USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 1

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

POST-HARVEST USE TREATMENT OF STRUCTURES – FOOD 

PROCESSING PLANTS

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING 

PLANTS

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Post Harvest Use on Structures -- Food Processing 

Plants (Submitted in 2012 for 2014 Use Season)

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF 

NOMINATION:

TABLE 1. QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF NOMINATION

YEAR NOMINATION AMOUNT (KILOGRAMS)

2014 22,800 kg

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone 

Secretariat website under Decision Ex. I/4(8).) 

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the 

original nomination on which the Party’s first-year exemption was approved, as well as any 

supplementary information provided by the Party in relation to that original nomination. As this 

earlier information is retained by MBTOC, a Party need not re-submit that earlier information. 

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Foreign Affairs Officer

Address: Office of Environmental Policy

U.S. Department of State

2201 C Street, N.W. Room 2657

Washington, D.C. 20520 

U.S.A.

Telephone: (202) 647-3819

Fax: (202) 647-1052

E-mail: SanMartiniFM@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) United States of America has 

determined that the specific use detailed in this Critical Use Nomination is critical because the 

lack of availability of methyl bromide for this use would result in a significant market disruption. 

■ Yes  No

Signature Name Date

Title: 
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 2

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger

Title: Division Director 

Address: Biological and Economic Analysis Division

Office of Pesticide Programs

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W. Mailcode 7503P

Washington, D.C. 20460

U.S.A.

Telephone: (703) 308-8200

Fax: (703) 308-7042

E-mail: Housenger.Jack@epa.gov

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE:

1. PAPER DOCUMENTS: 

Title of paper documents and appendices

No. of pages Date sent to Ozone 

Secretariat

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: 

*Title of each electronic file (for naming convention see notes above)

No. of 

kilobytes 

Date sent to Ozone 

Secretariat

USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING 

PLANTS

* Identical to paper documents
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 3

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

POST-HARVEST USE TREATMENT OF STRUCTURES – FOOD 

PROCESSING PLANTS

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL USE 

Food processing facilities in the United States have reduced the number of methyl bromide 

fumigations by incorporating a variety of different techniques to control pests. The most critical 

strategy implemented is integrated pest management (IPM), especially sanitation and equipment 

design modifications to enable cleaning and inspection in all areas of a facility. Facilities are 

being monitored for pest populations using visual inspections, pheromone traps, light traps, and 

electrocution traps. When insect pests are found, facilities attempt to contain the infestation with 

treatments of low volatility pesticides applied to both surfaces and cracks and crevices; spot 

treatments with heat or phosphine are 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 preventing pest outbreaks. 

However, when all these methods fail to control a pest problem, facilities must still rely on 

fumigation to kill insects in the processing equipment, bins, storage spaces, and even the walls of 

the structure. There are two primary chemical fumigants available to this industry that may 

accomplish these tasks: methyl bromide and sulfuryl fluoride. Sulfuryl fluoride is more sensitive 

to temperature and is less efficacious on insect eggs than is methyl bromide. Heat, a nonchemical option, is also used in this industry to disinfest facilities, but cannot be used in all 

situations (e.g., wood structures). 

USG is requesting methyl bromide for this sector to allow time for the industry to purchase 

equipment, modify structures, and/or gain experience using alternatives. 

It should be noted that in response to a petition, EPA has published a proposed order to revoke 

tolerances. However, sulfuryl fluoride, as ProFume®, remains registered in the U.S. for the uses 

described in this nomination chapter, and this nomination considers it to be a viable, available 

alternative. For additional information, please refer to the links on EPA’s website: 

http://www.epa.gov/oppsrrd1/registration_review/sulfuryl-fluoride/evaluations.html. 
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 4

TABLE 2. NOMINATION AMOUNT

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

This nomination is for facilities, or portions of facilities, where the use of alternatives is not 

technically suitable, or where the alternatives are not economically feasible. Sulfuryl fluoride is 

highly dependent upon temperature, so should a facility need fumigation during cold 

temperatures, this chemical may not be a cost-effective solution. Sulfuryl fluoride requires 

higher dosages for egg kill, a paramount concern in certain facilities. Phosphine can be 

explosive and is corrosive to many metals that are present in facilities, especially in the 

computers and other electronic process control instrumentation. Heat is dependent on several 

parameters: the structural composition, as different components expand and contract at different 

rates; the building design/layout factors, which affect the ability to evenly distribute heated air; 

and the availability of convenient and economical sources of heat. In addition, heat may not be a 

viable option for treatment of some food products or commodities (e.g., may cause rancidity of 

edible oils). 

In addition, there is some confusion as to the materials that may be directly fumigated with 

sulfuryl fluoride. According to the Profume® label, pet food is not listed as a material approved 

for direct treatment. The intention of the label is to have as much product removed as possible 

prior to fumigation. This “incidental” fumigation has resulted in problems with label 

interpretation. Some companies insist that all pet food products would need to be removed from 

treatment areas or sufficiently protected to prevent the formation of sulfuryl fluoride residues on 

the pet food products. This is also a factor for mills that produce mixes (e.g., cake mixes, muffin 

mixes, etc.). The need to remove as much material as possible affects both the technical 

feasibility and the cost. 

 Rice Millers Pet Food 

Institute 

 North American 

Millers Sector Total 

Quantity Requested for 2013: Amount (kgs) 2,467 4,666 18,201 25,334

Quantity Recommended by 

MBTOC/TEAP for 2013 :

Amount (kgs) 2,467 4,665 18,201 25,333

Amount (kgs) 2,467 4,665 18,201 25,333

Volume (1000 m3) 123 259 958 -

Rate 20 18 19 -

Transition from 2014 Baseline 

Adjusted Value

Percentage (%) -10% -10% -10% -

Amount (kgs) 2,220 4,199 16,381 22,800

Volume (1000 m3) 111 233 862 -

Rate 20 18 19 -

Quantity Approved by Parties for 

2013:

STRUCTURES

2014 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

Quantity Required for 

2014 Nomination:

SECTOR

Transition Use Reduction Description Spreadsheet
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 5

Millers have reported that tarping off-sulfuryl fluoride label ingredients and product is not 

practical because there could be dozens of ingredients in the facility. The ingredients and 

products that cannot be treated would have to be staged together in an open area in order to be 

covered with a tarp. The industry claims that there is not sufficient unused space in which to 

stage unlabeled ingredients and product during a sulfuryl fluoride fumigation.

The industry reports that complete removal of non-sulfuryl fluoride treatable ingredients and 

product from the target facility would present significant logistical challenges, including multiple 

forklifts and forklift drivers, plus rented truck trailers onto which the ingredients could be loaded. 

These trailers would then be removed from the facility, most likely to available space in the 

parking lot. A process that would add labor and trailer rental costs as well as costs associated 

with additional downtime needed to accomplish the ingredient removal task. 

Heat is an alternative that may be used in some facilities. In addition, heat may be used in 

conjunction with sulfuryl fluoride. However, facilities constructed primarily from wood, about 

25 percent of the flour mills in the U.S., may not be able to use heat because of warping of the 

wood. There is also a high initial investment to purchase equipment (heaters, fans, etc.), modify 

sprinkler systems, and educate personnel on heat treatments. 

USG is requesting methyl bromide for this sector to allow time for the industry to purchase 

equipment, modify structures, and/or practice using alternatives. Although EPA has proposed to 

revoke the tolerances of sulfuryl fluoride (see copy of the proposed order to revoke tolerances

and for additional information, please refer to the links on EPA’s website: 

http://www.epa.gov/oppsrrd1/registration_review/sulfuryl-fluoride/evaluations.html), it remains 

a viable alternative and this USG nomination has considered sulfuryl fluoride to be available.

3. RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES

Fumigants

The 2010 MBAO presentations included reports of several structural alternatives to methyl 

bromide. Horn et al. (2010) presented a study on the use of a system that facilitates efficacious 

phosphine treatments with lower concentrations of the gas (i.e., Horn Diluphos system). By 

using phosphine without ammonia, using constant low concentrations of phosphine, painting 

exposed metals (i.e., copper and its alloys), wrapping electronic equipment in plastics, and 

injecting fresh air, the study Horn et al. (2010) showed that efficacious but less corrosive levels 

of phosphine could be maintained with their diluphos system. 

Hartzer et al. (2010) compared methyl bromide, sulfuryl fluoride, and heat treatments in the 

Kansas State University flour mill. The efficacy results of the sulfuryl fluoride and methyl 

bromide treatments were not significantly different. However, the heat treatments were not as 

efficacious as the fumigants. There were some adult and larval survival with the heat treatment 

(Hartzer et al., 2010). 

Arthur et al. (2010) summarized the residual efficacy of pyrethrin plus insect growth regulator 

aerosols on red and confused flour beetles. Confused flour beetles were less susceptible to the 
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 6

aerosols than were red flour beetles. The aerosol mixtures provided residual control, up to 16 

weeks, for the 3% pyrethrin plus methoprene. Surface composition also affected the variation of 

residual control of the mixtures. The researchers found that plastic overwrap provided longer 

control than did paper bags. (Arthur et al., 2010)

Holcomb and McLean (2010) reported on an IPM approach in pet food processing plants and 

warehouses. The authors have had success in controlling pests in these facilities for over 5 years. 

They ensure outside sanitation around plants and warehouses. They also try to reduce 

introducing pests by inspecting incoming ingredients and goods to ensure they are “clean;” 

maintaining screens at windows and doors; and placing lights so that insects are not attracted to 

openings. Microsanitation and pest control access are stressed in Holcomb and McLean’s (2010) 

IPM approach. Holcomb mentioned during his MBAO (2010) presentation that companies need 

to hire a sanitation team to ensure that the facility and all equipment could be thoroughly cleaned 

every 30 days to break the life cycle of stored product pests (which is typically about 45 days). 

(Holcomb and McLean, 2010)

A USDA-NIFA Methyl Bromide Transition Grant is supporting an investigation of the major 

pests in the rice mills, and the spatial and temporal distribution of those pests within the rice mill. 

The results thus far have determined that the red flour beetle is the major pest. Preliminary 

investigation has shown that similar to flour mills, the populations inside a mill are higher when 

outside populations are higher. The focus is to develop an integrated pest management program 

and to determine the impact of sanitation on residual insecticides. This multiyear investigation 

also includes economic costs of control, and will incorporate information into the existing webbased management system. (Arthur et al., 2011a) 

Further investigations into aerosol treatments in sheds demonstrated some variation. In one test 

block, adult red flour beetles stayed in food patches, but in another block, adults moved more 

and had little development in the food patches. When adults were active, higher efficacy of 

aerosol applications occurred as evidenced by trap catch and dead insects. This was not the case 

when adults were not active. Authors intend to study further for explanations. Future tests also 

include trying to understand movement patterns; synergized pyrethrins and methoprene and 

using a series of covers for the food patches; and new foggers. In addition to those shed tests, 

more trials in the field are being planned. (Arthur et al., 2011b) 

4. ECONOMIC IMPACTS

TABLE 3. ECONOMIC SUMMARY FOR EACH ALTERNATIVE

METHYL BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

HEAT TREATMENT

For most facilities, i.e., those not constructed primarily of wood, it is feasible to switch to 

heat treatments. Some facilities experience better insect control with heat than fumigation 

due to leaky structures that allow gas to escape. 

SULFURYL FLUORIDE

Sulfuryl fluoride is an economically viable option for most food processing facilities. 

Exceptions include facilities that manufacture products not on the ProFume®label, e.g.,

cake mixes, pet food facilities.
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 7

Two economic analyses were conducted – one for pet food facilities, and one for mills and other 

food processing facilities. Pet food facilities are conducted separately because the industry 

supplied its own revenue data. For other facilities, the available data were a budget for a 500,000 

cubic foot flour mill.

It is important to note that sulfuryl fluoride is only considered to be technically feasible in 

facilities that do not prepare mixed products (e.g., cake mixes) due to labeling.

Pet Food Facilities

Many pet food manufacturing and storage facilities have converted to alternatives; the Pet Food 

Institute (PFI) estimates that less than 10 percent of pet food manufacturing facilities, generally 

older facilities, still use methyl bromide. In previous analyses (e.g., Ranville and Cook, 2011), 

the Agency has assumed that no additional days of downtime are necessary for heat treatment 

based on published estimates of time for heating a facility (e.g., Beckett et al., 2007). Although 

it could take slightly longer in some cases to conduct heat disinfestation of an entire facility than 

it would to conduct MeBr disinfestation, heat has the advantage of being safe to use in parts of 

the facility while the facility is still operating, a situation which would not be possible with 

chemical fumigants due to the possibility of chemical exposure. Based on the available 

information, additional days of downtime were not factored into the economic analysis of 

transition to heat. EPA used information obtained on the costs of heat treatment when a facility 

opts to purchase its own equipment (e.g., heaters, fans, ductwork, etc.). These costs are not 

industry specific. 

Table 4 displays the results of the economic analysis of transition to heat for a 28,300 cubic 

meter (1 million cubic foot) mill, the average size pet food mill according to the application. 

Cost information from Adam et al. (2010) was used for the analysis to reflect the average plant in 

the pet food industry. Percent change in gross revenue was used to compare heat disinfestation 

when a facility uses its own equipment with methyl bromide disinfestation. The first heat 

column reflects the cost of treatment plus the annualized cost of heating equipment (e.g., heaters, 

fans, ductwork, etc.) over ten years. The second heat column displays the cost of treatment only 

that would apply after heating equipment was purchased.
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 8

Table 4. Analysis of transition to heat treatments for pet food facilities 1

 Methyl Bromide 

Heat (purchase 

own equipment) 

Heat (purchase 

own equipment, 

post initial 

investment period) 

Size of facility to be treated (cu m) 28,300 28,300 28,300

Total Revenues/Sales 2 $ 33,176,000 $ 33,176,000 $ 33,176,000

Cost of Disinfestation 

3, 4 $ 37,700 $ 55,600 $ 30,700

Change in cost from MeBr to alternative $ 17,900 $ -7,000

% change in gross revenue from MeBr -0.05% 0.02%

1 Numbers may not add due to rounding; all figures are rounded to the nearest hundred. 

2 Revenues are estimated at $116,000 per day times 5.5 operating days per week or 286 operating days per year.

3 Disinfestation costs for methyl bromide based on figures from Adam et al. (2010), adjusted for changes in price 

of gas. Analysis assumes two MeBr fumigations per year. Assumes gas price of approximately $33.00 per kg 

($15.00 per lb) and application rates of approximately 15.4 g/cu m (0.96 lbs/cu ft) for methyl bromide.

4 Costs of heating equipment and energy needed to run heaters from TempAir. Analysis assumes three heat 

treatments per year. The first heat column assumes the facility is in an initial ten year investment phase when 

it is paying for the heaters and the cost of energy and materials for fumigation. Initial cost of heaters for a 

28,300 cubic meter facility is approximately $249,000, or $14,900 spread over ten years. The cost of energy and 

materials for each fumigation of a 28,300 cubic meter facility is approximately $10,229 after the initial 

investment period in the heaters.

Mills and Other Food Processing Facilities

Revenue data for flour mills were available in a sample budget; revenue data specific to rice 

mills were not publicly available, so the available data for the sample flour mill were used to 

estimate impact for both types of mills as well as other food processing facilities.

Two alternatives were considered for mills – sulfuryl fluoride and heat treatments. An average 

application rate of 1.35 lbs/1,000 cu ft (21.6 g/ cu m) was assumed for methyl bromide and 2.5 

lbs/1,000 cu ft (40.0 g/cu m) was assumed for sulfuryl fluoride. The two heat scenarios 

compared were contract service or a pay per treatment where the facility does not purchase its 

own equipment and a scenario, similar to pet food facilities, where the mills purchase their own 

equipment. A cost of $80/1,000 cu ft was used for the estimate of heat under a pay-per-treatment 

scenario. The same estimates used for pet food facilities were used in the mills analysis, but the 

investment period was stretched over twenty years. 

Sample revenue and cost data were available for a 14,200 cubic meter (500,000 cubic foot) flour 

mill, so the analysis was based on this information. Table 5 displays the economic analysis of 

transition to sulfuryl fluoride and heat from methyl bromide. 
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 9

Table 5. Analysis of transition to alternatives for mills and other food processors 1

 

Methyl 

Bromide 

Sulfuryl 

Fluoride 

Heat (pay per 

treatment)6 

Heat (purchase 

equipment)7 

Size of facility to be treated (cu m) 14,200 14, 200 14, 200 14, 200

Total Revenues/Sales 2 $ 32,277,000 $ 32,277,000 $ 32,277,000 $ 32,277,000

Operating Costs $ 28,281,000 $ 28,281,600 $ 28,326,200 $ 28,269,700 

Annual Cost of Disinfestation 

3 $ 34,900 $ 35,400 $ 80,000 $ 23,600 

Total cost of gas per treatment ($) $ 10,104 $ 9,355 na Na

 Price of fumigant gas ($/kg)

4 $ 33.00 $ 16.50 na Na

 Gas needed per fumigation (kgs) 5 306 567 na Na

Total application costs /treatment ($) $ 7,300 $ 8,300 $ 40,000 $ 11,800

 Cost of application ($/1,000 cu m) $ 518 $ 590 $ 2,825 Na

Net Revenue $ 3,996,000 $ 3,995,500 $ 3,950,900 $ 4,007,300 

Change in cost from MeBr to alternative $ 500 $ 45,100 $ (11,300)

% change in net revenue from MeBr -0.01% -1.13% 0.28%

1 Numbers may not add due to rounding; some figures are rounded to the nearest hundred. 

2 Revenues from sample budget (Kenkel and Holcomb, 2004); 10-year avg, rounded to nearest hundred.

3 Disinfestation costs for methyl bromide and sulfuryl fluoride, except for fumigant gas prices, based on figures 

from Adam et al. (2010), adjusted for changes in size of facility. Analysis assumes two fumigations per year for 

methyl bromide and sulfuryl fluoride, and two heat treatments. 

4 Assumes gas price of $33.00 per kg ($15.00 per lb) for methyl bromide and $16.50 per kg ($7.50 per lb) for 

sulfuryl fluoride.

5 Assumes application rates of 21.6 g/cu m (1.35 lbs/1,000 cu ft) for methyl bromide and 40 g/cu m (2.5 

lbs/1,000 cu ft) for sulfuryl fluoride. 

6 This column displays heat costs based on the assumption that the mill purchases heat treatment service and 

does not purchase its own equipment. The price is an average of estimates provided in the rice and flour mills 

CUE applications.

7 This column displays heat costs based on the assumption that the mill purchases its own heaters and other 

necessary equipment. The application costs per treatment include the cost of heaters, fans, sensors, ductwork, 

and natural gas. A usable life of 20 years is assumed for the heaters and fans to calculate an annual cost average. 

Raw cost estimates were provided by TempAir in 2010. 

CONCLUSION

This nomination is for facilities, or portions of facilities, where the use of alternatives is not 

technically suitable or where the alternatives are not economically feasible. Sulfuryl fluoride 

requires higher dosages for egg kill, a paramount concern in certain facilities. Heat is dependent 

on several parameters: the structural composition, as different components expand and contract 

at different rates; the building design/layout factors, which affect the ability to evenly distribute 

heated air; and the availability of convenient and economical sources of heat. 

USG is requesting methyl bromide for this sector to allow time for the industry to purchase 

equipment, modify structures, and/or gain experience using alternatives. 
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 10

It should also be noted that in response to a petition, EPA has published a proposed order to 

revoke tolerances. However, sulfuryl fluoride, as ProFume®, remains registered in the U.S. for 

the uses described in this nomination chapter, and this nomination considers it to be a viable, 

available alternative. For additional information, please refer to the links on EPA’s website: 

http://www.epa.gov/oppsrrd1/registration_review/sulfuryl-fluoride/evaluations.html. 

CITATIONS

Adam, B. D., Bonjour, E. L., & Criswell, J. T. (2010). Cost Comparison of Methyl Bromide 

and Sulfuryl Fluoride (ProFume®) for Fumigating Food Processing Facilities, 

Warehouses, and Cocoa Beans. 10th International Working Conference on Stored Product 

Protection, 27 June-2 July 2010, Portugal, Estoril Congress Center. Available at 

http://pub.jki.bund.de/index.php/JKA/article/viewFile/495/446. Accessed July 19, 2010. 

Arthur, F. H., A. E. Sutton, K. Y. Zhu, and J. F. Campbell. 2010. Residual efficacy of 

pyrethrin-methoprene aerosols on packaging surfaces. Presentation at MBAO, Nov. 2-5, 

2010, Orlando, Fl. Available at: http://mbao.org/2010/64Arthur.pdf. 

Arthur, Frank H., L. Ted Wilson, Yubin Yang, James F. Campbell, Tanja McKay, Brian Adam, 

and Thomas E. Reagan. 2011a. Insect pest management in rice mills. Presentation at the 

2011 Annual International Research Conference on Methyl Bromide Alternatives, San 

Diego, CA, Oct 31-Nov 2, 2011. Available at: http://mbao.org/2011/57Arthur%201.pdf. 

Arthur, F. H., J. F. Campbell, E. A. Fontenot. 2011b. Efficacy of Insecticide Treatments on 

Resident Populations of the Red Flour Beetle. Presentation at the 2011 Annual International 

Research Conference on Methyl Bromide Alternatives, San Diego, CA, Oct 31-Nov 2, 2011. 

Available at: http://mbao.org/2011/58Arthur%202.pdf. 

Beckett, S. J., Fields, P. G., & Subramanyam, Bh. (2007). Disinfestation of Stored Products and 

Associated Structures Using Heat. In J. Tang, E. Mitcham, S. Wang, & S. Lurie (Eds.), Heat

Treatments for Postharvest Pest Control Theory and Practice (pp. 182-237). CABI 

International, Wallingford, UK. [online] Available at 

http://home.cc.umanitoba.ca/~fieldspg/fields/heat-rev.pdf. Accessed July 15, 2010.

Brijwani, M., B.Subramanyam, M. Hartzer, D. E. Maier, W. Chayaprasert, S. Savoldelli, P. 

Flinn, and J. Campbell. 2009. Efficacy of structural heat treatments against Tribolium 

castaneum life stages. Presentation at Methyl Bromide Alternatives Outlook Conference, 

San Diego, November 2009. Available at: http://mbao.org/2009/066Brijwani.pdf. 

Hartzer, M. Subramanyam, B., Brijwani, M., Chayaprasert, W., and Maier, D. E. 2010. Methyl 

bromide, sulfuryl fluoride and heat: effectiveness against red flour beetle. Presentation at 

MBAO, Nov. 2-5, 2010, Orlando, Fl. Available at: http://mbao.org/2010/67Hartzer.pdf. 

Hartzer, M., B. Subramanyam, W. Chayaprasert, D. E. Maier, and S. Savoldelli. 2009. Methyl 

Bromide and Sulfuryl Fluoride Effectiveness Against Red Flour Beetle Life Stages. 

Presentation at Methyl Bromide Alternatives Outlook Conference, San Diego, November 

2009. Available at: http://mbao.org/2009/072Hartzer.pdf. 
USA CUN14 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 11

Holcomb, M. and M. McLean. 2010. An IPM approach to methyl bromide replacement: in pet 

food processing plants and warehouses. Presentation at MBAO, Nov. 2-5, 2010, Orlando, Fl. 

Available at: http://mbao.org/2010/65Holcomb.pdf. 

Horn, P., Horn, F. and Rogers, M. 2010 Automated structural fumigations with phosphine using 

the Horn Diluphos System. Presentation at MBAO, Nov. 2-5, 2010, Orlando, Fl. Available 

at: http://mbao.org/2010/066HornP.pdf. 

Kenkel, P., & Holcomb, R. 2004. Flour Milling Feasibility Template. Oklahoma State 

University. [online] Available at agecon.okstate.edu/coops/files/flour_milling_template_4-5-

2004.xls. Accessed July 13, 2010. 

Ranville, M. and Cook, C. 2011. Assessment of Impacts on Flour Mill Operators of a Stay in 

Sulfuryl Fluoride Food Tolerances. U.S. Environmental Protection Agency.