USA CUN1 3 POST HARVEST COMMODITIES 1



### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR POST HARVEST -- COMMODITIES NOMINATING PARTY : The United States of America FILE NAME : USA CUN 13 POST HAVEST USE FOR COMMODITIES BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methy l Bromide Critical Use Nomination for Post Harvest Use on Commodities (Submitted in 20 1 1 for 20 1 3 Use Season) QUANTITY OF METHYL B ROMIDE REQUESTED IN EACH YEAR OF NOMINATION: T ABLE 1 : Q UANTITY OF M ETHYL B ROMIDE REQUESTED IN E ACH Y EAR OF N OMINATION

Y EAR N OMINATION A MOUNT ( KILOGRAMS ) 20 1 3 822 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 info rmation. 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) 64 7

- 9799 Fax: (202) 647

- 5947 E

- ma il: 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 Criti cal 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 CUN1 3 POST HARVEST COMMODITIES 2

CONTACT OR E XPERT(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

- ma il: Housenger.Jack@epa.gov
LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE: 1. PAPER DOCUMENTS: Title of paper do cuments 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 CUN 1 3 POST HARVEST: COMMOD ITIES

* Identical to paper documentsUSA CUN1 3 POST HARVEST COMMODITIES 3



### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR POST HARVEST -- COMMODITIES
1. SUMMARY OF NEED FOR METHYL BROM IDE Commodity

fumigation with methy l 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. Sulfury l 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 tol erances. For additional information, please refer to the links on EPA’s website: http://www.epa.gov/oppsrrd1/registration_review/sulfuryl

- fluoride/evaluations. html

. T ABLE 2 . N OMINATION A MOUNT
C al ifor nia Dri ed Pl um Boar d C al if

or nia Wa lnut Co mmission C al if or nia Da te Co mmissio n S ec tor T otal / Av er age Qu anti ty Re que st ed fo r 2012: Amou nt (kg s) 3,317 558 1,063 4,938 Qu anti ty Re com me nded by MB TO C/ TE

APfo r 2012 : Amou nt (kg s) 829 527 1,063 2,419 Amou nt (kg s) 829 527 1,063 2,419 Vo lu me (1000 m 3 ) 392 130 97 619 Ra te 2 4 11 4 Tr an si ti on fr om 2 012 Ba se lin e Ad jus te d Val ue Pe rcent age (%) -66% -66% -6 6% -66%
Amou nt (kg s) 

### 282 179 361 822 Vo lu me (1000 m 3 ) 138 12 51 201.4 Ra te 2 14 7 4 Qu an tityR eq ui re d for 2013 N om

in ation : Qu an ti ty Appr ove d by Pa rt ie s fo r 2012: SE CTOR COM MO DI TIES

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, methy l 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 CUN1 3 POST HARVEST COMMODITIES 4

Research with sulfuryl fluoride indicates that this fumigant is a potential methy l bromide alternative for commodities , provided fumigation occurs at temperatures above 70 oF. Recent studies have shown that under vacuum or atmospheric conditions, sulfury l fluoride is effective against adult, pup al, and larval stages of stored produc t pests . The ovicidal effic acy of sulfury l fluoride is dependent upon temperature and exposure time

. Walnuts

– Quick turn

- around time for walnuts at peak harvest time is the primary justification for meth yl bromide use in this sector. Vacuum fumigatio n with methy l bromide may take 4

- 6 hours and atmospheric fumigation approximately 8

- 24 hours. Phosphine gas fumigation takes approximately

three day s and is being used to fumigate walnuts in storage. The industry

experts further observe that the walnut industry fumigates during 6 months of the ye ar at or below 50 °F and provide supporting temperature data for the San Joaquin and Sacramento Valley s of California , their main production areas

. Dates

- Meth yl bromide is used to rapidly fumigate Californ ia dates at harvest time, when up to a million pounds per day

are being harvested within a relativel y tight timeframe during the fall. Although several insect may infest dates, the carob moth, Ectomyelois ceratoniae , is the more damaging species. The Cal ifornia 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 meth yl bromide fumigation. Phosphine takes longer to fumigate dates, and during this time fermentation and off

- flavor can occur. Dried Fruit

– Methy l bromide is used to disinfest dried frui t 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 currentl y labeled for use on dried fruit ; h owever, 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. T he 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 secto r to allow time for the industry to purchase equipment, build chambers, modify structures, and/or practice using alternatives. The current registration of sulfury l fluoride, as ProFume ® , remains unchanged in the US for the uses included in this nomination . However, EPA has published a prepublication cop y 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 RESEARCHUSA CUN1 3 POST HARVEST COMMODITIES 5

Walse, et al. (2009) have demonstrated that sulfuryl fluoride does not readily kill egg stages of navel orangeworm or the eg gs of several stored product insects at temperatures bel ow 70 ° F at or below maximum label rates. USDA/ARS researchers plan to continue testing the efficacy and practicalit y of using sulfury l fluoride , relative to methyl bromide, to control post

- harvest p ests of nuts and dried fruit. S ulfury l 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 sulfury l fluoride at temperatures below 70 °F, as well as on the ovicidal efficacy of propy lene 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 sulf ury l 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 fumig ated with PPO had an LD 95 using 606 mg . h/l SF is just the opposite requiring higher CT product for the eggs, LD 95 966 mg . h/l,10% CO 2 was the most effective. Without CO 2 , combining the two fumigants together showed a LD 95 of 432 on RFB eggs and a LD 95 of 35 3 on RFB larvae. Adding 10% CO 2 reduces the dosages by about two

- thirds of the fumigants used alone. The CO 2 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 sulfury l fluoride. These included combinations of gases such as sulfury l 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 man y stored product pests of dried fruits and tree nuts. Reichmuth, also at the 2009 MBAO, presented data regarding sulfury l fluoride efficacy on the eggs of the r ice moth Corcyra cephalonica

. He showed that older eggs were more tolerant of sulfury l fluoride than were the y oung 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 a fter 5 day s 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 day s (ct=503 mgh/l) and 5 day s (ct=628 mgh/l), as well as three day s old eggs with 3 d fumigation (ct=377 mgh/l). 3 day s 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 mo ths Ephestia kuehniella , Plodia interpunctella and Ephestia elutella (Baltaci et al., 2006). “USA CUN1 3 POST HARVEST COMMODITIES 6

Williams (2009) ,of Dow AgroSciences, presented the results of sulfury l fluoride investigations on carob m oth (

Ectomyelosis ceratonia ) in f re shl y harvested date s. Complete mortality of eggs and larvae was achieved with 332 oz

- h/MCF (g

- h/m 3 ) 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, ov ernight 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 y ard, when time is not critica l and the tarps may be kept sealed for weeks or even months. With the anticipated 50+ h HL T actuall y measured with the tarps by this PIin 2007, a fumigation using onl y 1.3 lb/MCF of ProFume would require 16 h to achieve 300 oz

- h/MCF for carob moth contro l. Further gas savings can occur b y 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 onl y 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 sulfury l fluoride uses in post

- harvest at both the 2009 and 2010 MBAO conferences. Mr. Hosoda reported that walnuts began to transition to sulfury l fluoride in 2008, and made rapid progress in 2009 away from methy l 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 afte r 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 Safet y and Quality) to evaluate ProFume’s® efficacy on walnuts infested with Navel orangeworm eggs. The results showed that ProFume®, when applied under vacuum, will effectivel y control over 99% of the egg stage . USDA recently performed efficacy

studies under similar conditions with methyl bromide, and found egg survivalUSA CUN1 3 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. T homs, 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 follo w - up to the initial commercial fumigation trials in fresh dates reported at this conference last y ear, product bins full of dates and stacked in the same 142 m 3 (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 bioassay s 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 ra nge of 536

- 636 g

h/m 3 (oz

- h/Mcf) and 98.5% control in the fourth replicate exposed to 598 g

- h/m 3 . 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/m 3 observed in this trial would be achieved with an equivalent of 32 g/m 3 (2.0 lb/Mcf). This would be an arguabl y cost
- effective 1.5X the historically

stan dard MB dose of 21 g/m 3 (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 VAPORH 3 were also being used as meth yl bromide alternatives in many different commodities. Although most phosphine applications require a longer exposure period than meth yl bromide, users have made adjustments in their production schedu les and have invested in additional fumigation chambers to accommodate the use of these alternatives. A major nut processor made the transition to VAPORPH 3 OS® in their long

- term nut storage bins where short term fumigations are not required. This compan y initially converted to ECO 2 FUME® for these applications, but required such a large volume of cylinders, it made economical sense (b y purchasing a Fosfoquim HDS

- 200®) to implement VAPORPH 3 OS®in their fumigation program. This use eliminated approximately 50,000 lbs. of methy l bromide per y ear. Almond, pistachio, fig, bean and raisin processors have all replaced thousands of pounds of methy l bromide withUSA CUN1 3 POST HARVEST COMMODITIES 8

ECO 2 FUME®/VAPORPH 3 OS®. Wherever short term fumigations are not absolutel y necessary , cy linderized phos phine fumigants have become a suitable option, and are very economical to use. International acceptance of pho s phine residues (MRL ) also make phosphine a logical choice as an alternative fumigant.
4. E CONOMIC ANALYSIS OF TRANSITI ON TO ALTERNATIVES T A BLE 3. E CONOMIC S UMMARY FOR EACH A LTERNATIVE M ETHYL B ROMIDE A LTERNATIVE E CONOMIC S UMMARY

P HOSPHI

NE 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 fumi gant 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 w alnuts. S ULFURYL F LUOR IDE SF is a vi able alternative for walnuts, dried fruit, and dates. SF c osts less per lb than MeBr,

but application rates may be higher. Higher application rates will not change. A separate economic analy sis of alternatives was conducted for each commodities sub

- sec tor : walnuts, dried fruit, and dates. The economic analy ses 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 technicall y feasible alternatives. For the y ear 2012, the Parties granted 527 kgs for walnuts, 829 kgs for dried fruit, and 1,063 kgs for dates. The anal ys es focus on the differences in the cost of fumigant gas and the cost of fumigation space (i.e., fumigation chambers) between meth yl bromide and alternatives. The anal ys is 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, man y more additional chambers will be needed to accommodate the throughput during the harvest window. Since phosphine takes five times as long as meth yl 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 inve stment cost in the first y ear to purchase additional fumigation chambers. After the first y ear, 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 con siderably lower. The cost to transition to SF is negligible for both walnuts and dried fruit. In the case of dates, sulfury l fluoride is the only viable alternative. Fumigation with sulfury l fluoride requires slightl y higher application rates, but the transition results in a small cost savings due to its lower price relative to methy l bromide. WalnutsUSA CUN1 3 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 ye ar from 2005

- 2009 . Both production and sales peak in the fall in anticipation of the holiday season in December. Approximately 11 percent o f walnuts are sold in the shell. 1 The remaining 75 percent are shelled and processed further to create a variet y of packaged s helled 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 i s 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 display s information on th e walnut industry and meth yl 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 b romide Produ ction, Value, and Cost Commodity Metric Tons Produced per Year 1 3 45,093 Commodity Kilograms Produced per Year 3 45,093 , 075 Gross Revenue per Metric Ton 2 $ 1,866 Total Annual Gross Revenue $ 6 43,636,799 Operating Costs per Metric Ton 3 $ 805 Total Annual Operating Costs $ 2 77,866,004 Net Revenue per Metric Ton $ 1,060 Total Annual Net Revenue $ 352,328,837 MeBr Granted MeBr Granted by Parties 201 2 (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 anal ys is for walnuts are presented in Table 5. A sulfuryl fluori de treatment can be conducted in roughl y the same amount of time as a meth yl bromide treatment, which is assumed to be eight hours total, four hours for fumigation and four hours for fumigation. Assuming a 24 hour cy cle, three fumigations per day are cond ucted during peak harvest for both methyl bromide and sulfury l fluoride. Although the sulfuryl fluoride column display s a cost for fumigation chambers, it is assumed that this number of chambers or

1 O n average, approximately 39,000 metric tons are sold in

- shell out of 345,000 metric tons total production. (USDA NASS, 2005

- 2009)USA CUN1 3 POST HARVEST COMMODITIES 10

equivalent space is already available for methyl bromide fumigation and could be transitioned to sulfury l fluoride use with no additional cost. No additional chambers are needed. The anal ys is indicates a small cost savings each ye ar ($2,360) from a transition to sulfuryl fluoride. Previous anal ys es indicate d that a switch to phosphine would require an additional 84 day s of treatment time. This is due to the longer treatment time for phosphine compared to meth yl bromide. The current analy sis examines the cost of purchasing additional fumigation chambers to accommodate the throughput of walnuts during peak harvest time. The anal ys is assumes that all in

- shell walnuts are fumigated within 45 day s. Assuming that all walnuts are harvested in this short period likely

overestimates the number of additional chambe rs that will be needed since not all walnuts harvested are fumigated within a 45

- day window. Based on this analy sis, 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 y ear ($10,200) from using phosphine. Table 5 . Analysis of transition to alternatives for walnuts treated with methyl bromide Methyl Bromide Sulfuryl

Fluorid e 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 D ays of harvest 3 45 45 45 4 One day capacity of each chamber (cu m ) 4 374 374 25 5 Total c hambers 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 f umigation ( 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 alternati ve $ ( 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 differenc e as % of gross revenue (from Table 4) 0.0 0 %

- 0. 01 % 15 Cost difference as % of net revenue (from Table 4) 0.0 0 %

- 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 foun d 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 Ass umes 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 fumigationUSA CUN1 3 POST HARVEST COMMODITIES 11

available from Am erican Trailer Exchange, See Dry Van Trailers at www.am trex.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 me thyl bromide with phosphine in processing dried fruits. The CUE application states that methy l bromide is still needed for dried fruit because the industry still does not “have an alternative where proce ssing equipment/storage treatments are made” and that sulfury l fluoride is not as effective “at low temperatures and egg kill of target pests.” Table 6 display s information on the dried fruit industry and methyl bromide granted. Over the period from 20 05 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 i nf

ormation on dried fruit industry and methyl b romide Production and Value C ommodity 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 201 2 (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 anal ys is for drie d fruit are presented in Table 7. The anal ys is indicates a small cost savings each ye ar ($3,700) from a transition to sulfury l fluoride. No chambers are necessary because sulfury l fluoride, like methyl bromide can be used indoors without damaging e lectrical 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 fumiga tion chamber (cu m) 1 125 1 25 1 25 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 138USA CUN1 3 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 fu migant $ 17,363 $ 13,646 $ 21,295 13 Total cost difference between MeBr and alternative $ ( 3,716 ) $ ( 3 932 ) 14 Cost difference as % of revenue 0.0 0 % 0.0 0 % 1 See notes for this Line from Table 5. 2 Assu mes 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 electri cal equipment. The anal ys is for phosphine examines the cost of purchasing fumigation chambers to fumigate dried fruit outside of the storage warehouse. Assuming that fumigation can occur ye ar - 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 in dustry will save on fumigation each y ear (approximately $16,000) from switching to phosphin e. D ates Table 8 display s 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 i nf

ormation on d ate i ndustry and methyl b romide 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 201 2 (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 anal ys is for dates are presented in Table 9. Sulfury l fluoride is the only alternative considered for dates. A transition to sulfury l fluoride will result in cost savings for the industry of more than $4,000 per y ear. 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 $ 12.35USA CUN1 3 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) 0.0 1 %
1 Assumes rate of 1.5 lbs / mcf [24 kgs / tcm] for methyl bromide , 2 lbs / mcf [32 kgs / tcm] for sulfuryl fluoride

CI TAT IONS Barakat, D. A., D. Klementz, and C. Reichmuth,. 2009. Response of Eggs of Corcyra cephalonica towards Sulfury l 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

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