTOC 2013 CUNs: Final Recommendations - September2013 vii

MBTOC SC Methyl Bromide Technical Options Committee, Structures and 

Commodities Subcommittee

MBTOC S Methyl Bromide Technical Options, Soils Subcommittee

MITC Methyl isothiocyanate

MOP Meeting of the Parties

MS Metam sodium

Non-A5 Non Article 5 Party

OEWG Open Ended Working Group

Pic Chloropicrin

QPS Quarantine and Pre-shipment

SF Sulfuryl fluoride

TEAP Technology and Economics Assessment Panel

TIF Totally Impermeable Film

VIF Virtually Impermeable Film

VOC Volatile Organic Compounds

MBTOC 2013 CUNs: Final Recommendations - September2013 ix

2013 Evaluations of Critical Use Nominations for Methyl Bromide and 

Related Matters – Final Report

Table of Contents

1.1 SCOPE OF THE REPORT....................................................................................................1

1.2 EVALUATIONS OF CUNS – 2013 ROUND FOR 2015 EXEMPTIONS..........................1

1.3 ACHIEVING CONSENSUS ..................................................................................................2

1.4 MBTOC SOILS: FINAL EVALUATIONS OF 2013 CRITICAL USE NOMINATIONS 

FOR METHYL BROMIDE FOR 2015.................................................................................5

1.4.1 CRITICAL USE NOMINATIONS SUBMITTED .................................................................................5

1.4.2 CUN REASSESSMENT FOR PREPLANT SOIL USES.........................................................................6

1.4.3 GENERAL COMMENTS ON THE REASSESSMENT FOR PREPLANT SOIL USE..................................6

1.4.4 STANDARD PRESUMPTIONS USED IN ASSESSMENT OF NOMINATED QUANTITIES.......................7

1.5 FINAL EVALUATION OF CUNS: STRUCTURES AND COMMODITIES AND REPORT 

ON EMERGENCY USE BY CANADA OF MB FOR PASTA WAREHOUSES ...........16

1.5.1 MBTOC REPORT ON CANADA’S EMERGENCY USE OF METHYL BROMIDE TO FUMIGATE 

PASTA WAREHOUSING.............................................................................................................17

1.5.1.1 Executive Summary:..................................................................................................................17

1.5.1.2 Summary of Information Received from the Party ....................................................................18

a. Fumigation and Pest Aspects: ......................................................................................................................18

b. Economics Aspects: Costs of fumigation and pest contamination ...............................................................19

1.5.1.3 Comments by MBTOC...............................................................................................................20

a. About the fumigation methods.....................................................................................................................20

b. About the potential to destroy infested packages instead of fumigation ......................................................21

c. About the use of methyl bromide in facilities of poor gastightness.............................................................22

d. About the method used to determine pest resistance....................................................................................22

e. About the costs to conduct repeated fumigations.........................................................................................23

f. Recommendations ........................................................................................................................................23

1.5.2. DETAILS OF POSTHARVEST CUN EVALUATIONS......................................................................24

1.6. ACTIVITY REPORT 2013 AND WORKPLAN FOR 2014..............................................31

1.6.1. ACTIVITY REPORT FOR 2013 ....................................................................................................31

1.6.2. WORK PLAN AND INDICATIVE BUDGET FOR 2013.....................................................................31

1.7 REFERENCES: ....................................................................................................................33

ANNEX I: DECISION IX/6.......................................................................................................................37

ANNEX II - PART A: TREND IN MB PREPLANT SOIL NOMINATIONS AND EXEMPTIONS .38

ANNEX III - PART B: TRENDS IN MB STRUCTURAL AND COMMODITY NOMINATIONS AND

EXEMPTIONS......................................................................................................................45

MBTOC 2013 CUNs: Final Recommendations - September2013 1

2013 EVALUATIONS OF CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS 

1.1 Scope of the Report

This 2013 final report provides final evaluations by MBTOC of Critical Use Nominations (CUNs) 

submitted for methyl bromide (MB) for 2015 by three Parties (Australia, Canada, USA). Only three of 

the CUNs submitted in 2013 required reassessment after the 33rd OEWG. As per provisions set out in 

Decision IX/6 (Annex I, MOP16), CUNs were submitted to the Ozone Secretariat by the Parties in 

accordance with the timetable shown in paragraph 1 of Annex I, Decision XVI/4. After the OEWG, 

Parties were requested to provide further information by the end of July 2013. Australia and Canada 

complied with these timelines, but the USA required further time to compile information and this was 

supplied at the end of August 2013. Consequently, assessment of the CUN from the USA was

delayed and an advance copy of the report without the USA reassessment was posted. This final 

report replaces that version.

A review of an emergency use for two pasta warehouses by Canada is also provided. 

This report needs to be read in conjunction with the 2013 May TEAP report, which provides full 

detail of all CUN assessments conducted in 2013. It also provides information on the standard

presumptions used in the 2013 assessment, information on stocks (Decision Ex.1/4 (9f)), partial 

information on actual MB consumption for critical uses (in accordance with Decision XVII/9) and 

apparent adoption rates of alternatives, as evidenced by trend lines on reduction of MB CUNs (in 

accordance with Decisions XIX/9, XX/5). 

No changes to the presumptions are proposed for future nominations and thus no consideration is 

required by Parties at the forthcoming MOP as per paragraph 2 in Annex 1 to the report of MOP16. 

1.2 Evaluations of CUNs – 2013 round for 2015 exemptions

Detailed interim assessments of all CUNs were made by MBTOC at its meeting held in London, UK 

from 2-5 April, 2013, which was attended by the three MBTOC sub-committees: Soils, SC and QPS.

For the soils CUNs, Australia and Canada nominated similar amounts of MB to previous rounds for 

the strawberry runner sector, highlighting the difficulties with phase out of MB for this sector. In the 

USA the only soil CUN submitted was for strawberry fruit production. 

In the postharvest sector, in 2012, there were five CUNs submitted by three Parties. By contrast, in 

2013 two postharvest CUNs were submitted. Between 2012 and 2013, applicants from three Parties, 

Australia, Canada and the US, were able to complete their planned adoption of alternatives in flour 

and rice milling and several dried fruit sectors. Accordingly, Australia did not submit a CUN for rice 

processing, Canada did not submit a CUN for flour milling and the US did not submit a CUN for flour 

milling and also several dried fruit sectors. Completing the adoption of these former methyl bromide 

applications was no doubt difficult and required effort of the industry and government; MBTOC was 

happy to hear of these successes.

The total nominated amount for all countries for 2015 was 412.221 t representing a 14.8% reduction 

to that nominated in 2012 for 2014. MBTOC has made a final recommendation for all nominations 

from Australia, Canada and the USA of 313.766 t. The grounds used for these recommendations are 

given in detail for the relevant CUNs in Tables 1-4 and 1-6. 

Also during the first meeting in London in April 2013, progress reports were prepared and ‘Disclosure 

of Interest’ declarations updated. At the 33rd OEWG meeting in Bangkok, MBTOC held bilateral 

meetings with Australia, Canada and the United States to discuss the interim recommendations and 

since then all three Parties have provided further information to support reassessment of the three 
2 MBTOC 2013 CUNs: Final Recommendations - September2013

preplant soils nominations. In August, Canada informed MBTOC that it had granted emergency use 

of MB for two pasta warehouses under its domestic regulation as explained later in this report. 

MBTOC did not hold a face-to-face second meeting this year in view the small number of CUNs and 

funding difficulties faced by many non-A5 members in relation to meeting attendance. Consideration 

of new information and reassessment of CUNs and discussion regarding the emergency use were thus 

conducted electronically. 

As discussed in the May 2013 TEAP Progress Report, three Parties - Australia, Canada, and the USAsubmitted nominations for critical uses of MB for either preplant soil use and/or postharvest use in 

2015. Five nominations were submitted in this round (Tables 1-4 and 1-5). The total nominated 

amount for all countries for 2015 was 412.221t, which represented a 35% reduction with respect to 

amounts nominated in 2012 for 2014. 

After reassessment by MBTOC after the OEWG, the final recommendation for 2015 was 313.766, 

i.e., 76% of that nominated (Table 1.1). MBTOC has recommended quantities of MB for 2015, which 

are less those nominated. The grounds used for these recommendations are given in detail in the 

relevant CUNs in Tables 1-4 and 1-6. 

In general, the CUNs were submitted due to the following issues: regulatory restrictions that did not 

allow partial or full use of alternatives, difficulties in the scale-up of alternatives, alternatives 

considered uneconomical and unavailability of alternatives. Additionally, MBTOC-SC notes that one 

CUN use still does not have technically feasible alternatives. In paragraph 20 of Annex 1 referred to 

in Decision XVI/4, Parties specifically requested that MBTOC explicitly state the specific basis for 

the Party’s economic statement relating to CUNs. Tables 1-4 and 1-6 provide this information for 

each CUN. MBTOC notes there was an improvement in the economic information supplied in this 

round, which allowed the MBTOC economist to better assess the nominations from this perspective.

1.3 Achieving Consensus

In accordance with decision XX/5(9) and similar subsequent decisions (XXI/11(4), XXII/6(4) and 

XXIII/4(3)) the Parties have indicated that MBTOC ‘should ensure that it develops its 

recommendations in a consensus process that includes full discussion among all available members of 

the Committee and should ensure that members with relevant expertise are involved in developing its 

recommendations’.

In 2013 as described in the May 2013 TEAP Progress Report, MBTOC’s procedures were designed to 

improve members’ contribution and reaching final decisions on nominations before, during and after 

the MBTOC meetings. The following procedure ensured all members were able to review all the 

information available and thus participate in final consensus. 

Information from Parties was circulated electronically to all members for an opportunity to make 

comments about the reassessment. Members were asked to submit comments by mid -August, 2013

and these were considered by the relevant sub-committee. The coordinating Co-Chair (s) provided the 

sub-committee with a summary of all comments, and the members in question then reached a position 

which the Co-Chairs used to draft the proposed text boxes and recommendations. Sub-committee 

members then further discussed, commented on and made changes to this proposal. Once agreed, the 

text box and recommendation were circulated to the full MBTOC to obtain consensus (or agreement 

not to disagree) from each member of the Committee. Concerning the emergency use report, the 

process described was similar beginning with extensive discussion and further correspondence with 

the Party. The Co-Chair drafted the report, which was then circulated for further comment from 

MBTOC, which were then incorporated until full consensus was achieved. 

Several members recused from evaluation of nominations as required by MBTOC’s working 

procedures. These included George Lazarovits (US Strawberry fruit and Canadian Strawberry 
MBTOC 2013 CUNs: Final Recommendations - September2013 3

Nurseries), Jim Wells (US Strawberry Fruit) and Ian Porter (Australian Strawberry nurseries). The 

recusals took place either as a result of a member’s disclosure as per MBTOC's guidelines or 

members may have chosen to self recuse to avoid any perceived conflict of interest.
4 MBTOC 2013 CUNs: Final Recommendations - September2013

Table 1.1 - Summary of Critical Use Nominations and Exemptions of Methyl Bromide (tonnes) 

Quantities Nominated Quantities Approved

Final

Recomm

endation

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005

(1ExMOP 

and

16MOP)

2006

(16MOP+

2ExMOP+

17MOP)

2007

(17MOP + 

18MOP)

2008

(18MOP

+

19MOP)

2009

(19MOP)

2010

(20MOP

+

21MOP)

2011

(21MOP)

2012

(22MOP)

2013

(23MOP)

2014

(24 MOP)

2015

Australia 206.950 81.250 52.145 52.900 38.990 37.610 35.450 34.660 32.164 30.947 29.79 146.600 75.100 48.517 48.450 37.610 36.440 28.710 31.708 32.134 [27.971] [28.765]

Canada 61.992 53.897 46.745 42.241 39.115 35.080 19.368

+3.529

16.281 13.444 10.305 5.261 61.792 53.897 52.874 36.112 39.020 30.340

+3.529 19.368 16.281 13.109 [10.094] [5.050]

EC1

5754.361 4213.47 1239.873 245.00 0 0 0 0 0 0 0 4392.812 3536.755 689.142 245.146 0 0

0 0 0 0 0

Israel 1117.156 1081.506 1236.517 952.845 699.448 383.700 232.247 0 0 0 0 1089.306 880.295 966.715 860.580 610.854 290.878 0 0 0 0 0

Japan 748.000 741.400 651.700 589.600 508.900 288.500 249.420 221.104 3.317 0 0 748.000 741.400 636.172 443.775 305.380 267.000 239.746 219.609 3.317 0 0

New 

Zealand 53.085 53.085 32.573 0 0 0 0 0 0 0 0 50.000 42.000 18.234 0 0 0

0

0 0 0 0

Switzerland 8.700 7.000 0 0 0 0 0 0 0 0 0 8.700 7.000 0 0 0 0 0 0 0 0 0

USA 10753.997 9386.229 7417.999 6415.153 4958.034 3299.490 2388.128 1181.779+ 

6.339

691.608 442.337 377.170 9552.879 8081.753 6749.060 5355.976 4261.974 3232.856

+2.018

2055.200 993.706 562.328 442.337 [279.951]

TOTALS 18704.241 15617.837 10677.552 8297.739 6244.487 4044.380 2928.142 1460.163 740.533 483.589 412.221 16050.089 13418.200 9160.714 6990.039 5,254.838 3572.183 2343.024 1261.304 610.888 483.589 [313.766]

 

* Not yet available. 

1Members of the European Community which had CUNs/CUEs included:

2005 – Belgium, France, Germany, Greece, Italy, Netherlands, Poland, Portugal, Spain, and the United Kingdom.

2006 – Belgium, France, Germany, Greece, Ireland, Italy, Latvia, Malta, Netherlands, Poland, Portugal, Spain, and the United Kingdom.

2007 – France, Greece, Ireland, Italy, Netherlands, Poland, Spain, and the United Kingdom

2008 – Poland, Spain
MBTOC 2013 CUNs: Final Recommendations - September2013 5

1.4 MBTOC Soils: Final evaluations of 2013 Critical Use Nominations for Methyl 

Bromide for 2015

1.4.1 Critical Use Nominations submitted

At the Open Ended Working Group held in Bangkok from 24 to 28 June 2013, MBTOC Soils 

presented interim recommendations on all three nominations received from Australia, Canada and the 

United States as shown in Table 1-2. During bilateral discussions at the OEWG, all three Parties 

submitting nominations in the 2013 round indicated issues related to the interim assessments and 

subsequently sent further information and requests for reassessment. 

Figure 1-1: Amounts of MB nominated and exempted for CUE uses in Australian and Canadian 

Strawberry production and in the US strawberry fruit production from 2005 to 2015. 

Blue lines indicate the trend of CUN nominated and the red lines the amount CUE 

methyl bromide approved by the Parties or recommended for approval at the MOP in 

2013 for 2015.

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

CUN 35.75 37.5 35.75 35.75 29.79 29.79 29.79 29.79 29.76 29.76 29.76

CUE 35.75 37.5 35.75 35.75 29.79 29.79 29.79 29.76 29.76 29.76 28.77

0

5

1 0

1 5

2 0

2 5

3 0

3 5

4 0

Methyl Bromide (t)

Australia Strawberry Nursery 

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

CUN 6.84 7.995 7.462 7.462 7.462 5.261 5.261 5.596 5.261 5.261

CUE 6.84 7.995 7.462 7.462 7.462 5.261 5.261 5.261 5.261 5.05

0

1

2

3

4

5

6

7

8

9 Methyl Bromide (t)

Canada Strawberry Nursery (PEI)
6 MBTOC 2013 CUNs: Final Recommendations - September2013

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

CUN 2469 1918 1734 1605 1337 1103 1023 754 531.7 415.1 373.7

CUE 2053 1731 1476 1350 1269 1007 812.7 678 415.1 415.1 276.7

0

500

1000

1500

2000

2500

3000

Methyl Bromide (t)

USA Strawberry Fruit

1.4.2 CUN reassessment for preplant soil uses

In summary, in the final assessment, the Canadian CUN was unchanged from the interim 

recommendation (5.05 t) , but 28.765 t was reinstated for the Australian nomination

Table 1-2: Summary of the interim recommendations by MBTOC-S (in square brackets) for 

CUE’s for preplant uses of MB (tonnes) submitted in 2013 for 2015

NA – Assessment not yet completed

1.4.3 General Comments on the Reassessment for Preplant Soil Use

The Australian and Canadian nominations for strawberry runner production were predominantly 

based on economic considerations, as MBTOC considered that soilless substrate systems were 

suitable as technical alternatives for at least part (if not all) of the nominations. This posed a unique 

challenge for the committee, as MBTOC has no standard economic criteria with which to assess a 

nomination. In these instances, MBTOC considered the economic information provided by the Party 

in context with the extent of commercial adoption for similar sectors worldwide as an indication of 

economic feasibility. The MBTOC economist also provided his views on the comparison of soilless 

with bare rooted runner production outdoors and whilst in general soilless culture was considered 

uneconomical based on the Parties information, it was recognized that on a small scale capital costs 

would be lower and less prohibitive to uptake of soilless systems and thus feasible. MBTOC also 

noted that where soilless production has been adopted, costs for production of runners have generally 

decreased as technological expertise and knowledge increase (see references ahead). For both the 

Australian and Canadian nominations it was also apparent that Parties were considering a range of 

technologies in their effort to determine the most suitable and cost effective production system. 

MBTOC continues to encourage Parties to consider a review of regulations covering the registration, 

use and adoption of alternatives, particularly those regarding barrier films to reduce dosage rates and 

associated emissions of MB and its alternatives, MBTOC also notes that a large proportion of MB has 

been nominated for uses where regulations or legislation prevent reductions of MB dosage. In several 

cases, the mandatory use of MB is specified at a high dosage for either treatment of certified 

Country and Sector Nomination by 

the Party for 

2015

Interim 

Recommendation for 

2015

Final Recommendation 

for 2015

1. Australia

Strawberry runners 29.760 [0] [28.765]

2. Canada

Strawberry runners 5.261 [5.050] [5.050]

3. USA

 Strawberry fruit 373.660 [224.196] [276.711]

TOTAL 408.681 [229.246] [310.526]
MBTOC 2013 CUNs: Final Recommendations - September2013 7

propagation material or because regulations prevent use of barrier films which otherwise could have 

reduced the MB dosage rate. Further, regulations on the use of alternatives are preventing their uptake 

for preplant soil use in a substantial proportion of the remaining CUNs. 

1.4.4 Standard Presumptions Used in Assessment of Nominated Quantities.

Table 1-3 below contains the standard presumptions applied by MBTOC-S for this round of CUNs for 

preplant soil uses. These standard presumptions were first proposed in the MBTOC report of October 

2005 and were presented to the Parties at 17th MOP. Studies and reports to support them have been 

provided in previous reports and were revised for some sectors after consideration by the Parties at the 

19th MOP. The rates and practices adopted by MBTOC as standard presumptions are based on 

maximum rates considered acceptable by published literature and actual commercial practice. 

As in evaluations conducted in previous years, MBTOC considered reductions to quantities of MB in 

particular nominations to a standard rate per treated area where technical evidence supported its use. 

As a special case, MBTOC continues to accept a maximum rate of 200 kg/ ha (20 g/m2) in MB/Pic 

formulations with high Pic-containing mixtures with or without barrier films for certified nursery 

production, unless regulations prescribe lower or higher rates. However, MBTOC notes that studies 

have shown that rates of 200 kg/ha (20g/m2) or less of MB: Pic 50:50 are effective with barrier films 

for production of ‘certified’ nursery material and urge Parties to consider regulations which permit 

these lower rates. MBTOC also notes that certified runner production may involve regulations which 

specify the mandatory use of a fumigant such as MB or an alternative, in order for these nursery 

materials to be “certified”.

The indicative rates used by MBTOC were maximum guideline rates, for the purpose of calculation 

only. MBTOC recognises that the actual rate appropriate for a specific use may vary with local 

circumstances, soil conditions and the target pest situation. Some nominations were based on rates 

lower than these indicative rates.

Table 1-3: Standard Presumptions Used in Assessment of CUNs for Preplant Soil Use of MB 

Comment CUN adjustment Exceptions

1. Dosage rates Maximum guideline rates for 

MB:Pic 98:2 are 25 to 35 g/m2 

with barrier films (VIF or 

equivalent); for mixtures of 

MB/Pic are 12.5 to 17.5 g 

MB/m2for pathogens and 

nutsedge respectively, under 

barrier films depending on the 

sector. All rates are on a ‘per 

treated hectare’ basis.

Amount adjusted to 

maximum guideline rates. 

Maximum rates set dependent 

on formulation and soil type 

and film availability. 

Higher rates accepted 

if specified under 

national legislation or 

where the Party had 

justified otherwise.

2. Barrier films All treatments to be carried out 

under low permeability barrier 

film (e.g. VIF, TIF)

Nomination reduced 

proportionately to conform to 

barrier film use. 

Where barrier film 

prohibited or restricted 

by legislative or 

regulatory reasons

3. MB/Pic 

Formulation: 

Pathogens 

control

Unless otherwise specified, 

MB/Pic 50:50 (or similar) was 

considered to be the standard 

effective formulation for 

pathogen control, as a 

transitional strategy to replace 

MB/Pic 98:2. 

Nominated amount adjusted 

for use with MB/Pic 50:50 (or 

similar).

Where MB/Pic 50:50 

is not registered, or Pic 

(Pic) is not registered

4. MB/Pic 

Formulation: 

Weeds/nutsedge 

ass control

Unless otherwise specified, 

MB/Pic 67:33 (or similar) was 

used as the standard effective 

formulation for control of 

resistant (tolerant) weeds, as a 

transitional strategy to replace 

Nominated amount adjusted 

for use with MB/Pic 67:33 (or 

similar).

Where Pic or Piccontaining mixtures 

are not registered
8 MBTOC 2013 CUNs: Final Recommendations - September2013

MB/Pic 98:2.

5. Strip vs. 

Broadacre

Fumigation with MB and 

mixtures to be carried out under 

strip 

Where rates were shown in 

broad acre hectares, the CUN 

was adjusted to the MB rate 

relative to strip treatment (i.e. 

treated area). If not specified, 

the area under strip treatment 

was considered to represent 

67% of the total area. 

Where strip 

treatment was not 

feasible e.g. 

some protected 

cultivation, 

emission 

regulations on 

MB, or open 

field production 

of high health 

propagative 

material 
MBTOC 2013 CUNs: Final Recommendations - September2013 9

Table 1-4: Final evaluation of CUNs for preplant soil use submitted in 2013 for 2015

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

2014 

CUN for 

2015

MBTOC final rec 

for 2015 

Australia Strawberry 

runners

35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.760 29.760 29.760 29.760 [28.765]

MBTOC Final Recommendation for 2015

MBTOC recommends a reduced CUE of 28.765 tonnes of methyl bromide for use in 2015, which is a 3.4% reduction (0.995 tonnes) from the amount nominated by the Party. 

According to the CUN, the foundation stock stage in the strawberry runner production chain has already transitioned to soil-less production. Trials and commercial adoption for this 

alternative have given good results for the past several years (HAL 2009, 2011). MBTOC finds however that an amount of 0.47 tonnes is allocated by the Party each year for soilless production although “The exemption amount allocated for the Victorian Strawberry Industry Certification Authority is unlikely to be used following the VSICA’s successful 

transition to soil-less substrate production in 2011” (http://www.environment.gov.au/atmosphere/ozone/publications/exemption-list.html). This is thus a contingency use, which 

cannot be recommended by MBTOC.

In addition, MBTOC considers that it is feasible to transition the mother plant stage (2.10 hectares, 1,000,000 plants as per Table 2, page 13 of the new information received) to 

soil-less production as well. This would reduce the nominated amount by a further 0.525 tonnes (2.10 ha x 250 Kg/ha=0.525 tonnes).

Nomination by the Party:

The quantity requested for this CUN to produce mother (2.10 ha) and certified plants (118 ha) is 29.760 tonnes, an amount that has essentially remained unchanged since 2009.

MBTOC reassessment for 2015 after the OEWG:

After the OEWG, the Party requested reassessment based on the time needed to transition to a non-chemical alternative (soil-less) and chemical alternatives (Pic Plus + herbicide, 

Pic Plus + MS , 1,3-D/Pic: 20/80).The Party reported that multiplication of strawberry runners consists of four consecutive generations (Nucleus, Foundation, Mother, and Certified 

stock). Currently the certification scheme specifies fumigation for mother and certified plants production with a 50:50 mix of MB/ chloropicrin applied at 500 kg/ha, a rate required to

meet certification standards. Soil-less production has also been approved under the certification scheme. Although the required MB rate exceeds MBTOC’s standard presumption 

of 20 g/m2, this lower rate is not registered. Additionally, a key alternative, 1,3-D:Pic, is considered ineffective due to phytotoxicity and doubling of plant back times in the heavy 

and wet soil conditions in the high elevation regions.

Recently, in the 2011/12 season, the Certification Authority commissioned the construction of screen house facilities for cost effective production of foundation stock in soil-less 

systems. According to the new information received from the Party, yields obtained for foundation stock grown with the soil-less system in 2011/12 averaged 150.8 runners per 

plant, and total production was 38,000 plants. By comparison, yields of foundation stock grown in soils treated with MB:Pic soils in 2010/11 averaged 212.9 runners per plant, and 

total production was 66,000 plants. MBTOC considers that it is difficult to compare across years and accepts that it may take time to adjust the soil-less system and determine 

ways to increase the number of plants to an equivalent number as in the open fields. . 

Results obtained in 2005 show that fruit yields of plug plants produced in soil-less culture were 25% lower than those of bare-rooted runners produced in MB-treated soils. Trials in 
10 MBTOC 2013 CUNs: Final Recommendations - September2013

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Queensland, also showed that plug plants yielded 40% less fruit than bare-rooted runners produced in MB:Pic treated soil (Menzel & Waite, 2006). 

MBTOC considers that the reported results are 8 years old and have sometimes been contradicted by various reports from other countries. 

Soil-less culture has been researched for production of some or all generations of strawberries in many A5 and Non A5 countries, and in a number of countries runners and plug 

plants are produced commercially, i.e. Japan (Yoshida, 2013), Belgium (Robbe, 1997, 1998; Lieten, 2013), The Netherlands (Lieten, 2013), Poland (Treder et al., 2007), New 

Zealand (Walter et al., 2005), USA (Durner et al., 2002) and A5 countries e.g. Brazil (Janisch et al., 2012, Oliveira et al., 2010,),Uruguay (Gimenez, 2008, ), Paraguay (Nacimiento 

and Lopez- Medina, 2009) and others (Palha et al., 2012; Roosta and Afsharipoor 2012 ).

MBTOC agrees with the Party that extrapolation of results obtained in other countries to runner production in Australia is difficult because of the differences in the physiology, the 

varieties and agronomic requirements for growing strawberry runners. However, trials with different types of substrates may help improve economic feasibility, allow for higher 

yields and better quality (i.e., through more efficient nutrition and irrigation, increased planting densities and other management practices). MBTOC has reviewed the references 

provided in the interim report and has included a further list which may help with lowering costs and technologies that lead to the development of more suitable systems

After the OEWG, the Party confirmed that research on MB alternatives is continuing and provided a research plan aimed at identifying the most promising chemical alternatives 

(Pic Plus + herbicide, Pic Plus + MS , 1,3-D/Pic: 20/80, soilless and others. In the past, research focused mainly on methyl iodide and on its anticipated registration, which is no 

longer being pursued by the manufacturer. This new research program is a new research plan, which is in accordance with Decision IX/6.

It is anticipated that the Party will make every effort to commercialise any new chemical or non chemical alternative as soon as possible in order to assist phase out of MB for

certified strawberries plants production (118ha).

Circumstances of the Nomination by the Party:

The Party states that the key pests affecting strawberry runner production are fungi (Phytophthora, Pythium, Rhizoctonia and Verticillium spp.) and weeds (S. arvensis, Agrostis 

tenuis, Raphanus spp., Poa annua, Cyperus spp). In its answers to MBTOC, the Party reported that the fruit industry expansion in Victoria is currently constrained by the amount 

of MB:Pic available for the production of ‘certified’ transplants and that runner production in soils treated with MB:Pic is mandatory for meeting certification standards. The 

Victorian runner industry only produces runners in soils treated with MB:Pic, and is not using any other methods (other than substrates for foundation stock production). Some 

chemical alternatives are not feasible e.g., methyl iodide. Plant resistance is unreliable as an alternative to MB:Pic for delivering certified runners (Fang et al 2012). 

MBTOC Comments on Economics 2013:

After the OEWG, the Party provided an economic analysis of strawberry runner production (mother stock and certified stock). The Party’s main concern is that the significant 

capital investment for greenhouses/screen houses would only address a small portion of the problem and would only result in the foundation stock production. The economic 

analysis is based on the yields, revenue, and costs for the production of mother and certified stocks, and states that prices increase from A$0.34 per runner to A$2.03 and A$2.00 

per runner, respectively, when using soil-less production systems. By comparison, soil-less systems are economically feasible for production of foundation stock plants, at a price 

of A$3.60 per runner in the 2011/2012 season. Soil-less culture has proven to be technically and economically feasible for production of some or all generations of strawberries in 

many Non A5 countries as described above. 
MBTOC 2013 CUNs: Final Recommendations - September2013 11

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Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission control: No, but standard films are claimed by the Party to perform the same as VIF in the cold temperatures and heavy wet soils typical 

for strawberry runner production.

 Dec. IX/6 b(iii) Research program: The strawberry industry has a 3-year research plan in place to identify alternatives to MB based on the development of 

integrated disinfestation systems: efficacy of Pic Plus ,T80 (1,3 D/Pic 20:80), spading machines for application of metham sodium in the runner industry, and 

improvement of soilless production technology. A research leader has been appointed to implement the research plan.

 Dec. IX/6 b(iii) Appropriate effort: Research effort is adequate.

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Canada Strawberry 

runners (PEI)

6.840 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.261 5.261 5.261 [5.050]

MBTOC Final Recommendation for 2015:

MBTOC maintains its interim recommendation and recommends a reduced CUE of 5.050 tonnes, a 4% reduction of the nominated amount. This assumes adoption of alternatives

for an amount of MB equivalent to production of 50% of the stock plants grown in foundation fields.

Nomination by the Party

The Party has nominated 5.261 t of MB, which was similar to the CUE granted for 2014. It is for use on (24.3 ha) of field grown runners and (2.0 ha) of stock plants. The 

nomination is based on a reduced rate of MB of 20 g/m2 under high barrier films for the entire fumigated area (26.3 ha). 

Circumstances of the Nomination by the Party:

The Party has attempted to replace MB with 1,3-D, but this product was banned for use in Prince Edward Island in January 2003 due to ground water contamination. Chloropicrin 

(PIC 100) has been registered by PMRA, but the PEI authorities have denied a permit for its use until further groundwater testing has been conducted. Ground water studies have 

been submitted to PMRA and are awaiting final reviews and a regulatory decision. Registration applications for MI, DMDS and EDN have not been submitted to date. The 

company has tested organic production from 2006 - 2009 with different varieties, but found that significant reductions in yield resulted, ranging from 40% to 70%. Only one variety 

using the organic production system compared favourably to conventional production. While MB:Pic 67:33 at 500 kg/ha is the only formulation registered for strawberry runners, 

which exceeds MBTOC’s standard presumption of 200 kg/ha, the grower petitioned PMRA to use a lower rate under barrier films. PMRA, in the absence of a formal label 

amendment, granted permission to use a lower rate, but at the grower’s own risk and liability. The CUN for 2015 is based entirely on a reduced rate for MB of 200 kg/ha for the 

entire critical area (26.3 ha).

After the OEWG, the Party submitted further information, which showed that a groundwater study has finally been approved to evaluate whether Pic can be used on PEI. The 

Party stated that ‘at this time greatest effort is being concentrated on this study as chloropicrin is currently considered the most feasible alternative for the grower. The Party is 

also seeking technical advice on soilless systems to reduce dependency on chemical fumigants, including an assessment of the technical and economic feasibility of soilless 

systems, and evaluating a range of potential growing techniques. The Party also provided a detailed description of the production system from micropropagated plants through to 

the sale of either bare rooted plants or runner tips which is achieved in 3 generations and not the usual 4 generations seen elsewhere in North America. The Party states that they 

believe that this avoids the need for a foundation stage, but this seems to be in contrast to the process described later in the attached Annex. 
12 MBTOC 2013 CUNs: Final Recommendations - September2013

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MBTOC reassessment for 2015 after the OEWG:

After reconsideration of the new information from the Party, MBTOC maintains its recommendation that alternatives are available for a proportion of the early generation 

production of strawberry runners and recommends a reduced amount of 5.050 t. MBTOC carefully considered the new information and appreciated the detailed documentation of 

the production system and the economic data provided. On review, MBTOC maintains its position that soilless culture is a suitable technical alternative for the early foundation 

and mother stock generations for strawberries, but does consider that costs will become prohibitive for latter generations. Also, MBTOC carefully reviewed the data provided on 

potential costs of soilless systems and whilst the costs for the method shown were higher than production using methyl bromide, the committee considered that lower cost 

systems exist and should be suitable for a small proportion of the production. MBTOC acknowledges that different soilless production systems (trough and tip vs substrate bins 

and bare rooted plants) require different capital costs and labour requirements, but more efficient systems are evolving rapidly. These systems are also considered to provide 

more sustainable and higher health production of runners. MBTOC is aware that the Party intends to initiate a review of alternative soilless systems and completely supports this 

initiative. MBTOC also urges the Party to consider moving to small scale soilless production facilities as soon as possible to ensure they are prepared for the potential scale up 

that may be required in 2015. MBTOC is also aware that not all the production may need to move to soilless culture, if Pic becomes available after positive outcomes from the 

groundwater studies. MBTOC is unclear on the current position with Pic Plus availability, but accepts the Parties statement that it is not currently available for use on PEI.

MBTOC has reviewed the references provided in the interim report and has included a further list which may help with lower costs technologies to assist development of suitable 

systems for PEI. These include those used successfully in many Non A5 countries, e.g Australia (HAL 2009, 2011), Belgium and Holland (Lieten et al., 2004a, 2004b, Lieten,

2013), Japan (Yoshida, 2013), New Zealand (Walter et al., 2005), USA (Durner et al., 2002). MBTOC has recommended no further reductions in view of the Party stating the 

‘objective of an action plan’ is that 2016 will be the final year for use of MB for this sector. MBTOC also notes that MB formulations containing Pic (67:33) are used in PEI under 

permit without groundwater contamination apparently occurring and suggests a similar situation should be possible for Pic alone, which is not currently permitted. 

MBTOC comments on economics in 2013 for 2015:

The Party’s main concern is that the significant capital investment for greenhouses/screen houses would only address a small portion of the problem and would only result in an 

8% reduction in the amount of methyl bromide used by the grower. Canada is of the view that the required high cost investment is not justifiable from an economic standpoint and 

rather than focusing on less than l0% of the problem resources could be better used elsewhere. The Party presented costs for a soilless trough and tip system, which was 

estimated to have costs per runner, which were 3 times higher (42.5 c per runner) than bare rooted runners (13.5 c per runner). MBTOC considers there are cheaper systems 

available, which are being used commercially worldwide.

Comments requested in Dec. XX1/11 (para 9)

Dec. IX/6 b(i) Emission reduction: Yes, uses barrier films with a reduced application rate of MB conforming to MBTOC’s presumptions

Dec. IX/6 b(iii) Research program: A research program is proposed based on groundwater studies for Pic, evaluation of soilless methods to improve feasibility and consideration 

of improvements in the production processes.

Dec. IX/6 b(iii) Appropriate effort: The Party has demonstrated now that it is engaged in an active research program and is implementing groundwater studies. The party has also 

engaged a consultant to assist full evaluation of potential alternatives to MB
MBTOC 2013 CUNs: Final Recommendations - September2013 13

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United 

States 

Strawberry 

(field)

2052.846 1730.828 1476.019 1349.575 1269.32 1007.477 812.709 678.004 461.186 415.067 373.660 [276.711]

MBTOC final recommendation for 2015:

MBTOC recommends a reduced amount of 276.711 tonnes for use in this sector for 2015. MBTOC acknowledges that the Party reduced the nomination by 10% from the amount 

approved for 2014, In its interim recommendation, MBTOC accepted that alternatives were now available for the whole nomination, and recommended a two year transition time to 

adopt alternatives to MB. During a bilateral at the OEWG and afterwards the Party provided information which requested more time to transition to suitable alternatives, especially 

chloropicrin which has in early 2013 had label changes which now allow higher dosage rates. After further review, MBTOC has accepted the Parties arguments and recommends 

a 3 year transition period rather than 2 years. MBTOC has based the transition from the MOP approved amount in 2014 as 415.067 tonnes (first year), recommends 276.711 

tonnes in 2015 (second year) and anticipates that only 138.360 tonnes will be requested in 2016 (3rd year).

MBTOC also acknowledges that the Party has provided further information after the OEWG which states that the Party intends to phase out MB for this sector by the end of 2016.

MBTOC considers that alternatives (1,3-D/Pic and chloropicrin under the new permitted rates of up to 392 kg/ha) with or without barrier films, not restricted by regulations, are 

available to replace MB for specific uses, including Macrophomina sp. and Fusarium spp. in particular counties. This situation should also allow for greater use of 1.3-D/Pic 

formulations on a greater area where township caps are binding. MBTOC also considers that the alternatives suggested to replace MB for this nomination are similar to those 

already in commercial practice in California, however there are a number of regulatory issues that impact transition and therefore a three year period of transition period may be 

required. If the Party determines that chloropicrin and its mixtures can be implemented faster than the specified 3 year transition period from 2014 onwards, then it is anticipated 

that the Party will reduce the amount of MB further under its own domestic allocation rules. 

Nomination by the Party:

The Party nominated 373.660 t for 2,198 ha at a dosage rate of 170 kg/ha for use in 2015. The proportion of total crop area to be treated with MB was noted by the Party as 

13.5%. The CUN amount represented a 10% transition in 2015 from the exempted amount in 2014. 

Circumstances of the Nomination by the Party:

The CUN requests MB specifically for areas: 1) where Macrophomina and Fusarium have not been acceptably controlled with alternative fumigant methods, 2) where a transition 

period is necessary to implement use of straight chloropicrin, and 3) where township caps adversely impact the use of 1,3-D as an alternative. There was no further breakdown of 

the rationale for each provided by the Party for the reduction in 2015, nor an action plan for total phase-out of MB.

At the bilateral with MBTOC, the US advised that they are planning further work to test the efficacy of metam-sodium on Macrophomina under California conditions. The Party 

also plans to gather data on the efficacy of the high rate of chloropicrin under TIF and its ability to control diseases caused by Macrophomina, Fusarium and Verticillium in 

commercial field applications over time on California strawberries and will apprise MBTOC of its findings.
14 MBTOC 2013 CUNs: Final Recommendations - September2013

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MBTOC reassessment for 2015 after the OEWG:

MBTOC maintains that shank applied 1,3-D/Pic as well as other similar Pic mixtures, Pic alone or Pic in sequential application with MITC generators (KPam, Vapam, dazomet)

coupled with disease tolerant varieties of strawberries would be suitable to address a significant proportion of one or more of the 3 issues raised by the Party as a reason for the 

nomination (Medina-Minguez 2012, Noling and Cody 2011, Porter et al., 2006, Zveibel et al., 2012,). MBTOC also notes that formulations with chloropicrin are the key chemical 

alternative effectively adopted in other regions of the world. MBTOC notes that the technical expertise required for application of 100% chloropicrin already exists in California and 

uptake of this method should be feasible relatively quickly. As the nomination is for 2015, there is an additional period to gain further experience with these high rates of 

chloropicrin to accommodate both technical and regulatory issues, such as worker and bystander safety and effective pest control. Average annual use of chloropicrin for the last 

five years in California strawberry industry is of 1,786 t which accounts for 70% of the use of this product in the State (Cal DPR, 2012). There has been an increased use of 

chloropicrin alone and in formulations with 1,3-D in California. Their use has almost tripled between 2006 and 2010 (Cal DPR, 2012) whilst its use in formulations with MB has 

been declining.

Macrophomina phaseolina is a widespread fungus all over the world in many crops. MBTOC recognizes Macrophomina has increased in importance as a pathogen of strawberry 

crops in the last decade. Recent studies show effective alternatives to MB to control this pathogen in some countries. In Florida, Noling & Cody (2012) showed that 1,3D; 

DMDS+Pic; Vapam and KPam are as effective as MB for season-long protection of this pathogen. Zveibil et al., in Israel (2012) also reported that metam sodium was as effective 

as MB. TeloDrip has given inconsistent results, which confirm the Parties’ concerns with drip fumigation (Zveibel et al., 2012). A number of cultivars are also considered to provide 

options for tolerance to this disease (Fang et al., 2012; Daugovish et al., 2011). MBTOC reiterates its 2010, 2011 and 2012 suggestion that shank injection of 1,3-D/Pic by strip or 

broadcast application would result in improved disease control compared to drip applications (Noling and Cody 2012, Medina-Minquez 2012, Zveibil et al., 2012). Also in previous 

assessments it has been suggested that alternatives (1,3-D/Pic and Pic alone with or without barrier films), if not restricted by regulations, were considered available to replace MB 

for specific uses, including Macrophomina and Fusarium in specific counties. 

MBTOC recognizes the potential benefit of the establishment of a new committee (Strawberry Non Fumigant Workgroup) to evaluate and adopt further chemical and non-chemical 

technologies such as anaerobic soil disinfestation, soilless substrate systems and steam (CalDPR, 2013). 

MBTOC also notes that as of December 1, 2012, a new set of label changes went into effect for soil fumigant products, fully implementing important new protection for workers 

and bystanders. In light of these changes, the State of California now allows the use of VIF films for MB fumigation, which was formerly prohibited (Cal DPR, 2012b & c; EPA, 

2013). MBTOC is at this time unclear on the impact this change could have in terms of potential reduction of MB dose rates as well as emission control. Studies continue to show 

the advantages of barrier films and other technologies for reducing emissions and improving efficacy of alternatives as well as MB (Qin et al., 2013; Chellemi et al., 2013; Luo et 

al., 2013) and anticipate the party will fully address this issue in any future nominations. 

MBTOC comments on economics in 2013 for 2015:

A recent peer reviewed study (Mayfield and Norman, 2012) highlights the strong growth in output in the California strawberry industry since 2004. This publication also questions 

the accuracy of the economic data (and varying yields) in CUNs and how this makes analysis of the economic information difficult. 

The present CUN states that “The economic analyses...indicate fumigant-treated soils can result in gains or losses to net revenues that range from -37% (with drip Pic-Clor60) to 

9% (with 100% broadcast chloropicrin), based on the cost of the individual fumigant and estimated yield loss”. 
MBTOC 2013 CUNs: Final Recommendations - September2013 15

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The information provided in the CUN excludes fixed costs from the calculation of changes in net revenue because "... fixed costs are considered to be identical for all alternative 

scenarios ..." but by convention when fixed costs can be allocated fully to a specific activity they should be included in a partial budget. Because this has not been done, steam 

appears to be an economically feasible alternative.

Comments Requested in Dec. XX1/11 (para 9):

Dec. IX/6 b(i) Emission reduction: In California low permeability (high barrier) films are not allowed for use with MB, but are allowed and available for use with alternatives, 

this regulation is presently under review.

Dec. IX/6 b(ii) Research program: Yes, there is an on going research program, but specific data justifying CUN requests need to be provided.

Dec. IX/6 b(iii) Appropriate efforts: California has extensive research programs being conducted and continual regulatory reviews on the use of MB and other fumigant 

alternatives in the State. MBTOC is unaware from the CUN application what efforts are being made to register some alternatives registered and being used in other areas of 

the USA (eg. Pic-Clor 60 and 80, DMDS in combination with Pic).

1

1ExMOP and 16MOP; 216MOP+2ExMOP+17MOP; 3MOP17+MOP18; 4MOP18+MOP19; 5MOP19+MOP20; 6MOP20+MOP21; 7MOP21+MOP22; 8MOP22, 9MOP23, 

10MOP24

d 16MOP; 216MOP+2ExMOP216MOP+2ExMOP+17MOP; 3MOP17+MOP18; 4MOP18+MOP19; 5MOP19+MOP20; 6MOP20+MOP21; 7MOP21+MOP22; 8MOP22, 9MOP23
16 MBTOC 2013 CUNs: Final Recommendations - September2013

1.5 Final evaluation of CUNs: Structures and Commodities and Report on 

Emergency Use by Canada of MB for Pasta Warehouses

MBTOC, Structures and Commodities (SC), Soils and QPS, met initially together in London, United 

Kingdom April 3-5, 2013 to develop interim recommendations.

Those recommendations were included in the May 2013 TEAP Report and presented to the OEWG 

meeting in June in Bangkok. Although MBTOC met bilaterally with Parties in Bangkok, no Party 

requested re-reviews of the postharvest CUNs. Consequently the interim CUN recommendations 

became final recommendations as indicated here. 

In 2012 there were five CUNs submitted by three Parties. By contrast, in 2013 there were two 

postharvest CUNs submitted by Parties. In 2013, the US submitted two postharvest CUNs for 2015; 

one CUN was for dry cure pork and for CUN was for fresh dates (formerly included in the dried fruit 

CUN). 

Between 2012 and 2013, applicants from three Parties: Australia, Canada and the US, were able to 

complete their planned adoption of alternatives. Accordingly, Australia did not submit a CUN for rice 

processing, Canada did not submit a CUN for flour milling and the US did not submit a CUN for flour 

milling and also several dried fruit sectors. Completing the adoption of these former methyl bromide 

applications was no doubt difficult and required effort of the industry and government; MBTOC was 

happy to hear of these successes.

For more information on the process used to determine the recommendations and other work 

conducted by MBTOC, Parties are referred to the May 2013 TEAP report for those details. 

Figure 1-2: Amounts of MB nominated and exempted for CUE uses in Dates and cured pork from 

2005 to 2015. Blue lines indicate the trend in of CUN nominated and the red lines the 

amount CUE methyl bromide approved by the Parties

 

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

CUN 89.2 87.8 91.3 67.7 5 9 19.2 1 0 4.9 0.8 0.7 0.31

CUE 89.2 87.7 7 9 5 9 45.6 19.2 5 2.4 0.8 0.7 0

0

2 0

4 0

6 0

8 0

100

Methyl Bromide (Tons) 

USA dried fruits and nuts 
MBTOC 2013 CUNs: Final Recommendations - September2013 17

 

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

CUN 136.3 135.7 40.8 19.7 19.7 4.5 3.7 3.7 3.7 3.7 3.24

CUE 67.9 81.7 18.9 19.7 1 9 4.5 3.7 0 3.7 3.7 3.24

0

2 0

4 0

6 0

8 0

100

120

140

160

Axis Title

Smoke houses - hams 

1.5.1 MBTOC Report on Canada’s Emergency Use of Methyl Bromide to Fumigate 

Pasta Warehousing

1.5.1.1 Executive Summary: 

In August, MBTOC was informed that Canada used methyl bromide (MB) to fumigate two pasta 

warehouses in response to the finding of Sitophilus oryzae (rice weevil) in pasta packages and in the 

warehouse following three fumigations with a phosphine combination process. The pests were later 

determined to be phosphine resistant. Multiple documents were submitted using the format for 

Critical Use Nominations accompanied by test results and other supporting documents. 

Canada has an Emergency Use provision in domestic regulation. Permits to import and use methyl 

bromide under the emergency use provision are issued under the Ozone-depleting Substances 

Regulations, 1998 (Environment Canada).

The finding of phosphine resistant pests is both scientifically significant and of concern vis-à-vis the 

ability of Parties to use alternatives to MB. For example, MBTOC members noted that there were no 

previous published reports of phosphine resistant pests in Canada. Therefore, following the circulation 

of Canada’s documents, several MBTOC members had questions about the situation and the use of 

MB in this circumstance. 

MBTOC was unsure if it could send questions to the Party about this situation. Accordingly, we wrote 

Mr. Marco Gonzalez (Ozone Secretariat Executive Secretary) who responded that we were allowed to 

ask questions. Mr. Gonzalez also asked MBTOC, through TEAP, to prepare a report examining the 

Emergency Use focused on analyzing the cause of this use and recommending methods (if possible) 

to avoid similar situations and uses of MB in the future. 

Emergency MB use is allowed under the Montreal Protocol. The Emergency Exemption for ODSs,

other than MB, require consultation with TEAP prior to use and approval of the Ozone Secretariat, 

whereas the Emergency Exemption for MB specified retrospective review by MBTOC.

In his response to MBTOC, Mr. Gonzalez cited Decision IX/7 concerning emergency uses by Parties, 

"To allow a Party, upon notification to the Secretariat, to use, in response to an emergency event, 

consumption of quantities not exceeding 20 tonnes of methyl bromide. The Secretariat and the 

Technology and Economic Assessment Panel will evaluate the use according to the “critical methyl 

bromide use” criteria and present this information to the next meeting of the Parties for review and 

appropriate guidance on future such emergencies, including whether or not the figure of 20 tonnes is 

appropriate."
18 MBTOC 2013 CUNs: Final Recommendations - September2013

This is a consensus report of MBTOC.

1.5.1.2 Summary of Information Received from the Party

The basis for this summary of the Party’s viewpoint is the CUN form, test reports, climate reports, 

and correspondence from the Party.

a. Fumigation and Pest Aspects:

Canada allowed the emergency use of 6,171 kg for the fumigation of two warehouses which held 

packaged pasta products. The pasta warehouses were owned by a Canadian pasta manufacturer 

located in the Province of Ontario, which had formerly submitted critical use nominations (MBTOC 

does not release company names).

One large pasta warehouse (166,750 m3), was directly connected to the pasta processing facility and 

from there pasta packages were moved to the other, smaller, nearby warehouses (21,904 m3). These 

warehouses had previously been fumigated with methyl bromide under critical use exemptions. 

The Party reported the gas tightness of these warehouses to be ‘poor’. MBTOC, in its Critical Use 

Nomination forms, which were also used by Canada for this Emergency Use notification, defines 

‘poor gas tightness’ as “poor – 50-90% gas loss within 24 hours or half loss time of pressure 

difference 1-10 second”. The Party later supplemented this information by saying, “Every effort is 

made prior to fumigation to ensure that the warehouse is adequately sealed to prevent gas loss and to 

maximize the effects of the methyl bromide fumigation. External ambient air monitoring reports 

showed 0 ppm of methyl bromide over the course of the fumigation, indicated sufficient sealing to 

ensure a successful and efficient fumigation.” The gas tightness efforts were described as, “At all 

facilities, the doors, windows and vents in the structures are sealed with heavy duty 6mm tarp during a 

chemical fumigation to ensure that a suitable gas concentration can be maintained over the time 

period required for control of insects and rodents. “ 

Canadian regulation allows the fumigation of empty food processing premises with sulfuryl fluoride, 

however there is no food tolerance for sulfuryl fluoride in Canadian regulation. As a result, food 

products cannot be fumigated with sulfuryl fluoride in Canada. 

Following the loss of the ability to use MB, both these warehouses were four times fumigated with a 

combination process that relied on Eco2Fume® (cylinderized phosphine), CO2 and heat. The 

concentration of Eco2Fume® used in 2010 was 300 ppm, which caused extensive damage by 

corroding machinery and equipment. In 2011, the concentration of Eco2Fume used was 200 ppm. 

While this later concentration did not eliminate the corrosion damages completely, the damages were 

limited. 

To limit corrosion risk in the facilities, at seen with Eco2Fume® fumigations in 2010 and 2011, the 

last two fumigations with the aforementioned combination were conducted a low dosage rates of 

phosphine. During the July 2012 fumigation phosphine dosage rates ranged between 60 to 90 ppm, 

with an average of 71.5 ppm over the course of the 24 hour fumigation. The concentration of CO2

during that same time was in excess of 6% while interior temperatures were on average 24°C. During 

the September 2012 fumigation phosphine dosage rates ranged between 70 to 172 ppm, with an 

average of 121 ppm over the four days from September 14 to 17. The concentration of CO2 during 

that same time was approximately 6% while interior temperatures were on average 24.3°C. (Although 

adverse weather events can impact fumigation efficacy, the Party reported that no unusual weather 

events were reported during the fumigations. During the July 2012 fumigation, exterior temperatures 

averaged 21°C while during the September 2012 fumigation, the average exterior temperature was 

16°C. Therefore the temperatures reported in the warehouses were likely a result of supplemental heat 

applied by the fumigator company.) 
MBTOC 2013 CUNs: Final Recommendations - September2013 19

Noting that the July 2012 fumigation was ineffective in killing the pests, Canada reported on the 

applicant’s measures to conduct a more effective fumigation in September 2012. The information 

provided shows that the phosphine treatment exposure period was increased from 24 hours during the 

July 2012 fumigation to over 72 hours for the September 2012. Additionally, average phosphine 

levels were increased from 71.5 ppm during the July 2012 fumigation to 121 ppm during the 

September 2012 fumigation. 

Unfortunately, pests survived the second fumigation resulting in concerns about possible pest 

resistance to phosphine treatment. Canada notes that phosphine resistant pests have never before been 

reported in Canada. 

Following the finding of surviving pests after the second fumigation, the applicant company sent 

infested pasta packages to a US fumigation company with sufficient scientific resources and 

experience to test for insect resistance. The test protocol of the UN Food and Agriculture 

Organization (FAO) for insect resistance was used (although there were slightly fewer test insects 

than needed to fully satisfy the protocol). The test method and reports confirming the resistance to 

these Sitophilus oryzae survivors to phosphine were sent to MBTOC. The American company noted 

this was the first instance in their experience of this species being resistant to phosphine. 

The Party reported the applicant has plans intended to prevent another request for an emergency use 

of methyl bromide in the future. The applicant company has implemented a new partnership pest 

control program with a different licensed pest control company. The program includes additional time 

spent in the facilities (16 hours/week) using integrated pest management (IPM) tools such as 

additional visual inspections of facilities and packed product, locating and removing infested 

products. (MBTOC stresses the importance of a stringent IPM program and also notes that 16 

hours/week may not be sufficient. Full-time staff in the facility should be trained to more carefully 

clean and monitor pests and take action early.) Any infested products will be fumigated off site. The 

pest control program also includes the use of pheromone traps, residual and ULV treatments. 

(Although the Party noted that there is no commercially available pheromone traps for Sitophilus 

oryzae.) 

When fumigations with Eco2Fume® are resumed in 2014, the company will ensure that temperatures 

are at least in mid-20 oC and the gas concentration is between 200 to 250 PPM, with an exposure time 

of 48 hours. To limit any corrosion from any future use of phosphine based products, sensitive 

equipment (such as computers, telephones, forklifts, light fixtures) will be removed or protected by 

tarps.

b. Economics Aspects: Costs of fumigation and pest contamination 

The concentration of Eco2Fume® used in 2010 was 300 ppm, which caused extensive damage by 

corroding machinery and equipment. Cost of the corrosion damage following the 2011 Eco2Fume® 

fumigation was approximately $25,000. 

Following the 2010 fumigation, a combination process of Eco2Fume®, CO2 and Heat treatment in 

combination was done twice, BUT, the phosphine concentration was reduced. These two fumigations 

failed to kill the pests present. The cost of the two fumigations was reported as: 

Cost of two fumigations: $114,200 

Disposed product costs: $117,845

Trailer rental costs $58,496

Temporary labour costs: $108,264 (used to sort product to prevent from shipping infested 

pasta)

Total: $398,805
20 MBTOC 2013 CUNs: Final Recommendations - September2013

The pasta company noted concerns about its reputation if infested products were circulated in the 

marketplace. 

The cost of the methyl bromide fumigation was reported as approximately $100,000. 

1.5.1.3 Comments by MBTOC 

a. About the fumigation methods

Sub-lethal fumigations occur when one or more of the necessary fumigation treatment parameters are 

insufficient; achieving the necessary concentration of the fumigant, for the necessary time is key to a 

successful treatment (defined as one that kills all life stages of the stored product pests in question). 

These treatment parameters can be manipulated somewhat by changing environmental conditions 

such as increased temperature, which increases pest respiration and usually hastens death. 

Identifying the correct treatment parameters involves first a knowledge of which pests are of concern, 

since their sensitivity to fumigants and environmental conditions varies. There are numerous papers 

available showing that pest species vary in their response to phosphine; Hole et al, 1976 discusses 

phosphine sensitivity to a wide variety of stored product pests. Additionally, Parties are encouraged to 

review MBTOC’s previous Progress, CUN and Assessment reports.

Repeated sub-lethal fumigation treatments can lead to pest survivors. This is due to the survival 

during such treatments of resistant insects already present in populations, a process often termed 

selection. Non-resistant insects, however, will probably be killed. The offspring of surviving insects 

will also be resistant and the proportion of resistant insects in populations will be likely to increase 

with subsequent sub-lethal treatments. As a result the fumigant can become ineffective in controlling 

damaging insect. 

Two early, but valuable, papers on phosphine resistance are Monro et al, 1972 and Nakakita 1987. 

The biological mode of action of phosphine resistance has been shown to be lack of uptake of 

phosphine by resistant pests as described by Price, 1984 and Reichmuth, 1990. 

With the loss of methyl bromide to the pest control arsenal, it is absolutely critical that the use of 

alternative treatments be conducted properly, because the world cannot afford to lose more useful 

fumigants.

The phosphine, CO2 and heat combination treatment method not well documented in scientific or 

industry literature, beyond that of a treatment in a Canadian cereal mill in the 1990’s. The process has 

been used commercially in some mills in Canada but little has been written about it. Essentially, the 

method involves protecting electronic equipment (which can be damaged by exposure to phosphine) 

with plastic bubbles filled with CO2. The early Canadian report noted that CO2 was added to the mill 

as a combination treatment and not just to protect equipment. MBTOC is unclear how the CO2 was 

used in the warehouses in this current situation. 

MBTOC notes that there is not clarity in the research literature that CO2 will allow the use of lower 

dosages of phosphine. Valizadegan et al (2012) noted that CO2 was effective in allowing lower 

dosages of phosphine (although this research team did not test Sitophilus oryzae) – but the dosages 

and temperatures used in Canada were lower.. 

Cylinderized phosphine is used to speed up the spread of the gas and supplemental heat is used to 

hasten the insect response to the gas. It is difficult to balance the need for a phosphine concentration 

high enough to kill pests with a concentration low enough not to cause extensive damage to elements 

of the mill or warehouse. 
MBTOC 2013 CUNs: Final Recommendations - September2013 21

Nevertheless, without sufficient phosphine concentration and time the pests will not be killed and 

repeated fumigations at higher concentrations and time will also not kill them. (Noting also the factor 

that there are usually regulatory limits on the concentrations of fumigants that can be used.) 

Reichmuth, (1994) reported on differences of incorporation of phosphine by

susceptible and resistant insects. 

In response to the first treatment, where pest kill was good (300 pppm), damage to warehouse 

electronics was reported. In the next fumigation the phosphine dosage was 200ppm, which should be 

considered a minimum dose (see comments on Eco2Fume® label below). Pest control was achieved 

but some damage was reported. Then, without apparent critical thinking of the pest control impact, the 

phosphine dosage was significantly decreased, to the point where it was not an effective fumigation

(60 – 90 ppm). A second fumigation at a higher but still insufficient dosage (70 – 172 ppm) and 

longer time also did not kill the pests. 

The Eco2Fume® application manual (label) for Canada gives the following table: (Cytek Canada)

DOSAGE GUIDE

Recommended Dosages For ECO2FUME® Fumigant Gas Phosphine

Temperature Concentration Maintained Duration

Below 0o C (32 oF) Do not fumigate Do not fumigate

0-4o C (32-39o F) 200 - 1000 ppm 6-14 days

5-12oC (40-53o F) 200 - 1000 ppm 4-10 days

12-15oC (54-59o F) 200 - 1000 ppm 3-5 days

16o C (60o F)-above 200 - 1000 ppm 2-3 days

MBTOC notes that neither of the 2012 fumigations reached the critically needed concentration of 

phosphine (200 ppm) for the required length of time (longer than 48 hr) as prescribed by the 

Eco2Fume® label. Temperature should also have been higher (above 25 ̊C, especially since the 

dosage and duration used is at the low end of the range). 

MBTOC notes that temperature should be measured in the product when it is product (rather than 

facility) which is infested. The Party has only reported one temperature reading and that is insufficient 

to measure temperature. This becomes particularly important given that the September 2012 

fumigation environmental temperature was lower (16 ̊C), therefore with a facility of poor gastightness 

there is potential for cool spots in the facility, which can further decrease fumigant efficacy. 

It is no surprise that 48h fumigations of pasta facilities with low doses of phosphine fail to fully 

control pest beetles and weevils, particularly if naturally tolerant species/developmental stages are 

present (e.g., Sitophilus oryzae). 

Following the September 2012 fumigation, the applicant company again noted the persistence of pests 

in pasta packages. Concerned that they could not find all the infested packages by visual inspection, 

knowing that if infested pasta was to enter the market place that company reputation would be 

harmed, and apparently not wanting to destroy all the pasta in the warehouse, applied for an 

emergency use of methyl bromide for the warehouses and the pasta contained therein, via Canada’s 

domestic regulatory provisions for such use.

b. About the potential to destroy infested packages instead of fumigation

MBTOC is unaware of the extent of the infestation in these warehouses. These were large warehouses 

(one was very large); we acknowledge it is difficult, and sometimes impossible to locate infestation in 

a large warehouse. Therefore we do not know if it would have been possible, or not, to locate the 

infestation and destroy infested packages instead of conducting a fumigation. Generally speaking we 
22 MBTOC 2013 CUNs: Final Recommendations - September2013

are not in favour of unnecessary food wasting but in the instance of a localized infestation, 

destruction, instead of fumigation should be considered. (In fact since food laws of most countries do 

not allow the sale of infested materials, whether pests are dead or alive, the destruction of infested 

packages is the norm.) We note that dead insects in food packages in quantities visible to consumers 

can cause just about as much consumer consternation as live insects. Therefore fumigation might not 

resolve the concern about consumer complaints. 

Since the Party later reported that before the fumigated product was shipped, visual inspection of 

packages was conducted (followed by destruction of packages that appeared to have been infested). 

Therefore MBTOC wonders if another resolution of this problem might have been to conduct visual 

inspection before fumigation, then destroy infested or questionable packages, move non-infested 

items to a non-infested warehouse and fumigate the empty warehouse with sulfuryl fluoride as is

allowed in Canadian regulations. 

MBTOC asks whether visual inspection might have been a possibility in this instance of infestation by 

Sitophilus oryzae (as opposed to, for example, infestation by moths or some other pests) because 

Sitophilus is not quite as mobile and not as good at penetrating packages as some other pests 

(although Sitophilus is capable of drilling through packaging materials). 

Sitophilus contamination usually occurs pre-packaging. Although the Party noted that the origin of the 

infestation was not found, the applicant company did fumigate the empty pasta processing facility 

with sulfuryl fluoride during the time that the warehouses were fumigated with methyl bromide. 

MBTOC hopes this will have resolved the problem of the origin of the infestation. 

c. About the use of methyl bromide in facilities of poor gastightness

MBTOC is on record over several years of not accepting the use of MB in facilities noted to be of 

poor gastightness as defined by leak tests (“poor – 50-90% gas loss within 24 hours or half loss time 

of pressure difference 1-10 second”). In fact a facility with poor gastightness should not be considered 

to be a candidate for any fumigation; the fumigant leaks out, concentrations dip below necessary 

values, it is difficult to reliably determine fumigant concentrations, more gas must be added 

contributing to excessive costs etc. 

Methods of improving gastightness of facilities prior to fumigation have been well described by many 

authors and are well known to the pest control industry. Reichmuth (1990a), described methods of 

testing gas tightness by pressure testing and impacts on fumigation costs. 

MBTOC asks whether it would have been possible in the circumstances of these warehouses to 

manage the fumigation of infested packaged material by shrouding the infested material with leakproof tarps using methods to result in good gastightness under the tarp and then only fumigate the 

infested material and not the entire (and in this case quite large) warehouse. However this method 

would only have been possible if the infestation was both localized and located, and MBTOC does not 

know if this was the case. 

d. About the method used to determine pest resistance

The applicant company sent infested pasta packages to an American company known to have the 

scientific resources and experience necessary to conduct pest resistance testing. 

This testing company’s full report has been sent to MBTOC by Canada. We note that although the 

accepted FAO method to determine pest resistance was altered by virtue of having less pests available 

(only 50 pests) and somewhat less time (5 days instead of 14 days). There are reports indicating that 

Sitophilus mortality can be seen 10 – 14 days after phosphine treatment, therefore with Sitophilus it is 

even more important to hold the test pests long enough to properly judge mortality (Quereshi et al, 

1965; Nakakita et al, 1974)
MBTOC 2013 CUNs: Final Recommendations - September2013 23

In spite of these deficiencies, MBTOC accepts the test company’s assertion that the Sitophilus oryzae

resulting from the insufficient fumigations in Canada were likely to be resistant to phosphine. This is 

the first reported incidence of phosphine pest resistance in Canada and the first instance that this 

experienced testing company has observed of pest resistance of this species. 

In future, if the FAO method is to be used, MBTOC recommends it be followed as prescribed because 

then there is more certainty in the result. The reason that the correct use of resistance test protocols is 

needed is that in the past failed fumigations with phosphine have been claimed to be due to insect 

resistance when this has been in doubt and may have been the result of poor quality treatments, or 

fumigant leakage or other problems in fumigation technique.

The FAO test method while useful and precise, is tedious and time consuming. It produces 

reproducible and quantitative results, giving a quantitative measure of resistance level under the test 

conditions (20h exposure, adult insects). It has two major drawbacks in practice - it requires breeding 

up of a population of insects for testing (6 weeks or more) and it requires controlled laboratory 

conditions to carry out the testing, with a degree of training and experience in the method. It is 

therefore often not often used with the result of possible spread of resistant pests to other regions. 

MBTOC members report that other, faster and easier test methods are also available and could be 

used if this situation were to arise in other regions (Reichmuth, 1991b). Use of faster resistance tests 

allows on-site adjustments to fumigation parameters which can then result in effective fumigation and 

elimination of resistant pests (Mills, 2000) 

As a substitute, the semi-quantitative quick test, as described by Savvidou et al (1994) and Bell et al

(1994), can be carried out on site or in a minimally equipped laboratory. It is easy to do with minimal 

training. It used insects as collected, without requiring breeding up of test populations. As modified so 

that observations are taken at various times over 24 hours, it produces assessments of resistance levels 

quickly. The results are obvious to site operators if carried out on site.

Nayak et al (2012) provide a version of the quick test that discriminates between various levels of 

resistance. This is important as it allows setting of dosages for effective control of the tested strains. 

The rapid test permits rapid screening of a large number of samples. It forms an important part of 

current phosphine resistance screening in Australia. Populations found to contain resistant insects can 

be assessed later by the slower FAO method if desired.

e. About the costs to conduct repeated fumigations

As with many other things, the cost of doing things right the first time is less expensive in the long 

run. 

f. Recommendations

Avoid pest infestation, spread and the need for fumigation through the use of a stringent IPM program 

managed by experienced and capable pest control operators. A stringent IPM program with its 

enhanced emphasis on sanitation, monitoring, identification, and treatments intended to minimize pest 

harborage, multiplication and spread is the first and best line of defense against pests. A stringent IMP 

program is both a necessary and effective pre-requisite to any full site treatment. 

Avoid the development of pest resistance by correct (labelled) use of fumigation concentration and 

time, based on a knowledgeable assessment of the pests present and only fumigate facilities or 

structures of ‘good’ gastightness. 

Methyl bromide should not be used in facilities of ‘poor’ gastightness.

If pest resistance is thought to be possible, use quicker tests which can then allow for a more targeted 

and more effective follow-up fumigation.
24 MBTOC 2013 CUNs: Final Recommendations - September2013

Parties may find previous MBTOC Progress, CUN and Assessment Reports to be useful references 

when faced with pest control problems.

1.5.2. Details of Postharvest CUN evaluations

Parties have submitted two CUNs for the use of MB in structures and commodities in 2013. This year 

all CUNs were for one year – 2015.

The total MB volume nominated in 2013 for non-QPS post-harvest uses, was 3.550 tonnes. Of the 

nominations in 2013 for 2015, MBTOC recommended 3.240 tonnes (Table 1-5 and 1-6). Table 9-11 

provides the MBTOC-SC final recommendations for the CUNs submitted.

Table 1-5: Summary of the final recommendations by MBTOC SC (in square brackets) for 

CUE’s for postharvest uses of MB (tonnes) for 2015 submitted in the 2013 round. 

Country and Sector Nominated in 2013 (tonnes) Recommended for 2015 

(tonnes)

United States – cured pork 3.240 [3.240]

United States – fresh dates 0.310 [0]

Total 3.550 [3.240]
MBTOC 2013 CUNs: Final Recommendations - September2013 25

Table 1-6: Final evaluations of CUNs for structures and commodities submitted in 2013 for2015

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410

CUN for 

2015

MBTOC

rec. for 2015

United 

States

Commodities

(Dates only)

89.166 87.719 78.983 58.921 45.623 19.242 5.000 2.419 0.822 0.740 0.310 [NR]

MBTOC Final Recommendation for 2015:

MBTOC does not recommend the use of methyl bromide for fresh dates in the United States in 2015. 

Nomination by the Party:

The Party nominated 0.310 tonnes of methyl bromide for fresh dates in 2015. The nomination represented a 58.1% reduction in the former US Commodities CUN of which 

dates was an element in previous years. In 2012, as part of the Commodities CUN, the Party nominated 0.325 tonnes for dates, and therefore the 2013 CUN for dates 

represents a 4.6% reduction in the amount nominated for dates compared to 2012. 

Circumstances of the Nomination:

This nomination is for the portion of fresh dates for which quick shipment (defined as either three or 3-5 days in the CUN and subsequent correspondence) to the fresh 

market segment. The Party notes that phosphine and sulfuryl fluoride are the primary fumigants for dates, although sulfuryl fluoride has not been found to be effective at 

killing the eggs of pests at temperatures at or below 26.6 ̊C (80°F) which often occurs in Riverside County of California, their main date production area. 

The Party noted that fumigation with phosphine takes approximately 3-5 days, whereas MB fumigation is less than 24 hrs. As a result, when market demands fast 

turnaround immediately before shipping, methyl bromide treatment, typically a 20h exposure, is still required, according to the Party.

The Party noted that, currently, methyl bromide is the only treatment available to rapidly disinfest California dates at harvest time, when up to a million pounds per day are 

harvested within a relatively tight timeframe during the fall. These dates are harvested by hand, and growers need to get them to the marketplace in three, or 3-5 days, to 

meet the demand of a market segment for fresh dates. 

MBTOC Interim Assessment in 2103 for 2015:

MBTOC was unable to recommend this nomination because there are technically effective, commercially available alternatives and because the need for a three-day 

market window for the approximate 25% of the total harvest volume nominated was not substantiated by the Party. MBTOC was unable to determine a justification, 

technical, economic, market, regulatory or otherwise for the necessity of marketing within three days, as compared for example, to marketing within five days. 

In past, MBTOC’s text boxes have reported its concern about the length of time the sector is taking to make the logistical changes to enable the use of phosphine or other 

alternatives. MBTOC’s text boxes for the past few years have indicated a need for the date and dried fruit sector to hasten the expansion of its phosphine fumigation 

capacity. 
26 MBTOC 2013 CUNs: Final Recommendations - September2013

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410

CUN for 

2015

MBTOC

rec. for 2015

The California date sector conducts phosphine fumigation in chambers and also conducts fumigation in crates under tarps in the field -- for which it seems there is more 

than adequate capacity for expansion. By harvest 2015, MBTOC considers there is time to make logistical changes to expand phosphine treatment facilities which would 

allow for a staged release of sufficient product to meet a market demand for freshly harvested dates. 

For example, the use of phosphine generators or cylinderized phosphine (as opposed to solid forms of phosphine) would, for the warmer harvest months of August to 

October, result in three days or shorter phosphine treatment being effective. Using the example of other commodity marketing, the strongest consumer demand for fresh 

fruit often occurs in the beginning of the new harvest period. For dates the harvest period begins mid-August, a time of high temperatures in the California date producing 

region. This means that in the early harvest months the high ambient temperatures will assist to ensure an adequate phosphine treatment within three days. 

In California, date harvest continues until mid-December. In the colder months, phosphine treatment without supplemental heat would require four to five days, but if the 

chamber or bag stack was to be heated to > 25 ̊C, the treatment time would be closer to three days. (Readers can refer to table below pertaining to the time, temperature 

and concentration parameters as recommended by the manufacturer for treatment of dried fruit by cylinderized phosphine, although MBTOC would recommend longer 

exposures).

Changing the current methyl bromide treatments to phosphine treatments would interrupt logistics of market once, and only for a couple of days because as new 

commodity is harvested frequently (or daily), and treatment by phosphine would be staged frequently (or daily), it stands to reason that each day would see the completion 

of fumigation and the newly treated dates would be then available to meet the market demand for fresh dates. 

Phosphine has been commercially adopted to control pests of dried fruit. It has been widely adopted in all dried fruit producing countries. As temperature is an important 

parameter, this work done in Turkey is helpful. According to Tutuncu et al, 2012, phosphine applications at a concentration of 200 ppm at 15oC gave a complete mortality 

in all life stages of C. hemipterus in 36 h of exposure. Results also showed that complete mortality time of eggs, larvae, pupae and adult stages of C. hemipterus was found 

to be 36 h, 12 h, 24 h, and 16 h, respectively. Complete mortality times of 1- and 2-day-old eggs were 36 h and 20 h, respectively. For 1-, 2- and 3-day-old pupae, total 

mortalities were obtained after 24 h, 16 h, and 14 h of exposure, respectively.
MBTOC 2013 CUNs: Final Recommendations - September2013 27

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410

CUN for 

2015

MBTOC

rec. for 2015

MBTOC also notes that the efficacy of heat treatment is both well-known and commercially established in other countries (Navarro et al, 2006.) Compared to phosphine, 

heat treatment has the added benefit of actually removing the larvae from the fruit because they exit the fruit to escape. The eggs of insects are highly susceptible to heat 

treatment, dying within a few minutes. Unlike chemical treatments, heat is consistent with organic certification regulations in most countries and often organically certified 

product obtains a higher price in the marketplace. Heat treatment also allows the treatment and sale of dates while the dates are still attached to small branches; this is a 

very good-looking fresh product well appreciated by consumers of fresh dates in other countries. 

There is, however, a need for the California date sector to resolve practical adoption issues for heat treatment. As noted by Finkleman et al, (2010) in Israel, heat treatment 

with Deglet-Noor (one of the two date varieties included in the US CUN), was not successful because the large crates (200 – 400kg) did not allow for fast enough heat 

transfer. MBTOC notes that the same crate size is used in the United States.

However, as it is clear that heat treatment disinfests dates; it is worth the effort to overcome practicalities by using smaller crates or by using an in-line processing system 

and doing the needed food quality assessments. As this CUN pertains to MB use in 2015, and having studied the adoption of heat treatment in Israel, MBTOC believes that 

the logistical and practical issues could be resolved by 2015. 

MBTOC Comments on Economics 2012:

Dates: The CUN is largely, but not entirely, based on technical, rather than economic arguments. The Party reports only on the economic comparison of sulfuryl fluoride 

versus methyl bromide. Sulfuryl fluoride costs less than methyl bromide. The Party did not report on the comparison of methyl bromide versus phosphine. MBTOC believes 

that phosphine costs considerably less than methyl bromide. 

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission control: Fumigations are conducted in chambers or under tarps of sufficient gas tightness.

 Dec. IX/6 b(iii) Research program: Research on dates has been focussed and ongoing. A combination treatment of SF, carbon dioxide and propylene oxide 

continues to be researched as preliminary results were positive for dried fruits, but the registration approval scenario for this combination treatment indicates it 

would only be a longer term proposition. 

 Dec. IX/6 b(iii) Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol nominations has 

control over pesticide registration.
28 MBTOC 2013 CUNs: Final Recommendations - September2013

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410

CUN for 

2015

MBTOC

rec. for 2015

United 

States

Cured pork 67.907 40.854 18.998 19.669 18.998 4.465 3.73 3.730 3.730 3.730 3.240 [3.240]

MBTOC Final Recommendation for 2015: 

MBTOC recommends 3.240 tonnes, the amount nominated by the Party for use in US dry cure pork in 2015. 

Nomination by the Party: 

The Party nominated 3.240 tonnes, a reduction of 13.1% from the amount granted by the Parties for this use in 2014. This reduction has been achieved by improvements 

in methyl bromide fumigation efficacy.

Circumstances of the Nomination:

Currently there are no commercially effective alternatives to methyl bromide for Southern dry cure pork, a regional, traditional product. The pests of this product are the redlegged ham beetle (Necrobia rufipes) and the ham mite (Tyrophagus putrescentiae). The US dry cure pork research program has identified the incidence of pests in dry 

cure pork facilities; 50-60% of plants have reported infestations of the red-legged beetle. The incidence of mites is approximately 60-70 %. (Shilling, in USG response to 

MBTOC Mar 30, 2010). 

Of methods already considered and rejected, heat would alter the product unacceptably, and the only effective dosage of sulfuryl fluoride was three times the legal limit of 

use before mite eggs were controlled (and therefore not registered). (Phillips, et al., 2008). 

There is an ongoing multi-university, multi-state research program which is focused on improving meat processing sanitation, IPM and pest control through a variety of 

possible fumigants. So, for example, the Party reports processors are now trying to steam clean, use approved disinfectants with acaricidal properties, or both, to sanitize 

their facilities when the hams are not present and before new hams are introduced. 

In addition, prior to the phase-out of methyl bromide this industry tended to fumigate on a monthly basis. Plus processors brought in new hams into aging houses that also 

contained contaminated hams. This is no longer the case. Processors keep new hams away from the older hams and many have subdivided their aging house space to 

accomplish this. Southern cured pork processors only fumigate when the pests, or signs of the pests, are present. 

MBTOC Interim Assessment in 2013 for 2015:

The US has a robust research program which has investigated, and reported to MBTOC, the progress and results of its investigation of every possible mite-control method 

suggested by MBTOC in its previous text boxes. More research to find an effective treatment (or combination of treatments), followed by commercial trials need to be 

conducted before any treatment can be considered an alternative to methyl bromide for treatment of ham mites.

Research is still ongoing with phosphine. The Party released and discussed results of commercial scale trials conducted in winter 2013. Unfortunately, these phosphine 

tests did not show adequate efficacy against mites. Additionally, problems were experienced such as significant damage to electronic elements of the facility. Further 

learning would be needed to determine if phosphine treatment parameters could be achieved which might improve efficacy and while avoid facility damage. MBTOC notes 

that problems in achieving efficacy in phosphine at commercial scale might be overcome by increasing temperature. 
MBTOC 2013 CUNs: Final Recommendations - September2013 29

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410

CUN for 

2015

MBTOC

rec. for 2015

Additionally, the Party has noted that it intends to work on temperature-related control of mites for example, using both heat and cold as control measures. 

In the face of continued lack of success with what had been considered to be possible alternatives, and after considering the review of the Party’s ongoing research, 

MBTOC’s experts suggest a focus on the following aspects. While these steps might not eliminate the pests, it might take longer before hams are infested. These and other 

IPM steps might allow an increase in the time period between fumigation of the ham storage facilities. To this end, MBTOC agrees with the research being currently 

conducted by the Party to develop and test methods to quantify if and to what extent sanitation and pest control methods work to reduce mite infestation.

1. A continued focus on protecting the ham from mite infestation during the aging process. The Party’s research on dips such as with propylene glycol, hot lard (90°C; 

with curative and preventive effects), and other substances seems to offer a promising method to prevent infestation of these pests. This kind of protection may 

also lead to improvement of the final quality of the ham by avoiding excess drying. 

Another protective measure is a physical barrier against mites. The suggestion is a fine mesh gauze that is wrapped around the ham pieces (Lehms et al, 2012). Data is 

available on the effectiveness of the size of the mesh to prevent invasion of all stages of Tyrophagus putrescentiae (<30 μm). Following MBTOC’s release of this 

information in its 2012 text box, the Party has already begun testing and resolving practical aspects of implementing this method in the aging process.

2. Encourage measures which reduce pest pressure. Assess if improvements in environmental manipulation would decrease mite population and reduce reinfestation. For example, continue to make improvements outside of the facility to remove pest harborages, and also establish methods to prevent the entrance of 

mites into the facility by employees and other vectors. It might be possible that doorway shoe sanitization and ensuring employees change from street clothes to 

sanitized uniforms in the plant might reduce mite invasion.

Improvements in the building might be necessary to reduce the ability of mites to survive treatment and then re-infest the facility. For example, changes which make the 

walls and floors easier to clean might decrease the resident mite population. Cement floors and metal storage racks can be more effectively cleaned by power 

washing with steam and bleach. 

3. Continue to improve gastightness in facilities before fumigation. With improved gastightness, air circulation and temperature can be increased during the fumigation 

which will improve the effectiveness of the MB at the dosage of 20g/m3. 

4. Continue to gather up-to-date information on the use of MB in this sector, by, for example, updating its 2008 survey on frequency of fumigation as it relates to length 

of ham storage. MBTOC notes that the 2012 survey of facilities was quite useful. Also continue to improve understanding of actual use of MB by facility as this 

might help benchmark the actions of some better performing facilities to assist the ham sector as a whole.

MBTOC Comments on Economics 2012:

The CUN is not based on economics.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission control: Over the years the applicants have made facility improvements to improve gastighness, but this is a traditional meat curing 

process and some of the facilities are older and unusual. The research program continues to work with the applicants to improve gastightness, IPM and other 

process improvements which reduce the need for fumigation and result in decreased use of MB. This work needs to continue. Producers have modified their 

buildings both to make them more gas-tight and to exclude pests. 
30 MBTOC 2013 CUNs: Final Recommendations - September2013

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410

CUN for 

2015

MBTOC

rec. for 2015

 Dec. IX/6 b(iii) Research program: Excellent research effort to date and still ongoing. A multi-state, multi-university research program is ongoing and full reports of 

research have been made available to MBTOC. 

 Dec. IX/6 b(iii) Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol nominations has 

control over pesticide registration. Phosphine is registered for use on processed meats such as cured pork but it has not been shown to be effective against mites.

1

1ExMOP and 16MOP; 216MOP+2ExMOP+17MOP; 3MOP17+MOP18; 4MOP18+MOP19; 5MOP19+MOP20; 6MOP20+MOP21; 7MOP21+MOP22; 8MOP22, 

9MOP23
MBTOC 2013 CUNs: Final Recommendations - September2013 31

1.6. Activity Report 2013 and Workplan for 2014

1.6.1. Activity report for 2013 

 Initial summarisation of the 2013 CUNs (initial sorting and recording carried out by the 

Secretariat).

 Preparation of questions for Parties. Assessment of responses received from Parties. 

 First MBTOC meeting of MBTOC (in full) 3-5 April 2013 for assessment of CUNs (soils 

and SC). Further, the QPS sub-committee addressed Decision XXIII/5 and the full 

committee worked on updating the Handbook for Critical Use Nominations. Bilateral 

meetings were held by MBTOC-S and MBTOC-SC with the USA. 

 Interim recommendations were agreed. The committee prepared the CUN Interim Report 

and the 2013 Progress Report (including QPS) for consideration by the 32nd OEWG.

 Version 7.1 of the ‘Handbook for Critical Use Nominations” was updated to include 

observations made by the Parties at the 24th MOP. 

 MBTOC-QPS prepared their report in response to Decision XXIII/5, which was included 

as part of the TEAP 2013 Progress Report

 At the 33rd OEWG (Bangkok, 24- 28 June, 2013). Bilateral meetings with USA, the 

California Strawberry Commission (USA), Australia and Canada were held. 

 No second meeting was held in the year. MBTOC-S conducted its re-assessment by an 

agreed email process. MBTOC –SC prepared an analysis based on the emergency use of 

MB reported by Canada per the request of the Ozone Secretariat.

 MBTOC-S and MBTOC-SC prepared the final report on the CUNs for consideration by 

the Parties at their 24th Meeting.

 Three MBTOC members resigned; MBTOC thanked Antonio Bello, Andrea Minuto and 

Janny Vos for their work. 

1.6.2. Work plan and indicative budget for 2013

The following “Actions” and “Indicative Completion Dates” are the “Working procedures of MBTOC 

relating to the evaluation of nominations for critical uses of methyl bromide”, as described in Annex 1 

of the 16th Meeting of the Parties. The annual work plan is required to be drawn up by MBTOC 

(supported by the Ozone Secretariat) in consultation with TEAP, which shall submit it to the Meeting 

of the Parties each year.

Tasks and actions Indicative budget 

needs where 

applicable

Indicative 

completion date

Dates of 

meetings

1. Parties submit their nominations for critical-use exemptions to 

the Secretariat*

- 24 January 2014

2. The nominations are forwarded to MBTOC co-chairs for 

distribution to the subgroups of appointed members

- 7 February 2014

3. Nominations in full are assessed by the subgroups of 

appointed members. The initial findings of the subgroups, and any 

requests for additional information are forwarded to the MBTOC 

co-chairs for clearance

- 28 February 2014

4. MBTOC co-chairs forward the cleared advice on initial 

findings and may request additional information on to the 

nominating Party concerned and consult with the Party on the 

possible presumption therein

- 21 February 2014

5. Nominating Party develops and submits its response to the 

MBTOC co-chairs

- 7 March 2014
32 May 2011 TEAP Report on 2011 CUNs: Interim Report

Tasks and actions Indicative budget 

needs where 

applicable

Indicative 

completion date

Dates of 

meetings

6. MBTOC Meeting No 1 

 Meets as usual to assess nominations, including any additional 

information provided by the nominating Party prior to the 

MBTOC meeting under action 5 and any additional 

information provided by nominating Party through prearranged teleconference, or through meetings with national 

experts, in accordance with paragraph 3.4 of the terms of 

reference of TEAP (see Annex I of MOP16, Dec XVI/4) 

 Bilateral meetings

 To discuss and finalise the CUN evaluation process proposed 

by the co-chairs and commented by the MBTOC members

 To discussed any new or standard presumptions that MBTOC 

seeks to apply in its future assessment of critical-use 

nominations, for approval by the Meeting of the Parties

 Any administrative changes to improve the operations of the 

Committee, within the scope of Decisions that have been 

agreed by the Parties

 Draft the 2012 Progress Report

Funds for travel of 

1non-A5 member: 

US$3,000**

Meeting Costs 

$3,000

March – April 

2014

South Africa 

(tentative)

8. MBTOC provides its draft recommendations on the CUNs to 

TEAP

April, 2014

9- TEAP Meeting: To assess the MBTOC report on critical-use 

nominations and submits the finalised interim report on 

recommendations and findings to the Secretariat.

April 2014 TBD***

10. The Secretariat posts the finalised report on its web site and 

circulates it to the Parties

- May 2014

11. OEWG Bilateral Discussions: Nominating Party has the 

opportunity to consult with MBTOC on a bilateral basis in 

conjunction with the Open-ended Working Group meetings

June - August 

2014 (TBD)

TBD

12. The nominating Party submits further clarification for the 

critical-use nomination requested by MBTOC or if requested to do 

so by the Open-ended Working Group, and provides additional 

information should it wish to appeal against a critical-use 

nomination recommendation by MBTOC/TEAP

-

Depending on 

OEWG date

13. MBTOC Meeting No 2 or agreed email process (according to 

feasibility and justification of a second meeting):

 Meets to reassess only those critical-use nominations in the 

“unable to assess” category, those where additional 

information has been submitted by the nominating Party and 

any critical-use nominations for which additional information 

has been requested by the Open-ended Working Group (see 

Annex I of MOP16, Dec XVI/4)

 finalise the report, including notice of any proposed new 

standard presumptions to be applied by MBTOC

 conduct any bilateral consultations requested by Parties

 draft work plan and budget for MBTOC for 2013

Funds for travel of 

1 non-A5 

member**: 

US$3,000

Meeting costs: $US 

3,000

September-October 

2014

TBD

14. MBTOC drafts final report considered by TEAP, finalised and 

made available to Parties through the Secretariat

- Sept - October

2014 depending on 

MOP dates

15. 25th Meeting of the Parties November 2014

Total budget: US $: 12,000*

US$ 6,000 (Travel 

of Non Article 5 

member)

Meeting Costs 

$6,000 

* CUNs from A5 Parties could be submitted

** Travel funds for non A5 members have been requested in the past but not granted

*** TBD – To be determined
MBTOC 2013 CUNs: Final Recommendations - September2013 33

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1-8.

Wijayaratne, L.K.W., Fields, P.G., Arthur, F.H., (2011). Effect of methoprene on the progeny production of 

Tribolium castaneum (Coleoptera: Tenebrionidae). Pest Management Science 68:217–224
36 May 2011 TEAP Report on 2011 CUNs: Interim Report

Yoshida, Y. (2013); Strawberry Production in Japan: History and Progress in Production Technology and Cultivar 

Development; International Journal of Fruit Science; Volume 13, Issue 1-2, January 2013, Pages 103-

113.

Zveibil, A., Mor, N., Gnayem, N., (2012) Survival, Host–Pathogen Interaction, and Management of Macrophomina 

phaseolina on Strawberry in Israel. Plant Disease 96, pp. 265- 272
MBTOC 2013 CUNs: Final Recommendations - September2013 37

Annex I: Decision IX/6

1. To apply the following criteria and procedure in assessing a critical methyl bromide use for 

the purposes of control measures in Article 2 of the Protocol:

(a) That a use of methyl bromide should qualify as “critical” only if the nominating Party 

determines that:

(i) The specific use is critical because the lack of availability of methyl bromide for that 

use would result in a significant market disruption; and

(ii) There are no technically and economically feasible alternatives or substitutes 

available to the user that are acceptable from the standpoint of environment and 

health and are suitable to the crops and circumstances of the nomination;

(b) That production and consumption, if any, of methyl bromide for critical uses should be 

permitted only if:

(i) All technically and economically feasible steps have been taken to minimise the 

critical use and any associated emission of methyl bromide;

(ii) Methyl bromide is not available in sufficient quantity and quality from existing stocks 

of banked or recycled methyl bromide, also bearing in mind the developing countries’ 

need for methyl bromide;

(iii) It is demonstrated that an appropriate effort is being made to evaluate, 

commercialise and secure national regulatory approval of alternatives and 

substitutes, taking into consideration the circumstances of the particular nomination 

and the special needs of Article 5 Parties, including lack of financial and expert 

resources, institutional capacity, and information. Non-Article 5 Parties must 

demonstrate that research programmes are in place to develop and deploy 

alternatives and substitutes. Article 5 Parties must demonstrate that feasible 

alternatives shall be adopted as soon as they are confirmed as suitable to the Party’s 

specific conditions and/or that they have applied to the Multilateral Fund or other 

sources for assistance in identifying, evaluating, adapting and demonstrating such 

options;

2. To request the Technology and Economic Assessment Panel to review nominations and make 

recommendations based on the criteria established in paragraphs 1 (a) (ii) and 1 (b) of the present 

decision;

3. That the present decision will apply to Parties operating under Article 5 and Parties not so 

operating only after the phase-out date applicable to those Parties.

Para. 2 of Decision IX/6 does not assign TEAP the responsibility for determining the existence of 

“significant market disruption” specified in paragraph 1(a)(i).

TEAP assigned its Methyl Bromide Technical Options Committee (MBTOC) to determine whether 

there are no technically and economically feasible alternatives or substitutes available to the user that 

are acceptable from the standpoint of environment and health and are suitable to the crops and 

circumstances of the nomination, and to address the criteria listed in Decision IX/6 1(b).
38 May 2011 TEAP Report on 2011 CUNs: Interim Report

Annex II - Part A: Trend in MB Preplant Soil Nominations and Exemptions

List of nominated (2005 – 2015) and exempted (2005 – 2014) amounts of MB granted by Parties under the CUE process for each crop. 

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Australia Cut Flowers –

field 40.000 22.350 18.375 22.350

Australia Cut flowers –

protected 20.000 10.425

Australia

Cut flowers, 

bulbs – protected 

Vic

7.000 7.000 6.170 6.150 7.000 7.000 3.598 3.500

Australia Strawberry Fruit 90.000 67.000

Australia Strawberry 

runners

35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.790 29.760 29.760 29.760 35.750 37.500 35.750 35.750 29.790 29.790 23.840+ 

5.95 29.760 29.760 29.760

Belgium Asparagus 0.630 0.225 0.630 0.225

Belgium Chicory 0.600 0.180 0.180 0.180

Belgium Chrysanthemums 1.800 0.720 1.120

Belgium Cucumber 0.610 0.545 0.610 0.545

Belgium Cut flowers –

other 6.110 1.956 4.000 1.956

Belgium Cut flowers –

roses

1.640

Belgium Endive (sep from 

lettuce) 1.650 1.650

Belgium Leek & onion 

seeds 1.220 0.155 0.660
MBTOC 2013 CUNs: Final Recommendations - September2013 39

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Belgium Lettuce(& 

endive) 42.250 22.425 25.190

Belgium Nursery

Not 

Predictabl

e

0.384 0.900 0.384

Belgium Orchard pome & 

berry 1.350 0.621 1.350 0.621

Belgium Ornamental 

plants 5.660 0.000

Belgium Pepper & egg 

plant 5.270 1.350 3.000 1.350

Belgium Strawberry 

runners

3.400 0.900 3.400 0.900

Belgium Tomato 

(protected) 17.170 4.500 5.700 4.500

Belgium Tree nursery 0.230 0.155 0.230 0.155

Canada Strawberry 

runners (PEI) 14.792 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.596 5.261 5.261 (a)14.792 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.261 5.261

Canada Strawberry runners (Quebec) 1.826 1.826 (a) 1.826 1.826

Canada Strawberry runners (Ontario) 6.129 6.129

France Carrots 10.000 8.000 5.000 8.000 8.000 1.400

France Cucumber 85 revised 

to 60 60.000 15.000 60.000 60.000 12.500

France Cut-flowers 75.000 60.250 12.000 60.000 52.000 9.600

France Forest tree 

nursery

10.000 10.000 1.500 10.000 10.000 1.500

France Melon 10.000 10.000 7.500 6.000
40 May 2011 TEAP Report on 2011 CUNs: Interim Report

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

France

Nursery: 

orchard, 

raspberry

5.000 5.000 2.000 5.000 5.000 2.000

France Orchard replant 25.000 25.000 7.500 25.000 25.000 7.000

France Pepper

Incl 

in.tomato 

cun

27.500 6.000 27.500 6.000

France Strawberry fruit 90.000 86.000 34.000 90.000 86.000

France Strawberry 

runners

40.000 4.000 35.000 40.000 40.000 28.000

France

Tomato (and 

eggplant for 

2005 only)

150(all 

solanaceo

us)

60.500 33.250 125.000 48.400

France Eggplant 27.500 33.250 48.400

Greece Cucurbits 30.000 19.200 30.000 19.200

Greece Cut flowers 14.000 6.000 14.000 6.000

Greece Tomatoes 180.000 73.600 156.000 73.600

Israel Broomrape 250.000 250.000 125.000 12.500 12.500 250.000 250.000 125.000 12.500

Israel Cucumber - protected new 2007 25.000 18.750 18.750 12.500 25.000 18.750 - 15.937

Israel Cut flowers –

open field 77.000 67.000 80.755 53.345 42.777 42.554 23.292 77.000 67.000 74.540 44.750 34.698 28.554

Israel Cut flowers –

protected 303.000 303.000 321.330 163.400 113.821 72.266 52.955 303.000 240.000 220.185 114.450 85.431 63.464

Israel Fruit tree 

nurseries 50.000 45.000 10.000 50.000 45.000 7.500
MBTOC 2013 CUNs: Final Recommendations - September2013 41

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Israel Melon –

protected & field 148.000 142.000 140.000 87.500 87.500 87.500 35.000 125.650 99.400 105.000 87.500 87.500 70.000

Israel Potato 239.000 231.000 137.500 93.750 75.000 239.000 165.000 137.500 93.750 75.000

Israel Seed production 56.000 50.000 22.400 56.000 28.000 NR

Israel Strawberries –

fruit (Sharon) 196.000 196.000 176.200 64.125 52.250 47.500 28.500 196.000 196.000 93.000 105.960 42.750

Israel

Strawberries –

fruit (Sharon & 

Ghaza)

57.063

Israel Strawberry 

runners (Sharon) 35.000 35.000 20.000 15.800 13.570 13.500 35.000 35.000 28.000 31.900 15.825

Israel

Strawberry 

runners and fruit 

Ghaza

87.875 67.500 67.500 34.000 47.250

Israel

Strawberry 

runners (Sharon 

& Ghaza)

22.320

Israel Tomatoes 90.000 22.750

Israel Sweet potato 95.000 20.000 20.000 111.500 95.000 20.000

Italy Cut flowers 

(protected) 250.000 250.000 30.000 250.000 187.000 30.000

Italy Eggplant 

(protected) 280.000 200.000 15.000 194.000 156.000

Italy Melon 

(protected) 180.000 135.000 10.000 131.000 131.000 10.000
42 May 2011 TEAP Report on 2011 CUNs: Interim Report

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Italy Pepper 

(protected) 220.000 160.000 67.000 160.000 130.000 67.000

Italy Strawberry Fruit 

(Protected) 510.000 400.000 35.000 407.000 320.000

Italy Strawberry 

Runners 100.000 120.000 35.000 120.000 120.000 35.000

Italy Tomato 

(protected) 1300.000 1030.00 418.000 871.000 697.000 80.000

Japan Cucumber 88.300 88.800 72.400 68.600 61.400 34.100 29.120 26.162 88.300 88.800 72.400 51.450 34.300 30.690 27.621

Japan Ginger – field 119.400 119.400 112.200 112.100 102.200 53.400 47.450 42.235 119.400 119.400 109.701 84.075 63.056 53.400 47.450

Japan Ginger –

protected 22.900 22.900 14.800 14.800 12.900 8.300 7.770 6.558 22.900 22.900 14.471 11.100 8.325 8.300 7.036

Japan Melon 194.100 203.900 182.200 182.200 168.000 90.800 77.600 67.936 194.100 203.900 182.200 136.650 91.100 81.720 73.548

Japan Peppers (green 

and hot) 189.900 200.700 169.400 162.300 134.400 81.100 68.260 61.101 187.200 200.700 156.700 121.725 81.149 72.990 65.691

Japan Watermelon 126.300 96.200 94.200 43.300 23.700 15.400 13.870 12.075 129.000 98.900 94.200 32.475 21.650 14.500 13.050

Malta Cucumber 0.096 0.127

Malta Eggplant 0.128 0.170

Malta Strawberry 0.160 0.212

Malta Tomatoes 0.475 0.594

New 

Zealand Nursery material 1.085 1.085 0

New 

Zealand Strawberry fruit 42.000 42.000 24.78 42.000 34.000 12.000
MBTOC 2013 CUNs: Final Recommendations - September2013 43

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

New 

Zealand

Strawberry 

runners

10.000 10.000 5.720 8.000 8.000 6.234

Poland Strawberry 

Runners 40.000 40.000 25.000 12.000 40.000 40.000 24.500

Portugal Cut flowers 130.000 8.750 50.000 8.750

Spain Cut Flowers –

Cadiz 53.000 53.000 35.000 53.000 42.000

Spain Cut Flowers –

Catalonia 20.000 18.600 12.840

17

20.000

15.000 43.490

(+Andaluci

a)

(+Andalu

cia)

Spain Pepper 200.000 155.000 45.000 200.000 155.000 45.000

Spain Strawberry Fruit 556.000 499.290 80.000 556.000 499.290 0.0796

Spain Strawberry 

Runners 230.000 230.000 230.000 215.000 230.000 230.000 230.000

UK Cut flowers 7.560 6.050

UK Ornamental tree 

nursery

12.000 6.000 6.000 6.000

UK

Strawberry (& 

raspberry in 

2005)

80.000 63.600 68.000 54.500

UK Raspberry 

nursery

4.400 4.400 54.500

USA Chrys. 

Cuttings/roses 29.412 29.412 0

USA Cucurbits – field 1187.8 747.839 598.927 588.949 411.757 340.405 218.032 59.500 11.899 1187.800 747.839 592.891 486.757 407.091 302.974 195.698 59.500
44 May 2011 TEAP Report on 2011 CUNs: Interim Report

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

USA Eggplant – field 76.761 101.245 96.48 79.546 62.789 34.732 21.561 6.904 1.381 76.721 82.167 85.363 66.018 48.691 32.820 19.725 6.904

USA Forest nursery 

seedlings 192.515 157.694 152.629 133.140 125.758 120.853 106.043 192.515 157.694 122.032 131.208 122.060 117.826 93.547

USA Ginger 9.2 9.2 0

USA Orchard replant 706.176 827.994 405.415 405.666 314.007 226.021 203.591 18.324 6.230 706.176 527.600 405.400 393.720 292.756 215.800 183.232 18.324

USA Ornamentals 210.949 162.817 149.965 138.538 137.776 95.204 70.178 48.164 48.164 154.000 148.483 137.835 138.538 107.136 84.617 64.307 48.164

USA

Nursery stock -

fruit trees, 

raspberries, roses

45.789 64.528 12.684 51.102 27.663 17.954 7.955 1.591 0.541 45.800 64.528 28.275 51.102 25.326 17.363 7.955 1.591

USA Peppers – field 1094.782 1498.53 1151.751 919.006 783.821 463.282 212.775 28.366 1094.782 1243.542 1106.753 756.339 548.984 463.282 206.234

USA Strawberry fruit 

– field 2468.873 1918.40 1733.901 1604.669 1336.754 1103.422 1023.471 753.974 531.737 415.067 373.660 2052.846 1730.828 1476.019 1349.575

1269.321 1007.477 812.709 678.004 415.067 415.067

USA Strawberry 

runners

54.988 56.291 4.483 8.838 8.837 7.381 7.381 3.752 3.752 54.988 56.291 4.483 8.838 7.944 4.690 + 

2.018

6.036 3.752

USA Tomato – field 2876.046 2844.985 2334.047 1840.1 1406.484 994.582 336.191 54.423 10.741 737.584 2476.365 2065.246 1406.48

4

1003.876 737.584 292.751 54.423

USA Turfgrass 352.194 131.600 78.040 52.189 0 131.600 78.04 0

USA Sweet potato 224.528 18.144 18.144 18.144 14.515 8.709 18.144 18.144 14.515 11.612

USA Research 2.768 2.768
MBTOC 2013 CUNs: Final Recommendations - September2013 45

Annex III - Part B: Trends in MB Structural and Commodity Nominations and Exemptions

List of nominated (2005- 2015) and exempted (2005 - 2014) amounts of MB granted by Parties under the CUE process for each commodity. 

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Australia Almonds 1.900 2.100 1.900 2.100

Australia Rice 

consumer 

packs

12.300 12.300 10.225 9.200 9.2 7.82 5.66 3.653 2.374 1.187 1.187 6.150 6.150 9.205 9.200 7.820 6.650 4.870 3.653 1.187 1.187

+1.8

Belgium Artefacts and 

structures

0.600 0.307 0.590 0.307

Belgium Antique 

structure & 

furniture

0.750 0.199 0.319 0.199

Belgium Churches, 

monuments 

and ships' 

quarters

0.150 0.059 0.150 0.059

Belgium Electronic 

equipment

0.100 0.035 0.100 0.035

Belgium Empty silo 0.050 0.043 0.050 0.043

Belgium Flour mill see 

mills below

0.125 0.072 See mills 

below

0.072

Belgium Flour mills 10.000 4.170 9.515 4.170

Belgium Mills 0.200 0.200 0.200 0.200

Belgium Food 

processing 

facilities

0.300 0.300 0.300 0.300
46 May 2011 TEAP Report on 2011 CUNs: Interim Report

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Belgium Food 

Processing 

premises

0.030 0.030 0.030 0.030

Belgium Food storage 

(dry) structure

0.120 0.120 0.120 0

Belgium Old buildings 7.000 0 .306 1.150 0.306

Belgium Old buildings 

and objects

0.450 0.282 0 0.282

Belgium Woodworking 

premises

0.300 0.101 0.300 0.101

Canada Flour mills 47.200 34.774 30.167 28.650 26.913 22.878 14.107 11.020 7.848 5.044 5.044 (a)47 34.774 30.167 28.65 26.913 22.878 14.107 11.020 5.044 5.044

Canada Pasta 

manufacturing 

facilities

(a) 10.457 6.757 6.067 4.740 4.740 2.084 (a) 10.457 6.757 6.067 4.740 3.529

Canada Commodities 0.068

France Seeds sold by 

PLAN-SPG 

company

0.135 0.135 0.100 0.135 0.135 0.096

France Mills 55.000 40.000 8.000 40.000 35.000 8.000

France Rice 

consumer 

packs

2.000 2.000 2.000 2.000

France Chestnuts 2.000 2.000 1.800 2.000 2.000 1.800

Germany Artefacts 0.250 0.100 0.250 0.100
MBTOC 2013 CUNs: Final Recommendations - September2013 47

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Germany Mills and 

Processors 

45.000 19.350 45.000 19.350

Greece Dried fruit 4.280 3.081 0.900 4.280 3.081 0.450

Greece Mills and 

Processors 

23.000 16.000 1.340 23.000 15.445 1.340

Greece Rice and legumes 2.355 2.355

Ireland Mills 0.888 0.611 0.888

Israel Artefacts 0.650 0.650 0.600 0.650 0.6500

Israel Dates (post 

harvest)

3.444 3.444 2.200 1.800 2.100 3.444 2.755 2.200 1.800 2.100 1.040

Israel Flour mills 

(machinery & 

storage)

2.140 1.490 1.490 0.800 0.300 2.140 1.490 1.040 0.312 0.300

Israel Furniture–

imported

1.4220 1.4220 2.0420 1.4220 0

Italy Artefacts 5.500 5.500 5.000 5.225 0 5.000

Italy Mills and 

Processors

160.000 130.000 25.000 160.000 65.000 25.000

Japan Chestnuts 7.100 6.500 6.500 6.300 5.800 5.400 5.350 3.489 3.317 7.100 6.800 6.500 6.300 5.800 5.400 5.350 3.489

Latvia Grains 2.502 2.502

Netherlands Strawberry runners post 

harvest

0.120 0.120 0.120 0 0.120

Poland Medicinal 

herbs & dried 

mushrooms as 

dry 

commodities

4.000 3.560 1.800 0.500 4.100 3.560 1.800 1.800
48 May 2011 TEAP Report on 2011 CUNs: Interim Report

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Poland Coffee, cocoa 

beans

(a) 2.160 2.000 0.500 2.160 1.420 1.420

Spain Rice 50.000 42.065

Switzerland Mills & 

Processors

8.700 7.000 8.700 7.000

UK Aircraft 0.165 0.165

UK Mills and 

Processors

47.130 10.195 4.509 47.130 10.195 4.509

UK Cereal processing plants 8.131 3.480 (a) 8.131

UK Cheese stores 1.640 1.248 1.248 1.640 1.248 1.248

UK Dried 

commodities 

(rice, fruits 

and nuts) 

Whitworths

 2.400 1.256 2.400 1.256

UK Herbs and 

spices

0.035 0.037 0.030 0.035 0.037

UK Mills and 

Processors 

(biscuits) 

2.525 1.787 0.479 2.525 1.787

UK Spices 

structural 

equip.

1.728 1.728 0 0.479

UK Spices stored 0.030 0.030 0

UK Structures 

buildings 

(herbs and 

spices)

3.000 1.872 0.908 3.000 1.872 0.908
MBTOC 2013 CUNs: Final Recommendations - September2013 49

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

UK Structures, 

processors 

and storage 

(Whitworths)

1.100 0.880 0.257 1.100 0.880 0.257

UK Tobacco 

equipment

0.523 0.050

UK Woven 

baskets

0.770 0.770

USA Dried fruit 

and nuts 

(walnuts, 

pistachios, 

dried fruit and 

dates and 

dried beans)

89.166 87.719 91.299 67.699 58.912 19.242 10.041 2.419 0.822 0.740 0.310 89.166 87.719 78.983 58.921 45.623 19.242 5.000 2.419 0.740 0.740

USA Dry 

commodities/ 

structures 

(cocoa beans) 

61.519 61.519 64.028 52.256 51.002 61.519 55.367 64.082 53.188

USA Dry 

commodities/ 

structures 

(processed 

foods, herbs 

and spices, 

dried milk and 

cheese 

processing 

facilities) 

NPMA

83.344 83.344 85.801 72.693 66.777 37.778 17.365 0.200 83.344 69.118 82.771 69.208 54.606 37.778 17.365

USA Smokehouse 

hams (Dry 

cure pork 

products) 

(building and 

product)

136.304 135.742 40.854 19.669 19.699 4.465 3.730 3.730 3.730 3.730 3.730 67.907 81.708 18.998 19.699 18.998 4.465 3.730 3.730 3.730 3.730

USA Mills and 

Processors 

536.328 505.982 401.889 362.952 291.418 173.023 135.299 74.51 25.334 22.800 483.000 461.758 401.889 348.237 291.418 173.023 135.29

9

74.510 22.80

0

22.80

0

USA Research 0.159 0.159