USA CUN13 POST HARVEST COMMODITIES 1

METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST -- COMMODITIES

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN13 POST HAVEST USE FOR COMMODITIES

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Post Harvest Use on Commodities (Submitted in 

2011 for 2013 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)

2013 822 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: John Thompson

Title: Division Director

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) 647-9799

Fax: (202) 647-5947

E-mail: Thompsonje2@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) The 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 CUN13 POST HARVEST COMMODITIES 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 CUN13 POST HARVEST: COMMODITIES

* Identical to paper documents
USA CUN13 POST HARVEST COMMODITIES 3

METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST -- COMMODITIES

1. SUMMARY OF NEED FOR METHYL BROMIDE

Commodity fumigation with methyl bromide is used primarily at harvest time, when rapid 

fumigation is needed to keep up with the large volumes of incoming commodities and when 

commodities are in storage. 

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

equipment, build chambers, modify structures, and/or practice using alternatives. 

Sulfuryl fluoride, as ProFume®, remains registered for the uses included in this nomination in the 

US. However, EPA has published a prepublication copy of the proposed order to revoke 

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

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

TABLE 2. NOMINATION AMOUNT 

 California

Dried Plum 

Board 

 California 

Walnut

Commission 

 California Date

Commission 

 Sector Total / 

Average

Quantity Requested for 2012: Amount (kgs) 3,317 558 1,063 4,938

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 829 527 1,063 2,419

Amount (kgs) 829 527 1,063 2,419

Volume (1000 m3) 392 130 97 619

Rate 2 4 11 4

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -66% -66% -66% -66%

Amount (kgs)

 282 179 361 822

Volume (1000 m3) 138 12 51 201.4

Rate 2 14 7 4

Quantity Required for

2013 Nomination:

Quantity Approved by Parties for 

2012:

SECTOR

COMMODITIES

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

This sector includes walnut, dried fruit (prunes, raisins, figs), and dates, all of which are subject 

to infestation by several insect pests. Since infestation begins in the field, methyl bromide is 

used to rapidly fumigate harvested commodities and to disinfest commodities in storage. Most 

fumigation occurs over several weeks, during the peak production season, as the bulk of the 

harvest moves from the field into storage and shipping channels. Upon arrival from the field, 

each load is fumigated with methyl bromide in preparation for shipment to national and 

international markets. 
USA CUN13 POST HARVEST COMMODITIES 4

Research with sulfuryl fluoride indicates that this fumigant is a potential methyl bromide 

alternative for commodities, provided fumigation occurs at temperatures above 70 oF. Recent 

studies have shown that under vacuum or atmospheric conditions, sulfuryl fluoride is effective 

against adult, pupal, and larval stages of stored product pests. The ovicidal efficacy of sulfuryl 

fluoride is dependent upon temperature and exposure time. 

Walnuts – Quick turn-around time for walnuts at peak harvest time is the primary justification 

for methyl bromide use in this sector. Vacuum fumigation with methyl bromide may take 4-6 

hours and atmospheric fumigation approximately 8-24 hours. Phosphine gas fumigation takes 

approximately three days and is being used to fumigate walnuts in storage. 

The industry experts further observe that the walnut industry fumigates during 6 months of the 

year at or below 50 °F and provide supporting temperature data for the San Joaquin and 

Sacramento Valleys of California, their main production areas. 

Dates - Methyl bromide is used to rapidly fumigate California dates at harvest time, when up to a 

million pounds per day are being harvested within a relatively tight timeframe during the fall. 

Although several insect may infest dates, the carob moth, Ectomyelois ceratoniae, is the more 

damaging species. The California Date Commission reports that it is currently testing the 

efficacy of sulfuryl fluoride on dates, in collaboration with Dow AgroSciences and Dr. Spencer 

Walse of USDA. The applicant reports that preliminary results show less than adequate egg kill,

even when the amount used is twice that needed for comparable methyl bromide fumigation. 

Phosphine takes longer to fumigate dates, and during this time fermentation and off-flavor can 

occur. 

Dried Fruit – Methyl bromide is used to disinfest dried fruit in storage when the fruit is stored at 

processing facilities. Phosphine would corrode the electrical and electronic equipment in the 

processing areas. Phosphine also takes longer to fumigate and would consequently shut down 

the processing area as well. Sulfuryl fluoride is currently labeled for use on dried fruit; however, 

research results presented at the 2009 MBAO meeting (Walse et al., 2009), the indicate that 

under low temperatures and current label rates efficacy is inadequate against dried fruit beetle, 

red flour beetle, and Indianmeal moth eggs. The California Dried Plum Board reports that 

commodities cannot always be treated at 80 oF and that control of egg stages of target pests is 

imperative. 

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

equipment, build chambers, modify structures, and/or practice using alternatives. The current 

registration of sulfuryl fluoride, as ProFume®, remains unchanged in the US for the uses included 

in this nomination. However, EPA has published a prepublication copy of the proposed order to 

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

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

3. SUMMARY OF RECENT RESEARCH 
USA CUN13 POST HARVEST COMMODITIES 5

Walse, et al. (2009) have demonstrated that sulfuryl fluoride does not readily kill egg stages of 

navel orangeworm or the eggs of several stored product insects at temperatures below 70° F at or 

below maximum label rates. USDA/ARS researchers plan to continue testing the efficacy and 

practicality of using sulfuryl fluoride, relative to methyl bromide, to control post-harvest pests of 

nuts and dried fruit. Sulfuryl fluoride thus appears to be an effective methyl bromide alternative 

for in-shell walnuts. 

The applicants believe that further research is needed on the ovicidal efficacy of sulfuryl fluoride

at temperatures below 70 °F, as well as on the ovicidal efficacy of propylene oxide/sulfuryl 

fluoride combinations. The California Walnut Commission is providing funding to the Dried 

Fruit Association of California to continue its investigations of combinations of PPO and sulfuryl 

fluoride and carbon dioxide. Muhareb, et al. (2009) presentation at the 2009 MBAO that adding 

carbon dioxide increased the larval efficacy of the PPO+SF mixture. The combination also was 

more efficacious on eggs. 

Past data showed RFB larvae fumigated with PPO had an LD95 using 606 

mg.h/l SF is just the opposite requiring higher CT product for the eggs, LD95

966 mg.h/l,10% CO2 was the most effective. Without CO2, combining the two 

fumigants together showed a LD95 of 432 on RFB eggs and a LD95 of 353 on 

RFB larvae. Adding 10% CO2 reduces the dosages by about two-thirds of the 

fumigants used alone. The CO2 along with the synergy of the blend reduces 

cost, lowers environmental emission and provides greater safety. 

Reichmuth and Klementz presented at the 2009 MBAO possible investigations to overcome the 

egg weakness of sulfuryl fluoride. These included combinations of gases such as sulfuryl 

fluoride with phosphine, or carbon dioxide. They also proposed using heat to increase the 

efficacy of sulfuryl fluoride. Their preliminary data demonstrated that these combinations show 

promise for many stored product pests of dried fruits and tree nuts. 

Reichmuth, also at the 2009 MBAO, presented data regarding sulfuryl fluoride efficacy on the

eggs of the rice moth Corcyra cephalonica. He showed that older eggs were more tolerant of 

sulfuryl fluoride than were the young eggs. His data show that increasing the exposure time the 

difference between the ages of the eggs is reduced and disappears. 

Full control was achieved at a concentration of 4.19 mg/l only after 5 days 

of fumigation (ct=120 x 4.19mgh/l=502mgh/l) 5.24 mg/l were sufficient to 

control all investigated eggs with exposure of 4 days (ct=503 mgh/l) and 5 

days (ct=628 mgh/l), as well as three days old eggs with 3 d fumigation 

(ct=377 mgh/l). 3 days fumigation served to kill all eggs of all ages with 

6.24 mg/l (ct=449mgh/l). These ct-products are in range with 

corresponding values for lethal ct products for the other related stored 

product pest moths Ephestia kuehniella, Plodia interpunctella and 

Ephestia elutella (Baltaci et al., 2006). “
USA CUN13 POST HARVEST COMMODITIES 6

Williams (2009),of Dow AgroSciences, presented the results of sulfuryl fluoride investigations 

on carob moth (Ectomyelosis ceratonia) in freshly harvested dates. Complete mortality of eggs 

and larvae was achieved with 332 oz-h/MCF (g-h/m3) CT (concentration x time) dosage of 

ProFume at 21°C (70°F) during a 14-h exposure. Compare that to 1.5 lb/MCF of MB, for 

chambers with a moderate HLT of 20 h and a short, overnight exposure of 16 h. 

Chamber fumigation needing a quick overnight turnaround represents 

30% of the production fumigation. The remaining 70% of the fumigations 

occur in 5.0-MCF stacks of bins under tarps in the open yard, when time is 

not critical and the tarps may be kept sealed for weeks or even months. 

With the anticipated 50+ h HLT actually measured with the tarps by this 

PI in 2007, a fumigation using only 1.3 lb/MCF of ProFume would require 

16 h to achieve 300 oz-h/MCF for carob moth control. Further gas 

savings can occur by extending the exposure time. At 50-h HLT and 72-h 

exposure, a 300 oz-h/MCF CT dosage for ProFume can be achieved 

applying only 0.4 lb MCF. 

These considerations of CM efficacy at 300 oz-h/MCF CT dosages 

combined with good HLT, which can be achieved with good structural 

sealing techniques, demonstrate that ProFume is an equivalent (weight: 

weight) alternative to MB in fresh dates for short-exposure overnight 

fumigations. When extended exposures are possible in tarped stacks, 

ProFume becomes superior (weight: weight) to MB. This research 

demonstrates that in all aspects (technical, practical & economical), 

ProFume is a viable alternative to MB for fumigation in dates and is 

available as an immediate industry replacement for MB. 

Hosoda (2009), of Cardinal Professional Products, presented an update of sulfuryl fluoride uses 

in post-harvest at both the 2009 and 2010 MBAO conferences. Mr. Hosoda reported that 

walnuts began to transition to sulfuryl fluoride in 2008, and made rapid progress in 2009 away

from methyl bromide. Mr Hosoda reported:

One of the concerns with some of the major processors was the control 

of the egg stage of the Navel orangeworm, which is primarily a field 

pest that comes in with the product after harvest. It has recently been 

found that it is critical to control the egg stage of the Navel 

orangeworm, when it was once considered to be a field pest that 

cannot proliferate in storage. Dow AgroSciences funded a project 

with the Dried Fruit and Tree Nut Association (American Council for 

Food Safety and Quality) to evaluate ProFume’s® efficacy on walnuts 

infested with Navel orangeworm eggs. The results showed that 

ProFume®, when applied under vacuum, will effectively control over 

99% of the egg stage. USDA recently performed efficacy studies 

under similar conditions with methyl bromide, and found egg survival 
USA CUN13 POST HARVEST COMMODITIES 7

to be 31%-43% depending on the dose. These data created a comfort 

level for the last few processors to make the conversion to ProFume®.

Dr. Thoms, of Dow AgroSciences, also provided an update on ProFume at MBAO in 2008

(Williams and Thoms, 2008):

Dow AgroSciences continues to work with post-harvest processors to 

document commercial suitability of ProFume for fumigating 

commodities. As a follow-up to the initial commercial fumigation 

trials in fresh dates reported at this conference last year, product bins 

full of dates and stacked in the same 142 m3(5 Mcf) commercial 

fumigation chamber used in previous trials were exposed to ProFume 

for 15.6 hours at 21° C (70° F) in April 2008. All-life-stage culture 

bioassays of dried fruit beetle (Carpophilus hemipterus) buried about 

30 cm (1 ft) deep in separate bins in the stacks showed 100% control 

in three of the four culture replicates exposed to a range of 536-636 gh/m3

(oz-h/Mcf) and 98.5% control in the fourth replicate exposed to 

598 g-h/m3. These results are more favorable in both performance and 

subsequent economics than previous findings. Following necessary

repairs to the fumigation chamber to again provide the 35-h HLT 

observed in the first set of trials in 2006, the same average 582 g-h/m3

observed in this trial would be achieved with an equivalent of 32 g/m3

(2.0 lb/Mcf). This would be an arguably cost-effective 1.5X the 

historically standard MB dose of 21 g/m3(1.3-lb/Mcf) that could 

provide nearly 100% control of all life stages of dried fruit beetle 

infesting fresh dates.

However, investigations into other alternatives have been reported at MBOA as well. Mr. 

Hosoda, (2008) reported that ECO2FUME and VAPORH3 were also being used as methyl

bromide alternatives in many different commodities. 

Although most phosphine applications require a longer exposure 

period than methyl bromide, users have made adjustments in their 

production schedules and have invested in additional fumigation 

chambers to accommodate the use of these alternatives. 

A major nut processor made the transition to VAPORPH3OS® in their 

long-term nut storage bins where short term fumigations are not 

required. This company initially converted to ECO2FUME® for these 

applications, but required such a large volume of cylinders, it made 

economical sense (by purchasing a Fosfoquim HDS-200®) to 

implement VAPORPH3OS®in their fumigation program. This use 

eliminated approximately 50,000 lbs. of methyl bromide per year.

Almond, pistachio, fig, bean and raisin processors have all replaced 

thousands of pounds of methyl bromide with 
USA CUN13 POST HARVEST COMMODITIES 8

ECO2FUME®/VAPORPH3OS®. Wherever short term fumigations 

are not absolutely necessary, cylinderized phosphine fumigants have 

become a suitable option, and are very economical to use. 

International acceptance of phosphine residues (MRL) also make 

phosphine a logical choice as an alternative fumigant.

4. ECONOMIC ANALYSIS OF TRANSITION TO ALTERNATIVES

TABLE 3. ECONOMIC SUMMARY FOR EACH ALTERNATIVE

METHYL BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

PHOSPHINE

PO3 is a viable alternative for walnuts and dried fruit but not for dates. In the case of both 

walnuts and dried fruit, use of phosphine as a primary fumigant will require purchase of 

additional fumigation chambers due to longer fumigation time. Economic losses will be 

incurred initially as a result of investment in additional chambers. This loss will be greater 

for walnuts. 

SULFURYL 

FLUORIDE

SF is a viable alternative for walnuts, dried fruit, and dates. SF costs less per lb than MeBr, 

but application rates may be higher. Higher application rates will not change.

A separate economic analysis of alternatives was conducted for each commodities sub-sector: 

walnuts, dried fruit, and dates. The economic analyses of transition to alternatives are based on 

the cost of transitioning the total commodity treated with quantity granted by the Parties for 2012 

to the technically feasible alternatives. For the year 2012, the Parties granted 527 kgs for 

walnuts, 829 kgs for dried fruit, and 1,063 kgs for dates. 

The analyses focus on the differences in the cost of fumigant gas and the cost of fumigation 

space (i.e., fumigation chambers) between methyl bromide and alternatives. The analysis of 

fumigation space is applicable to a transition to phosphine for walnuts and dried fruit. Transition 

to phosphine in these sectors would require an initial investment in additional chambers. In dried 

fruit, the number of chambers needed is expected to be small since there is not a “harvest 

window” issue. The chambers are needed to avoid the need to fumigate in the storage 

warehouse. In the case of walnuts, many more additional chambers will be needed to 

accommodate the throughput during the harvest window. Since phosphine takes five times as 

long as methyl bromide or sulfuryl fluoride, five times as many chambers would be necessary. 

Due to the need to purchase additional fumigation space, there would be an initial investment 

cost in the first year to purchase additional fumigation chambers. After the first year, however, 

the cost of fumigating with phosphine would be lower than fumigating with methyl bromide 

because the cost of the gas and the application rates are considerably lower. The cost to 

transition to SF is negligible for both walnuts and dried fruit. 

In the case of dates, sulfuryl fluoride is the only viable alternative. Fumigation with sulfuryl 

fluoride requires slightly higher application rates, but the transition results in a small cost savings 

due to its lower price relative to methyl bromide. 

Walnuts
USA CUN13 POST HARVEST COMMODITIES 9

The United States walnut industry is concentrated in the state of California where production 

averaged 366,000 short tons of walnuts per year from 2005-2009. Both production and sales 

peak in the fall in anticipation of the holiday season in December. Approximately 11 percent of 

walnuts are sold in the shell.1 The remaining 75 percent are shelled and processed further to 

create a variety of packaged shelled products. All walnuts must be fumigated before they are put 

in to long-term storage or continue in the processing chain. Phosphine can be used for the 75 

percent of walnuts that are allocated for packaged shelled products because turnaround time is 

not crucial. For the 25 percent that are sold in-shell, they are sold in a short period of time very

close to harvest time. A rapid fumigant is needed to accommodate the throughput during this 

critical window. 

Table 4 displays information on the walnut industry and methyl bromide granted. Over the 

period from 2005 through 2009, approximately 345,000 metric tons of walnuts were produced, 

valued at more than $643 million. 

Table 4. Summary information on walnut industry and methyl bromide

Production, Value, and Cost

Commodity Metric Tons Produced per Year 1 345,093

Commodity Kilograms Produced per Year 345,093,075

Gross Revenue per Metric Ton 2 $ 1,866 

Total Annual Gross Revenue $ 643,636,799

Operating Costs per Metric Ton 3 $ 805 

Total Annual Operating Costs $ 277,866,004

Net Revenue per Metric Ton $ 1,060 

Total Annual Net Revenue $ 352,328,837 

MeBr Granted

MeBr Granted by Parties 2012 (kg) 527

Commodity Treated with 2012 Granted MeBr (cu m) 4 21,958

1 Five year average from USDA NASS, 2005-2009. 

2 Based on five-year average price from USDA NASS of $1,692 per U.S. short ton, 

2005-2009

3 CUE applicant provided total operating cost of $731 per ton in worksheet 2-D of 

the CUE application. Converted to cost per metric tons.

4 Based on use rate of 1.5 lbs per 1,000 cubic feet, 24 kgs per 1,000 cubic meters. 

The results of the analysis for walnuts are presented in Table 5. 

A sulfuryl fluoride treatment can be conducted in roughly the same amount of time as a methyl

bromide treatment, which is assumed to be eight hours total, four hours for fumigation and four 

hours for fumigation. Assuming a 24 hour cycle, three fumigations per day are conducted during 

peak harvest for both methyl bromide and sulfuryl fluoride. Although the sulfuryl fluoride 

column displays a cost for fumigation chambers, it is assumed that this number of chambers or 

 

1 On average, approximately 39,000 metric tons are sold in-shell out of 345,000 metric tons total production. 

(USDA NASS, 2005-2009)
USA CUN13 POST HARVEST COMMODITIES 10

equivalent space is already available for methyl bromide fumigation and could be transitioned to 

sulfuryl fluoride use with no additional cost. No additional chambers are needed. The analysis 

indicates a small cost savings each year ($2,360) from a transition to sulfuryl fluoride. 

Previous analyses indicated that a switch to phosphine would require an additional 84 days of 

treatment time. This is due to the longer treatment time for phosphine compared to methyl

bromide. The current analysis examines the cost of purchasing additional fumigation chambers 

to accommodate the throughput of walnuts during peak harvest time. The analysis assumes that 

all in-shell walnuts are fumigated within 45 days. Assuming that all walnuts are harvested in this 

short period likely overestimates the number of additional chambers that will be needed since not 

all walnuts harvested are fumigated within a 45-day window.

Based on this analysis, the cost to transition the commodity treated by 527 kgs to phosphine 

would be a $90,000 initial investment in chambers. After the initial investment in additional 

chambers, the industry will experience a small cost savings each year ($10,200) from using 

phosphine. 

Table 5. Analysis of transition to alternatives for walnuts treated with methyl bromide

Methyl 

Bromide

Sulfuryl 

Fluoride

Phosphine

1 Cubic meters treated with 2012 granted MeBr 1 21,933 21,933 21,933

2 Capacity of fumigation chamber (cu m) 2 125 125 125

3 Days of harvest 3 45 45 45

4 One day capacity of each chamber (cu m)

4 374 374 25

5 Total chambers needed 5 2 2 20

6 Total Cost of Fumigation Chambers (@ $5,000 each) 6 $ 10,000 $ 10,000 $ 100,000

7 Cost difference between MeBr and alternative na $ - $ 90,000

8 Total gas for cubic feet needing fumigation (kgs) 7 527 703 88

9 Price of fumigant gas ($ / kg) 8 $ 20.94 $ 12.35 $ 9.37 

10 Total cost of fumigant gas ($) $ 11,037 $ 8,675 $ 823

11 Cost difference between MeBr and alternative $ (2,362) $ (10,214)

12 Total cost of fumigation space and fumigant $ 21,037 $ 18,675 $ 100,823

13 Total cost difference between MeBr and alternative $ (2,362) $ 79,786

14 Cost difference as % of gross revenue (from Table 4) 0.00% -0.01%

15 Cost difference as % of net revenue (from Table 4) 0.00% -0.02%

1 From Table 4.

2 Size of fumigation chamber (5,500 cubic feet or 156 cubic meters) based on size of dry freight van trailer 

found at www.pensketruckrental.com/commercial-truck-rentals/trailer-truck/, (Accessed Jan 6, 2011); 

reduced by 20% to account for air space in fumigation chamber. 

3 Assumes that all commodity to be treated is treated within this time period.

4 Using methyl bromide and sulfuryl fluoride, each chamber can be used three times (Line2 x 3 = Line4); for 

phosphine, each fumigation takes 5 days (15 times longer than MeBr and SF), so each chamber can be used the 

equivalent of 1/5 of a time per day (Line2 ÷ 5 = Line 4). Also, the capacity of each chamber is reduced so that 

only 80% of it is used for commodity. 

5 Divide commodity to be treated (Line1) by harvest capacity of each chamber (line 

6 One-time cost to purchase chambers. Approximate cost of dry van trailer that could be used for fumigation 
USA CUN13 POST HARVEST COMMODITIES 11

available from American Trailer Exchange, See Dry Van Trailers at

www.amtrex.net/AMTREXsalesinventory.htm, Accessed Jan 6, 2011.

7 Assumes rate of 1.5 lbs / mcf [24 kgs / tcm] for methyl bromide, 2 lbs / mcf [32 kgs / tcm] for sulfuryl 

fluoride, and 0.25 lbs / mcf [4 kgs / tcm] for phosphine. 

Dried Fruit

The dried fruit industry has already replaced a large portion of methyl bromide with phosphine in 

processing dried fruits. The CUE application states that methyl bromide is still needed for dried 

fruit because the industry still does not “have an alternative where processing equipment/storage 

treatments are made” and that sulfuryl fluoride is not as effective “at low temperatures and egg 

kill of target pests.” 

Table 6 displays information on the dried fruit industry and methyl bromide granted. Over the 

period from 2005 through 2008, approximately 464,000 metric tons of dried fruit (which 

included raisins, prunes, and figs) were produced, valued at more than $535 million. 

Table 6. Summary information on dried fruit industry and methyl bromide

Production and Value

Commodity Metric Tons Produced per Year 1 464,270

Commodity Kilograms Produced per Year 349,284,269

Total Annual Gross Revenue 2 $ 535,434,200 

MeBr Granted 

MeBr Granted by Parties 2012 (kg) 829

Commodity Treated with 2012 Granted MeBr (cu m) 3 34,502

1 Four year average from USDA NASS, 2005-2008. 

2 Based on four-year average of combined total crop values, 2005-2008

3 Based on use rate of 1.5 lbs per 1,000 cubic feet, 24 kgs per 1,000 cubic meters.

The results of the analysis for dried fruit are presented in Table 7. 

The analysis indicates a small cost savings each year ($3,700) from a transition to sulfuryl 

fluoride. No chambers are necessary because sulfuryl fluoride, like methyl bromide can be used 

indoors without damaging electrical equipment. 

Table 7. Analysis of transition to alternatives for dried fruit treated with methyl bromide

Methyl 

Bromide

Sulfuryl 

Fluoride Phosphine

1 Cubic meters treated with 2012 granted MeBr 1 34,502 34,502 34,502

2 Capacity of fumigation chamber (cu m) 1 125 125 125

3 Time available to fumigate (days) 2 365 365 365

4 One day capacity of each chamber (cu m) 3 na na 31

5 Total chambers needed 3 0 0 4

6 Total Cost of Fumigation Chambers (@ $5,000 each) 1 $ - $ - $ 20,000

7 Cost difference between MeBr and alternative $ - $ 20,000

8 Total gas for cubic feet needing fumigation (kgs) 1 829 1,105 138
USA CUN13 POST HARVEST COMMODITIES 12

9 Price of fumigant gas ($ / kg) $ 20.94 $ 12.35 $ 9.37 

10 Total cost of fumigant gas ($) $ 17,363 $ 13,646 $ 1,295

11 Cost difference between MeBr and alternative $ (3,716) $ (16,068)

12 Total cost of fumigation space and fumigant $ 17,363 $ 13,646 $ 21,295

13 Total cost difference between MeBr and alternative $ (3,716) $ (3 932)

14 Cost difference as % of revenue 0.00% 0.00%

1 See notes for this Line from Table 5. 

2 Assumes that fumigation occurs year-round; no time constraint.

3 No chambers are needed for methyl bromide and sulfuryl fluoride because they can be used in existing 

storage facilities. Chambers are only needed for phosphine because it is corrosive to electrical equipment. 

The analysis for phosphine examines the cost of purchasing fumigation chambers to fumigate 

dried fruit outside of the storage warehouse. Assuming that fumigation can occur year-round 

and there is no particular time when the majority of it is fumigated, the industry will need to 

purchase four fumigation chambers at a total cost of $20,000. After the initial investment in 

fumigation chambers, the industry will save on fumigation each year (approximately $16,000) 

from switching to phosphine.

Dates

Table 8 displays information on the dried fruit industry and methyl bromide request. Over the 

period from 2005 through 2008, almost 16,000 metric tons of dates were produced, valued at 

more than $32 million. 

Table 8. Summary information on date industry and methyl bromide

Production and Value

Commodity Metric Tons Produced per Year 1 15,898

Commodity Kilograms Produced per Year 15,898,413

Total Annual Gross Revenue 1 $ 32,179,500 

MeBr Granted

MeBr Granted by Parties 2012 (kg) 1,063

Commodity Treated with 2012 Granted MeBr (cu m) 2 44,241

1 Four year average from USDA NASS, 2005-2008. 

2 Based on use rate of 1.5 lbs per 1,000 cubic feet, 24 kgs per 1,000 cubic meters.

The results of the analysis for dates are presented in Table 9.

 

Sulfuryl fluoride is the only alternative considered for dates. A transition to sulfuryl fluoride will 

result in cost savings for the industry of more than $4,000 per year.

Table 9. Analysis of transition to alternatives for dates treated with methyl bromide

Methyl 

Bromide

Sulfuryl 

Fluoride

1 Cubic meters to be treated (CUE request) 44,241 44,241

2 Total gas needed for fumigation (kgs) 1 1,063 1,417

3 Price of fumigant gas ($ / kg) $ 20.94 $ 12.35 
USA CUN13 POST HARVEST COMMODITIES 13

4 Total cost of fumigant gas ($) $ 22,263 $ 17,498

5 Cost difference between MeBr and alternative $ (4,765)

6 Cost difference as % of gross revenue (from Table 8) 0.01%

1 Assumes rate of 1.5 lbs / mcf [24 kgs / tcm] for methyl bromide, 2 lbs / mcf [32 kgs / tcm] 

for sulfuryl fluoride

CITATIONS

Barakat, D. A., D. Klementz, and C. Reichmuth,. 2009. Response of Eggs of Corcyra 

cephalonica towards Sulfuryl Fluoride. Presentation at 2009 MBAO, Nov. 10-12, 2009, San 

Diego, CA. Available online at: http://mbao.org/2009/061Reichmuth.pdf. 

Hosoda, Ed. 2009. California ProFume Update, 2009. Presentation at 2009 MBAO, Nov. 10-12, 

2009, San Diego, CA. Available online at: http://mbao.org/2009/069Hosada.pdf. 

Hosoda, Ed. 2008. Eco2Fume® and VaporPH3OS®. Presentation at 2008 MBAO, Nov. 11-14, 

2008, Orlando, Fl. Available at: http://mbao.org/2008/125Hosoda.pdf

Muhareb, Jeannette. 2009. Evaluation of Combining Sulfuryl Fluoride, Propylene Oxide & 

CO2 for Stored Product Insect Control. Presentation at 2009 MBAO, Nov. 10-12, 2009, San 

Diego, CA. Available online at: http://mbao.org/2009/064Muhareb.pdf. 

Russo, C., Green, R.D. & Howitt, R.E. “Estimation of Supply and Demand Elasticities of 

California Commodities”. Department of Agricultural and Resource Economics University of 

California, Davis, Working Paper No. 08-001, June 2008.

Walse, Spencer, J.G. Leesch, and S. Tebbets. 2009. Ovicidal Efficacy of Sulfuryl Fluoride to 

Stored-Product Pests of Dried Fruits. USDA/ARS, San Joaquin Valley Agricultural Sciences 

Center, Parlier, CA 93648. Presentation at 2009 MBAO, Nov. 10-12, 2009, San Diego, CA. 

Available online at: http://mbao.org/2009/060Walse.pdf. 

Williams, Robert. 2009. Control of Carob Moth (Ectomyelosis ceratonia) in Fresh Dates 

Fumigated with ProFume®. Presentation at 2009 MBAO, Nov. 10-12, 2009, San Diego, 

CA. Available online at: http://mbao.org/2009/063Williams.pdf. 

Williams, R. and E. Thoms. 2008. ProFume® gas fumigant update: post-harvest commercial 

acceptance and performance in North America. Presentation at 2008 MBAO, Nov. 11-14, 

2008, Orlando, Fl. Available at: http://mbao.org/2008/084Thoms.pdf