USA CUN 14 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 TI TLE OF NOMINATION : Methyl Bromide Critical Use Nomination for Post Harvest Use on Structures

-- Food Processing Plants (Submitted in 201 2 for 2014 Use Season)

QUANTITY OF METHYL B ROMIDE REQUESTED IN EACH YEAR OF

NOMINATION:

T ABLE 

### 1. Q UANTITY OF 

### M ETHYL 

### B ROMIDE 

### R EQUESTED IN 

### E ACH 

### Y EAR OF 

### N OMINATION



### Y EAR 

### N OMINATION 

### A MOUNT 

### ( 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 CUN 14 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 documentsUSA CUN 14 POST HARVEST STRUCTURES

- FOOD PROCESSING PLANTS Page 

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## METHYL BROMIDE CRITICAL USE RENOMINATION FOR

POST

- HARVEST USE TREATMENT OF STRUCTURES

– FOOD

PROCESSING PLANTS

1. SUMMARY OF NEED FOR METHYL BROMIDE A S 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 ) , especial ly 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 insec t 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 ingredient s 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 pre venting 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 non

chemical 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, s ulfuryl fluoride, as ProFume ® 

### , remains registered in the U.S. for the uses

described in this nomin ation 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 CUN 14 POST HARVEST STRUCTURES

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### 4

T ABLE 

### 2. N OMINATION 

### A MOUNT



### 2. SUMMARIZE WHY KE Y ALTERNATIVES ARE N OT 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

- effe ctive 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.USA CUN 14 POST HARVEST STRUCTURES

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Millers have re ported 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 becaus e 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 in dustry 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 remai ns a viable alternative and this US G 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) present ed 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 met als (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 treatme nts were not as
efficacious as the fumigants. T here w ere 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 theUSA CUN 14 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

wareho uses. 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 t hey 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 MB AO (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 M cLean, 2010)

A USDA

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

pes ts in the rice mills, and the spatial and temporal distribution of those pests with in 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 e conomic costs of control, and will incorporate information into the existing web

based 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 i n 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., 201 1b)

4. ECONOMIC IMPACTS

T ABLE 

### 3. E CONOMIC 

### S UMMARY FOR EACH 

### A LTERNATIVE

M ETHYL B ROMIDE
A LTERNATIVE E CONOMIC S UMMARY

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

heat treatments. S ome facilities experience better insect control with heat than fumigation due to leaky structures that allow gas to escape.

S ULFURYL F LUORIDE Sulfuryl fluoride is an economically viable option for most food processing facilities.

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

, cake mixes, pet food facilities.USA CUN 14 POST HARVEST STRUCTURES

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T wo 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 s ulfuryl 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, 20 11 ), the Agency has assumed that no additional days of downtime are nece ssary 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 disi nfestation, 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

inf ormation, additional days of downtime were not factored into the economic analys is 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 28,3 00 cubic meter ( 1 million cubic foot ) mill, the average size pet food mill according to the application.

C ost information f

rom Adam et al. (2010) was used for the analysis to reflect the average plant in the pet food industry

. P ercent 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

. T he second heat column displays the cost of treatment only that would apply after heating equipment was purchased.USA CUN 14 POST HARVEST STRUCTURES

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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) 28,3 00 28,3 00 28,3 00



### 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 $ 17,9 00 $

- 7

, 0 00 

### % change in gross revenue from MeBr

- 0.0 5 % 0.0 2 %

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

28,3 00 cubic meter facility is approximately $249,000, or $14,900 spread over ten years. The cost of energy and

materials for each f

umigation of a 28,3 00 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 w ere 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 sulfur yl 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 we re available for a 14, 200 cubic meter (500,000 cubic foot) flour mill, so the analysis was bas ed on this information. Table 5 displays the economic analysis of transition to sulfuryl fluoride and heat from methyl bromide.USA CUN 14 POST HARVEST STRUCTURES

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Table 5 . Analysis of transitio n 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, 277,0 00 $ 32, 277,0 00 $ 32, 277,0 00 $ 32, 277,0 00 

### Operating Costs $ 28,281,000 $ 28,281,6 00 $ 28

, 326

, 2 00 $ 28,269,7 00

Annual Cost of Disinfestation 3 $ 34,9 00 $ 35,400 $ 8 0 ,000 $ 23,600 Total cost of gas per

treatment ($) $ 10,104 $ 9,355 n a N a Price of fumigant gas ($/kg ) 4 $ 33.00 $ 16.50 n a N a

G as needed per fumigation ( kg s) 5 306 567 n a N a Total application costs /treatment ($) $ 7,300 $ 8,300 $ 40,000 $ 11, 800
Cost of application ($/1,000 cu m ) $ 518 $ 590 $ 2,825 N a



### Net Revenue $ 3,996,000 $ 3,995,5 00 $ 3,950,9 00 $ 4,007,3 00 

### Change in cost from MeBr to alternative $ 500 $ 45,1 00 $ ( 11,3 0 0 ) 

### % change in net revenue from MeBr

- 0.0 1 %

- 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

, 20 04 ) ; 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 tw o 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 meth yl bromide a nd $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 assu mption 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 calcul ate 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 ec onomically 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; t he 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 CUN 14 POST HARVEST STRUCTURES

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It should also be noted that in response to a petition, EPA has published a proposed ord er 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 r efer to the links on EPA’s website: http://www.epa.gov/oppsrrd1/registration_review/sulfuryl

- fluoride/evaluations.html

.

C ITATIONS

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. 10 th 

### International Working Conference on Stored Product

Protec tion, 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.or g/2010/64Arthur.pdf

. Arthur, Frank H., L. Ted Wilson, Yubin Yang, James F. Campbell, Tanja McKay, Bri an Adam, and Thomas E. Reagan. 2011a. Insect pest management in rice mills. Presentation at the 2011 Annual International Research Conference on Methyl Br omide 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 Methy l 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

200 9. Available at: http://mbao.org/2009/072Hartzer.pdf

.USA CUN 14 POST HARVEST STRUCTURES

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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. Pr esentation 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] Av ailable 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.