UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHI NGTON D.C., 20460

MEMORANDUM

MAY 0 12009 OFFICE OF

PREVENTION, PESTICIDES AND TOXIC

SUBSTANCES

SUBJECT:

FROM:

THRU:

TO:

Revised Assessment of Pereent Commod ity Treated Values used in the

Registrant ' s Dietary Exposure Assessment for Fluo ride (DP# 36 104 1)

" / ?} Colwell A. Cook, Entomologist It,<' j ' Jonathan Becker, Senior Scie nce Advisck d £. ,

Bio logical Analysis Branch

Elisa Rim, Economist to<,1l v«

Economic Analysis Branch J

Bio logical and Economic Analysis Division (7 P)

Ame t Jones,Chief j" d ,,'i'u!.. ,8 ,',.."

Biological Analysis Branch e:f

Timoth y Kiely, Chief ,/.\- vv....1 Economic Analysis Branch ' JJ

Biological and Economic Analysis Division 03P)

Kable DavisNenus Eagle

Product Registration - Section 3

Registratio n Division (7505P)

Michael Doherty/Christina Swartz

Registration Action Branch 2

Health Effects Division (7509P)

PRODUCT REVIEW DATE: April 2, 2009

Sl lMMARY

The Office of Wate r (OW) is currentl y re-evaluating the relative source contribution of fluoride.

As part of this assessment, contributions from all sources of fluoride are being examined for the

overall expo sure of fluoride. The Office of Pesticide Programs (OPP) is provid ing OW with the

pesticida l portion of that overall exposure . This memorandum reviews the post-harvest usage of

the fumigant sulfuryl fluoride for incorporation into the Health Effects Division' s (BED) report.

Page I
ln support of chara cterizing the usage ofsulfuryl fluoride, Dow AgroSc iences (DAS), the

sulfuryl fluoride registrant, has submitted information to refine the dietary exposure originally

calculated by HED (EPA, 2004 and 2006). The Biological and Economic Analysis Division

(BEAD) evaluated the Information provided by DAS and USDA reports. BEAD is providing

HED wi th commodity treated calculations based on methyl brom ide usage information. Sulfuryl

fluoride is a methyl bromide replacement; however, many of the commod ities did not use methyl

brom ide prior to its phase-out and would be unlikely to use sulfuryl fluoride . BEAD is also

providing a comparison of sulfuryl fluoride with aluminum phosphide which is the current

market leader in post harvest fumigations.

Sulfuryl fluoride is registered both for direct fumigation of certain commodities and also for

fumigation of grain mills and food processing plants where food s may be present and may be

indirectly treated . As to direct fumigation, BEAD has assessed usage only those commodities

specifically listed on the label as food s that may be directly fumi gated with sulfuryl fluoride.

For space fumigations (grain mills and processing plants), BEAD concludes that up to 1.2 % of

grai ns could contain fluoride residue s resulting from space treatments. For all other foods (i.c.,

non-milled grains), the fraction resultin g from space treatment is 0.4 %.

For direct treatmen ts to commodities, BEAD has data available for some commodities through

applications submitted for the methyl bromide critical use exemption process under the Mon treal

Protocol. For other crops, limited data are avai lable (e.g., USDA NASS surveys and private

market surveys). and BEAD conservativel y estima ted Percent Commodity Treated based on

current and prior methyl bromide usage. Aluminum phosphide, or phosphine, is the dom inant

fumigant in these markets. It is efficacious, cost-effective, eas y to apply , and BEAD does not

anti cipate a migration from the phosphi ne market to sulfuryl tluoride. BEAD does, however,

antic ipate sulfuryl fluoride to replace methyl bromide in these commodity markets. BEAD

extrapol ate s these estimates to other commodities based on similarities in storage, pests, andlor

end uses.

The summary of BEAD 's estimate s of percent commodity treated from direct fumi gation is

present ed in Table 1.

T ABLE I. Sl lMMARYOF R EVIS ED EST I:\IATES or Pt:RCENT C n a xro nr r v DIR ECTl\" TREATEO WITII SIILFt"R\ 'L

FU'ORIDE.

B EAD Covnron n-s PERn :.'H C O.' O IODITY TR[ ATEO*

G ROl"PI:"oG CCH I:\IODlT\ * ()AS I BEAD

I EsTl \ IATE RECO\I:\IENOEO

Cheese 0.0 % 0.0 % 0.0 %

EA TS '\~O CIIHS [ Ilam 0.0 % 0.0 % 0.0 %

Bee f (Dried) 0.0 % 0.0 % 0.0 %

Coco nut 0.1 % 0.0 % 0.1 %

L"AR-\~TI:"rriED uses' Coffee Bean 0.1 % 0.0 % 0.1 %

Macadamia Nut 0.1 % 0.0 % 0. 1%

Ginger 0.1 % 0.0% 0. 1%

Page 2
Ba lded text indicates BEAD s recornrncndarions are higher than DAS csumatcs.

L Based on BEAD calculations from comparative methyl bromide usage.

1. Currently fumigated with methyl bromide to fulfill federal or state quarantine requirements.

3. Estimates based on PCT for sorghum and oats. BEAD assumes similar categorizatio n ofsmall coarse grains.

4. This group did not request a methyl bromide CUE and BEAD is anticip ating sulfuryl fluoride to replace methyl bromide.

BEAD estimates PCT to be no more than the DAS estimate for almonds. Based on the pest spectrum, nuts arc primarily treated

with phosphine . with some treated with Propylene Oxide.

5_ Based on estimates from similar methyl bromide critical use exemption commodities

6. Based on reports of methyl bromide usage by USDA NASS

7. BEAD' s estimate is based on a commodity with a similar usc pattern; therefore BEAD defaults to the higher ofthe two

estimates ofthe original commod ity.

BEAD C O.\I_\10 DrlT PJ::RCE:-iT CO:\I.\lODlTYTREATED'"

GROtIPIN(; C():\I:\IODlTY'" (lAS BEA D

ESTIU\TE RECOI\IME)'IiDEU

Barlev' 0.1 % 0.1 % 0.1 %

Com 0.1 % 0.1 % 0.1 %

Cottonsee d 0.1 % 0.1 % 0.1 %

COARSE GRAINS Millet 0.0% 0.1 %. 0.1 %

Oats 0.1 % 0.1 % 0.1 %

Rice Hulls~ 0.0 % 0.1 % 0.1 %

Sorghum 0.1 % 0.1 % 0.1 %

T r it ica le 0.0% 0.1 % 0.1 %

Com Flour, Grits, Mea l 0.1% 0.0 % 0.1 %

Herbs And Spices 0.1 % <0.1 % 0.1 %

PROCESSED Poocom 0.1 % <0.1 % 0.1 %

c oa a oomss Rice - Flour. Bran 3.0% 0.0 % 3.0%

Wheat Flour. Germ, Bran. Shorts. Milled 0.1 % 0.0 % 0.1 % Byproducts

Pea nut6 0.1 % 0.6 % 0.6 %

STOREDCOI\I.\IODITIES Wheat 0.1 % 0.4 % 0.4 %

Rice 3.0% 0.9% 3.0%

Wild Rice 0.9 % 3.0%

Almonds 10.0% 2.2% 10.0 %

Beechn ut 0.0% 2.2 % 10.0 %

Br azil Nut 0.1 % 2.2% 10.0 %

Butternut 0.0% 2.2 % 10.0 %

Cashew 0.1 %. 2.2 % 10.0 %

NlITS4 C hest nut 0.1 % 2.2 % 10.0 %

Cfuecuaem 0.0 % 2.2 % 10.0 %

Filber t 0.1 % 2.2 % 10.0 %

Htckorv Nut 0.1 % 2.2 % 10.0 %

Pecans 0.1 % 2.2 % 10.0 %

Pine Nul 0.1 OJ,, 2.2 % 10.0%

Pistachio l 0.1 % 27.0 % 27.0%

Walnuts 20.0% 99.0 % 99.0%

MF.TIIYLBRO:\UDE Dates 40.0% 42.0 % 42.0 %

C RITICAL USE Prunes, Raisins, FilJS 40.0% 69.0 % 69.0 %

X~ I\I PT :-i Other Dried FruitS. 7 0.1 % 69.0 % 69.0%

C():'II:\IODITIES Dried Beans 100.0 % 92.0 % 100.0%

Legumes (Dried, except C hick pea & 0.1 % 92.0 % 100.0 % p ea ·7

Cocoa Beans 100.0 % 100.0 % 100.0 %

• , , ,

Page 3
BACKGROUSD

Sulfuryl fluoride is a biocid e fumigant that is used to kill insect pests, rodents. birds, and snake s

within facilities as well as commodities. Sulfuryl fluoride was initially registered as Vikane" , a

fumigant to treat drywood termites and other wood boring insects in 1959. It was identified as a

potential alternative for post-harvest uses of methyl bromide, which is bein g phased out, in

accordance with the Montreal Protocol on ozone-de pleting substances. In 2004, USEPA

registered a sulfuryl fluoride product, Propume" , a fumigant to treat food proce ssing facilities,

cereal grains, tree nuts. and dried fruit. As noted abov e, DAS is the sole registrant for this

product. In the summer of2005, USEPA granted DAS ' request to expand its sulfuryl fluoride

food use registrations to essentially match the methyl bromide labe l for commodity fumigati ons.

Sulfuryl fluoride is stored in standardized, compressed gas containers, which are placed outside

the structure. Gas is introduced from the cylinder through a suitab le leak-proof tube with a

minimum burst pressure of 3450 kPa (500 psi). Relea se ofthe fumigant into a large open space is

recommended. The label for sulfuryl fluoride requires the use of electric fans to provide forced

air circulation for facilitating rapid dispersion ofthe fumigant during its introduction into spaces

or air recirculation through commodity fumigation.

Sulfuryl fluoride's label requires the use ofa DAS computer program . designated as the

Pumlgulde" , which calculates the application rate based on the pest. life stage, temperature, and

exposure period for specific fumigation scenarios. Because the Fumiguide is part ofthe

pesticide label, it is unlawful under FIFRA to use sulfuryl fluoride in a manner inconsistent with

the Fumiguide . Monitoring concentrations throughout the fumigation is required and

concentrations are input into the Fumiguide" , which will calculate the actual half-life time and

any additional amount of fumigant and/or increase in exposure time necessary. In add ition,

sulfuryl fluoride fumigations require a minimum of two trained and certified applicators, at least

one of whom must be a licensed fumigator, at the trea tment site for the duration of the

application and aeration. Licensed fumigators may be available at large grain storage faciliti es,

but typically, work for fumigation companies.

Sulfuryl fluoride retails for about $5.00 per pound. Application rates for commodities vary

widely, and chemical costs may range from $15 to $50 for 1,000 bushels.

Sulfuryl fluoride is expected to take over most of the methyl bromide post-harve st market, as

methyl bromide is phased out. Like sulfuryl fluoride , methyl bromide is available as a

compressed gas stored in standardized cylinders. Fumigation with methyl bromide does not

require a computer program like the Fumiguide'[. Both fumigants target essentially the same

pests although there are some differences. The efficacy of sulfuryl fluoride is more sensitive to

temperature than methyl bromide. The chemical costs for both chemica ls are similar for

fumigation at high temperatures, but lower temperatures require more sulfuryl fluorid e. Methyl

bromide and sulfuryl fluoride are used when rapid fumigati on is needed, or in locations whe re

silver and copper metals and the ir alloys occur (primarily in electrical and computer systems in

mills and processing facilities) as methyl bromide and sulfuryl fluoride arc non-corrosive.

Page 4
The other major fumigant in the market is aluminum phosphide. or phosphine. Sulfuryl fluoride

is not anticipated to replace any aluminum phosphide fumigations because aluminum phosphide

is efficacious for the same pests. easy to use, and inexpensive. It is manufactured as tablet s or

pellets that slowly react with atmospheric moisture to produce phosphine gas. Aluminum

phosphide is the most widely used post harvest fumigant for stored commodities such as com,

oats, peanuts, rice. sorghum. and wheat. It can be inserted into the stored grain by a plunger or

can be added as the grain is being binned. The bin is closed or the surface of the grain is covered

by plastic tarpaulin. Fumigation takes five to seven days.

The aluminum phosphide label requires two persons, at least one of whom is a certified

applicator, to be present when pellets/tablets are introduced and again at the end of aeration, but

a fumigator' s license is not required. Some farmers may be certified applicators and could

conduct their own aluminum phosphide applications on farm. It is also relatively low cost.

Aluminum phosphide retails from $5 to $10 per pound. Application rates vary between 0.26 to

1.00 pound per 1,000 bushes of grain, thereby costing anywhere from $ I.30 to $10 in chemical

costs for 1,000 bushels.

Aluminum phosph ide is seldom used to fumigate food processing facilities or mills, however,

unless it is done in small. confined areas. It is corrosive to metals and would damage equipment,

particul arly components ofsensitive computerized systems. In addition the time required for

fumigation with aluminum phosphide is a major drawback to its use as closing facilitie s for up to

a week would have substantial impacts on production.

Another fumigant used for some commodities is propylene oxide (PPO). It is often used to

control a variety of microbi al pests that are not affected by methyl bromide or sulfuryl fluoride.

A combi nation of aluminum phosphide and PPO work very well for many nuts and dried beans.

Food processors have significantly reduced their reliance on fumigation in the last couple of

decades. Their first line of defense is integrated pest management, especia lly sanitation, and

equipment design modifications to enable cleaning and inspection in all areas ofa facility .

Facilities are now being monitored for pest popu lations, using visual inspections, pheromone

traps, light traps, and electrocution traps. When insect pests are found, facilities will attempt to

contain the infestation with treatments of low volatility pesticide s applied to both surfaces and

cracks and crevices; spot treatments with heat or phosphine will be used in areas that are

suitable. Incoming ingredients are inspected for insect pests and may be treated with phosphine if

temperature and time are sufficient. or contaminated ingredients may be rejected. These

techniques do not disinfest a facility but are critical in monitoring and managing pests, and

hopefully preventing outbreaks. However. when all these methods fail to control a pest problem.

facilities must rely on fumigation. to kill pests within the processing equipment, bins, storage

spaces and even the walls of the structure.

Most grain is not directly treated with pesticides. Pest contro l in grain storage is primarily by

cleaning empty bins, aerating ducts. and by removing spilled grain and vegetat ion near the bins.

Typically bins are treated when they are empty, either with a fumigant, a liquid insecticide, or

diatomaceous earth. Grain may be treated as it is augured into a storage bin or after it is in a

grain bin. Iftreated, the commonly used insecticides are cyfluthrin, chlorpyrifos methyl,

Page 5
pirimiphos methyl. and malathion. Grain in storage is mainly treated with aeration devices. often

with chilling. especially at ofT-farmstorage facilities. Or grain in storage may be fumigated.

usually wi th aluminum phosphide .

The food usage of sulfuryl fluoride is currently low, w-ith some exceptions, but the situation is

dynamic. Methy l bromide is available for the post-harvest sector only through the critical use

exemption (CUE) process of the Montreal Protocol and is being greatly reduced each year. For

this memorandum. BEAD estimates that sulfuryl fluoride replaces all methyl bromide postharvest uses other than the quarantine usc. Sulfuryl fluoride is currently not a contender for the

quarantine commodity uses of methyl bromide. which are exempt from the Montreal Protocol.

and it has not yet met the phytosanitary conditions established by the International Plant

Protection Convention.

S PACE F UMIGAT IO:-rl S (GRAI:-rl MILLS A:-rlD PROCESSING PLANTS)

Residues may be left on commodities if they are present in a mill or processing plant at the time

of fumigation. The proportion of commodities present during a fumigation depends on the

proportion of facilities treated, the frequency oftreatments, and the proportion of armual product

present during the fumigation period . BEAD estimates this as follows:

PC]" (Space Treatments) PFT * NF *(DF I TOD)

Where:

• PCT (Space Treatments) is the estimated percent of commodities exposed during

fumigation, PIT is the percent of facilities treated,

• NF is the average number of fumigation s per year,

• OF is the duration of a fumigation, and

• TOO is the total operating days of the facilities.

This method results in a conservative estimate of the percent of commodities exposed because

the ratio of fumigation duration to total days of operation overstates the proportion of annual

product present during fumigation. First. fumigations may be limited to specific areas of a plant

or mill that are isolated from on-going production. Second, if the majority of the plant is to be

fumigated, facilities will halt production during fumigat ion and most will slow, if not clear,

production lines prior to shutting down for fumigation, reducing the amount of product that may

be exposed relative to average daily production.

BEAD and DAS agree with the following parameters: percent ofthe facilities treated (40%),

number of days of production held in facility during a fumigation (2 days for grain mills; 1 day

for processing facilities) and the number of fumigations per year (3 per year for grain mills; 2.5

per year for processing facilities).

However. BEAD and DAS differ on the numbe r of operating days per year at grain mills and

processing plants. DAS assumes that these facilities are in operation 350 days per year, based on

"consultation with operators." BEAD originally assumed that these facilities operate 300 days

per year because facilities do not operate at 100% capacity year round (Becker, et al. 2005).

Page 6
Manufacturers need to repair or service mach inery, so portions of a production may temporarily

go offline. A few facilities do not operate year round. To maintain a conservative estimate,

BEAD retains this assumption; although, the difference in estimated percent of commodity

exposed is small. In addition, BEAD round s up to the nearest 0.1% in order to be conservative.

Table 2 presents DAS and BEAD estimates.

TABLt; 2 ESTIMATED pERCENT cOM:\IO DIf Y EXPOSED c DUR1:\G S C ruu TURAL Fl:MIGATl O:"l.

STRl lCTl'RE I)AS BEAD

Grain Mills 0.7% 0.8%

Food Processine Facilities 0.3% 0.4%

Tota l (Grain) 1.0% 1.2%

BEAD agrees with DAS that treatments occurring in the mills and food processing facilities are

independent. Thus up to 1.2% of grains could contain fluoride residues resulting from space

treatments (i.e., 0.8% from treatment in mills and 0.4% from treatment in processing facilities).

For all other foods (i.e., non-milled grains), the fraction resulting from space treatment is 0.4 %.

D I RI<:CT FOOl) TREAT ME NTS

DAS Methodology

DAS derived percent crop treated estimates for seven commodities that are directly treated

(almonds, cocoa, corn, popcorn, prunes, rice and wheat). Their approach is as follows:

PCT (Commodity) [VP(l-Dcl)]'p I (FAPC'US pop)

Where:

• PCT (Commodity) is the estimated percent of a commod ity directly treated with sulfuryl

fluoride,

• VT is the volume ofthe commodity treated,

• p is the bulk density of the comm odity,

• FACP is Food Availability Per Capita, and

• US pop is the population of the United States.

Fumigators using sulfuryl fluoride report to DAS the volume of commodities treated via the

Fumiguide". DAS then adjusts this value downward by to % to account for incomplete filling

of the fumigation bin. Total volume treated is multiplied by the bulk density of the commodity

to estimate the weight oftreated commodity. Food Availability Per Capita is obtained from

USDAIERS (http://www.ers.usda.gov/Data/FoodConsumption/FoodAvaillndex.htm) and is

calculated as the sum of total annual production, imports, and beginning stocks ofa particular

commodity less exports, ending stocks, and non-food uses, divided by U.S. population. Thus,

multiplying this amount by U.S. population returns the total amount of a commodity available

for food consumption in a year but does not account for spoilage or waste. This method is a

reasonably conservative approach for commodities with significant use as animal feed, since

feed may also be fumigated, and very conservative for commodities with significant exports, as

they are also likely to be fumigated.

BEAD has some concerns over the data used in the DAS estimates, including:

Page 7
• Company data are incomplete for many ofthe seven commodities. In recent years,

fumigato rs have not submitted complete reports of usage and commodities treated.

• There are limited data on how full each bin is when the fumigation occurs. The label

requires some active aeration during fumigation, but this does not prevent bins from

being completely filled.

BEAD Met hodology

BEAD usually estimates a percent crop or commodity treated for new insecticides or new uses as

the average and/o r observed maximum Percent Crop Treated of the market leader, which is the

most widely used insecticide for that crop. These initial estimates do not consider target pests or

specifics of the chemical. Analysis has shown that new chemicals rarely overtake the market

leader by crop site and pesticide type within 5 years, i.e. less than 2% of the time (Keigwin,

2006). Data are primarily from USDN NASS and California Department of Pesticide

Regulation. BEAD also uses EPA proprietary data to supplement data gaps. These data are

direct reports ofpcrcent crop treated, and not calculated from volumes. An average of the

highest "area applied" percentages for the last three years for each site is then used.

However, in this case, sulfuryl fluorid e has been registered for food uses for 5 years. Its pest

spectrum and chemistry is well-known. It is comparable to methyl bromide and not the postharvest market leader (aluminum phosphide). for reasons previously describe d in the

Background section ofthis document . Therefore, BEAD uses the historic values for methyl

bromide as the percent of the commodity that may be treated with sulfuryl fluoride, unless

otherwise stated in the specific commodity sections below. Due to the phaseout ofmethyl

bromide , BEAD also uses data from the methyl bromide CUE process. For the purpose of

estimating percent of commodity treated for dietary risk assessment, to be conservative. BEAD's

recommended estimate is the higher of either BEAD's likely estimate or DAS's estimate. In

addition, in certain circumstances, when the estimate is based on a commodity with a similar use

pattern, BEAD defaults to the higher of the two estimates of the original commodity.

Commodities

Sulfuryl fluoride is registered on an extensive list of commodities. The following tables have

comm odities with the percent crop treated as proposed by DAS based on their proposed

methodology and Fumiguide'" data from 2004·2007. Sulfuryl fluoride is a methyl bromide

replacement, and many of the commodities did not use methyl bromide prior to its phase-out.

BEAD has data available for some commodities through applications submitted for the methyl

bromide critical use exempt ion process. For other crops, limited data are available (e.g., USDA

NASS surveys and private market surveys), and BEAD conservatively estimated Percent

Commodity Treated to equal current or prior methyl bromide usage . Aluminu m phosphide, or

phosphine, is the dominant fumigant in these markets. It is efficacious, cost-effective, and easy

to apply; therefore BEAD does not anticipate a migration from the phosphine market to sulfuryl

fluoride. BEAD docs. however. anticipate sulfuryl fluoride to replace methyl bromide in these

commodity markets.

Page 8
Meats and Cheese

DAS is anticipating zero percent commodity treated on the following commodities: cheese and

ham. BEAD can confirm that these two commodities are not likely to undergo sulfury l fluoride

treatment (Table 3). These commodities are part of the Methyl Bromide Critical Use Exemption

Process and have demonstrated critical need because there are no alternatives for the key pests.

BEAD agrees that sulfuryl fluo ride will not be used on cheese and ham based on data

demonstrating no efficacy on the target pests in these commodities (Phillips, et al. 2008). BEAD

also agrees that sulfuryl fluoride will not be used on dried meat (beet) because it is processed and

packaged in such a way to minimize pest infestations and therefore not fumigated (Table 3).

T ABLE3. REVISED EST I\l.\TES 01<' PE R('Io;:\,T MEATS A:'Ii . D C IlEE SES. TRIo;\H'D . . WITII .S UI H1RYL FLUORIDE.

B EAD CO.\1.\10DITY PERU::"T cosmoenv TREATED

G ROl:j' ISG Cml:\IOIlITY DAS BEAD

ESTI\J..\TE RE('O~I\lEl\D ED

Cheese 0.0% 0.0 % 0.0%

MI:Al'S A!'IiD C HEESE Ham 0.0 % 0.0 % 0.0%

Beef (Dried) 0.0% 0.0 % 0.0 %

I. Based on BEAD calculations from comparative methyl bromide usage.

Quarantine Uses

According to their Fumig uide'", DAS has had no documented uses on coconut, coffee bean,

ginger, and macadamia nut in the last four years. They are proposi ng 0.1% as a conservative

estimate for those commodities. Coconut is imported into the USA and requi res quarantine

fumigation. USDA APHIS, in their treatment manual, requires methyl bromide to be used in

these fumigations. The other commodities have state (primarily Hawaii and California)

quarantine requirements. BEAD does not expect sulfuryl fluoride to replace quarantine uses of

methyl bromide, because these uses have a special exemption under the Montreal Protocol

(Tab le 4). In addition, sulfuryl fluoride has not yet met the phytosanitary conditions established

by the International Plant Protection Convention to meet quarantine requi rements.' Therefore

BEAD does not expect sulfuryl fluoride to displace methyl bromide quarantine uses. BEAD

believes it is likely that zero percent commodity will be treated. However, for the purpose of

estimating percent of commodity treated for dietary risk assessment and for consistency with

BEAD's methodology of using the higher of the two estimates, BEAD conservatively

recommends 0.1% commodity treated for coconut, coffee bean, ginger, and macadam ia nut.

T ABLE 4 R EVISED . EST. 1\1AT S OF P C E I:R E:\T QUARA:'oITlSE U.SES. TREATE.D WITII St'LFVR YL FU.'ORIDE

DEAD COMMOIllTY PI::RCEKf CO:\I\lODrI"V TREAn:n

CO.\I,\foJ)ITY DEAD caornxo DAS

ESTI\J,\n: RECOM:\JENJ)[ D

Coconut 0.1 % 0.0 % 0.1 %

QlIAR.\:'\'TI:\ED USESI Coffee Bean 0.1 % 0.0% 0.1%

Macadamia NUl 0.1 % 0.0 % 0.1 %

Gineer 0.1 % 0.0 % 0.1 %

I. Currently fumigated With methyl bromide to fulfill federal or state quarantine requirements

Page 9
Coarse Grains

DAS has no documented fumigation on cottonseed, oats, sorghum, barley acco rding to the last

four years of Fumiguidef data . DAS has documentation of fumigation on a very small amount of

com in 2004. DAS has proposed that the follow ing commod ities be assessed at 0.1%

commodity treated : cotton seed, oats, sorghum, barley, and com. DAS also has not documented

sulfuryl fluoride fumigation ofmill et, rice hulls and triticale. DAS does not anticipate any use

and estimates 0% commodity treated for these commodities.

USDA data are available for fumigant use on com. sorghum, and oats. Based on these usage

data and the similar use patterns for cottonseed, oats, sorghum, barley and com, BEAD believes

that the DAS estimate for these grains of 0.1% is conservative. BEAD 's analysis ofthe data on

com, sorghum, and oats is discussed below. Since millet, rice hulls, and triti cale are also coarse

grains with similar pest spectrum and uses to oats, sorghum, barley and com, BEAD expects the

usage of sulfuryl fluoride to be similar. Therefore, BEAD has used 0.1% as a conservative

estimate (Table 5).

Com

DAS estimates a percent commodity trea ted for com of 0.1%. Based on available data

cove ring historic methyl bromide use patterns, BEAD believes that this is a conservative

estimate.

As indicated in the Background section, most stored grain is not treated with insecticides.

BEAD estimates less than 7% are treated with insecticides based on EPA private market

data and USDA NASS data. To the extent that stored com is treated with an insecticide,

the most recent USDA data from 2004 indicate that the most widely used insecticide is

the fumigant aluminum phosphide (NASS, 2004). USDA reports that aluminum

phosphide was used on 97% of the volume treated with an insecticide. Aluminum

phosph ide is efficacious, cost-effective, easy to apply, and BEAD does not anticipate a

migration from the aluminum phosphide market to sulfuryl fluorid e. BEAD does,

however, anticipate that sulfuryl fluorid e will replace methyl bromide in this market.

USDA data indicate that methyl bromide was used in the 2002 mark eting year on com;

however, USDA reports the usage as so low that a numerical estimate is not provided .

USDA does not make a numerical estimate when usage is so infrequent that reporting a

number may compromise the confidentiality of the survey. The 2002 methyl bromide

data are a conservative estimate for sulfuryl fluoride usage because these data are prior to

the conclusion ofthe phaseout ofmethyl bromide when methyl bromid e was readily

available. Accordingly, BEAD believes that the recomm ended estimate ofsulfuryl

fluoride use of 0.1% is conservative.

Sorghum and Oats

DAS estimates a percent commodity treated for sorghum and oats of 0.1%. Based on

available data coveri ng insecticide use on stored sorghum and oats and historic methyl

bromide use patterns, BEAD believes that this is a conservative estimate.

As indicated in the Background section, most stored grain is not treated with insect icides.

According to USDA data (NASS, 2007) 6% of stored oats are treated with an insec ticide .

Page 10
Similarly, according to USDA data (NASS, 2001) 4% of stored sorghum are treated with

an insecticide. To the extent that stored sorghum and oats are treated with an insecticide,

the most recent USDA data from 2001 and 2007 indicate that the most widely used

insecticide is the fumigant aluminum phosphide. USDA reports that aluminum

phosphide was used on 77% of stored sorghum and 86% of stored oats of the volume

treated with an insecticide. Aluminum phosphide, or phosphine, is efficacious and costeffective and BEAD does not anticipate a migration from the phosphine market to

sulfuryl fluoride. BEAD docs, however, anticipate that sulfuryl fluoride will replace

methyl bromide in this market. USDA data indicate that methyl bromide was used in the

1999 and 2005/06 marketing year on stored sorghum and oats, respectively; however,

USDA reports the usage as so low that a numerical estimate is not provided. USDA does

not make a numerical estimate when usage is so infrequent that reporting a number may

compromise the confidentiality of the survey. Accordingly, BEAD believes that

recommended estimate of sulfuryl fluoride use of 0.1% is conservative.

Bolded text indicate s BEAD s recommendatio ns are higher than DAS estimates.

I. Based on reports ofmethyl bromide by USDA NASS.

2. Estimates based on PCT for sorghum and oats. BEAD assumes similar categorization of small coarse grains.

T ,\BLE 5 RHISED ESTI MATE S, 01- PERCt: NT COARSE G RAI:'IiS USE,D T REAT ED WITH SlILH 'RYI F, ll, lORIDE,

B EA D CO.\l:\ 10 Dl T Y

Pf:RCENT C O.\ I.\ 10 DITY TREATEDGROl'PI:'IiG C()~1~ 10 DlTY-

" AS B EAD

ESTI.\1AT£ t:C .\1 1f: S D

Barley' 0.1 % 0. 1 % 0.1 %

Com 0.1 % 0.1 % 0.1 %

Cottonseed 0.1 % 0.1 % 0.1 %

COARSE GRAINS Millet 0.0% 0.1 % 0.1 %

Oats 0.1 % 0.1 % 0.1 %

Rice Hulls 0.0% 0.1 % 0.1 %

Sorghum 0.1 % 0.1 % 0.1 %

Triticale 0.0 % 0.1 GIG 0.1 %

•

Processed Commodities

Processed foods are not likely to get fumigated with sulfuryl fluoride. After commodities are

processed they are shipped to storage warehouses, where sanitation is critical. Processed

commodities are inspected, both the commodity and their packaging material, upon receipt at a

warehouse. Sanitation and other IPM strategies are used to prevent infestation of processed

foods (see Background Section). However, if any processed food is contaminated, pests either

on or within the packaging, it will be removed for destruction or fumigated. The fumigant of

choice in these situations is phosphine because it is efficacious, easy to use and cost effective

(Mason, personal communication, 2009; Hui, et at 2003).

DAS has evidence of direct treatment on popcorn. As a result, DAS estimated that popcorn

might get fumigated and calculated 0.1% commodity treated. Given how processed goods are

handled, BEAD believes the direct treatment of popcom is an anomaly and possibly the result of

labeling a space treatment by the commodity that was to be stored in the treated space.

Moreover, BEAD would typically average usage ofa registered product across several data

points, rather than using the maximum observed. Thus, BEAD estimates usage at much less than

0.1%. In keeping with BEAD's methodology to be conservative, however, BEAD recommends

using 0.1% commodity treated for popcorn.

Page II
DAS also anticipates fumigating a small proportion of herbs and spices based on past methyl

bromide CUE requests. However, past requests for methyl bromide were for space treatments of

areas used to process or store herbs and spices, not for direct treatments. Processors of herbs and

spices ceased use ofmethyl bromide well before the conclusion ofthe phaseout of methyl

bromide, and fumigate with either PPO or ethyle ne oxide to control microbial pests. Therefore

BEAD estimates much less than 0.1 percent crop treated. However, to be conservative, BEAD

recommends using 0.1% commodity treated, which is the higher ofthe two estimates.

DAS estimated 0.1% commodity treated for com flour, com grits, com meal, wheat flour, wheat

germ, wheat bran, wheat milled byproducts and wheat shorts (Table 6). These estimates are

extrapolated from DAS estimates of the treated grain (see Table 7) rather than evidence of direct

treatments of the processed forms.

BEAD anticipates that the following processed commodities (com flour, com grits, corn meal,

wheat flour, wheat germ and wheat bran, wheat shorts and wheat milled byproducts) will not be

treated as a direct commodity fumigation (zero percent crop treated). As previously indicated, to

the extent processed commodities such as these become infested, they are either destroyed or

fumigated with phosphine. There is no evidence ofmethyl bromide use on these commodities to

address infestation either from pre-methyl bromide phaseout data or in terms of CUE requests

after conclusion of the phaseout. However. for the purpose of estimating percent ofcommodity

treated for dietary risk assessment and for consistency with BEAD's methodology of using the

higher ofthe two estimate s, BEAD conservatively recommends 0.1% commodity treated for the

processed commodities for direct fumigations (Table 6).

DAS estimated that rice flour and rice bran would be treated at 3% commodity treated; however,

BEAD does not think this estimate is reasonable as it was-extrapolated from the rice grain

estimate without regard to how processed commodities are treated. BEAD categorizes this

commodity as a processed commodity and believes it is likely that zero percent commodity will

be treated as a direct commodity fumigation for the reasons given above as to processed grain

commodities. However, for the purpose of estimating percent of commodity treated for dietary

risk assessment and for consistency with BEAD' s methodology of using the higher ofthe two

estimates, BEAD conservatively recommends 3.0 % commodity treated for rice flour and rice

bran for direct fumigations (Table 6).

Page 12
TABI [6. Rn'lsl'o ESTJ:\1AT£S. OF PERCE:\T PROC.E.

s..s EO C OI\I\ IOIll TU.:'s T R£.\T£ DWITII S t: U IIRYl FU:ORIDE. BEAD Cml\lOlHTY

PI:RCEST coseronrr v TRE,\no

GROl 'I'I'G

CO.\I.\ 10011'\· HAS DEAD

[ sTnIATE RECO"i\lE~DED

Com Flour, Grits, Meal 0.1 % 0.0 % 0.1 %

Herbs And Soices 0.1 % <0.1 % 0.1 %

PROCESSED Poecom 0.1 % <0.1 % 0.1 %

O~MODrTlE Rice Flour. Bran2 3.0 % 0.0 % 3.0 %

Wheat - Flour. Germ, Bran, Shorts, Milled 0.1 % 0.0 % 0. 1% bvoroducts

I. Estimates based on assumption that these commoditie s are treated as a result or space fumigations and nOI direct commodity

fumigations.

2. BEAD assumes these uses are miscategonzed by DAS according to similar commod ity type and nOI by usc pattern.

Stored Commodities

Based on their Fumiguidef data. DAS estimated a percent commodity treated for stored peanuts

and wheat of 0.1%. and rice of 3%. BEAD' s analysis for these commodi ties is explained below.

Peanuts

DAS estimates 0.1% crop treated for stored peanuts. BEAD recommends the estimate of

stored peanuts that may be treated with sulfuryl fluoride to be 0.6% based on available

data regard ing meth yl bromide use.

As indicated in the Backgrou nd section, most stored peanuts are not treated with

insecticides. USDA (2006) estimates that 33% of peanuts stored off-farm is treated with

an insecticide (see Background section for explanation on why on-farm fumigation is

unlikely). To the extent stored peanuts are treated with an insecticide, the most recent

USDA data from 2006 indicate that the most widely used insecticide in stored peanuts is

the fumigant aluminum phosphide . USDA reports that alum inum phosphide was used on

73% ofthe volume treated with an insecticide. Aluminum phosphide is efficacious, costeffe ctive, easy to apply, and BEAD doe s not anticip ate a migration from the phosphine

market to sulfuryl fluorid e. BEAD does. however, anticipate that sulfuryl fluoride will

replace the methyl brom ide in this market. USDA (200 I) data also indicate that methyl

bromide was used on 0.6% ofstored peanuts for the 1999 marketing year. The 1999

methyl bromide data are a conservative estimate for sulfuryl fluoride usage because these

data are before the conclusion ofthe phaseout of methyl bromide when methyl bromide

was readily avai lable. Moreover, there have been no CU E requests for methyl bromide on

peanuts under the Montreal Protocol. Accordingly, BEAD estimates that the percent of

stored peanut s treated with sulfuryl fluoride to be 0.6% (Table 7).

Wheat

DAS estimated a percent commodity treated for wheat of 0.1%. BEAD recommends the

estimate of wheat that may be treated with sulfuryl fluoride to be 0.4% based on ava ilable

data regard ing methyl bromide use.

As indicated in the Background section, most stored grain is not treated with insecticides.

The amount of wheat treated with insecticide for both off-farm and on-farm use is

estimated to be approximately 30%, based on EPA market data and USDA reports of the

Page 13
volume of off-farm stored wheat handled (NASS, 2002). To the extent that stored wheat

is treated with an insecticide, the most recent USDA data from 2002 indicate that the

most widely used insecticide is the fumigant aluminum phosphide. USDA reports that

aluminum phosphide was used on 87% of the volume treated with an insecticide.

Aluminum phosphide, or phosphine, is efficacio us, cost-effective, easy to apply, and

BEAD does not anticipate a migration from the phosphine market to sulfuryl fluoride.

BEAD docs, however, anticipate that sulfuryl fluoride will replace the methyl bromide in

this market. USDA data also indicate that methyl bromide was used on 0.4% ofstored

wheat for both 1997 and 2000 marketing years. The 1997 and 2000 methy l bromide data

are a conservative estimate for sulfuryl fluoride usage because these data are before the

conclu sion of the phaseout of methyl bromide when methyl bromide was readily

available. Moreove r, there have been no CUE requests for methyl bromide on wheat

under the Montrea l Protocol. Accordingly, BEAD estimates that the percent of wheat

treated with sulfuryl fluoride to be 0.4% (Table 7).

Rice

For rice, DAS has data documenting use on 0.14 to 2.5% ofrice with an average peT of

0.8%. DAS estimated a percent commodity treated for rice of 3.0% based on anticipated

future potential expansion into the rice, brown rice, and wild rice markets and round ing

up from their maximum estimate. DAS's maximum estimate is from 2006, the year after

methyl bromide was phased out and BEAD belie ves that this "vas a trial period and many

rice companies tried sulfuryl fluoride. In 2004 and 2005 there were 4 to 6 fumigations on

rice, in 2006 there were 45 fumigat ions, and in 200 7 there were 6 fumigations. BEAD

considers the one year spike an anomaly and does not anticipate usage to reach that level

in the future. Based on historic methyl bromide use patterns; BEAD believes 3.0 % is a

very conservative estimate.

As indicated in the Background section, most stored grain is not trea ted with insecticides.

Total off-farm stored rice treated with all insecticides is estimated at 2 1% for rough rice

and 23% for proce ssed rice (NASS, 2001). EPA proprietary data suggests that most rice

is stored off-farm and that a larger proportion ofoff-farm stored rice is treated with an

insecticide than on-farm stored rice. However, the data are sparse and, to be

conservative, BEAD assumes similar proporti ons are treated. Based on these limited

data, a conservative estimate of the amount of off-fann rice treat ed with an insecticide is

approximately 23%. To the extent that stored rice is treated with an insecticide, the most

recent USDA data indicates that the most widel y used insecticide is the fumigant

aluminum phosphide. USDA reports that aluminum phosphide was used on 97% of the

volume treated with an insecticide. Aluminum phosphide, or phosphine, is efficacious

and cost-effective and BEAD does not anticipate a migration from the phosphine market

to sulfuryl fluoride. BEAD does, however, anticipate that sulfuryl fluoride will replace

methyl bromide in this market. USDA data indicate that there is some usc of methyl

bromide in the 1999 marke ting year on processed rice; however, USDA reports the usage

as so low that a numerica l estimate is not provided. USDA does not make a numerical

estimate when usage is so infrequent that reporting a number may compromise the

confidentiality ofthe survey.

Page 14
DAS data represent the best ava ilable estimates of the amo unt of rice treated with sulfuryl

fluoride. To account for the possibility that chambers are completely filled, however,

BEAD increases the volume treated by 10%. BEAD does not make an adjustment for the

total rice availab le for food consumption as rice is not subject to significant spoilage or

wastage. Once dried, rice is easy to store for long. Therefore, BEAD estimates about 0.9

percent commodity treated. However, for the purpose of estimating percent of

commodity treated for dietary risk asse ssment and for consistency with BEAD's

methodology of using the higher of the two estimates, BEAD conservative ly recommends

3.0 % commodity treated on rice (Table 7).

In the absence of data specific to wild rice, BEAD assumes it will be treated like other small

grains, including wheat, barley, rye, and rice. To be conservative, BEAD extrapo lates from the

highest estimate among these commodities, rice, to be used for wild rice (Tab le 7).

T \BLE '7 REVISED ESTIMA1'ES OF P ERCE" T STORED Cm·l~10 [)lTlES T KJ'AT H ) WITII S UI H 'Rn FUTORIDE

Boldcd text indicates READ s recommendations are higher than DAS esumates.

I. Based on reports of methyl bromide usage by USDA NASS

2. DAS grouped with rice.

, . . . 0 .. 0

BEAD Co.\nIODlTY P ERCE!"T CmIMOI>lTY TREATED*

GKOl !PI'O(; CO\ I\IOIHTY'" DAS BEAD

ESTIMATE R ECO\ l l\l E:"DED

Peanu t' 0.1 % 0.6 % 0.6 %

STORED C m l MODlT JES Wheat 0.1 % 0.4 % 0.4 %

Rice 0.9% 3.0%

Wild Rice 3.0% 0.9% 3.0%

• . ,

Nuts

Based on the pest spectrum, nuts are primari ly a phosphine market, with some treated with PPO.

DAS has docume nted fumigations of almonds in the last four years, which DAS estimates to

range from 3. 1 to 8.3% commodity treated with an ave rage PCT of6.0%. DAS estimated a

percent commodity treated for almonds of 10% based on anticipated future potential expansion

into the almo nd market and .rounding up from their maximum estimate. DAS methodology

results in a very conservative estimate in this situation because they calculate PCT assuming that

tota l sulfuryl fluoride usage on almonds is used only on almonds available for domestic

consumption. However, nearly 80% ofV.S. almond produ ction is exported (FAS , 2008) and

there is no reason to believe that exports are less likely to be fumigated with sulfuryl fluoride

than almonds destined for the domestic market. DAS data represent the best ava ilable

inform ation on amo unt treated. To estimate percent commodity treated, BEAD calculates the

ave rage quantity treated based on DAS data, which BEAD increases by 10% to acco unt for

complete fill of fumigation chambers, and divides by ave rage utilized production, which is total

produ ction less culls and storage losses (NASS, 2008). This results in a BEAD estimate of2.2%

commodity treated for almonds. However, for the purpose of estimating percent of commodity

treated for dietary risk assessment and for consistency with BEAD's methodology of using the

higher of the two estimates, BEAD conservatively recommends 10% commodity treated on

almonds (Table 8).

Based on the similarity of the following commod ities to almonds (i.e., they are all tree nuts),

BEAD estimates 2.2% commodity treated for beec lmut, butternut, Brazi l nut, cashews, chestn uts,

Page 15
chinquapin, filberts, hickory nuts, pecans, and pine nuts. DAS anticipated zero usage for

beechnut, butternut, and chinquapin and 0.1% usage for Brazil nut, cashews, chestnuts, filberts,

hickory nuts, pecans, and pine nuts. The se groups did not request a meth yl bromide CUE and

BEAD is not anti cipating sulfuryl fluoride will penetrate this market other than as serving as a

methyl bromide replacement. However, for the purpose of estimating percent of commodity

treated for dietary risk assessment and for consistency with BEAD 's methodology, we

recommend defaulting to the higher ofthe t\VOestimates. In this case, since all estimates are

based on data from almond s, BEAD conservatively recommends 10% commodity treated on

beechnut, buttern ut, chinquapin, Brazil nut, cashews, chestnuts, filberts, hickory nuts, pecans,

and pine nuts (Table 8).

T ABLE 8 RHISED ES"I'IMATES OF P ERCF.:'IiT NUTST REATEll WITH SULfU RYL FUIORIUE

• Bolded text indicates BEAD s recommendations arc higher lhan DAS estimates.

I. This group did nol request a methyl bromide CUE. Based on the pest spectrum, nuts are primarily treated w ith phosphine•

w ith some treated with Propylene Oxide.

2. BEAD's estimate is based on a commodity .... ith a similar usc pattern; therefore BEAD defaults to the higher of the two

estimates of the original commodity.

, , " ,

DEAD CO.\I:\IOl>lH · PERO::\T COMMODITY TR L\TEI>*

GR()('PI:"'G CO:\ I:\IOIlITY* OAS DEAIl

EH IM" TF. R ECO:\I:'> IE:'IiDED

Almonds 10.0 % 2.2 % 10.0 %

Beechn ut 0.0 % 2.2 % 10.0 -;.

Bra zil Nut 0.1 % 2.2 0/_ 10.0 V.

Butternut' 0.0 V. 2.2 -/_ 10.0 V.

Cashew' 0.1 -;. 2.2 V. 10.0 V.

xcrs' C hest nu t 0.1 -I. 2.2 V. 10.0 V.

C hinq ua pin 0.0 -I. 2.2 % 10.0 ·/e

Filber t 0. 1 -/e 2.2 % 10.0 %

Hickon: Nut' 0.1 -/e 2.2 V. 10.0 %

Peca ns O.t -/e 2.2 V. 10.0 %

Pin e N ut- 0. 1 % 2.2 V. 10.0 % ,

Methyl Bromide Critical Use Exemption Commodities (CUE)

Several commodity groups have requested a methyl bromide CUE eac h year since the phase-out

of methyl brom ide (Table 9). These commod ities are walnuts, raisins, prunes, figs, dried beans,

and dates. Pistachios requested a methyl bromide CUE for the first three years of the process.

Table 9 contains the calculation s of BEAD's best estimate of the projection of sulfuryl fluoride

percent crop treated for these commodities. Estimates are based on the difference between the

applicant-requested amount of methyl bromide and the final nominated amount granted for

critical use ofmethyl bromide. BEAD assumes the gap between the amount requested and the

amount nominated would reflect the portion of the sulfuryl fluoride use on that commodity

because sulfuryl fluoride is a methyl bromide replacement. For example, the applicant requested

amount of methyl brom ide for prunes, raisins, and figs was 20,41 2 kg and the final nominated

amount granted for this critical use was 6,266 kg. According ly, methyl bromide is projected to

be used on 31% of the prunes, raisins, and figs so the remaining 69% could be treated with

sulfuryl fluoride.

Page 16
BEAD's approach to estimating percent crop treated for these commodities is conservative for

two reasons. First, the portion of the requested amount ofmethyl bromide not grant ed as a CUE

is unlikely to be replaced fully by sulfuryl fluoride given the availability of other methyl bromide

alternati ves, including phosphine. Second, the approach assumes that the entire commodity

(100% crop treated) is currently treated with methyl bromide, which is unlikel y to be the case.

Not only would it be uncomm on for the entire commodity to be fumigated but other fumigants

(e.g., phosphine) are likely to be used in circumstances where speed of fumigation is not

essential.

Sulfuryl fluoride is unlikely to replace any methyl bromide use granted as a CUE given both the

general advantages of methyl bromide ove r sulfuryl fluoride (see Background) and the fact that

resources required to obtain a CUE demonstrate a strong preference for methyl bromid e.

For nearly all commodities, BEAD estimates higher percent commodity treated than does DAS

and recommends using BEAD's estimates in the dietary risk assessment. The exception is dried

beans, where DAS anticipates 100% PCT. The dried bean commodity group has demonstrated a

critical need for methyl bromide for the next several years in order to transition to the use of

alternatives, including sulfuryl fluorid e. The US has nomin ated 8% of the requested amount of

methyl bromide ; therefore BEAD estimates 92% of dried beans may be treated with sulfuryl

fluoride. However, for the purpo se of estimating percent of commodity treated for dieta ry risk

assessment and for consistency with BEAD's methodology of using the higher of the two

estimates, BEAD conservatively estimates 100% commodity treated.

DAS anticipated 0.1% commodity treated on other dried fruit and legum es (dried, except

chickpea and cowpea). These groups did not reque st a methyl bromide CUE and, as BEAD is

anticipating sulfuryl fluoride to replace methyl brom ide, there is likely to be little use. However,

in the absence of data, BEAD estimates that 69% ofthe other dried fruit may be treated with

sulfuryl fluoride based on estimated use in similar commodities, prune s, raisins, and figs. Based

on the estimated use of sulfuryl fluoride in dried beans, BEAD also estimates that 92.0 % ofthe

other dried legumes (except chickpea and cowpea) may be treated with sulfuryl fluoride.

However, for the purpose of estimating percent of commodity treated for dietary risk assessment

and for consistency with BEAD's methodology of defaulting to the higher of the two estimates

of the original commodity (in this case, dried beans); BEAD conservatively recommends 100.0

% commodity treated on legumes (dried, except chickpea and cowpea) (Table 9).

Cocoa bean producers have made great strides in transitioning from methyl bromid e to sulfuryl

fluoride, and they intend to convert 100.0 % to sulfuryl fluoride by 20 IO. BEAD concurs with

DAS and recomm ends an estimate of 100.0 %.

Page 17
• Bolded text indicates BEAD s recommen dations are higher than IJAS estimates.

I. Based on BEAD calculations from comparative methyl bromide usage,

2. Based on estimates from similar methyl bromide critical use exemption commodities

J. BEAD' s estimate is based on a commodity with a similar use pattern ; therefore BEAD defaults to the higher of the two

estimates of the original commodity.

T ABLE 9. REVISED EsTl ;\L\ T1::S o r PERCE:'IoT METHYL BROMIDE C RITICAL USE EXEMPTIO"iC OWUODlTIE:S

T REATED WITII Sn R IU 'L Hl'ORIDE. BEAD

I

Pl:RCE:'OT C m mODITI' TRL-\rrn -

CO\ I'IODIH ' CO'l'lODlTY- DAS BEAD

GROl'PI.'liG E$T1\ f-\TE RECO.\fMESP ED

Pista chio ' 0.1 -/_ 27.0 -/_ 27.0 %

!\IEnlH

Walnuts 20.0 -/0 99.0 -/_ 99.0 %

BRO;\nD E Dales 40.0 % 42.0 -/_ 42.0 %

C RITICAL USE Pr-unes, Raisins, Ftas 40.0 % 69.0 -/_ 69.0 %

ExuwTlo:\, O t he r- Dri ed Fr ui t ' 0.1 -/_ 69.0 % 69.0 -/_

CO " "ODITIl:S Dried Be ans 100.0 % 92.0 % 100.0 %

Leaumes lDr ied, exceot C hicknea & Co woea r'" 0.1 % 92.0 % 100.0 ''/0

Cocoa Beans 100.0 % 100.0 % 100.0 % ..

Co nclusion

DAS submitted studies 10 EPA to refine their dietary exposures for the post-harvest uses of

sulfuryl fluoride . BEAD evaluated the information provided by DAS. BEAD agr-ees with most

of the space fumigation assumptions, the exception'being the number of operating days per year

at mills and proce ssing facilities. For space fumigations (grain mills and processing plants,

BEAD concludes that up to 1.2% of grains could contain fluoride residues resulting from space

treatments (i.e., 0.8% from treatment in mills and 0.4% from treatment in processing facilities).

For all other foods (i.e., non-milled grains), the fraction resulting from space treatment is 0.4%.

For direct treatments to commodities, BEAD reviewed the informat ion submitted by DAS.

BEAD conservatively estimated Percent Commodity Treated based on current and prior methyl

bromide usc. BEAD finds that the DAS estimates for beef(dried), cheese, ham, coconut, coffee

bean, macadamia nuts, ginger, cottonseed, corn, popcorn, herbs and spices, oats, barley, rice,

sorghum, almonds, dried beans, and cocoa beans are conservati ve. BEAD recommends a higher

percent commodity treated for millet, rice hulls, triticale, corn flour, corn grits, corn meal,

peanut, wheat, beechnut, Brazil nut, butternut, cashew, chinquapin, filbert. hickory nut, pecans,

pine nut, pistachios, walnuts, dates, dried fruit (prunes, raisins, figs), othe r dried fruit, and

legumes (dried, except chickpea & cowpea ).

References:

Becker, J., W. Chism, and C. Cook . 2005. BEAD Respon se to Selected Sulfuryl fluoride

(ProFumeTM ) Comments Submitted By the Fluoride Action Network Pesticide Project

(DP Barcode D3 I6797). Memorandum submitted to Registration Division. June I.

Becker, J., C. Cook, and E. Rim. 2009. Assessment of Percent Crop Treated Values used in the

Registrant's Dietary Exposure Assessment for Fluoride (DP# 36104 1). Memorandum

submitted to Registration Division. February 26,2009.

Page 18
FAS, USDA. 2008. Tree Nuts: World Markets & Trade. November 20 08. Un ited States

Department of Agriculture, Foreign Agricultural Service. Ava ilable online at:

http://www.fas.usda.gov/htplhorticulturerr ree%20Nuls/2008_Treenuts.pdf

Hui, Y. H., Wai-Kit Nip, and 1. R. Gorham. 2003. Sanitation and Warehousing. In: Food Plant

Sanitation, edited by: Y. H. Hui , B. L. Bruinsma, 1. R. Gorham, W-K N ip, P. S. Tong,

and P. Ventresca. Marcel Dekker, Inc, New York. 719 pp .

Keigwin, R. 2006. BEAD's Approach to Providing Projected Percent Crop Treated Estimates

for Use in Dietary Risk Assessme nts in OPP. Memorandum submitted to Lois Rossi and

Tina Levine. December 14.

Mason, Linda. 2009. Professor of Food Industry Pest Management, Department of Entomology,

Purdue University, We st Lafayette, IN. Spoke with Colwell Cook, April 20, 2009 .

NASS , USDA. 1999. Agricultural Chemical Usage Postharvest Applications - Com and Wheat

Summary . March 1999. United States Department of Agriculture, National Agricultural

Statistics Service.

NASS, USDA. 2001. Agricultural Chemical Usage Postharvest Applications - Peanuts, Rice

and Sorghum Summary. March 200 1. United States Department of Agriculture, National

Agricultural Statistics Service.

NASS, USDA. 2002. Agricultura l Chemical Usage Postharvest Applications - Wheat

Summary. March 2002. United States Departmen t of Agriculture, National Agricu ltural

Statistics Service.

NASS, USDA. 2004. Agricu ltural Chemical Usage Postharvest Applications - Com and

Soybean Summary. March 2004. United States Department of Agriculture, National

Agricultural Statistics Service.

NASS, USDA. 2006. Agricultural Chemical Usage Postharvest Applications - Peanuts

Summary. March 2006. United States Department of Agriculture, National Agricultural

Statistics Service.

NASS , USDA 2007. Agricultural Chemical Usage Postharvest Applications - Oats and

Potatoes Summary. March 2007. United States Department of Agriculture, National

Agricultural Statistics Service.

NASS, USDA. 2008. Noncitrus Fruits and Nuts 2007 Preliminary Summary. January 2008.

United States Department of Agricu lture, Na tional Agricultural Statistics Service.

Available online at:

http://u sda.mannlib.comell.edu/usda/nass/None FruiNu/12000s/20081NoncFruiNu-0 1-23-

2008 .pdf

Page 19
Phillips, T., Md. M. Hasan, M. J. Aikins, and W. Schilling. 2008. Efficacy of sulfuryl fluoride

to control ham mites and red-legged ham beetles. Presented at MBAD, Orlando, FI,

November 12, 2008 . Found at: http://mbao.org/2008/089Phillips.pdf.

USDA. 2002. Popcorn Pest Management Strategic Plan for the North Central Region. Found

at: htlp:/IW\\w.ipmcenters.org/pmsp/pdffNCRPoQCom .pdL

USDA. 2003. Crop Profile for Com (Pop) in the Uoited States (North Central Region). Found

at: http ://\\'w w.ipmcenters.org!cropproIi1esldocs/u s-ncr-popcorn.pdf

EPA. 2004. Human Health Risk Assessment for Sulfuryl Fluoride and Fluoride Anion

Addressing the Section 3 Registration of Sulfuryl Fluoride Post-Harvest Fumigation of

Stored Cereal Gra ins, Dried Fruits and Tree Nuts and Pest Control in Grain Processing

Facilities. PP#l F63 12. DP Barcode D275199. From M. Doherty, E. Budd, and B. Daiss

(Healt h Effects Division, Office of Pesticide Programs, U.S. Environmental Protection

Agency). January 20.

Ll.S. Environmental Protection Agency (EPA). 2006. Human Health Risk Assessment for

Sulfuryl Fluoride and Fluoride Anion Addressing the Section 3 Registrati on of Sulfuryl

Fluoride as a Fumigant for Foods and Food Processing Facilities. PP#3F6573. DP

Barcode D312659. From M. Doherty (Health Effects Division, Office of Pesticide

Programs, U.S. Environmental Protection Agency). January 18.

Page 20