MONTREAL PROTOCOL

ON SUBSTANCES THAT DEPLETE

THE OZONE LAYER

UNEP

REPORT OF THE

TECHNOLOGY AND ECONOMIC ASSESSMENT PANEL

OCTOBER 2012

EVALUATION OF 2012 CRITICAL USE NOMINATIONS FOR METHYL 

BROMIDE AND RELATED MATTERS

FINAL REPORT
ii October 2012 MBTOC CUN Final Report

UNEP

OCTOBER 2012 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATION OF 2012 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

FINAL REPORT
October 2012 MBTOC CUN Final Report iii

Montreal Protocol

On Substances that Deplete the Ozone Layer

Report of the

UNEP Technology and Economic Assessment Panel

October 2012

EVALUATIONS OF 2012 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

The text of this report is composed in Times New Roman.

Co-ordination: Methyl Bromide Technical Options Committee

Composition of the report: MBTOC Soils: Co-chairs Ian Porter, Mohamed Besri

MBTOC SC: Co-chair Michelle Marcotte 

MBTOC QPS: Co-chair Marta Pizano

Reproduction: UNON Nairobi

Date: October2012

Under certain conditions, printed copies of this report are available from:

UNITED NATIONS ENVIRONMENT PROGRAMME

Ozone Secretariat, P.O. Box 30552, Nairobi, Kenya

Normally from SMI Distribution Service Ltd., Stevenage, Hertfordshire, UK, fax: + 44 1438 

748844

This document is also available in portable document format from

http://www.unep.org/ozone/teap/Reports/TEAP_Reports/

No copyright involved. This publication may be freely copied, abstracted and cited, with 

acknowledgement of the source of the material.

ISBN: **********
October 2012 MBTOC CUN Final Report iv

Disclaimer

The United Nations Environment Programme (UNEP), the Technology and Economic 

Assessment Panel (TEAP) Co-Chairs and members, and the Methyl Bromide Technical Options 

Committee (MBTOC) Co-Chairs and members, and the companies and organisations that employ 

them do not endorse the performance, worker safety, or environmental acceptability of any of the 

technical options discussed. Every industrial operation requires consideration of worker safety 

and proper disposal of contaminants and waste products. Moreover, as work continues -

including additional toxicity evaluation - more information on health, environmental and safety 

effects of alternatives and replacements will become available for use in selecting among the 

options discussed in this document.

UNEP, TEAP Co-Chairs and members, and the MBTOC Co-Chairs and members, in furnishing 

or distributing this information, do not make any warranty or representation, either express or 

implied, with respect to the accuracy, completeness, or utility; nor do they assume any liability of 

any kind whatsoever resulting from the use or reliance upon any information, material, or 

procedure contained herein, including but not limited to any claims regarding health, safety, 

environmental effect or fate, efficacy, or performance, made by the source of information.

Mention of any company, association, or product in this document is for information purposes 

only and does not constitute a recommendation of any such company, association, or product, 

either express or implied by UNEP, TEAP Co-Chairs and members, and the MBTOC Co-Chairs 

and members or the companies or organisations that employ them.

Acknowledgement

The Technology and Economic Assessment Panel and its Methyl Bromide Technical Options 

Committee acknowledge with thanks the outstanding contributions from all of the individuals and 

organisations who provided support to Panel and Committee Co-Chairs and members. The 

opinions expressed are those of the Panel and the Committee and do not reflect the reviews of any 

sponsoring or supporting organisation.

Methyl Bromide Technical Options Committee:

MBTOC Soils (S) Co-Chairs: Ian Porter (Australia). Mohamed Besri (Morocco) Members of 

MBTOC S: Antonio Bello (Spain); Aocheng Cao (China); Peter Caulkins (USA); Raquel Ghini 

(Brazil); George Lazarovits (Canada); Andrea Minuto (Italy); Marta Pizano (Colombia); Sally 

Schneider (USA); JL (Stappies) Staphorst (South Africa); Akio Tateya (Japan); Alejandro Valeiro 

(Argentina); Janny Vos (The Netherlands); Jim Wells (USA); Suat Yilmaz (Turkey)

MBTOC Structures and Commodities (SC) Chair: Michelle Marcotte (Canada) Members of 

MBTOC SC Fred Bergwerff (Netherlands); Chris Bell (UK); Ricardo Deang (Philippines); 

Alfredo Gonzalez (Philippines); Darka Hamel (Croatia); Christoph Reichmuth (Germany); Jordi 

Riudavets (Spain); John Sansone (USA); Robert Taylor (UK); Chris Watson (UK)

MBTOC Quarantine and Preshipment Chair: Marta Pizano (Colombia), Members of 

MBTOC QPS Jonathan Banks (Australia); Ken Glassey (New Zealand); Takashi Misumi 

(Japan); David Okioga (Kenya); Ian Porter (Australia); Ken Vick (USA) and Eduardo Willink 

(Argentina).

MBTOC Economist: Nick Vink (South Africa)
October 2012 MBTOC CUN Final Report v

OCTOBER 2012 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATIONS OF 2012 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE AND RELATED MATTERS

FINAL REPORT
October 2012 MBTOC CUN Final Report vi

UNEP

OCTOBER 2012 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

MBTOC FINALCUN REPORT – OCTOBER 2012

Common Acronyms

1,3-D 1,3-dichloropropene

A5 Article 5 Party

ASD Anaerobic soil disinfestation

CUE Critical Use Exemption

CUN Critical Use Nomination

DOI Disclosure of Interest

EC European Community

EMOP Extraordinary Meeting of the Parties

EPA Environmental Protection Agency

EPPO European Plant Protection Organisation

IM Iodomethane

IPM Integrated Pest Management

IPPC International Plant Protection Convention

ISPM International Standard Phytosanitary Measure

LPBF Low Permeability Barrier Film (including VIF films)

MB Methyl Bromide

MBTOC Methyl Bromide Technical Options Committee

MBTOC QPS Methyl Bromide Technical Options Committee, Quarantine and Preshipment Subcommittee
October 2012 MBTOC CUN Final Report vii

MBTOC SC Methyl Bromide Technical Options Committee, Structures and 

Commodities Subcommittee

MBTOC S Methyl Bromide Technical Options, Soils Subcommittee

MITC Methyl isothiocyanate

MOP Meeting of the Parties

MS Metam sodium

OEWG Open Ended Working Group

Pic Chloropicrin

QPS Quarantine and Pre-shipment

SF Sulfuryl fluoride

TEAP Technology and Economics Assessment Panel

TIF Totally Impermeable Film

VIF Virtually Impermeable Film

VOC Volatile Organic Compounds
October 2012 MBTOC CUN Final Report 8

2012 Evaluations of Critical Use Nominations for Methyl Bromide and 

Related Matters – Final Report

Table of Contents

1.1 SCOPE OF THE REPORT ..............................................................................................................9

1.2. CRITICAL USE NOMINATIONS FOR METHYL BROMIDE ................................................9

1.2.1. MANDATE ..................................................................................................................................9

1.2.2 FULFILMENT OF DECISION IX/6 ..................................................................................................9

1.2.3 REPORTING OF MB CONSUMPTION FOR CRITICAL USE .............................................................10

1.2.4 TRENDS IN METHYL BROMIDE USE FOR CUES SINCE 2005......................................................10

1.2.5 DISCLOSURE OF INTEREST........................................................................................................11

1.2.6 ARTICLE 5 ISSUES ....................................................................................................................11

1.2.7 CONSIDERATION OF STOCKS, DECISION EX.1/4 (9F) .................................................................12

1.3 EVALUATIONS OF CUNS – 2012 ROUND FOR 2014 EXEMPTIONS ...................................17

1.3.1 CRITICAL USE NOMINATIONS REVIEW......................................................................................17

1.3.2 ACHIEVING CONSENSUS............................................................................................................18

1.4 MBTOC SOILS: FINAL EVALUATIONS OF 2012 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE FOR 2014 ........................................................................................19

1.4.1 CRITICAL USE NOMINATIONS SUBMITTED.................................................................................19

1.4.2 CUN ASSESSMENT FOR PREPLANT SOIL USES ............................................................................19

1.4.3 ISSUES RELATED TO CUN ASSESSMENT FOR PREPLANT SOIL USE ..........................................19

1.4.3.1 Australia..................................................................................................................................20

1.4.3.2 Canada....................................................................................................................................20

1.4.3.3 United States...........................................................................................................................20

1.4.3.4. General comments on assessment...........................................................................................20

1.4.4 REGISTRATION OF ALTERNATIVES FOR PREPLANT USES - DECISION EX I/4 (9I) AND (9J)...........21

1.4.5 SUSTAINABLE ALTERNATIVES FOR PREPLANT USES...................................................................21

1.4.6 STANDARD PRESUMPTIONS USED IN ASSESSMENT OF NOMINATED QUANTITIES.........................21

1.4.7 ADJUSTMENTS FOR STANDARD DOSAGE RATES USING MB/PIC FORMULATIONS .......................24

1.4.8 USE/EMISSION REDUCTION TECHNOLOGIES - LOW PERMEABILITY BARRIER FILMS AND 

DOSAGE REDUCTION ................................................................................................................24

1.5 MBTOC-STRUCTURES AND COMMODITIES – FINAL CUN REPORT.................................36

1.5.1 PROCESS USED BY MBTOC SC TO CONDUCT CUN RE-REVIEWS .............................................36

1.5.2 RESOURCING ISSUES IN 2012 AND IN COMING YEARS ...............................................................36

1.5.3 DETAILS OF EVALUATIONS ......................................................................................................37

1.6 ACTIVITY REPORT FOR 2012 AND WORK PLAN FOR 2013...............................................60

1.6.1 ACTIVITY REPORT FOR 2012.....................................................................................................60

1.6.2 WORK PLAN AND INDICATIVE BUDGET FOR 2013 .....................................................................60

1.7 REFERENCES: ................................................................................................................................62

ANNEX 1: DECISION IX/6 ......................................................................................................................64

ANNEX II: MINORITY REPORT.................................................................................71

ANNEX III - PART A: TREND IN MB PREPLANT SOIL NOMINATIONS AND EXEMPTIONS75

ANNEX IV - PART B: TRENDS IN MB STRUCTURAL AND COMMODITY NOMINATIONS AND

EXEMPTIONS......................................................................................................................83
October 2012 MBTOC CUN Final Report 9

2012 Evaluations of Critical Use Nominations for Methyl Bromide and 

Related Matters 

1.1 Scope of the Report

This 2012 final report provides evaluations by MBTOC of Critical Use Nominations (CUNs) 

submitted for methyl bromide (MB) for 2014 by three Parties (Australia, Canada, USA). As per 

provisions set out in Decision IX/6 (Annex I, MOP16), CUNs were submitted to the Ozone 

Secretariat by the Parties in accordance with the timetable shown in paragraph 1 of Annex I, Decision 

XVI/4. 

This final report 1) provides new updated recommendations for the CUNs for which the Parties 

provided further information or requested reassessment after the 32nd OEWG, 2) lists the CUNs for 

which interim assessments have not changed and 3) provides information on the CUNs from Parties 

on stocks (Decision Ex.1/4 (9f)). It further provides partial information on actual MB consumption 

for critical uses (in accordance with Decision XVII/9) and apparent adoption rates of alternatives, as 

evidenced by trend lines on reduction of MB CUNs (in accordance with Decisions XIX/9, XX/5). It is 

noted that trend lines on adoption may not necessarily indicate true adoption rates for alternatives, as 

the use of stocks of MB that may have been available to the same sector or areas of production may 

have increased or fallen within the sector due to a range of circumstances. MBTOC notes that stock 

volumes have significantly decreased in recent years. 

Standard presumptions used in the 2012 round were the same as those used in the 2011evaluations of 

the CUNs. These standard presumptions are subject to continual review. However, any changes 

proposed by MBTOC are required to be approved by the Party‟s in the MOP preceding the year of 

assessment based on a draft Decision presented to the MOP in accordance with paragraph 2 in Annex 

1 to the report of MOP16. 

1.2. Critical Use Nominations for Methyl Bromide

1.2.1. Mandate

Under Article 2H of the Montreal Protocol, Parties not operating under Article 5(1) are required to 

phase-out all production and consumption (defined as production plus imports minus exports) of MB 

after 1 January 2005. However, the Parties agreed to a provision enabling exemptions for those uses 

of MB that qualify as critical. Parties established criteria, under Decision IX/6 (see Annex 1 of this 

report) of the Protocol, which all critical uses need to meet in order to qualify for an exemption. 

TEAP and its MBTOC provided guidance to the Parties‟ decisions on critical use exemptions in 

accordance with Decisions IX/6, Annex I of Decision XVI/2 and a number of subsequent decisions 

(XVI/2; XVII/9, XVIII/13, XIX/9, XX/5, XXI/11, XXII/6 and XXIII/4).

1.2.2 Fulfilment of Decision IX/6

Decision XVI/2 and Decision XXI/11 directed MBTOC to indicate whether all CUNs fully met the 

requirements of Decision IX/6. When the requirements of Decision IX/6 are met, MBTOC can 

recommend critical uses of MB. Where some of the conditions are not fully met, MBTOC can 

recommend a decreased amount depending on its technical and economic evaluation, or determine the 

CUN as “unable to assess” and request further information from the Party. When the information is 

submitted, MBTOC is required to re-assess the nomination, following the procedures defined in 

Annex 1 of the Sixteenth Meeting of the Parties 

MBTOC recommended less methyl bromide that requested in a CUN when technically and 

economically feasible alternatives were considered to be available or, in a few cases, when the Party 

failed to show that there was no technically and economically feasible alternative. In this round of 
October 2012 MBTOC CUN Final Report 10

CUNs, as in previous rounds, MBTOC considered all information provided by the Parties, including 

answers to questions requested by MBTOC up to the date of the evaluation. 

Now that technically and economically feasible alternatives have been identified for virtually all 

applications, regulations on the use of these alternatives often determine their availability to the end 

users. In addition, comparative information on the economic feasibility/infeasibility of the use of 

alternatives compared to MB is critical to the outcomes of present and future CUNs. MBTOC needs 

annual updates of the economics information evaluating the costs of alternatives. In many cases, 

MBTOC has proposed that existing commercially and economically feasible alternatives should be 

used. Where these are not available, MBTOC has suggested research that could lead to commercial 

alternatives to replace MB. MBTOC has also shown how regulatory issues can hinder or promote the 

phase out of MB, and has directed Parties attention toward such issues.

1.2.3 Reporting of MB Consumption for Critical Use

A number of decisions (Ex.I/3(5); XVI/2(4); XVII/9(5)), XVIII/13(6), XIX/9(7), XX/5(7), XXI/11(6), 

XXII/6(5) and XXIII/4(4) set out provisions which request Parties to submit by 1 February each year 

information on how criteria in IX/6(1) is met when licensing permitting or authorizing CUEs. 

Decision XVII/9 of the 17th MOP specifically requests TEAP and its MBTOC to “report for 

2005 and annually thereafter, for each agreed critical use category, the amount of methyl 

bromide nominated by a Party, the amount of the agreed critical use and either: 

(a) The amount licensed, permitted or authorised; or 

(b) The amount used

Since the start of the CUN reviews in 2003, MBTOC has provided the amounts of MB nominated and 

agreed for each critical use (Annexes III and IV). MBTOC is now able to report more information on 

amounts of MB permitted and/or used for CUE uses. Parties are required to report the data to UNEP 

by March 2012 as part of the accounting framework, form 2.

The Meeting of the Parties authorised use of 4.87 tonnes of MB for rice in 2011 in Australia, but 

4.043 tonnes were used for that purpose. In addition, Parties authorised 29.79 tonnes for strawberry 

runners in that same year, but 29.29 tonnes were used for strawberry runners. 

For Canada, the Meeting of the Parties authorised 2.084 tonnes for pasta manufacturing in 2011, 

however 0.9349 tonnes were used; and 14.106 tonnes for flour-mills, but 11.495 tonnes were used. A 

further 5.261 tonnes were granted for strawberry runners, and that full amount was fully used. 

Japan was authorised a use of 239.746 tonnes for a range of vegetable crops, ginger and chestnuts for 

2011 by the MOP, and used 222.239 t. Japan did not apply for CUEs for 2014..

For Israel, the MOP authorised 290.878 tonnes for a range of vegetable and strawberry crops in 2011. 

The actual amount used is as yet unknown, as Israel has not submitted an Accounting Framework 

Report for 2012. Israel did not apply for CUEs in 2014.

For the United States, the MOP authorised 1855.2 tonnes for a wide range of crops and commodities 

in 2011 (Annex III and IV). In their allocation regulation for 2011 critical uses, the Party reported that 

in 20111,382.206 tonnes had been approved for pre-plant soil uses and 117.794 tonnes for postharvest 

uses (Federal Register, September 30, 2011).

1.2.4 Trends in Methyl Bromide Use for CUEs since 2005

The nominated amounts and the apparent rate of reduction in MB or adoption of alternatives achieved 

by Parties are shown in Table 1-5, as well as Figures 1-1 and 1-2. It is noted that for those countries 

that have pre-2005 stocks of MB that are being drawn down, the reductions in CUEs from year to year 

cannot be taken directly as evidence of alternative adoption since pre-2005 stocks may have been used 
October 2012 MBTOC CUN Final Report 11

in the same sectors. Tables 1-9 and 1-11 in particular show the amounts nominated by Parties for soil 

uses, and structures and commodity uses and the final recommendations for „Critical Use‟ in 2014. 

Decision XVII/9 requires TEAP to show trends in the phase out of the critical uses of MB by the 

Parties (Figs 1-1 to 1.2, Annexes III and IV). Since 2005, there has been a progressive trend in the 

reduction of methyl bromide for CUNs by all Parties for both soil and post harvest uses, although this 

has occurred at different rates. Figs 1-1 to 1.2 show reduction trends in amounts approved/nominated 

by Parties for „Critical Use‟ from 2005 to 2014 for all the remaining soil uses and some of the 

remaining structures and commodity uses. The complete trends in phase out of MB by country, as 

indicated by change in CUE, are shown in Annexes III and IV.

1.2.5 Disclosure of Interest

As in past reports, MBTOC members were requested to update their disclosure of interest forms 

relating specifically to their level of national, regional or enterprise involvement for the 2012 CUN 

process. The Disclosure of Interest declarations for 2012, updated in February 2012 can be found on 

the internet at 

http://ozone.unep.org/new_site/en/disclosure_of_interest.php?body_id=6&committee_id=6 and a list 

of members in Annex I, chapter 11 of this TEAP report. As in previous rounds, some members 

withdrew from a particular CUN assessment or only provided technical advice on request for those 

nominations where a potential conflict of interest was declared. 

MBTOC co-chairs requested members to complete a Categorisation of Interest Form on the 

application of declarations of interest to the best extent possible. Most MBTOC members found it 

difficult to accurately categorise their conflicts accordingly, however they discussed these during the 

plenary at the start of the MBTOC meeting in Beijing and members were given the opportunity to 

declare there conflicts of interest. Where known, these were managed appropriately by recusal or self 

recusal during the relevant CUN assessment.

MBTOC co-chairs seek guidance from TEAP and the Parties on how to improve DOI/COI updating 

and management procedures and in particular to implement them for the CUN process.

1.2.6 Article 5 issues

Methyl bromide is due to be fully phased out in A5 Parties by January 1, 2015, 10 years after full 

phaseout by non-A5 Parties. In both cases, uses for feedstock and QPS are exempted from phase out 

under the control measures described in Article 2H. There is also provision for exemption from phase 

out for uses deemed „critical‟ according to Article 2H, as complying with Decision IX/6.

Presently, nearly 80% of the controlled consumption in A5 Parties has been phased out, well ahead of 

the 2015 deadline. This has been achieved largely as a result of investment projects implemented by 

the Montreal Protocol agencies, with MLF funding, bilateral cooperation and also national funding. 

Most of the remaining MB consuming A5 Parties have agreements in place with the MLF and other 

organisations for full phaseout of methyl bromide by 2015 at the latest, very often earlier. These are 

usually accompanied with legislation to ban further consumption of MB for controlled uses, and 

funding to support ongoing implementation of alternatives therefore promoting the sustainability of 

the phase out. 

Article 5 Parties may choose to submit nominations for Critical Use Exemptions (CUEs) for 

remaining uses they consider appropriate for the year 2015 and possibly subsequently. The first 

CUNs by non-A5 Parties were made in 2003 for CUEs to be in force in 2005. If a similar advanced 

submission period is to be followed, some A5 Parties may choose to submit CUNs in 2013 for 

assessment by MBTOC for potential use as 2015 CUEs.
October 2012 MBTOC CUN Final Report 12

MBTOC is mindful of the difficult and complex process that occurred during the first round of CUNs 

in 2003 for non A5 Parties. TEAP urges Parties to consider the requirements for CUNs in due time as 

set out in the „Handbook on Critical Use Nominations‟ which has been revised and updated to meet 

the needs of the non A5 and A5 Critical Use Process in response to Decision XXIII/14. 

(http://ozone.unep.org/Assessment_Panels/TEAP/Reports/MBTOC/Handbook%20CUN-version 7)

1.2.7 Consideration of Stocks, Decision Ex.1/4 (9f)

One criterion for granting a critical use is that MB “is not available in sufficient quantity and quality 

from existing stocks of banked or recycled methyl bromide” (paragraph 1 (b) (ii) of Decision IX/6). 

Parties nominating critical use exemptions are requested under decision Ex.I/4(9f) to submit an 

accounting framework with the information on stocks. MBTOC has not reduced its recommended 

amount of methyl bromide in consideration of stocks held by the Party and has instead relied on 

Parties to take this into consideration when approving the amounts recommended by TEAP for each 

nomination. To assist the Parties with their consideration of stocks, and in accordance with Decision 

XVIII/13(7), a summary of the data on stocks as reported by the Parties in the first year for accounting 

in 2006, and then reports submitted in 2011 and 2012 are summarized in Tables 1-1 to 1-3 below. 

Parties may wish to consider this information in the light of Decision IX/6 1(b)(ii) when authorising 

methyl bromide for critical uses.

Efficient functioning of commerce requires a certain level of available stocks and additional stocks to 

respond to emergencies. Additionally, stocks may be held on behalf of other Parties or for exempt 

uses (feedstock and QPS uses). The correct or optimal level of stocks for virtually every input to 

production is not zero. In addition, stocks are privately owned and may not be readily available for 

critical uses, or there may be national regulations preventing the transfer of stocks. Despite these 

restrictions, Parties may wish to ensure that stocks are used wherever possible in order to minimize 

the quantity of MB that need to be produced each year for critical uses. Tables 1-1 to 1.3 report the 

quantities of MB „on hand‟ at the beginning and end respectively of 2005, 2010 and 2011 as required

under Decision XVI/6. The earlier CUN reports list stocks for the other years.

Table 1-1: Quantities of MB (metric tonnes) ‘on hand’ at the beginning and end of 2005, as first 

reported by Parties in 2006/2007 under Decision XVI/6.

Party

Critical use 

exemptions 

authorized 

by MOP for 

2005

Quantity of MB as reported by Parties (metric tonnes)

Amount on 

hand at 

start of 

2005

Quantity 

acquired for 

CUEs in 2005 

(production 

+imports)

Amount 

available 

for use in 

2005

Quantity 

used for 

CUEs in 

2005

Amount 

on hand at 

the end of 

2005

Australia 146.6 0 114.912 114.912 114.912 0

Canada 61.792 0 48.858 48.858 45.146 3.712

EU 4 392.812 216.198 2 435.319 2 651.517 2 530.099 121.023

Israel 1 089.306 16.358 1 072.35 1 088.708 1 088.708 0

Japan 748 0 594.995 594.995 546.861 48.134

New Zealand 50 6.9 40.5 47.4 44.58 2.81

USA(a) 9 552.879 7 613 not reported 7 170 443

Additional information on stocks was reported on US EPA website, September 2006: MB inventory held by USA 

companies: 2004 = 12,994 tonnes; 2005 = 9,974 tonnes.
October 2012 MBTOC CUN Final Report 13

Table 1-2: Quantities of MB ‘on hand’ at the beginning and end of 2010, as reported by Parties in 

2011 under Decision XVI/6. 

Party Critical use 

exemption 

authorized 

by MOP for 

2010

Quantity of MB as reported by Parties (metric tonnes)

Amount on 

hand at 

start of 

2010

Quantity 

acquired for 

CUEs in 2010

(production 

+imports)

Amount 

available 

for use in 

2010

Quantity 

used for 

CUEs in 

2010

Amount 

on hand 

at the 

end of 

2010

Australia 36.44 0 34.167 34.167 34.167 0

Canada 33.277 6.38 23.456 29.836 25.254 1.185

Israel 290.88 12.47 288.94 301.41 290.86 10.55

Japan 267.00 8.82 248.67 257.49 251.159 6.331

USA 1,956 3,063 (a) 1,955 5,018 1,955

613 (c)

1,803(b)

(a) Amount of pre-2005 stocks available at the start of 2010 

(b) Amount of pre-2005 stocks available at the end of 2010.

(c) Stocks used for CUE uses in 2010.

Table 1-3: Quantities of MB ‘on hand’ at the beginning and end of 2011, as reported by Parties in 

2012 under Decision XVI/6.

Party Critical use 

exemption 

authorized 

by MOP for 

2011

Quantity of MB as reported by Parties (metric tonnes)

Amount on 

hand at 

start of 

2011

Quantity 

acquired for 

CUEs in 2011 

(production 

+imports)

Amount 

available 

for use in 

2011

Quantity 

used for 

CUEs in 

2011

Amount 

on hand 

at the 

end of 

2011

Australia 34.66 0 33.333 33.333 33.333 0

Canada 21.451 1.185 15.889 17.074 17.691 -0.617

Israel Not reported

Japan 239.746 6.413 225.552 231.965 222.239 9.726

USA 1,500

[2055 

approved by 

MOP for 

CUEs]

1,803(a) 1,499 3,302 1,499

555(c)

0

1,249(b)

(a) Amount of pre-2005 stocks available at the start of 2011

(b) Amount of pre-2005 stocks available at the end of 2011

(c) Stocks used for CUE uses in 2011
October 2012 MBTOC CUN Final Report 14

Figure 1-1: Amounts of MB nominated and exempted for CUE uses in nominated preplant soil 

sectors from 2005 to 2014. Blue lines indicate the trend in of CUN nominated and the 

red lines the amount CUE methyl bromide approved by the Parties

Australia - Strawberry runners

0.0

10.0

20.0

30.0

40.0

Tonnes

CUN 35.8 37.5 35.8 35.8 29.8 29.8 29.8 29.8 29.8 29.8

CUE 35.8 37.5 35.8 35.8 29.8 29.8 29.8 29.8 29.8

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Canada - Strawberry runners

0.0

5.0

10.0

15.0

20.0

Tonnes

CUN 14.8 8.7 16.0 7.5 7.5 7.5 5.3 5.3 5.6 5.3

CUE 14.8 8.7 16.0 7.5 7.5 7.5 5.3 5.3 5.3

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

USA - Strawberry fruit

0.0

500.0

1000.0

1500.0

2000.0

2500.0

3000.0

Tonnes

CUN 2468.9 1918.4 1733.9 1604.7 1336.8 1103.4 1023.5 754.0 531.7 415.1

CUE 2052.8 1730.8 1476.0 1349.6 1269.3 1007.5 812.7 678.0 415.1

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
October 2012 MBTOC CUN Final Report 15

Figure 1-2:Amounts of MB nominated and exempted for CUE uses in in mills and food processing 

facilities and for commodities from 2008 to 2014 in nominated postharvest industries 

from 2005 to 2014. Blue lines indicate the trend in of CUN nominated and the red 

lines the amount CUE methyl bromide approved by the Parties

Australia - Rice 

0

2

4

6

8

10

12

14

Tonnes

CUN 12.3 12.3 10.2 9.2 9.2 7.8 5.7 3.6 2.4 1.2

CUE 6.2 6.1 9.2 9.2 7.8 6.6 4.8 3.6 2.4

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Canada - Flour Mills

0.0

10.0

20.0

30.0

40.0

50.0

Tonnes

CUN 47.2 34.8 30.2 28.6 26.9 22.9 14.1 11.0 7.8 5.0

CUE 47.2 34.8 30.2 28.6 26.9 22.9 14.1 11.0 7.8

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

USA - Dried fruits and nuts

0.0

20.0

40.0

60.0

80.0

100.0

Tonnes

CUN 89.2 87.8 91.3 67.7 59.0 19.2 10.0 4.9 0.8 0.7

CUE 89.2 87.7 79.0 59.0 45.6 19.2 5.0 2.4 0.8

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

USA - Smoke house hams

0.0

50.0

100.0

150.0

Tonnes

CUN 136.3 135.7 40.8 19.7 19.7 4.5 3.7 3.7 3.7 3.7

CUE 67.9 81.7 18.9 19.7 19.0 4.5 3.7 3.7 3.7

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

USA - Mills and Processors

0.0

100.0

200.0

300.0

400.0

500.0

600.0

Tonnes

CUN 536.3 506.0 401.9 363.0 291.4 173.0 135.3 135.3 25.3 22.8

CUE 483.0 461.7 401.9 348.2 291.4 173.0 135.3 74.5 22.8

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
16 October 2012 MBTOC CUN Final Report

Table 1-4. Summary of Critical Use Nominations and Exemptions of Methyl Bromide (tonnes) 

Quantities Nominated Quantities Approved

Final

Recomme

ndation

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005

(1ExMOP 

and

16MOP)

2006

(16MOP+

2ExMOP+

17MOP)

2007

(17MOP + 

18MOP)

2008

(18MOP

+

19MOP)

2009

(19MOP)

2010

(20MOP

+

21MOP)

2011

(21MOP)

2012

(22MOP)

2013

(23MOP)

2014

Australia 206.950 81.250 52.145 52.900 38.990 37.610 35.450 34.660 32.164 30.947 146.600 75.100 48.517 48.450 37.610 36.440 28.710 31.708 32.134 [27.971]

Canada 61.992 53.897 46.745 42.241 39.115 35.080 19.368

+3.529

16.281 13.444 10.305 61.792 53.897 52.874 36.112 39.020 30.340

+3.529 19.368 16.281 13.109 [10.094]

European 

Community1 5754.361 4213.47 1239.873 245.00 0 0 0 0 0 0 4392.812 3536.755 689.142 245.146 0 0 0 0 0 0

Israel 1117.156 1081.506 1236.517 952.845 699.448 383.700 232.247 0 0 0 1089.306 880.295 966.715 860.580 610.854 290.878 0 0 0 0

Japan 748.000 741.400 651.700 589.600 508.900 288.500 249.420 221.104 3.317 0 748.000 741.400 636.172 443.775 305.380 267.000 239.746 219.609 3.317 0

New 

Zealand 53.085 53.085 32.573 0 0 0 0 0 0 0 50.000 42.000 18.234 0 0 0

0

0 0 0

Switzerland 8.700 7.000 0 0 0 0 0 0 0 0 8.700 7.000 0 0 0 0 0 0 0 0

USA 10753.997 9386.229 7417.999 6415.153 4958.034 3299.490 2388.128 1181.779+ 

6.339

691.608 442.337 9552.879 8081.753 6749.060 5355.976 4261.974 3232.856

+2.018

2055.200 993.706 562.328 [415.646]

TOTALS 18704.241 15617.837 10677.552 8297.739 6244.487 4044.380 2928.142 1460.163 740.533 483.589 16050.089 13418.200 9160.714 6990.039 5,254.838 3572.183 2343.024 1261.304 610.888 [453.711]

 

* Not yet available. 

1Members of the European Community which had CUNs/CUEs included:

2005 – Belgium, France, Germany, Greece, Italy, Netherlands, Poland, Portugal, Spain, and the United Kingdom.

2006 – Belgium, France, Germany, Greece, Ireland, Italy, Latvia, Malta, Netherlands, Poland, Portugal, Spain, and the United Kingdom.

2007 – France, Greece, Ireland, Italy, Netherlands, Poland, Spain, and the United Kingdom

2008 – Poland, Spain
October 2012 MBTOC CUN Final Report 17

1.3 Evaluations of CUNs – 2012 round for 2014 exemptions

Detailed interim assessments of all CUNs were made by MBTOC during its first meetings for Soils 

and QPS in Beijing, China, from February 27- March 2 and MBTOC Structures and Commodities in 

Berlin, Germany, from February 28 - March 1. 

For the soils CUNs, Australia and Canada submitted similar amounts to the previous rounds 

highlighting difficulties with phase out of MB for the strawberry runner sector. In the USA the only 

soil CUN submitted was for strawberry fruit; none of the other previous years‟ CUNs were submitted. 

Australia, Canada and the US submitted five CUNs in total for the postharvest sector. In Structures 

and Commodities, Parties continued to show progress in reducing the quantity of methyl bromide 

requested in the CUNs. The reduction was most likely the result of continuing efforts by Parties to 

resolve the inter-related issues of treatment logistics, costs and effectiveness of alternatives. Japan did 

not submit a CUN for fresh chestnuts this year. 

Also during the first meeting progress reports were prepared and „Disclosure of Interest‟ declarations 

updated. At the 32nd OEWG meeting in Bangkok, MBTOC held bilateral meetings with the 

Australia, Canada and the United States to discuss the interim recommendations and since then all 

three Parties have provided further information to support reassessment of five nominations. 

MBTOC did not hold a second meeting this year in view the small number of CUNs and funding 

difficulties faced by many non-A5 members in relation to meeting attendance. Consideration of new 

information and reassessment of CUNs was thus conducted electronically, as discussed in the 

pertinent sections ahead. MBTOC has updated the Handbook by email exchange for presentation at 

the 24th MOP in November 2012.

As discussed in the TEAP Progress Report, three Parties only, (ie Australia, Canada, and the USA)

submitted nominations for critical uses of MB for either preplant soil use and/or postharvest use in 

2014 round. These Parties have submitted nominations in previous CUN years. Eight nominations 

were submitted in this round (Tables 1.5 and 1.10).The total nominated amount for all countries for 

2014 was 483.589 t and this represented a 35% reduction to that nominated in 2011 for 2013. 

After reassessment by MBTOC after the OEWG, the final recommendation for 2014 was 453.711 t, 

ie. 93% of that nominated (Table 1.4).

MBTOC has sometimes recommended quantities of MB for 2014 which are less those nominated. 

The grounds used for these recommendations are given in detail in the relevant CUNs in Tables 1-9 

and 1-11. The adjustments for soil uses may in part be to account for presumptions given in Tables 1-

6.

In general the CUNs were submitted due to the following issues: regulatory restrictions that did not 

allow partial or full use of alternatives, difficulties in the scale-up of alternatives, alternatives 

considered uneconomical and unavailability of alternatives. Additionally, MBTOC-SC notes that 

some Parties continue to struggle with the ability make an effort to adapt previously identified 

alternatives to their circumstances. In paragraph 20 of Annex 1 referred to in Decision XVI/4, Parties 

specifically requested that MBTOC explicitly state the specific basis for the Party‟s economic 

statement relating to CUNs. Tables 1-9 and 1-11 provide this information for each CUN. This 

information was prepared by the MBTOC economist. MBTOC notes there was an improvement in the 

economic information supplied in this round.

1.3.1 Critical Use Nominations Review

The meetings were held as required in accordance with the time schedule for the consideration of 

CUNs provided in Annex I referred to in Decision XVI/4. In considering the CUNs submitted in 

2012, as in previous rounds, both MBTOC subcommittees applied as much as possible the standards 
18 October 2012 MBTOC CUN Final Report

contained in Annex I of the final report of 16 MOP, and, where relevant, the standard presumptions 

given below. In particular, MBTOC sought to provide consistent treatment of CUNs within and 

between Parties while at the same time taking local circumstances into consideration. Unless 

otherwise indicated, the most recent CUE approved by the Parties for a particular CUN was used as 

baseline for consideration of continuing nominations. In evaluating the CUNs for soil treatments, 

MBTOC assumed that the presence of a technically feasible alternative to MB would need to provide 

sufficient pest and/or weed control for continued production of that crop to existing market standards. 

For commodity and structural applications, it was assumed that technically and economically feasible 

alternatives would provide disinfestation to a level that met the objectives of a MB treatment, e.g. 

meeting infestation standards in finished product from a mill. Costs for alternatives for soil or 

postharvest uses should be within 20% (MBTOC 2011) of the cost of using methyl bromide for it to 

be considered economically feasible in the context of that nomination, to the extent that could be 

determined. 

The outcome of evaluations of CUNs for the soil and structural treatments are presented in Table 1.9 

and 1.11 below.

1.3.2 Achieving Consensus

In accordance with decision XX/5(9) and similar subsequent decisions (XXI/11(4), XXII/6(4) and 

XXIII/4(3)) the Parties have indicated that MBTOC „should ensure that it develops its 

recommendations in a consensus process that includes full discussion among all available members of 

the Committee and should ensure that members with relevant expertise are involved in developing its 

recommendations’.

In 2012 as described in the TEAP Progress Report, MBTOC‟s procedures were designed to improve 

members‟ contribution and reaching final decisions on nominations before, during and after the 

MBTOC meetings. This procedure ensured all members were sent information and able to discuss 

issues related to all nominations. 

For the final reassessment, MBTOC Co-Chairs agreed on the following process to conduct the rereviews electronically. 

All the information from Parties was circulated to all members for an opportunity to make comments 

about the reassessment. Members were asked to submit comments by the end of August, 2012. 

Comments from all members of MBTOC on the nominations submitted for reassessment were 

considered by the relevant sub-committee 

The coordinating Co-Chair (s) provided a summary of all the comments received to the subcommittee, who then formed a position which the cochairs used to draft the proposed text boxes and 

recommendations. Sub-committee members then further discussed, commented on and made changes 

to the proposal. The agreed text box and recommendation was again circulated to obtain consensus (or 

agreement not to disagree) by each member of the sub-committee. The consensus positions of each 

sub-committee were then sent to full MBTOC for information and approval of the sub-committee 

findings.

The results of the re-reviews were incorporated into this report which focuses mainly on the 

reassessed CUNs.

During the final assessments, one MBTOC Soils member disagreed with the position of the subcommittee on one CUN; consensus was achieved for the rest of the soils CUNs. The postharvest subcommittee of MBTOC achieved consensus on its nominations. The minority view submitted by the 

dissenting member can be found in Annex II. 
October 2012 MBTOC CUN Final Report 19

1.4 MBTOC Soils: Final evaluations of 2012 Critical Use Nominations for Methyl 

Bromide for 2014

1.4.1 Critical Use Nominations submitted

At the Open Ended Working Group in Bangkok , in July 2012, MBTOC Soils presented interim 

recommendations on all three nominations received from Australia, Canada and the United States as 

shown in Table 1-5. During bilateral discussions at the OEWG, all three Parties who had submitted 

nominations in the 2012 round indicated issues related to the interim assessments and subsequently 

sent further information and requests for reassessment. 

1.4.2 CUN reassessment for preplant soil uses

In summary, in the final assessment, the Australian and Canadian CUNs were unchanged from the 

interim recommendation, but the US strawberry fruit nomination was increased by 45.9 t as MBTOC 

agreed that the withdrawal of methyl iodide from the market would impact the nomination for 2014.

Table 1-5: Summary of the interim recommendations by MBTOC-S (in square brackets) for 

CUE’s for preplant uses of MB (tonnes) submitted in 2012 for 2014

1.4.4 Issues Related to CUN Assessment for Preplant Soil Use

Key issues which influenced assessment and the need for MB for preplant soil use of MB in the 2012 

round were:

i) Limitation on the uptake of a key alternative, methyl iodide (MI or iodomethane) because of 

issues related to its registration. In Australia, further studies have been asked for before 

registration can be granted, in Canada the registrant is not seeking registration at present and 

in the USA it has been withdrawn from sales.

ii) Changing regulations on key alternatives, particularly metam sodium and Pic used alone or in 

mixtures and the township caps and buffer zone regulations on 1,3-D in the US.

iii) Continued adoption of a new formulation of 1,3-D/Pic („Pic-Clor 60‟) in the USA, which 

increases the area that may be treated with 1,3-D in regions affected by township caps.

iv) Effect of restrictions on use of high rates of Pic (greater than 200 kg/ha (20 g/m2)) in some 

counties in California.

v) Ineffective disease control achieved by some alternative fumigants (1,3-D/Pic, Pic alone) 

when applied by drip fumigation as not all of the bed is treated.

MBTOC has noted more specific issues related to requests for CUNs below and also in the CUN text 

boxes (Table 1.9).

Country and Sector Nomination by 

the Party for 

2014

Interim 

Recommendation for 

2014

Final Recommendation 

for 2014

1. Australia

Strawberry runners 29.760 [26.784] [26.784]

2. Canada

Strawberry runners 5.261 [5.050] [5.050]

3. USA

 Strawberry fruit 415.067 [343.740] [389.640]

TOTAL 450.088 [375.574] [421.474]
20 October 2012 MBTOC CUN Final Report

1.4.4.1 Australia

In its interim assessment, MBTOC noted that the nomination submitted by Australia for the critical 

use of MB for the production of strawberry runners stated that a 20% reduction in MB consumption 

would commence in 2015 and reduce at 20% per year up to and including 2019. MBTOC examined 

only the amount requested for consumption in 2014. MBTOC strongly recommends that the Party 

review the 5-year reduction proposed in the nomination with a view to eliminating this small 

consumption in MB in one year. MBTOC notes that Australia has been undertaking trials for many 

years with the most likely alternative methyl iodide, which has been pending registration in Australia 

for several years. Only the state of Victoria requests CUEs at present; other States, such as 

Queensland, which requested CUEs in the past, have now implemented alternatives. 

1.4.4.2 Canada

In its interim assessment, MBTOC noted that the CUN submitted by Canada for the production of 

strawberry runners did not provide details of research that was being undertaken to identify and 

implement alternatives. MBTOC notes that the Parties are „.. required to demonstrate that an 

appropriate effort is being made to evaluate, commercialize and secure national regulatory approval 

of alternatives and substitutes. Parties must demonstrate that research programmes are in place to 

develop and deploy alternatives and substitutes”

2

. MBTOC notes that if the nomination were to be 

assessed according to the criteria agreed in decisions of the Parties, MB would not be recommended. 

However, MBTOC acknowledges that for this particular round they have no registered alternatives 

and is mindful that the lack of MB authorised by the Parties due to inadequate research would result 

in this company on Prince Edward Island not being able to produce strawberry runners and therefore 

provided a recommendation. MBTOC strongly recommends that the Party consider a phase out plan 

to eliminate this small consumption in MB in one year. 

1.4.4.3 United States

In its nomination, the US provided several reasons for the requirement for critical uses of 

methyl bromide for the production of strawberries in California, including limitation on the 

uptake of a key alternative, methyl iodide (MI or iodomethane) because of issues related to its 

registration. “After MBTOC’s meeting in Beijing in 2012 , the manufacturer of MI suspended 

product sales for all formulations of methyl iodide in USA3, although at this stage it still 

maintains federal registration. However, the California Department of Pesticide 

Registration” cancelled all products containing methyl iodide at the request of the 

registrant4”. 

At the OEWG, the Party requested reassessment, largely based on the withdrawal of methyl iodide but 

also presented new information about regulations affecting two of the key alternatives, 1,3_D/Pic and 

chloropicrin.

1.4.4.4. General comments on assessment

MBTOC continues to encourage Parties to consider a review of regulations covering the registration, 

use and adoption of alternatives, particularly a review of barrier films to reduce dosage rates of MB 

and its alternatives, and associated emissions. In this regard, MBTOC was pleased to receive 

information from the US on buffer zone credits that are due to take effect from 1 December 2012. 

Further information is provided in Section 1.4.4.

 

2

Paragraph 1(b)(iii) of Decision IX/6.

3

Arysta. 2012. Arysta LifeScience suspends MIDAS in the USA. http://www.arystalifescience.com/release/MIDASPress3-20-12FINAL.pdf

4

CDPR. 21 March 2012. Methyl Iodide Registration. http://www.cdpr.ca.gov/docs/registration/methyl_iodide.htm
October 2012 MBTOC CUN Final Report 21

MBTOC also notes that a large proportion of MB has been nominated for uses where regulations or 

legislation prevent reductions of MB dosage. For several uses, the mandatory use of MB is specified 

at a high dosage for either treatment of certified propagation material or because regulations prevent 

use of barrier films which otherwise could have reduced the MB dosage rate. Also regulations on the 

use of alternatives are preventing their uptake for a substantial proportion of the remaining CUNs for 

preplant soil use. 

1.4.5 Registration of alternatives for preplant uses - Decision Ex I/4 (9i) and (9j)

Decision Ex. I/4 (9i) requires MBTOC,

“To report annually on the status of re-registration and review of methyl bromide uses for the 

applications reflected in the critical-use exemptions, including any information on health effects and

environmental acceptability”. Further, Decision Ex I/4 (9j) requires MBTOC “To report annually on 

the status of registration of alternatives and substitutes for methyl bromide, with particular emphasis 

on possible regulatory actions that will increase or decrease dependence on methyl bromide”.

Prior to the OEWG, but after the interim recommendations, the manufacturer of methyl iodide 

announced “... the immediate suspension of product sales for all formulations of methyl iodide in the 

United States ... based on a review [by the manufacturer] of the fumigant’s economic viability in the 

US”

5

. Even though the fumigant may remain registered, the company is not willing to sell the 

fumigant in the US from 20 March 2012. At the request of the registrant (Arysta), the registration of 

methyl iodide has been cancelled by the California Department of Pesticide Regulation. Arysta has 

also announced it is no longer seeking registration in Australia and the product was never considered 

for use in Canada. The company has only maintained registration in limited countries, eg, Japan. 

The EU has further reported that registration for 1,3-D and other chemical alternatives including 

chloropicrin, dazomet and metam sodium are under review. A grace period for the registration of 1,3-

D is presently granted in the EU for a specific time period on a yearly basis, but future registration has 

not been supported by the EU. Similarly, registration of chloropicrin in the EU may not continue.

In any future nominations submitted by Australia, Canada and the US should include information on 

expected rates of adoption of alternatives following registration, in accordance with paragraphs 34-35 

of Annex 1 of the MOP16, as this information would assist MBTOC in its evaluation of these CUNs. 

1.4.6 Sustainable alternatives for preplant uses

MBTOC urges Parties to consider the long term sustainability of treatments adopted as alternatives to 

MB; whilst chemical treatments have been shown to offer an adequate solution, combining them with 

environmentally sustainable non-chemical alternatives where possible, within an integrated approach 

will provide best results in the longer term. Decision IX/6 1(a)(ii) refers to alternatives that are 

„acceptable from the standpoint of environment and health’. . MBTOC has visited various regions 

where successful non-chemical alternatives e.g. grafting, soil less culture, solarisation, steam, 

biodisinfestation and anaerobic soil disinfestation, are used as sustainable alternatives to MB. Several 

Parties consider these techniques as viable alternatives, particularly when an integrated approach that 

combines different options is adopted. 

1.4.7 Standard presumptions used in assessment of nominated quantities.

The tables below (Tables 1-6 and 1-7) provide the standard presumptions applied by MBTOC-S for 

this round of CUNs for preplant soil uses. These standard presumptions were first proposed in the 

MBTOC report of October 2005 and were presented to the Parties at 17th MOP. Studies and reports to 

 

5

Press release. 20 March 2012. Arysta LifeScience Suspends MIDAS in the United States. 
22 October 2012 MBTOC CUN Final Report

support them have been provided in previous reports and were revised for some sectors after 

consideration by the Parties at the 19th MOP. The rates and practices adopted by MBTOC as standard 

presumptions are based on maximum rates considered acceptable by published literature and actual 

commercial practice. 

As in the evaluations in previous years, MBTOC considered reductions to quantities of MB in 

particular nominations to a standard rate per treated area where technical evidence supported its use. 

As a special case, MBTOC continues to accept a maximum rate of 200 kg/ ha (20 g/m2) in MB/Pic 

formulations with high Pic-containing mixtures with or without barrier films for certified nursery 

production, unless regulations prescribe lower or higher rates. However, MBTOC notes that studies 

have shown that rates of 200 kg/ha (20g/m2) or less of MB: Pic 50:50 are effective with barrier films 

for production of „certified‟ nursery material and urge Parties to consider regulations which permit 

these lower rates. MBTOC also notes that certified runner production may involve regulations which 

specify the mandatory use of a fumigant such as MB or an alternative, in order for the runners to be 

“certified runners”.

The indicative rates used by MBTOC were maximum guideline rates, for the purpose of calculation 

only. MBTOC recognises that the actual rate appropriate for a specific use may vary with local 

circumstances, soil conditions and the target pest situation. Some nominations were based on rates 

lower than these indicative rates. 
October 2012 MBTOC CUN Final Report 23

Table 1-6: Standard presumptions used in assessment of CUNs for preplant soil use of MB from 

the 2009 -2012 assessments

Comment CUN adjustment Exceptions

1. Dosage rates Maximum guideline rates for 

MB:Pic 98:2 are 25 to 35 g/m2 with 

barrier films (VIF or equivalent); 

for mixtures of MB/Pic are 12.5 to 

17.5 g MB/m2for pathogens and 

nutsedge respectively, under barrier 

films depending on the sector. All 

rates are on a „per treated hectare‟ 

basis.

Amount adjusted to maximum 

guideline rates. Maximum rates 

set dependent on formulation 

and soil type and film 

availability. 

Higher rates accepted if 

specified under national 

legislation or where the 

Party had justified 

otherwise.

2. Barrier films All treatments to be carried out 

under low permeability barrier film 

(e.g. VIF, TIF)

Nomination reduced 

proportionately to conform to 

barrier film use. 

Where barrier film 

prohibited or restricted 

by legislative or 

regulatory reasons

3. MB/Pic 

Formulation: 

Pathogens control

Unless otherwise specified, MB/Pic 

50:50 (or similar) was considered to 

be the standard effective 

formulation for pathogen control, as 

a transitional strategy to replace 

MB/Pic 98:2. 

Nominated amount adjusted for 

use with MB/Pic 50:50 (or 

similar).

Where MB/Pic 50:50 is 

not registered, or Pic 

(Pic) is not registered

4. MB/Pic 

Formulation: 

Weeds/nutsedge 

ass control

Unless otherwise specified, MB/Pic 

67:33 (or similar) was used as the 

standard effective formulation for 

control of resistant (tolerant) weeds, 

as a transitional strategy to replace 

MB/Pic 98:2.

Nominated amount adjusted for 

use with MB/Pic 67:33 (or 

similar).

Where Pic or Piccontaining mixtures are 

not registered

5. Strip vs. 

Broadacre

Fumigation with MB and mixtures 

to be carried out under strip 

Where rates were shown in 

broad acre hectares, the CUN 

was adjusted to the MB rate 

relative to strip treatment (i.e. 

treated area). If not specified, 

the area under strip treatment 

was considered to represent 

67% of the total area. 

Where strip 

treatment was not 

feasible e.g. some 

protected 

cultivation, 

emission 

regulations on MB, 

or open field 

production of high 

health propagative 

material 

Table 1-7: Maximum dosage rates for preplant soil use of MB by sector used in the 2009 and later 

assessments (standard presumptions).

Film Type

Maximum MB Dosage Rate (g/m2) in MB/Pic mixtures (67:33, 50:50) 

considered effective for:

Strawberries and 

Vegetables

Plant 

Nurseries*

Orchard Replant Ornamentals

Barrier films -

Pathogens

12.5 15 15 15

Barrier films -

Nutsedge

15.0 17.5 17.5 17.5

No Barrier films 

– Pathogens

20 20 20 20

No Barrier films 

- Nut sedge

26 26 26 26

* Maximum rate unless certification specifies otherwise
24 October 2012 MBTOC CUN Final Report

1.4.8 Adjustments for standard dosage rates using MB/Pic formulations

One key transitional strategy to reduce MB dosage has been the adoption of MB/Pic formulations 

with lower concentrations of MB (e.g. MB/Pic 50:50, 33:67 or less). These formulations are 

considered to be equally as effective in controlling soilborne pathogens as formulations containing 

higher quantities of MB (e.g. 98:2, 67:33) (Porter 2006; Santos et al., 2007; Hamill et al., 2004; 

Hanson et al., 2006). Parties are urged to consider even lower dosage rates of MB for the remaining 

CUNs. This includes rates as low as 75 kg/ha (7.5 g/m2) with mixtures of 30:70 or 33:67 mixtures (at 

250 kg/ha or 25 g/m2) or 100 kg/ha (10 g/m2) of MB in 250 kg/ha (25 g/m2) of 50:50 MB/Pic mixtures 

in conjunction with barrier films (Table 1-8).

Table 1-8: Actual dosage rates applied during preplant fumigation when different rates and 

formulations of MB/Pic mixtures are applied with and without barrier films. Rates of 

application reflect standard commercial applications rates.

Commercial application rates 

(kg/ha) of MB/Pic 

formulation

MB/Pic formulation (dose of MB in g/m2)

98:2 67:33 50:50 30:70

A. With Standard Polyethylene Films 

400 39.2 26.8 20.0 12.0

350 34.3 23.5 17.5 10.5

300 29.4 20.1 15.0 9.0

B. With Low Permeability Barrier Films (LPBF)

250 24.5 16.8 12.5 7.5

200 19.6 13.4 10.0* 6.0

175 17.2 11.8 8.8 5.3

* Note: Trials from 1996 to 2008 (previous CUN reports) show that a dosage of 10g/m2 (e.g. MB/Pic 50:50 at 

200kg/ha with low permeability barrier Films) is technically feasible for many situations and equivalent to the 

standard dosage of >20g/m2 using standard PE films 

1.4.9 Use/Emission reduction technologies - Low permeability barrier films and dosage 

reduction

Decision XXI/11 (para 9) requested further reporting on Decision IX/6 to ensure Parties adopted 

emissions controls where possible. For preplant soil use, this includes the use of barrier films and 

lowest effective dose of MB with mixtures of chloropicrin. Other methods include deep shanking and 

use of ammonium thiosulphate and different irrigation technologies (Yates et al., 2009). These latter 

technologies have not been reported or adopted widely by Parties and need to be evaluated more 

widely.

In southeast USA the reported use of barrier films in vegetable crops, which expanded rapidly to over 

20,000 hectares in 2009 has continued to increase. An exception to the adoption of barrier films is in 

the State of California in the USA where a regulation currently prevents use of barrier films with MB 

(California Code of Regulations Title 3 Section 6450(e). MBTOC notes that barrier films particularly 

more recently developed totally impermeable (TIF) films can be used with alternatives and this is 

consistently improving the performance of alternatives at lower dosage rates (Driver et al. 2011;

Fennimore and Ajwa, 2011). Effectiveness at lower dosages can allow for greater areas to be treated 
October 2012 MBTOC CUN Final Report 25

with 1,3-D under township cap regulations or increase the likelihood of chloropicrin being applied at 

dosage rates below the 125 or 200 lb/acre restrictions presently imposed in California.

In the USA as a result of mitigation developed for the fumigants undergoing reregistration, buffer 

zones around treated fields will go into effect on fumigant labels as of 1 December 2012. By 

choosing to use certain low permeability tarps, the applicator can qualify for buffer zone reduction 

credits. These credits are specific for each fumigant and tarp. The most impermeable tarps to 

chemical fumigants results in amaximum buffer zone credit of 60%, which may allow for a larger 

quantity of the alternative chemical to be used. Applicators of fumigants can obtain more information 

on the appropriate buffer reduction 

creditathttp://www.epa.gov/pesticides/reregistration/soil_fumigants/factsheets/sfm-buffer-zones2012.pdf. . Buffer zone credits apply tosoil fumigant products such as MB/Pic (but not in California), 

Pic, 1,3-D/Pic, and Pic, and metam sodium or metam potassium.

MBTOC notes that the impact of these changes will be difficult to determine and therefore will 

require thorough clarification from the Party on the impact on use of alternatives in any future 

nominations. MBTOC is aware that the only fumigant labels that currently specify buffer zones in 

the US are on 1,3-D products, which will not be affected by the new EPA labels and buffer zone 

credits as they are not part of re-registration. Buffer zones for methyl bromide are included in 

Californian regulations. Buffer zones for metam sodium and chloropicrin are in Californian county‟s 

permit conditions. Regulations and permit conditions supersede labels if they are more stringent than 

the labels. In essence, the requirement for buffer zones on the MB, metam and chloropicrin labels 

will go into effect at the end of 2012 or in early 2013 for the first time along with the buffer zone 

credits so it is difficult to know the impact on use of the alternatives.
26 October 2012 MBTOC CUN Final Report

Table 1-9: Final evaluation of CUNs for preplant soil use submitted in 2012 for 2014

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

2012

8

CUE for 

20139

CUN for 

2014 

MBTOC rec 

for 2014 

Australia Strawberry 

runners

35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.760 29.760 29.760 [26.784]

MBTOC Recommendation for 2014:

MBTOC has not changed the interim recommendation and recommends a reduced CUE of 26.784 tonnes for use in 2014 which is a 10% reduction from the 

amount nominated by the Party. According to the transition timeframe in the nomination, the anticipated quantity was proposed to be reduced by 10% in 2015. 

However, MBTOC considers the timeframe for reduction could be advanced by one year and encourages the Party to consider a faster transition than stated in the 

nomination. MBTOC considers that soilless culture is a technique used widely throughout the world for production of strawberry runners and is technically and 

economically suitable for some of the nursery production system as well as stock plants resulting in healthy nursery material. MBTOCs original recommendation 

was not based on methyl iodide registration, but on the adoption of soilless culture.

Reassessment by MBTOC after the OEWG:

After the OEWG, the Party requested reassessment based on the time needed to transition to soilless and potential lack of suitability of the technology for runner 

production. The party reported that the cost of change to soilless culture is significant. The party indicated thatthe final phase out of methyl bromide, which was to 

commence in 2015, was based on methyl iodide as the alternative to achieve 100% transition. The research effort focused primarily on commercial scale-up of 

methyl iodide ahead of its anticipated registration. The registration of this fumigant has however been withdrawn. This withdrawal means that the transition away 

from methyl bromide will not commence in 2015 as no research of other alternatives has been done. According to the Party, soilless culture is not technically and 

economically feasible because of substrate availability, used substrate disposal and high costs. MBTOC considers that transition to foundation stock into substrates 

has been successful to date and that further adoption of soilless culture is feasible for other stages of the multiplication process. 

Strawberry runner growers in Queensland successfully used Telone C-35. Telone C-35 has not been successful in Victoria due to phytotoxicity and lower 

production (by up to 40%) caused by heavier soils and lower temperatures. Although this occurred even after 3-4 months, MBTOC considers Pic alone as a key 

component in the production of healthy runners and suggest that lower rates in combination with other registered products may be worth consideration. 

Given the recent loss of methyl iodide as the most promising full replacement, the Australian Government and the strawberry runner industry is reviewing their 

research and development programs to phase out methyl bromide. A revised strategy will be developed in the next few months

Original Nomination by the Party:

The quantity requested for this CUN is 29.760 tonnes and has remained unchanged since 2009.
October 2012 MBTOC CUN Final Report 27

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Circumstances of the Nomination:

The Party states that the key pests affecting strawberry runner production are fungi (Phytophthora, Pythium, Rhizoctonia and Verticillium spp.) and weeds (Sinapsis 

arvensis, Agrostis tenuis, Raphanus spp., Poa annua, Cyperus spp). The Party also states that MB:Pic 50:50 at a MB dose of 25 g/m2is required to meet 

certification standards. Although this quantity exceeds MBTOC‘s standard presumption of 20 g/m2, the lower rate is unregistered. MBTOC acknowledges the 

notification by the Party of the QPS issues. The Party has informed MBTOC of its intention to phase out MB for critical uses over 5 years beginning in 2015, 

assuming that an alternative is registered by this time.

Original MBTOC Review and Assessment:

MBTOC considers, and the Party demonstrated, that soil-less substrate production is technically feasible for the foundation generation and plans to commission 

soil-less production in the 2011/2012 season. MBTOC considers soilless substrates are also technically feasible for successive early generations of nursery 

runners and can be implemented for a portion of the production in the next 2 years. Therefore MBTOC recommends a 10% transition to soil-less substrates for 

early generation runners in 2014. Victorian Strawberry Industry certification Authority has established a commercial facility in 2011 with a capacity for producing 

60,000 foundation stock plants. Methyl iodide test results have been very positive, and more data has been submitted to support the registration. However, this 

fumigant has not yet been registered. If methyl iodide or any other alternative is registered before the MOP 2012, MBTOC will need to reassess the nomination. A 

key alternative, 1,3-D/Pic, is considered ineffective due to phytotoxicity and doubling of plant back times in the heavy and wet soil conditions in the high elevation 

regions.

MBTOC Comments on Economics 2012:

Economic information on the infeasibility of plug plants was insufficient to validate Australia‘s assertion that soilless production of runners would not be economic.

Soilless production has been found economic in many countries.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission control: No, but standard films are claimed by the Party to perform the same as VIF in the cold temperatures and heavy wet soils 

typical for strawberry runner production.

 Dec. IX/6 b(iii) Research program: On going research is being conducted in (a) supporting reduced application rates of MB/Pic, (b) supporting the 

registration of MI and EDN, (c) use of MB recaptured from QPS applications in combinations with chloropicrin, (d) soilless production systems.

 Dec. IX/6 b(iii) Appropriate effort: Research effort is adequate, but commercialization of chemical alternatives is confronted with regulatory obstacles.
28 October 2012 MBTOC CUN Final Report

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Canada Strawberry 

runners (PEI)

6.840 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.261 5.261 [5.050]

MBTOC Final Recommendation for 2014:

MBTOC has not changed the interim recommendation and recommends a reduced amount of 5.05 tonnes for use in 2014, which is a 4% reduction from the 

quantity nominated by the Party. MBTOC considers that soilless culture is widely used around the world for strawberry runner production and is technically and 

economically feasible to replace 50% of the foundation stock within the 14 month time period until this CUE takes effect. MBTOC notes that whilst the 4% 

reduction addresses transition of only 50% of the foundation stock, it is a suitable and sustainable method to replace the entire use of MB for this purpose. 

MBTOC accepts that its cost effectiveness for other generations may need further evaluation and suggests that a pilot study be conducted on this aspect. 

MBTOC further encourages the Party in developing a suitable action plan to support the adoption of alternatives and to overcome regulatory restrictions that 

currently impact the successful adoption if alternatives in PEI. 

Reassessment by MBTOC after the OEWG:

After the OEWG the Party requested reassessment based on the need for more time to transition to soilless culture and on the potential unsuitability of this 

technology for strawberry runner production. In addition, the Party questioned whether soilless culture provided a solution for all stages of runner production and 

whether it would still be the alternative of choice if chloropicrin became available. They identified that the cost of converting to soilless culture techniques is 

significant: the approximate cost for a greenhouse alone is on average $62 per square meter ($620,000/hectare) and costs will rise to approximately $129 per 

square meter ($1.29M/hectare) when machinery and equipment costs are included (Chaudhary and Nabj, 2011). A complete analysis of the potential capital 

costs for the grower in PEI to transition to soilless culture in greenhouses for its transition stock would thus be needed. Despite the fact that foundation stock 

yields are reported to increase significantly through greenhouse production, Canada has concerns that the logistics of soilless culture are quite complex and that 

time will be required to implement a transition. Canada has also reconfirmed continuing efforts to implement an action plan to assist the grower to phase with MB 

phase-out, but the actual characteristincs of this plan have not been submitted. The Party asks for reinstatement of the full nominated amount.

After consideration of production methods adopted by strawberry runner producers around the world and transition made to soilless production systems, MBTOC 

considers it is still feasible to transition to soilless culture for stock plants, in particular because the soilless production facility in question is quite small. MBTOC 

further considers soilless production to be a reliable method for production of high health stock plants that would not be redundant if a suitable alternative, such 

as chloropicrin was registered. MBTOC notes that dazomet, metam sodium and metam potassium are registered and considers that in the absence of any other 

suitable chemical alternative that more effort be made to evaluate these products at PEI. MBTOC notes that whilst the reduction is only for 50% of the stock 

plants that the Party may wish to consider implementation of this technology for all the stock plants at the one time. MBTOC notes the increased efforts being 

made by the Party and strongly suggest development of an action plan to phase out the remaining use of methyl bromide.
October 2012 MBTOC CUN Final Report 29

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Original Nomination from the Party:

The Party has nominated 5.261 t of MB for use on (24.3 ha) of field grown runners and (2 ha) of stock plants. The nomination is based on a reduced rate of MB 

of 20 g/m2 under high barrier films for the entire 26.3 ha to be fumigated. 

Circumstances of the Nomination:

The Party has considered replacing MB with 1,3-D, but 1,3-D was banned for use in Prince Edward Island (PEI) in January 2003 due to potential ground water

contamination. In addition, Telone C-35 was withdrawn from Canada in 2011. Chloropicrin (PIC 100) has been registered by the Pest Management Regulatory 

Agency (PMRA) and is used by other runner growing companies in Canada. The PEI Department of Environment is not prepared to allow the application of Pic 

until PMRA indicates that groundwater contamination is unlikely in PEI soil conditions. A study was conducted and submitted to PEI authorities and to PMRA for 

use in their re-evaluation of chloropicrin but the outcome has not yet been determined. The registration of methyl iodide has not been applied for use in Canada. 

The company has been testing organic production from 2006 - 2009 with different varieties and has found that they obtained significant reductions in yield 

ranging from 40% to 70%. Only one variety using the organic production system compared favourably to conventional production with methyl bromide. The Party 

states that the producer cannot meet disease-free requirements of their buyers with organically produced runners. The Party stated that 100% of the crop is 

exported and therefore all plants are subject to inspection to meet phytosanitary requirements.

Original MBTOC Review and Assessment:

MBTOC acknowledges the Party‘s reduction of the rate of methyl bromide being used by the grower in PEI in the absence of formal registration for this dosage 

rate. MBTOC also notes that 100% of the crop is exported and MB is used as an aid to meet phytosanitary certification standards for export. MBTOC considers 

that soilless culture is suitable at least for foundation stock. MBTOC notes that other Parties have adopted a number of chemical alternatives (ie. methyl 

iodide/chloropicrin, chloropicrin combined with herbicides and 1,3-D/Pic) for strawberry runner production, however these chemical alternatives are prevented 

from use because of regional regulations in PEI. MBTOC notes that dazomet, metam sodium and metam potassium are registered for use in Prince Edward 

Island (PEI), however under Health Canada‘s legislation, combinations of these products are not permitted (i.e. application at the same time). Dazomet used 

alone or sequential applications may warrant evaluation. It is expected that the PMRA will make a final decision on chloropicrin reevaluation in the spring of 

2012 and that PEI will consider the outcomes of the PMRA decision. If the decision is to permit the use of Pic 100 following their review of the groundwater 

study before the MOP 2012, or any other chemical alternative is registered, MBTOC will need to reassess the nomination. 

MBTOC strongly recommends that the Party submit 1) a phase out plan for MB use in PEI. (2) expand its research efforts to better comply with Decision IX/6 

by examining the feasibility of expanding soilless culture beyond foundation stock and the suitability of other chemical and non chemical alternatives.

MBTOC Comments on Economics 2012:

The nomination was not based on economic arguments.
30 October 2012 MBTOC CUN Final Report

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Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission reduction: Yes, uses barrier films with reduced application rate of MB conforming to MBTOC‘s presumptions

 Dec. IX/6 b(ii) Research Effort: Although some research/adoption has been done in the past (ie high barrier films, biofumigation, organic varieties), 

MBTOC expects significant progress in accordance with Decision IX/6 with adoption of their proposed research program.

 Dec. IX/6 b(iii) Appropriate effort: Registrants for Midas, EDN and DMDS have not submitted any registration application materials at this time. A 

groundwater study for chloropicrin has been submitted by the registrant to PEI and federal authorities.
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United 

States 

Strawberry 

(field)

2052.846 1730.828 1476.019 1349.575 1269.32 1007.477 812.709 678.004 461.186 415.067 [389.640]

MBTOC final recommendation for 2014:

MBTOC recommends a reduced amount of 389.640 tonnes for use in strawberry fruit in California for 2014. This is based on 170 kg/ha and a 2,292 ha. 

Reassessment by MBTOC after the OEWG:

After the OEWG the Party requested the original amount be reinstated based on the fact that alternatives can-not be used for areas of high pest pressure or 

where of regulatory constraints are in place. The Party also stated that methyl iodide has been taken off the market by the manufacturer (Arysta) and thus is no 

longer available in California. Further, the Party suggests that organic production is not a replacement for areas of high pest pressure and that steam is 

extremely costly.

In view of MI withdrawal from the market, the majority of MBTOC (all but one member) agreed with consensus to recommended reinstating the 45.9 t of MB that 

had been deducted for adoption of methyl iodide. MBTOC acknowledges the Party‘s statement that ―The amount of methyl bromide nominated was calculated 

based on using 100% of the 1,3-D township cap using Pic-Clor 60 for strawberry fruit in 2014.‖ MBTOC however does not agree that totally impermeable (TIF) 

films are not effective to increase the proportion of fumigants that can be used for replacing MB as studies have shown that these films allow for a significant 

reduction in dosage rates in strawberries and other sectors (Fennimore and Ajwa 2011, Driver et al, 2011). This enables an increase in the area that can be 

treated with key alternatives, especially Pic-Clor 60. Fennimore and Ajwa, (2011) showed in separate trials over two years that using TIF at 224 kg/ha of PicClor 60 (a 33% reduction from the standard rate) led to fruit yields and weed control similar to dosages of 336 kg/ha of Pic-Clor 60 with standard film and to MB

/Pic at 396 kg/ha with standard film. They also found that TIF films at rates of 224kg/ha or 336 kg/ha had higher fumigant concentrations, better weed control 

 ̳and possibly pathogen control‘ under the film for at least 100 to 160 hours under the film than standard films although no data on pathogen control was reported. 

MBTOC considers that whilst high barrier films may not reduce the Application Factor (AF), the reduced dosage rate does allow more hectares to be treated 

under the same township cap. 

A review of commercial usage data (PUR) suggests that past dosage rates used commercially are lower than regulations which prevent use of chloropicrin in 

some counties. Also barrier films again offer opportunities to reduce dosage rates with chloropicrin. In a number of trials where pathogens were severe, Ajwa et 

al. (2005) found that the rates of drip-applied chloropicrin required to produce strawberry yields similar to shank applied methyl bromide plus chloropicrin were 

330 and 222 kg/ha under standard and VIF films, respectively, a 48% reduction in chloropicrin. From information provided by the Party it appears that the lower 

rate falls within the restrictions of most counties and would allow chloropicrin to be used. 

The Party contends that organic production may not be a suitable replacement for areas of high disease pressure, however MBTOC still considers that a small 

proportion of the existing production can transition to organics and maintains its initial recommendation for transitioning 10 ha of area previously treated with MB 

to organic production.

Although no reduction was made for the uptake of steam, MBTOC considers that on a small scale (ie buffer zones) and used within an IPM approach, steam 

should be considered as a suitable replacement in future nominations. This has been confirmed for example by Fennimore et al (2011). New and lower cost 
32 October 2012 MBTOC CUN Final Report

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boilers with improved treatment speed are available in several countries and in use in horticulture and tree nurseries, mushroom growing, viniculture and weed 

control (see for example www.moeschle.de).

The minority view of one member was that a further annual transition can be expected with existing alternatives and under the current regulatory restrictions, 

recommended no more than 381.310 tonnes and that the nomination be reduced to a critical area of no more than 2243 ha and a use rate of170 kg/ha in 2014 

(See Annex II)

Original Nomination by the Party:

The Party nominated 415.067 tonnes of methyl bromide for critical uses for strawberry fruit for 2014. This was approximately a 10% reduction of the amount 

approved at the MOP in 2013. The nomination is based on 2,442 ha at a dosage rate of 17.0 g/m2 which conforms to the MBTOC standard presumptions for use 

with high barrier films, although high barrier films can not be used in California with MB (http://www.cdpr.ca.gov/docs/emon/methbrom/tarps.pdf.). The Party 

stated that this reduction was based on a composite figure encompassing all the used and available alternatives and was unable to present a specific basis tor 

this proposed reduction. 

Circumstances of the Nomination:

The Party states that Californian growers have a critical need for methyl bromide to treat fields where the primary alternative, 1,3-D/chloropicrin, cannot be used 

due to township caps restricting the total amount of 1,3-D that can be used (Fennimore and Ajwa, 2011) or where diseases caused by Macrophomina and

Fusarium cannot be managed effectively (Ajwa, personal communication). Methyl iodide (iodomethane, Midas®) was registered in California in December 2010. 

To date, it has only been used on a few acres throughout California and only 5 acres have been for strawberry production. This is likely due to cost concerns 

and to fear by growers that the public will perceive that the methyl iodide fumigation is unsafe and that strawberries are unsafe if they have been produced on 

methyl iodide-treated land. 

The Party reduction of 10% is based on uptake of a range of alternatives including 1,3-D/Pic in line and shank applied, Pic alone.

The Party states that mixtures of 1,3D and Chloropicrin have regulatory constraints. The Party assumed township caps were fully used up, consistent with 2013 

CUE approved by the parties. This mixture, when applied by drip, does not effectively control Macrophomina (Ajwa, personal communication). Additional 

research is underway to improve efficacy of shank application of 1,3-D /Pic. Use of shank application increases the Township Cap factor and reduces the total 

acreage that can be treated with 1,3-D over the acreage that can be treated if drip application is used. With successful research over the next 2 years, shank 

1,3-D /Pic will be part of the 10% reduction. The CUN states that research has indicated that with the use of totally impermeable films, drip-applied 1,3-

D/chloropicrin formulations (Telone C-35 with 63% 1,3-D) at 200 lb per acre (225 kg/ha) is as effective in terms of yield and weed control as a standard methyl 

bromide treatment (Fennimore and Ajwa, 2011). The CUN states that research has shown that this can lower the amount of 1,3-D by 33% below the rate 

typically used with standard films and, therefore, may result in reducing the burden of caps that restrict the overall amount of 1,3-D used in a township. Pic-Clor 

60 is formulated with lower rates of 1,3-D (39% 1,3-D) and has been effective in field trials, but chloropicrin restrictions are also in place in some counties and 

reduce its use. These research trials did not address issues associated with Macrophomina or Fusarium.

Carbonation of 1,3-D/chloropicrin formulations may help to reduce the overall use of 1,3-D by increasing its dispersal in the soil while providing yields 

comparable to methyl bromide (Thomas et al., 2011b). In Florida trials (Noling and Cody, 2011), most alternative fumigants evaluated produced yields which 
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were statistically equivalent to that of methyl bromide chloropicrin 50/50 (320 lb/[treated] acre). Co-formulated fumigants such as Telone C-35, generally 

performed better than that of Pic-Clor 60 for maintaining strawberry crop productivity and nematode control‖.

The nomination and subsequent responses received by MBTOC state that chloropicrin is a widely used alternative and is considered part of the reduction in 

2014. Regulatory restrictions at the county level limit the maximum rate and potentially the efficacy against key pathogens. Areas with high pest pressure would 

likely require rates above 200 lbs/acre (224 kg/ha), requiring a permit from the County Agricultural Commissioner – which has to date seldom been granted and 

is given on a case-by-case basis.

The CUE outcome approved by Parties in 2011 was based on methyl iodide uptake of 21% over 3 yrs, i.e. 721 ha by 2013. In 2011 only 2 ha used MI/Pic, even 

though a reduction of 7% (240 ha) was made for transition to methyl iodide in 2011. 

Anaerobic soil disinfestation (ASD) has given promising results on demonstration plots. No test data has been obtained on Macrophominia or Fusarium; only 

Verticillium in test plots. Type of organic matter, amounts, method of incorporation, keeping moisture on plots, and source of organic matter are technical issues 

to be determined. Further research on efficacy is required (and planned).

The Party states that steam technologies are under development and look promising. While there is some commercial application of steam in flowers, there is 

no commercial application of steam in strawberry production other than demonstration trials (two acres in 2011). The current price of steam application is 50% 

higher than treatment with MB. More research is needed to increase efficiency and decrease cost. 

A substantial increase in organic acres would not allow a continued price premium for organic strawberries, a necessity for this industry. Moreover, any increase 

in organic acres will likely be insignificant relative to the net number of strawberry acres, thus having a negligible impact on the CUN.

Breeders are working on development of cultivars that are tolerant or resistant to key diseases, especially Macrophomina and Fusarium. Dimethyl disulfide 

(DMDS) is registered for the use in strawberries at the federal level, however, it is not registered in California. Substrate use has not shown economical 

feasibility, but research continues to reduce costs. 

MBTOC Assessment:

Review of the Californian databases by MBTOC, has shown that for the three major strawberry MB use regions in California (Oxnard, Watsonville/Salinas and 

Santa Maria, the fruit production areas are almost 4713 ha, 6228 ha and 3947 ha respectively (California Strawberry Commission (CSC) surveyl). The most 

recent PUR data (2003-2010) show that alternatives, namely 1,3-D, Pic and metam have been widely adopted in these production districts. State-wide in 

California, the CSC survey expects 15,535 ha strawberry fruit in 2012. The Californian Department of Pesticide Regulation – Pesticide Use Reporting (PUR) 

database shows that in California the area of 1,3-D use has more than tripled from 2001 ha (2003) to 6422 ha (2010), and the Pic straight area of use more than 

doubled from 1021 ha (2003) to 2405 ha (2010). In addition, CSC survey data show that the organic production acreage will grow from 245 ha (2003) to an 

expected 790 ha (2012). 

MBTOC notes that regulations in California prohibit the use of low permeability (high barrier) films with MB application, and therefore discourage reduction of MB 

dose rates as well as emission control through use of these films (eg VIF, SIF and TIF).
34 October 2012 MBTOC CUN Final Report

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MBTOC acknowledges that the alternatives have been significantly adopted in all counties in the past 4 years, which indicates their technical and economic 

feasibility. MBTOC understands that regulatory restrictions, township caps on 1,3D and maximum rate restrictions for Pic imposed by county Ag commissioners 

affect their use. MBTOC notes encouraging trends for increased uptake for Pic alone, Pic-Clor60 and 1,3D + Pic reported through 2010. 

MBTOC acknowledges that the Party has made a 10% reduction for uptake of a range of alternatives, but has calculated that further adoption of alternatives is 

possible and has reduced the nomination by an additional 15% to enable transition to these alternatives in 2014. MBTOC understands that this situation may be 

affected by impacts of new label restrictions on fumigants that come into effect in December 2012, and legal issues regarding the availability of MI. If methyl 

iodide becomes unavailable, MBTOC would need to reassess this nomination. 

The total reduction includes a10% reduction of the 2013 CUE made by the Party and the further reduction (15.47%) made by MBTOC. The total reduction as 

calculated by MBTOC is based on;

1) 261 ha (or 15%) of the expected area in 2013 affected by township caps on 1,3-D mixtures being able to transition to strategies using these fumigant 

mixtures. These include those which use less 1,3-D dose per unit area, including uptake of Pic-Clor 60, use of barrier films to reduce dosage rates with 

all 1,3-D formulations and rotation with broad acre fumigant strategies to improve the effectiveness of disease control. MBTOC notes that official 

databases report approximately 6,500 ha of strawberry fruit production using different formulations of 1,3-D in 2010.

2) 150 ha of the total nomination being able to uptake Pic straight formulations which are not restricted by permit conditions

3) 270 ha of the total nomination being able to uptake methyl iodide

4) 10 ha of the total nomination being able to uptake new technologies of either steam, anaerobic soil disinfestation or organic production strategies. 

In regards to concerns about an increase of diseases caused by adoption of alternatives, reports stress that there is not enough evidence to directly support the 

relationship between the appearance of Macrophomina and Fusarium diseases and MB replacement (López-Aranda et al., 2009). The diseases are present in 

numerous crops and regions of the world independently from MB use. MBTOC, however, does accept that reports (rKoike et al. , 2010) show that there is an 

association of these diseases in areas where drip applied fumigants are being used and that broad acre shank treatments with fumigants (e.g. 1,3-D/Pic 

mixtures, Pic and metam sodium) may be required to clean up infested fields. 

MBTOC notes that the available literature shows promising non MB management strategies for these diseases. Disease susceptibility varies between cultivars 

and some of the currently used strawberry varieties show good levels of resistance although not for both pathogens (Koike et al., 2010; Daugovish et al., 2011). 

Fumigants applied in Californian conditions provide protection from these pathogens early and mid-season although not in late season during May-June, (Koike, 

2011; Daugovish et al., 2011); in Israel research shows that metam sodium (730 l/ha) caused 90 and 95% pathogen mortality in field experiments, at the same 

levels of MB, indicating that fumigation may be an effective method of managing this pathogen in infested soils (Zveibil et al., 2012). Attention should also be 

given to efficiency in fumigant delivery and distribution to all bed areas to delay plant collapse at the most susceptible zones such as bed sides (Koike et al., 

2010; Daugovish et al., 2011). An integrated management strategy for these diseases should include: a) site selection avoiding infested fields; b) crop rotation 

with plant non-hosts; c) Pre-plant fumigation; d) Sanitation measures to avoid moving infested soil or contaminated equipment; e) the use of tolerant cultivars, 
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and f) reducing plant stress mainly by maintaining optimum soil moistures and proper irrigation (Koike et al., 2010; Daugovish et al., 2011).

MBTOC notes that low permeability (high barrier) films can be used on MB alternatives and that lower dose rates of 1,3-D with barrier films are effective. 

MBTOC notes that databases show MB use for strawberry fruit in California has been higher than the exempted amount for four years since 2006. In 2010, 

almost 100 tonnes more MB was used than was exempted for this particular use. MBTOC also notes that in 2010, the overall average dosage used across 

strawberry fruit producing counties was 208 kg/ha, with a predominant formulation of 57% MB. Formulations of 67% and 98% are still used in a significant 

number of applications (Source: Cal DPR-PUR). MBTOC continues to encourage wider use of 50:50 formulations, which still allow for complying with regulatory 

restrictions on Pic use.

MBTOC notes and commends the withdrawal of MB for this use in Florida and Eastern USA, where full transition to alternatives has been completed.

MBTOC continues to urge the Party to develop an action plan for California, particularly addressing the restrictions on the use of alternatives adopted elsewhere 

in the USA, and showing stepwise reductions to effectively progress the transition to MB alternatives. 

MBTOC comments on Economics in 2012:

An economic analysis indicates that the gross margin (termed net revenue in the CUN) for strawberries using methyl bromide was $33,744 per hectare while that 

of broadcast alternatives ranged from +10% (with Pic-Clor 60 (1,3-D plus chloropicrin)) to -9% (with methyl iodide, 33:67), based primarily on the cost of the 

individual fumigant. These changes are not large and fall within the range of expected annual variation experienced in agriculture, with the implication that these 

alternatives are economically feasible. Drip alternatives also result in higher gross margins, while steam results in a small decline of 1% in the gross margin, 

again implying that these alternatives are economically feasible. However, in the case of steam, the costs that are presented are based on small plots (10 acres 

or less), so it may not yet be economically feasible on a commercial scale.

MBTOC notes the outcomes from a key economic study conducted in California (Mayfield and Norman, 2012) which indicates that the years of declining MB use 

have been years of rising yields, increased cropping areas, exports and revenues. In future nominations, it is anticipated that a thorough review of the 

information used as the basis for this study is considered by the Party.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission reduction: In California low permeability (high barrier) films are not allowed for use with MB, but are allowed and available 

for use with alternatives;

 Dec. IX/6 b(ii) Research program: Yes, there is an on going research program, but specific data justifying CUN requests need to be provided.

 Dec. IX/6 b(iii) Appropriate efforts: In California there is varying effort in the different production districts.

1

1ExMOP and 16MOP; 216MOP+2ExMOP+17MOP; 3MOP17+MOP18; 4MOP18+MOP19; 5MOP19+MOP20; 6MOP20+MOP21; 7MOP21+MOP22; 8MOP22, 9MOP23
36 2012 MBTOC Report on 2012 CUNs:Final Recommendations

1.5 MBTOC-Structures and Commodities – Final CUN Report

At the Open Ended Working Group in Montreal, in July 2012, MBTOC (SC) held a bilateral meeting 

with the United States. The purpose was to discuss Parties‟ views concerning MBTOC SC‟s interim 

CUN recommendations, receive and provide additional information and discuss outstanding technical 

and economic questions. In the May TEAP report, MBTOC SC had been unable to assess one CUN 

for cured pork pending the receipt of data pertaining to MB use in those facilities. 

MBTOC SC indicated that it would conduct re-reviews of CUN decisions if Parties requested and 

provided additional information; the United States requested re-reviews of the cured pork CUN for 

2014 and the dried fruit sector of the commodities CUN for 2014. The additional information was 

sent in August 2012.

1.5.1. Process used by MBTOC SC to conduct CUN re-reviews

Parties have required MBTOC to ensure both robust discussion by all members and that CUN 

recommendations are formed by members with appropriate expertise. 

In its October 2010, May 2011 and May 2012 TEAP reports, MBTOC SC indicated that lack of 

funding of members to travel to meetings would result in the ability to hold only one MBTOC SC 

meeting in 2011 and one meeting in 2012. As most MBTOC SC members continue to be inadequately 

funded for MBTOC travel, and knowing that a second meeting had not been planned in 2012, 

MBTOC SC agreed to conduct the re-reviews by email. 

Accordingly, MBTOC Co-Chairs agreed on the following process to conduct the re-reviews 

electronically. 

All the information from Parties was circulated to all members for an opportunity to make comments 

about the reassessment. Additionally the information was posted on MBTOC‟s private website. 

Members were asked to submit comments by the end of August. 

Comments from members of other sub-committees were-considered by each member of the relevant 

sub-committee, who then submitted their own assessment comments, and then discussed the various 

views. Originally, each member of the relevant sub-committee was asked to send their review/position 

to the relevant Co-chair(s) during the second week of September, 2012. In the case of MBTOC SC, 

this process was very robust and continued until the third week of September. 

The coordinating Co-Chair provided a summary of this information to the sub-committee, and began 

forming a consensus position by the drafting of proposed text boxes and recommendations. Subcommittee members then further discussed, commented on and made changes to the proposal until a 

consensus was reached. The agreed text box and recommendation was again circulated to obtain 

consensus (or agreement not to disagree) by each member of the sub-committee. The consensus 

positions of each sub-committee were sent to full MBTOC for information and approval of the subcommittee findings.

The results of the re-reviews were incorporated into this report which focused mainly on the 

reassessed CUNs.

1.5.2. Resourcing issues in 2012 and in coming years

Under Decision XV I/4 Annex 1, MBTOC was instructed to meet twice a year when making CUN 

recommendations to ensure it has full information and to allow Parties seeking CUEs to provide 

information after MBTOCs first review. At the time of that Decision, twice annual meetings were 

considered necessary to allow MBTOC to conduct re-reviews or to complete reviews of CUNs. 

Parties can request a re-review if they disagree with MBTOC‟s first-review recommendations, and by 

providing additional information supporting their CUN. 
2012 MBTOC Report on 2012 CUNs:Final Recommendations 37

However, when MBTOC has not been preparing an Assessment report and when Parties re-reviews 

have been few, MBTOC has occasionally met only once per year. Aside from those factors, the 

ability of MBTOC to meet is limited by the on-going lack of availability of funds for members‟ travel 

and subsistence. MBTOC SC met only once in 2011, and once in 2012, and instead conducted its rereview by email. This was necessitated because of lack of funding by members, but also because just 

a few CUNs required re-review. 

In October 2011, MBTOC draws the attention of the Parties to that the requirement that MBTOC 

meet twice a year in Decision XVI/4 Annex 16, may require further clarification in light of the 

reductions of CUNs, lack of funding of members, and that now, seven years after MOP 16, meetings 

can take place electronically. Some Parties commented on this aspect during MOP 23, indicating 

understanding of this situation and reserved agreement as long as robust discussion of CUNs was 

incorporated.

In recent years, the number of CUNs has been reducing steadily, but it is unclear if this trend will 

continue if A-5 Parties begin to submit CUNs in 2013. Another unknown factor that will affect 

resourcing is that initial CUN submissions take more time to review; Parties in their initial 

submissions, have difficulty understanding the information requirements for critical use nominations 

and necessary information may not be available. MBTOC may be unfamiliar with the specific 

circumstances of the CUN. 

If, in coming years, several new CUNs are submitted, and if there are difficulties understanding 

requirements and sourcing information, MBTOC will require two meetings a year. Furthermore, it 

would be preferable if more MBTOC members could receive funding to attend the OEWG meeting 

for discussions with Parties that seek any clarification on the interim recommendation by MBTOC. 

1.5.3. Details of evaluations

In 2012, Parties submitted five CUNs for the use of MB in structures and commodities in 2014. 

In its May 2012 TEAP report, MBTOC indicated it was unable to assess the CUN for cured pork 

because we were awaiting further information on the volume of the aging rooms to be treated, as 

explained in the text box. The Party was asked to supply the needed information. Accordingly in 

August 2012, the Party submitted considerable new information to MBTOC based on a survey of 

cured pork facilities. Additionally, the Party submitted new information about the adaptability of 

certain alternatives for dried fruit when fast turnaround is required. MBTOC then considered this 

information in its re-review. 

The total MB volume nominated in 2012 for non-QPS post-harvest uses was 33.501 tonnes. Of the 

nominations in 2012 for 2014, and following the re-reviews, MBTOC recommended 32.237 tonnes, 

(Table 1.10 and 1.11). Table 1-8 provides the MBTOC-SC final recommendations for the CUNs 

submitted.
38 2012 MBTOC Report on 2012 CUNs:Final Recommendations

Table 1-10. Summary of the final recommendations by MBTOC-SC (in square brackets) for 

CUE’s for postharvest uses of MB (tonnes) for 2014 submitted in the 2012 round.

Country and Sector Nominated in

2012

Recommendation for 

2014

Australia. Packaged rice 1.187 [1.187]

Canada. Mills 5.044 [5.044]

USA

1. Commodities

 2. Mills and Food Processing Structures 

 3. Cured Pork

0.740

22.800

3.730

[0.740]

[22.800]

[2.466]

USA Sub total 27.270 [26.006] 

Total 33.501 [32.237]
October 2012 MBTOC CUN Final Report 39

Table 1-11. Final evaluations of CUNs for structures and commodities submitted in 2012 for2014

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

Australia Rice 6.150 6.150 .205 9.200 7.820 6.650 4.87 3.653 2.374 1.187 [1.187]

MBTOC Recommendation for 2014: 

MBTOC recommends 1.187 tonnes of MB, the amount nominated by the Party, for use on packaged rice in 2014.

Nomination by the Party: 

The Party nominated 1.187 tonnes, a 50% decrease of the amount of MB granted by the Parties for this use in 2013.

Circumstances of the Nomination: 

The nomination is for packaged rice. The Party confirmed its phase out plan nominating in 2012 for 2014 as a final transition year with the aim that in 2015, 

there would be no further MB CUN nomination. The Party indicated that regardless of the volumes of rice harvested, this phase out plan would be carried 

out. Fifty percent of all non QPS MB use is being recaptured.

The Party indicates that the applicant is pursuing the adoption of phosphine for treatment of rice in silo bins and in fumigation chambers. They are planning 

to fumigate milled rice in silo and conduct chamber fumigations on packaged rice. As explained to MBTOC on previous occasions and in the current CUN, 

the applicant does not yet have the required facilities to deal with the lengthy exposure times required for phosphine. They are currently working through this 

project and the first stage of construction is going into the 2012 capital budget. It is expected that construction of the first stage will be in 2012 and the 

second stage in 2013 through early 2014, in line with their phase out plan.

MBTOC Review and Assessment: 

MBTOC notes that these applications with phosphine will only succeed in controlling the developmental stages of Sitophilus spp. if the appropriate 

temperature (> 25°C) occurs during the treatments and if the treatments will last for 72-144 hours. 

The Party submitted the results of a research study on the efficacy of sulfuryl fluoride (SF) to control the pests of rice. MBTOC notes, however, that the 

treatment of packaged rice with (SF) is not registered in Australia. In the research the temperature of the reported trials was far below the levels that are 

necessary for achieving complete control of all stages including the eggs of pest insects like Sitophilus spp., Tribolium spp. and Plodia spp. MBTOC 

recommends further experiments with SF at temperatures of 26°C or above. The Party in its response to MBTOC noted that the temperature of rice after 

milling is 30 ̊C, and so a reasonable temperature for SF effectiveness should not be difficult to achieve. MBTOC encourages the Party to continue its 
40 October 2012 MBTOC CUN Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

research effort to generate data in support of SF registration for this purpose in Australia because of the need for an alternative should resistance to 

phosphine occur. 

To ensure the success of the adopted alternative, the Party should thoroughly conduct 1) disinfestations of raw rice prior to packaging to control especially 

the internally feeding Sitophilus spp. and 2) disinfestation of processed rice in packages. 

1) After milling of the rice, which is a control method in itself for externally feeding stored product pest insects, the fairly high temperature of 30°C should 

immediately be used to carry out any disinfestations measure. Internally developing Sitophilus stages do survive some milling.

2) If any holes are pinned into the packages to avoid package ballooning it must be ensured that their size remains always below a diameter of 0.1 mm to 

prevent young larvae of externally feeding species from invading these packages and resulting post-process re-infestation. 

Independently of what kind of fumigant is used for disinfestation of packages, the permeation or diffusion of the gas through the plastic laminate is a crucial 

factor for control. SF is even a less penetrating gas than MB and phosphine. So, the fumigation of packages will only be successful if there are enough 

openings. Improvements in pest control will improve rice quality and a recent report indicates that consumers may be inclined to pay more for rice when 

improved pest control techniques have been used (Su et al, 2012, in press) 

Tribolium and Plodia complaints indicate post-process reinfestation. Insect-tight packaging should be used to protect the processed rice products to prevent 

pest infestation while the product is in the food chain. Perforated packages will possibly allow postpackaging infestation. As part of the reason supporting its 

request for MB for packaged rice, the Party cites product returns costing $AU 3,440 in 2009 related to pest infestation of product. The Party notes that 

reducing these claims has been a focus of the rice company for the past several years and that use of MB has been part of their pest control system that 

has since 2002 resulted in significant reduction in claims against the company for insect contamination. The Party was unable to inform MBTOC about the 

species of insects involved in the claims; this information would indicate whether the insects were those that might have survived milling (Sitophilolus 

oryzae, for example) or those that likely entered the packaging after milling (Plodia interpunctella for example). The Australian rice company, as many other 

companies, punches holes in their packaging to facilitate stacking, but as the recent reviews by Athanassiou et al. (2011) and Bell (2011) detailed, these 

holes can easily allow larvae and even small adults of certain pest species access to infest the product after packaging. This can occur during transport or in 

the marketing channel. Use of MB does not prevent this type of infestation. 

MBTOC Comments on Economics 2012:

The Party reports the applicant is making the necessary investments in silos and chambers to allow it to complete transition to phosphine.
October 2012 MBTOC CUN Final Report 41

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

Comments Requested in Dec. XX1/11 (para 9):

Dec. IX/6 b(i) Emission control: Fifty percent of all non QPS MB use is being recaptured.

Dec. IX/6 b(iii) Research program: Research on efficacy of SF for packaged rice has not been successful, perhaps due to inappropriate temperature, but 

SF is not registered for packaged rice in Australia. The applicant is completing its transition to phosphine

Dec. IX/6 b(iii) Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol 

nominations has control over pesticide registration. Phosphine, the selected alternative, is already registered for this use.
42 October 2012 MBTOC CUN Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

Canada Mills 47 

(included 

mills and 

pasta)

34.774 30.167 28.650 26.913 22.878 14.107 11.020 7.848 5.044 [5.044]

MBTOC Recommendation for 2014:

MBTOC recommends 5.044 tonnes, the amount nominated by the Party, for use in mills in 2014. 

Nomination by the Party:

The Party nominated 5.044 tonnes, an approximate 35% decrease of the amount granted by the Parties for this use in 2013.

Circumstances of the Nomination:

The Party advises that mills that are producers of durum semolina or have integrated/contiguous bakery mix plants and those that are particularly large 

structures are the remaining methyl bromide users. The CUN states that the amount requested is only sufficient for a single treatment of up to 5 of the 11 

mills in the application, 6 fewer than last year‘s application due to transfer to alternative treatments such as heat and upgraded IPM programs. As per 

Canadian regulation, mills which are listed in the CUN may, if necessary, share some of the total CUN amount granted so that is why more mills are listed 

than will actually be fumigated. The listed mills are processing semolina or are very large mills with internal grain storages. Mills with internal grain storages 

present problems with the use of sulfuryl fluoride in the Canadian context because there is no food contact tolerance and it is not possible to completely 

empty internal grain storages before a fumigation.

The Party notes that mills producing semolina from durum wheat cannot use entoleters as an end process to ensure complete insect control on finished 

product because the process would reduce semolina size making it unsuitable for pasta production.

Barring any unexpected event, The Party notes this is the last year the Canadian National Millers Association (CNMA) intends to present an aggregated 

request from all flour millers. The Party notes that future nominations will be done by an individual mill on an as-needed basis. 

MBTOC Review and Assessment:

Pertaining to the Party‘s concerns on insects in semolina as a reason for using MB, Bhuvaneswari et al., 2011, indicates that specks, commonly agreed to 

be an indicator of low quality in finished pasta and couscous, originated in part from insect fragments. However, MBTOC considers that processes and 

techniques to eliminate insects in wheat and during early milling processes would have a more important impact to remove insects than mill fumigation in 

this instance. Insects remaining in semolina will be killed by the heat processes used to make couscous or pasta. In this and past CUNs, however, MBTOC 

notes and accepts that the presence of pests in mills, alive or dead, is unacceptable from viewpoints of regulatory inspection, commercial standards, 
October 2012 MBTOC CUN Final Report 43

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

consumer expectation and human health.

MBTOC notes that there has been substantial investment in upgrades in construction aspects which have significantly improved gastightness in some mills. 

Evaluation of alternatives to methyl bromide in progress include: heat treatments; ECO2Fume (carbon dioxide and phosphine mixed in gas cylinders), 

sulfuryl fluoride (SF) (but only if there is no food contact); plus integrated pest management programs alone or in combination with heat treatments and/or 

fumigations with one of the fumigants mentioned above. Large mills have difficulty with heat treatment because of heat sinks and slow heat transfer in 

wood. Complete evaluation of the heating requirements for any single milling facility is a process of trial and error, unique to each site and one that takes 

time to complete. 

The use of phosphine is a cause of concern because of the potential for corrosion of electronic components and for the likelihood of developing pest 

resistance when there are repeated applications of short exposures at warm temperatures which result in pest survival. The results of current trials with SF 

have indicated poorer than expected efficacy, it would seem because adequate temperatures of 26 ̊C (80 ̊F) or above are not being maintained and the 

vulnerability of concentration level maintenance in windy conditions, resulting in the survival of eggs of red flour beetle. This is significant because red flour 

beetle is the pest of most concern in Canadian mills. This was most recently confirmed by Hawkin et al, 2011. 

For all alternatives, the intensifying regulatory pressure in North America to improve food safety by eliminating all human pathogens, contaminants and 

stored product pests from food ingredients and processed foods, with forthcoming new food safety legislation in the US, is increasing the pressure to raise 

the already high efficacy levels of treatments to eliminate pests. Mills in Canada have to operate according to a ―Required efficacy‖ standard which means 

no live insects, including eggs, in milled grain product fractions leaving the mill for customer destinations across the continent. 

There is registration of SF for empty facilities but the widening of this registration originally expected in the summer of 2009 has stalled, perhaps due to 

concerns raised about its use because of the potential to increase fluoride to unacceptable levels where there are high natural fluoride levels in certain 

regions of the US. Until such problems can be resolved commercial adoption of SF will be delayed. MBTOC notes that in the EU the use of SF has been 

more widely accepted if mills discard the first 10 or so tonnes of flour after a SF fumigation. If a similar technical decision could be implemented in Canada it 

could improve prospects for wider use of SF in Canadian mills.

MBTOC Comments on Economics 2012:

In past years, the Party has submitted economic analysis with its technical reports; the sector is proceeding with transition to alternatives in 

spite of higher costs. The CUN is not based on economics. Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission control: Over the years the Party has reported considerable investment in mill improvements to improve sealing and 

decrease MB use. MB dosage rate is within standard presumptions. Mills are sealed before fumigation to ensure gastightness and ensure the 

standards for dosage rate are met.
44 October 2012 MBTOC CUN Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

 Dec. IX/6 b(iii) Research program: Excellent research multi-mill, multi-stakeholder research program in past with several full reports submitted to 

MBTOC (SF, heat and DE, SF and elevated temperature, phosphine + CO2, etc.,). New mill research has been conducted this year. 

 Dec. IX/6 b(iii) Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol 

nominations has control over pesticide registration. SF is not approved for food contact in Canada. A technical decision giving an interpretation 

clarifying product discard after an SF treatment might encourage wider use. 
October 2012 MBTOC CUN Final Report 45

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

United 

States

Commodities 89.166 87.719 78.983 58.921 45.623 19.242 5.000 2.419 0.822 0.740 [0.740]

MBTOC Recommendation for 2014:

MBTOC recommends 0.740 tonnes for use in dried fruit and walnuts in 2014, a 10 % decrease of the amount granted by the Parties for this use in 2013. If it 

were to be provided, an updated phase out plan for dates and walnuts would inform MBTOC and Parties of the continued timing of its transition to 

alternatives.

Nomination by the Party:

The Party had requested 0.740 tonnes for use in dried fruit and walnuts, a 10% decrease of the amount granted by the Parties for this use in 2013. 

Circumstances of the Nomination:

In its interim report of May 2012, MBTOC had recommended 0.487 tonnes for this use and disaggregated into the following amounts: California walnuts 

0.161 tonnes; dates 0.325 tonnes and dried plum board 0.001 tonne. However, the Party then requested the recommendation of their original nomination of 

0.740 tonnes. 

Phosphine and sulfuryl fluoride are the primary fumigants for dried fruit and walnuts in storage. The Party said that the industry has already transitioned as 

much as it can to SF and phosphine

Fumigation with phosphine takes approximately three days, a time which is said to disrupt market flow and shuts down the processing area. There are 

concerns that the use of phosphine would eventually result in some corrosion of electrical and electronic equipment in the processing areas, but MBTOC 

believes this concern should be manageable. . 

Companies are delaying the purchase of new chambers which could expand the use of phosphine as they await research results of combination treatments 

which may offer improved efficacy against the eggs of pests and then, a regulatory review may be required.

The combination process mentioned above is sulfuryl fluoride (SF) and propylene oxide (PPO). Currently, propylene oxide (PPO) label limits the size of 

chambers to 10,000 cubic feet, a size impractical for the tons of dried fruit involved. In addition, there is a 200 foot buffer requirement for use of PPO in 

10,000 cubic foot chambers, which the Party says would negatively impact ongoing plant operations. Furthermore, the label requirement for 8% PPO 

includes a minimum heat treatment of 100 oF (37.8 oC), which would be costly—but which MBTOC believes should be achievable. 
46 October 2012 MBTOC CUN Final Report

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

PPO is more effective on the egg stage of many insect pests of dried fruit than SF. As noted above, a combination treatment of PPO and sulfuryl fluoride is 

being researched by the USDA Agricultural Research Service that could minimize disruption to the current dried fruit processing flow and retain current 

processing equipment without major modification. This effort is being undertaken to establish an effective treatment using SF and PPO against eggs at 20 

oC and under, i.e., during the cooler season. Changes in use patterns, such as a fumigation with a combination of SF plus PPO or the use of PPO in larger 

chambers, could require regulatory review by the EPA to allow for label revisions. 

As a result, when market demands fast turnaround immediately before shipping, methyl bromide vacuum treatment, a 4-6 hr treatment, is still occasionally 

required.

SF is efficacious for walnuts and dried fruit, but the Party has documented temperatures at or below 50°F in San Joaquin and Sacramento Valleys of 

California, their main date production areas and this would be incompatible with SF fumigation.

The Party noted that, currently, methyl bromide is the only treatment available to rapidly disinfest California dates at harvest time, when up to a million 

pounds per day are harvested within a relatively tight timeframe during the fall. These dates are harvested by hand, and growers need to get them to the 

marketplace in three days before fermentation begins. Although several insects may infest dates, the carob moth, Ectomyelois ceratoniae, is the most 

damaging species. The Party reports that the California Date Commission is currently testing the efficacy of sulfuryl fluoride on dates in collaboration with 

USDA; unfortunately, preliminary results show less than adequate egg kill, even when the amount used is twice that needed for comparable methyl bromide 

fumigation (Walse, 2011). Phosphine takes longer, 5 to 7 days, to fumigate dates, and during this time the dates ferment, resulting in an off-flavor and an 

unmarketable product. 

Dr. Walse's current (and future) research on dates focuses on disinfestations of insects required within hours of harvesting. The ovicidal deficiencies of SF 

toward several insect species endemic to California has questioned its technical merit, economic feasibility, and regulatory compliance when used in this 

capacity under local conditions. This critical drawback to SF can be circumvented if it is paired with a potent ovicide over the course of the fumigation 

process if extra heat cannot be provided. Accordingly, Dr. Walse conducts research that evaluates ovicides to use in concert with SF fumigations.

MBTOC Review and Assessment:

Upon review of the information submitted by the Party pertaining to research results, logistics and economics of the alternatives, including difficulties 

obtaining efficacy in killing the eggs of pests in dried fruit, and including the need to fumigate quickly before shipments in cool autumn months, MBTOC was 

able to recommend the full nomination. 

However, it must also be said that MBTOC is concerned about the length of time the sector is taking to make the logistical changes to enable the use of 

phosphine or other alternatives. MBTOC believes a complete transition to alternatives should be possible by 2015 for walnuts and the dried fruit included in 
October 2012 MBTOC CUN Final Report 47

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUN for 

2014 

MBTOC

rec. for

2014 

the dried plum board segments of this nomination. 

MBTOC believes supplemental heaters could be used to improve the efficacy of treatments with walnuts and dried fruit in the absence of data to the 

contrary. However, time might be required to gain experience with their use and resolve logistical issues. For this reason MBTOC was able to agree with 

the recommendation for walnuts for this year to allow for the continued transition to alternatives. However, we would expect that this transition would be 

completed next year since little information has been received on progress in transition. 

In its 2013 text box on the US dried fruit and walnut CUN, MBTOC noted that there were alternatives available dried plums saying, ―We would expect that 

any further commodities CUN would not include dried plums since they should be protected from post-process re-infestation with treatments other than MB‖. 

(MBTOC Oct 2011). In May 2010 MBTOC said, ―The USG reported that until viable options with the registered alternatives are further developed, the dried 

fruit industry has reached the maximum adoption of alternatives. But MBTOC believes there are several lines of action available with registered alternatives 

to almost entirely avoid the use of MB for dried fruit and nuts. For example, phosphine, cold storage after heat drying to prevent re-infestation and propylene 

oxide (when used to reduce bacteria and mold, insect pests will also be killed) are alternatives that could be used for the commodities in this CUN. SF is 

also registered for some of these commodities. In Germany carbon dioxide under pressure is used to disinfest some dried fruits.

The industry acknowledges that dried plums are free of insects when they come out of the dryer and that re-infestation occurs fairly soon thereafter; the reinfestation is the reason for these stored commodity treatments. MBTOC‘s view is that the industry should work to prevent re-infestation and recommends 

this logistical problem be resolved on a priority basis. 

The USG said in correspondence that the industry has already transitioned to phosphine where possible, but that MB is needed if treatments need to occur 

around electronic and electrical equipment. MBTOC, in its May 2012 interim recommendation did not find this a valid reason. Commodity requiring 

phosphine fumigation could be moved to an appropriate location for fumigation, and new fumigation chambers could be purchased. 

However, companies are delaying the purchase of new chambers, which could expand the use of phosphine, as they await research results of combination 

treatments (sulfuryl fluoride and propylene oxide) which may offer improved efficacy against the eggs of pests and then, a regulatory review may be 

required. MBTOC will expect that this process will be completed before any further nomination for dried fruit as there will then have been adequate time to 

purchase phosphine chambers and resolve the logistics problem. 

The Party states that the California dried fruit and nut industries continue to financially support research on methyl bromide alternatives for postharvest 

applications, but full reports of these tests have not been submitted to MBTOC.‖ (MBTOC May 2010.)

Additionally, new research conducted at USDA laboratories reported, ‖...biweekly or monthly applications of methoprene plus 1% pyrethrins or 

esfenvalerate eliminated P.interpunctella populations on raisins, as did biweekly methoprene aerosol treatments. The dried fruit and nut industries use 

fumigants for control of Indianmeal moths... and our simulations show that it may be possible to also use aerosol applications in sites where products are 
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processed, bagged, and stored.‖ (Fontenot, 2012 in press)

In its May 2012 interim recommendation, MBTOC noted that there are sufficient alternatives and sufficient time has passed to transition, and therefore 

recommended only a minimal 1 kg to allow for access to MB stocks under the US regulatory system. However, in its final recommendation, MBTOC has 

agreed to the use of MB as nominated for 2014, and assumes it is the final year for walnuts and the dried fruit included in the California Plum Board section 

of this CUN. 

MBTOC currently agrees with the information provided on dates, the lack of effective alternatives which would result in a marketable product, the 

assessment of the research results, and the research plan. 

MBTOC Comments on Economics 2012:

Walnuts: The CUN provides a detailed financial analysis in the form of a partial budget of the cost of fumigating walnuts with methyl bromide, with sulfuryl 

fluoride, and with phosphine. SF results in an increase in gross margin because the price per unit is lower, even though the dosages applied are higher. 

Phosphine requires capital investment in fumigation chambers in the first year because of the longer fumigation time and the danger of missing a market 

window, but thereafter is cheaper to use as the unit cost is lower than that of methyl bromide. The full cost of the fumigation chambers is charged in the first 

year.

Dried fruit: The CUN shows that treatment with SF results in a higher gross margin, and that treatment with phosphine, while resulting in a lower gross 

margin in the first year because of the need to provide fumigation chambers, will in later years also lead to a higher gross margin.

Dates: SF is the only technically feasible alternative in dates, and the CUN shows that its use results in an increase in gross margin.

The CUN is largely, but not entirely, based on technical, rather than economic arguments. However, in its request for re-review of this nomination the Party 

discussed higher costs of the alternatives as a reason for their lack of adoption. 

For example, the party provided the following discussion concerning the costs of cold storage. ―Total new cold storage construction costs for prunes, raisins 

and figs would be substantial, even assuming the producer would not have to incur costs in acquiring land for that purpose. Cold storage also involves 
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reoccurring costs related to consumption of electricity for cooling and maintenance in addition to those fixed construction costs.‖

Concerning the use of propylene oxide, the Party said, ―Furthermore, the label requirement6for 8% PPO includes a minimum heat treatment of 100 oF (37.8 

oC), which would be costly. ―

Concerning the use of supplemental heat which would be expected to improve the efficacy of sulfuryl fluoride treatment against pest eggs, the Party said, 

―The costs of raising the temperature in the storage warehouses to allow for more effective treatment of dried fruit with SF under the current conditions 

would be expensive and additional time would be required to gain experience with their use and to resolve logistical issues. ―

Concerning the use of carbon dioxide under pressure, the Party said, ―The dried fruit industry has previously evaluated the use of controlled atmosphere 

(CA) storage. While an efficacious treatment, the additional costs render it not economically viable. According to Dr. James Thompson, Agricultural 

Engineering, UC Davis, construction costs for CA are 10% more than conventional Normal Atmospheric Pressure (NAP) storage. Newer storage chambers 

could be retrofitted at the additional costs but most of the industry‘s chambers are too old to be retrofitted.―

MBTOC appreciates this information but requests that any further nomination be accompanied by partial budget analysis of these alternatives. 

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission control: Fumigations are conducted in chambers of sufficient gas tightness.

 Dec. IX/6 b(iii) Research program: Research on dates has been focussed and ongoing, although the trials were not successful within the 

regulated requirements. A new research plan has been submitted which hold promise. A combination treatment of SF, carbon dioxide and 

propylene oxide continues to be researched as preliminary results were positive for dried fruits. 

 Dec. IX/6 b(iii) Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol 

nominations has control over pesticide registration. However, there are several alternatives registered for dried fruit and walnuts. Although SF is 

registered for dates, pest control efficacy cannot be achieved within regulatory limits. 

 

6

http://www.epa.gov/pesticides/chem_search/ppls/047870-00003-20100519.pdf
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United 

States

Mills and 

processors

483.000 461.758 401.889 348.237 291.418 291.418 173.023 74.510 25.334 22.800 [22.8]

MBTOC Recommendation for 2014:

MBTOC recommends 22.8 tonnes for use in mills in 2014. The recommendation is disaggregated into the following amounts: rice milling, 2.220 t; for pet 

food facilities 4.199 t; for mills 16.38t. If it were to be provided, an updated phase out plan would inform MBTOC and Parties of the continued timing of its 

transition to alternatives

Nomination by the Party:

The Party nominated 22.8 tonnes, a 10% decrease of the amount granted by the Parties for this use in 2013

Circumstances of the Nomination:

USG is requesting methyl bromide for this sector to allow time for the industry to purchase equipment, modify structures, and/or practice using alternatives. 

Pertaining to heat treatment, two companies with several mills and food processing plants have converted nearly all of their facilities, but are having difficulty 

with some facilities. For example, the Party reports that despite successful use of heat in other facilities, in one ―problem‖ mill it was not possible to maintain 

sufficiently high temperature for an appropriate exposure period to kill all stored product pests present. The company concerned is trying to determine how 

to address the problem of a heat sink in that mill. Another company has encountered difficulties attributed to the failure of heat to penetrate wall voids in 

order to kill the pests harboring there. Treatment of some facilities has resulted in the formation of ―hot spots‖ which damaged epoxy flooring, electronics, 

wood and plastic computer components in the facilities. Another mill has a corrugated sheet metal wall that is unable to maintain high enough temperatures 

for the length of time needed to kill the insects in the area.

Although there have been good advancements in the availability of appropriate heat treating equipment available to this sector, there are still localized 

problems in hot regions which do not normally need external heat equipment. So, while steam, electric or forced air gas heaters are available to this sector 

in most regions, two companies in California and Louisiana reported difficulty obtaining heat equipment at this time. 

The Party reported that, should a facility need fumigation during cold months, SF may not be a cost-effective solution because of the requirement to use 

supplemental heat and additional dosage. 

Pertaining to the use of sulfuryl fluoride in the sectors included in this CUN, there has been no regulatory change; SF is allowed for use in mills and rice 

processing but not allowed for contact of pet food and for the mixes and multiple ingredients present in many bakery products often found in some mills 

which produce such foods. If such foods are present, they cannot merely be tarped off during a fumigation and the Party says its applicants indicate that 
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completely removing all products would present significant logistical challenges. 

Barakat et al. (2011) described the necessary amount of SF for control of Plodia interpunctella eggs of different age at 27°C within one to four days stating 

that the ct product for these times is not constant but decreasing with longer exposures than two days. This indicates the possibility of controlling this pest at 

fairly low SF concentrations of 2 g/m3 by expanding the exposure to 96 hours. The Party could also refer to the MBTOC Progress Report of 2011 for the 

Special Report on SF Efficacy for a more thorough discussion of how to achieve efficacy in mills when using SF, 

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. 

MBTOC Review and Assessment:

Most of the facilities in all three of the sectors included in this nomination use alternatives, most of the time. This nomination is for those times when 

alternatives fail to control a pest problem and 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. Heat is the other 

main alternative. Sulfuryl fluoride is more sensitive to temperature and is less efficacious on insect eggs than 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., where there are problems with heat sinks). This nomination is for 

facilities, or portions of facilities, that are unsuitable for the alternatives, or where the alternatives are not economically feasible.

Pertaining to the Party‘s reporting of problems with heat sinks, hot spots and penetration problems at a few specific mills, while MBTOC finds that heat is a 

widely applicable alternative in use at many mills, we also acknowledge that the problems reported are also consistent with its experience and published 

research. Some of these problems are surmountable, some are not. We cite noted Kansas State Professor Dr. Subramanyam who said, heat treatment is 

an art (but he did not say it is impossible!) (Beckett et al, 2007; Subramanyam et al, 2011)

The lethal effects of sulfuryl fluoride (SF) are highly dependent upon temperature and MBTOC recommends that SF treatments occur at above 26 ̊C (80 ̊F) 

to ensure the treatment kills pest eggs.

MBTOC noted that some companies own mills in both Canada and the United States, and that Canadian mills have adopted heat treatment to a much 

greater extent than American mills. MBTOC asked the Party to explain the technical or structural differences between the mills or sectors, which would 

affect pest control matters. The Party provided technical reasons for differences between the two milling regions with which MBTOC could agree. The 

geographical locations, structural components, and building configurations make each facility unique and there is no single method of pest control that works 

in all instances. For example, representatives of some of these types of companies reported that in the southern United States there is pest pressure year 

round at much higher levels than they experience in their facility in Canada. A company that has a facility in the Midwest of the United States has a problem 
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with prevailing winds preventing them from maintaining heat for effective kill in that area; however, they have converted all their other mills to the 

alternatives. Phosphine, is used in combination with heat and CO2 in some Canadian mills, but the use of phosphine can be a cause of concern because of 

the potential of corrosion of electronic components and the likelihood of development of pest resistance when there are repeated applications of short 

exposures at raised temperatures which result in survival. 

Research in mills has focussed lately in IPM aspects to decrease pest presence, to monitor pests so they can be controlled when localized before 

spreading, to control pests in warehouses and where food mixtures are present (where SF cannot be used because of lack of regulatory approval). In 

overview, these approaches work to prevent the need for full site fumigations, allow improved efficacy of spot treatments and allow IPM treatments to 

function without full site fumigations. As examples, Fontenot et al, 2012 examining the effectiveness of aerosols and insect growth regulators noted that that 

single applications of a contact insecticide or aerosol may not be sufficient to manage P. interpunctella populations over a 6-month period but some of the 

biweekly and monthly insecticide treatments were predicted to be effective for management of P. interpuctella (Fontenot et al, 2012 in press). Investigating 

whether the use of methoprene aerosols could synergistically act with heat or cold treatments to control pests, Wijayaratne and Fields (2010) found that 

adult T. castaneum exposed to methoprene were less heat tolerant, although there was no such effect on larvae nor when exposed to cold treatment. 

Wijayaratne et al, 2011, also found that methoprene, an aerosol whose pest control action is thought to diminish fairly quickly after application will still 

reduce reduce populations of T. castaneum by reducing their progeny production, even if adults emerge. 

Pet food sector has a particular problem in that SF cannot be used to disinfest pet foods because it is not labelled for that purpose. The processing of pet 

foods is itself a disinfestation process, but the rich nutrient content of pet foods is highly attractive to pests. A recent examination of the locations and 

movements of pests in a pet mill indicates that IPM improvements especially rigorous hand sweeping of the production area, rejection of poor quality 

incoming products, closing doors between production and warehousing areas, cleaning and monitoring resulted in decreased pest infestation (Belda et al

2011). Holcomb and McLean (2010) reported on an IPM approach in pet food processing plants and warehouses. The authors have had success in 

controlling pests in these facilities for over 5 years. They ensure outside sanitation around plants and warehouses. They also try to reduce introducing 

pests by inspecting incoming ingredients and goods to ensure they are ―clean;‖ maintaining screens at windows and doors; and placing lights so that insects 

are not attracted to openings. Microsanitation and pest control access are stressed in Holcomb and McLean‘s (2010) IPM approach. Holcomb mentioned 

during his MBAO presentation that companies need to hire a sanitation team to ensure that the facility and all equipment could be thoroughly cleaned every 

30 days to break the life cycle of stored product pests (which is typically about 45 days). (Holcomb and McLean, 2010). 

Additionally, it is known that heat treatment either full site or spot heat treatment of rooms or equipment has been efficient in most pet food establishments. 

With the new, clear details provided on the IPM approaches that are effective in pet food establishments indicated in the research reported above, and the 

use of heat, MBTOC signals that unless significant new, specific and detailed data is provided showing that IPM and heat is not effective for the remaining 

pet food establishments, it would not support a recommendation for pet food for 2015. 

MBTOC Comments on Economics 2012:

Improved financial information was provided, verified from third party sources. In both alternatives examined costs of treatment increase. However, this 
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increase is only a miniscule fraction of gross margins. In the case of postharvest CUNs one would also want to look at the proportionate change in costs. In 

both these cases this is however also small. In summary, the nomination is not based on economic grounds, and it would be difficult to recommend an 

exemption on economic grounds.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission control: Mills are sealed before fumigation to ensure gastightness and ensure the standards for dosage rate are met. 

 Dec. IX/6 b(iii) Research program: Extensive research program. USDA research for mills is focussed on IPM aspects such as monitoring pests, 

use of volatiles and pest modelling. A USDA-NIFA Methyl Bromide Transition Grant is supporting an investigation of the major pests in the rice mills, 

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

 Dec. IX/6 b(iii) Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol 

nominations has control over pesticide registration.
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United 

States

Cured pork 67.907 40.854 18.998 19.669 18.998 4.465 3.73 3.730 3.730 3.730 2.466

MBTOC Recommendation for 2014: 

MBTOC recommends 2.466 tonnes for use in US dry cured pork in 2014 (sometimes referred to as Southern or Country Ham). This represents a 34% 

reduction over the nominated amount. 

Nomination by the Party: 

The Party nominated 3.73 tonnes, the same amount as was granted by the Parties for this use in 2013. Following MBTOC interim recommendation in May 

2012, and when assessing the survey of MB users in this sector which reported that 3.664 tonnes of MB was used, the Party maintained their originally 

nominated amount with the following statement. ―The amount of methyl bromide nominated by the United States government is 3,730 kg. This amount is 

slightly larger than that reported as being used by the 26 producers that responded to the questionnaire given yearly variations in production, economics, 

pest pressure, and environmental conditions (e.g. weather).‖ 

Circumstances of the Nomination:

Currently there are no viable alternatives to methyl bromide for Southern dry cure pork, a regional traditional product; heat would alter the product, and 

phosphine has failed to control mites, a major pest. Sulfuryl fluoride received federal registration and has been tested for efficacy against the mites and 

other pests of cured meat products. Although mortality of the red-legged ham beetle (Necrobia rufipes) occurred at levels below maximum rates of sulfuryl 

fluoride, control of the ham mites took three times the legal limits of sulfuryl fluoride (Phillips, et al., 2008). The US cured pork research program has 

identified the incidence of pests in cured pork facilities; 50-60% of plants have reported infestations of the red-legged beetle. The incidence of mites is 

approximately 60-70 %. (Shilling, in USG response to MBTOC Mar 30, 2010)

At the time of this nomination, there are no known registered alternatives for use on hams in the U.S. that provide the same level of mite control as methyl 

bromide. Research is still ongoing with phosphine; recent attempts to scale-up a phosphine treatment previously tested at lab level did not show adequate 

efficacy. More research and commercial applications need to be conducted before any treatment can be considered an alternative to methyl bromide for 

treatment of ham (mold) mites.

There is an ongoing multi-university, multi-state research program which is focused on improving meat processing sanitation, IPM and pest control. So, for 

example, the Party reports, processors are now trying to steam clean, bleach, or both to sanitize and their aging facilities when the hams are gone and 

before new hams are introduced. In addition, some changes to a few facilities have taken place, such as cement floors that they can power wash with 

steam and bleach. While this has not eliminated the pests, it does take longer before hams are infested with mites, ham beetles and/or ham skippers. 
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These and other IPM steps should allow for a reduction in frequency of fumigation of the ham storage facilities. 

In addition, prior to the phase-out of methyl bromide this industry tended to fumigate on a monthly basis. Plus processors brought in new hams into aging 

houses that had contaminated old hams. This is no longer the case. Processors keep new hams away from the older hams, many have subdivided their 

aging house space. Processors are only fumigating when the pests, or signs of the pests, are present. 

MBTOC Review and Assessment:

MBTOC has closely followed the research in this difficult pest control problem and agrees that no pest control has proven effective at this time. However, 

MBTOC finds that significant improvements are needed in facility gas tightness and efforts to reduce frequency of fumigation are required to fully satisfy 

Decision IX/6. The amount of methyl bromide recommended by MBTOC in this report should both ensure pest control of this commodity, and ensure the 

requirement of Decision IX/6 is met. MBTOC‘s calculations based on new MB use data submitted by the Party in August 2012 will be found below. 

At the time of its interim recommendation in May 2012, MBTOC was unable to recommend a volume. In May, MBTOC asked the Party to supply the 

following information: a total true volume of the aging rooms which are fumigated in each facility, irrespective of the number of fumigations. In other words, if 

one of the applicants‘ aging rooms is fumigated 3x/yr we did not want them to multiply the volume of their aging room 3x and then report that as the volume. 

We then noted that we needed to know the average of how often each aging room is fumigated annually by each applicant.

Following the May TEAP report, Dr. Wes Schilling (Mississippi State University) conducted a survey of Southern dry-cure pork facilities, receiving 26 

responses. The information collected provides the size of the aging rooms, the maximum yearly amounts of methyl bromide used, and the maximum 

number of fumigations per year, by facility. This information was provided to MBTOC and will be found in some aspects of the table below.

MBTOC re-reviewed the CUN and the new information supplied by the Party in August and September 2012. When all facilities were included, MBTOC 

determined the dosage rate used was 25.45 g/m3. If we exclude the three facilities only fumigating twice a year and with which we have no problems, then 

the average dosage increases to 25.84 g/m3. The MBTOC standard presumption is a dosage rate of 20g/m3. MBTOC acknowledges that occasionally 

during a fumigation, extenuating weather circumstances require the use of additional fumigant, but in a sufficiently gastight facility the use of a higher 

dosage rate should not be the norm. The Party, in its August 2012 response to MBTOC noted that, ―The amount of methyl bromide listed includes additional 

gas added to adjust for any loss to ensure the required CT (Concentration Time) is maintained during treatment.‖ This indicates to MBTOC that the 

requirement for additional gas may be more frequent than should be required in a sufficiently gastight facility as is required for good practise. 

Additionally, although three facilities fumigated a maximum of twice a year, many other facilities were reported to fumigate a maximum of four and five times 

a year. Our review of the Southern cured pork process, the likely dwell time in the various storage rooms, product turn over and total length of process does 

not seem to justify a frequency of fumigation of up to 5 times a year – if IPM procedures are being followed. 

These factors led MBTOC to recommend a reduced nomination as explained by the following: one fewer fumigation per year at each facility (except for 
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those already only fumigating twice a year) with a dosage of 20 g/m3, plus a 10% allowance for occasional unforeseen requirement for additional MB due to 

inclement weather or the sudden need for an extra treatment at a particular facility or possibly for one or two facilities not included in, or responding in time 

to, the survey, summed up as 10% for contingency measures. 

Given that the application was expressed as the maximum number of treatments, MBTOC believes the sector can achieve this reduction by improving 

facility gastightness and through IPM improvements. With improved gastightness, air circulation and temperature can be increased during the fumigation 

which will improve the effectiveness of the MB at the dosage of 20g/m3. 

In its interim report May 2012, MBTOC noted that for any future nomination for this sector, MBTOC would like actual MB use data; we believe there are only 

a few MB applicators working in this sector. We would like an explanation for any increase of the standard 20 g/m3 dosage rate being used by the 

applicants and what actions are being taken to decrease the dosage rates through facility improvements and improvements in gastightness. We have read 

with interest the advances being made in sanitation and IPM but we wonder why this has not resulted in a decrease in MB use over time; the CUN in this 

sector has requested the same amount for several years. 

Although some of this information has been supplied to MBTOC, we are indicating that a fuller and repeated submission of this information will be essential 

for any future nomination for this sector. 

MBTOC members, knowing that the Party and its research scientists are grappling with a difficult challenge, would like to report that it can propose some 

other alternatives which work with similar cured meat products in Europe. (Although we acknowledge that each country‘s cured meat products have 

variations which may affect infestation issues.). Different types of Ham products are produced in Spain (in the south - Jabugo, in the Pyrenees – Serrano), 

France (Bayonne) and Italy (Parma). There are similar mites problems but no MB is used in these areas. In the EU the use of any pesticide is not approved 

on hams. Procedures to avoid mite problems rely on sanitation, modernization of structures, fumigation of empty structures with PH3 and other authorized 

pesticides, dipping the hams in olive oil and lard at 90oC (control of superficial mites), strict control of the RH during the process (initial 75 % to allow salt 

penetration and afterwards gradually decrease to 65%), control of moulds in the ham surface. Updating the old ham houses to modernize them into modern 

meat processing facilities would assist in avoiding pest infestations. 

In the next phase of the research planned in the US, we could recommend increasing the fumigation temperature to at least 30oC in order to achieve control 

of eggs effectively. Also they could try double PH3 fumigation with the timing done to catch the growth cycle. This has been demonstrated with other 

species. Physical exclusion by means of fine mesh or air blowing out of the curing chamber could help avoid mite infestation. Lehms et al. (2012) showed 

that nets of 30 μm were sufficient to keep out all stages of the mite Tyrophagus putrescentiae. This needs to be confirmed in commercial process. Also, the 

mesh could be used to form a shroud over the hanging shelves of hams to keep mites infesting the aging room from attacking the clean hams. 
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US Dry Cure Pork Text Box Table 

Note: units in kilograms

1. Columns 1-4 were supplied to MBTOC By the Party as “U.S. Country Ham Facility Questionnaire Conducted by Dr. Schilling, May 2012:” 

2. Column 5 is MBTOC’s recommendation based on the following: one fewer fumigation per year at each facility (except for those already only 

fumigating twice a year) with a dosage of 20 g/m3, plus a 10% allowance for occasional unforeseen requirement for additional MB

US1

Facility #

US1

Maximum MeBr used per 

year (kg)

US1

Aging Room Size (1,000 

cubic meters)

US1

Maximum number of 

fumigations per year

MBTOC Recommendation2

(kg)

1 55 0.64 4 38.4

2 272 2.61 5 208.8

3 91 0.85 4 51.0

4 681 6.37 4 382.2

5 55 0.57 4 34.2

6 50 0.57 4 34.2

7 45 0.57 4 34.2

8 64 0.57 4 34.2

9 272 2.83 4 169.8

10 1,135 7.70 5 616.0

11 27 0.28 4 16.8

12 27 0.28 4 16.8
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13 68 0.57 4 34.2

14 272 2.83 4 169.8

15 18 0.17 4 10.2

16 14 0.14 4 8.4

17 45 0.43 4 25.8

18 45 0.45 4 27.0

19 23 0.28 4 16.8

20 64 0.71 4 42.6

21 114 1.27 4 76.2

22 36 0.34 4 20.4

23 82 0.79 4 47.4

24 27 0.85 2 34.0

25 27 0.85 2 34.0

26 54 1.46 2 58.4

Total 3,664 kg MeBr 2241.8

(+ 10% = 2,466 kg)

Footnotes:1 The volumes of MB supplied in the US originated columns were rounded by Excel spreadsheet after conversion from the original U.S. 

units.

 2

Apart from facilities 24-26, this amount provides for one less fumigation at each facility per year.
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MBTOC Comments on Economics 2012:

The CUN is not based on economics.

Comments Requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission control: Over the years the applicants have made facility improvements to improve gas tighness, but this is a traditional 

meat curing process and some of the facilities are older and unusual. The research program continues to work with the applicants to improve 

gastightness, IPM and other process improvements which reduce the need for fumigation and result in decreased use of MB. This work needs to 

continue. Producers have modified their buildings both to make them more gas-tight and to exclude pests. 

 Dec. IX/6 b(iii) Research program: . Excellent research effort to date and still ongoing. Now researching phosphine effectiveness on commercial 

scale. A multi-state, multi-university research program is ongoing and full reports of research have been made available to MBTOC. 

Dec. IX/6 b(iii) Appropriate effort: As with all postharvest registration issues, neither the applicant nor the Party mandated with Montreal Protocol 

nominations has control over pesticide registration. Phosphine is registered for use on processed meats such as cured pork

1

1ExMOP and 16MOP; 216MOP+2ExMOP+17MOP; 3MOP17+MOP18; 4MOP18+MOP19; 5MOP19+MOP20; 6MOP20+MOP21; 7MOP21+MOP22; 8MOP22, 9MOP23
60 October 2012 MBTOC CUN Final Report

Activity Report 2012 and Workplan for 2013

1.6.1. Activity report for 2012

 Initial summarisation of the CUNs (initial sorting and recording carried out by the 

Secretariat).

 Preparation of questions for Parties. Assessment of responses received from Parties. 

 First meeting of MBTOC sub committees in last week of February 2012 on the assessment of 

the CUNs: MBTOC- S and QPS met in Beijing, China (February 27 – March 2) and 

MBTOC- SC met in Berlin, Germany (February 28 – March 1). Meetings were held 

simultaneously and a consultation session was held via Skype between the subcommittees to 

share interim recommendations made on corresponding CUNs. Bilateral meetings were held 

by MBTOC-S with the USA. MBTOC-SC held a teleconference with the USA to discuss 

details of their nominations.

 Interim recommendations and preparation of the CUN Interim, QPS and Progress reports for 

consideration by the 32nd OEWG

 Site visits: MBTOC-S conducted a field trip to observe alternatives adopted by vegetable and 

tomato growers in the vicinity of Beijing. MBTOC-QPS visited the Tianjing Quarantine 

Station in Tangu. 

 32nd OEWG (Bangkok, 23- 27 July, 2012). Bilateral meetings with USA, the California 

Strawberry Commission (USA), Australia and Canada. 

 No second meetings were held in the year, and MBTOC (S and SC) conducted its re-reviews 

by an agreed email process.

 MBTOC-S and MBTOC-SC prepared the final report on the CUNs for consideration by the 

Parties at their 23rd Meeting.

 The Handbook on Submitting Critical Use Nominations was updated and posted at the Ozone 

Secretariat Website.

 Three MBTOC members resigned; MBTOC thanked Tom Batchelor, Patrick Ducom and Jim 

Schaub for their work. 

The following “Actions” and “Indicative Completion Dates” are the “Working procedures of MBTOC 

relating to the evaluation of nominations for critical uses of methyl bromide”, as described in Annex 1 

of the 16th Meeting of the Parties. The annual work plan is required to be drawn up by MBTOC 

(supported by the Ozone Secretariat) in consultation with TEAP, which shall submit it to the Meeting 

of the Parties each year.

1.6.2. Work plan and indicative budget for 2013

Table 1-12. MBTOC work plan and indicative budget: 2011

Tasks and actions Indicative budget 

needs where 

applicable

Indicative 

completion date

Dates of 

meetings

1. Parties submit their nominations for critical-use exemptions to 

the Secretariat*

- 24 January 2013

2. The nominations are forwarded to MBTOC co-chairs for 

distribution to the subgroups of appointed members

- 7 February 2013

3. Nominations in full are assessed by the subgroups of 

appointed members. The initial findings of the subgroups, and any 

requests for additional information are forwarded to the MBTOC 

co-chairs for clearance

- 28 February 2013

4. MBTOC co-chairs forward the cleared advice on initial 

findings and may request additional information on to the 

nominating Party concerned and consult with the Party on the 

possible presumption therein

- 21 February 2013
October 2012 MBTOC CUN Final Report 61

5. Nominating Party develops and submits its response to the 

MBTOC co-chairs

- 7 March 2013

6. MBTOC Meeting No 1 

 Meets as usual to assess nominations, including any additional 

information provided by the nominating Party prior to the 

MBTOC meeting under action 5 and any additional 

information provided by nominating Party through prearranged teleconference, or through meetings with national 

experts, in accordance with paragraph 3.4 of the terms of 

reference of TEAP (see Annex I of MOP16, Dec XVI/4) 

 Bilateral meetings

 To discuss and finalise the CUN evaluation process proposed 

by the co-chairs and commented by the MBTOC members

 To discussed any new or standard presumptions that MBTOC 

seeks to apply in its future assessment of critical-use 

nominations, for approval by the Meeting of the Parties

 Any administrative changes to improve the operations of the 

Committee, within the scope of Decisions that have been 

agreed by the Parties

 Draft the 2012 Progress Report

Funds for travel of 

1non-A5 members: 

US$3,000**

Meeting Costs 

$3,000

March 2013 TBD

8. MBTOC provides its draft recommendations on the CUNs to 

TEAP

April, 2013

9- TEAP Meeting: To assess the MBTOC report on critical-use 

nominations and submits the finalised interim report on 

recommendations and findings to the Secretariat.

April 2013 TBD

10. The Secretariat posts the finalised report on its web site and 

circulates it to the Parties

- May 2013

11. OEWG Bilateral Discussions: Nominating Party has the 

opportunity to consult with MBTOC on a bilateral basis in 

conjunction with the Open-ended Working Group meetings

June - August 

2013 (TBD)

TBD

12. The nominating Party submits further clarification for the 

critical-use nomination requested by MBTOC or if requested to do 

so by the Open-ended Working Group, and provides additional 

information should it wish to appeal against a critical-use 

nomination recommendation by MBTOC/TEAP

-

Late June 2013 

depending on 

OEWG date

13. MBTOC Meeting No 2 or agreed email process (according to 

feasibility and justification of a second meeting):

 Meets to reassess only those critical-use nominations in the 

“unable to assess” category, those where additional 

information has been submitted by the nominating Party and 

any critical-use nominations for which additional information 

has been requested by the Open-ended Working Group (see 

Annex I of MOP16, Dec XVI/4)

 finalise the report, including notice of any proposed new 

standard presumptions to be applied by MBTOC

 conduct any bilateral consultations requested by Parties

 draft work plan and budget for MBTOC for 2013

Funds for travel of 

1 non-A5 

members**: 

US$3,000

Meeting costs: $US 

3,000

September-October 

2013

TBD

14. MBTOC draft final report considered by TEAP, finalised and 

made available to Parties through the Secretariat

- Middle October 

2013

15. 24th Meeting of the Parties November 2013

Total budget: US $: 12,000*

US$ 6,000 (Travel 

of Non Article 5 

member)

Meeting Costs 

$6,000 

* CUNs from A5 Parties could be submitted

** Travel funds for non A5 members have been requested in the past but not granted
62 October 2012 MBTOC CUN Final Report

1.7 References:

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Strawberry yield with various rates of chloropicrin and inline applied under VIF. In: Proc Ann Int Res Conf 

on MeBr Alternatives and Emission Reductions. San Diego, CA, Oct. 31–Nov. 3, 2005. Abstr. 53.

Athanassiou, C.G., Riudavets, J., and Kavallieratos N.G., (2011) Preventing stored-product insect infestations in packagedfood products. Stewart Postharvest Review. 3:8 pp1-5 

Beckett S.J., Fields P.G and Subramanyam Bh. (2007). Disinfestation of stored products and associated structures using 

heat.. In, CAB International 2007, Heat treatment for postharvest pest control: theory and practice. pp. 182-

237

Belda, C., Ribes-Dasi M, and Riudavets, J. Improving pest management in pet food mills using accurate monitoring and 

spatial analysis. (2011). Journal of Stored Product Research. 47. Pp 385-392.

Bell, C.H. (2011). Insect and mite penetration and contamination of packaged foods. In: Kilcast, D., Subramaniam, P. 

(Eds.), Food and Beverage Stability and Shelf Life. Woodhead Publishing Ltd, Cambridge, ISBN 978-1-

84569-701-3, pp. 106-131.

Bhuvaneswari, K., Fields, P.G., White, N.D.G., Sarkar, A.K., Singh, C.B., and Jayas, D.S. (2011). "Image analysis for 

detecting insect fragments in semolina. Journal of Stored Products Research, 47(1), pp. 20-24. doi: 

10.1016/j.jspr.2010.08.003

Bowley, C. R. and Bell, C. H. (1981) The toxicity of twelve fumigants to three species of mites infesting grain. J. stored 

Prod. Res. 17, 83-87.

Californian Department of Pesticide Regulation. http://www.cdpr.ca.gov/

Daugovish, O., Koike, S., Gordon, T., Ajwa, H., and Legard, D. (2011). Fumigant and strawberry variety evaluations in 

Macrophimina phaseolina and Fusarium oxysporum infested fields. International Research Conference on 

Methyl Bromide Alternatives and Emissions Reductions (2011). 

http://mbao.org/2011/Proceedings/10DaugovishOFumigantandvarietyevaluations.pdf

Driver, J., Welker, R. and Louws, F. (2011). Totally impermeable films for fumigant rate reduction in North Carolina. In: Proc Ann Int Res 

Conf on MeBr Alternatives and Emission Reductions. San Diego, CA, Oct. 31–Nov. 2, 2011. Abstr. 16

Federal Register. Protection of stratospheric ozone: The 2011 Critical Use Exemption from the phase out of methyl 

bromide. 40 CFR Part 82. EPA. September 30, 2011, Vol 76, No. 190. Pp 60736 – 60748. 

Fennimore, S. A. and Ajwa, H. A. (2011). Totally impermeable film retains fumigants, allowing lower application rates in strawberry. 

California Agriculture, October-December, 2011. Vol. 65:211-215. 

http://ucce.ucdavis.edu/files/repositoryfiles/ca.E.6504p211-91055.pdf

Fennimore, S., Samtani, J. and Subbarao, K (2011). Soil disinfestation in strawberry with steam. . Annual International Research 

Conference on Methyl Bromide Alternatives and Emission Reduction, Orlando, FL, November 2011

Fields, P.G. (2007). Evaluation of Alternatives to Methyl Bromide for Use in Structural Fumigation of Canadian Pasta 

Manufacturing Facilities 2007/2008. Agriculture and Agri-Food Canada and the Canadian National Millers 

Association.

Fontenot, E.A., Arthur, F., Nechols, J.R., and Throne, J.E. 2012 Using a population growth model to simulate response of 

Plodia interpunctella Hübner populations to timing and frequency of insecticide treatments. Journal of Pest 

Science. (In press).

Hamill, J. E., Dickson, D. W., T-Ou, L., Allen, L. H., Burelle, N. K. and Mendes, M. L. (2004). Reduced rates of MBR and 

C35 under LDPE and VIF for control of soil pests and pathogens. In: Annual International Research 

Conference on Methyl Bromide Alternatives and Emissions Reductions 31 October - 3 November, 2004, 

Orlando, Florida, USA, pp. 2-1.

Hanson, B., J. Gerik and S. Schneider (2006). Evaluation of reduced Methyl Bromide rates and alternative fumigants in field 

grown perennial crop nurseries. In: Annual International Research Conference on Methyl Bromide 

Alternatives and Emissions Reductions, Orlando, Florida, USA, 2006.

Hawkin, K.J., Stanbridge, D.M., and Fields, P.G. (2011) Sampling Tribolium confusum and Tribolium castaneum in mill 

and laboratory settings: Differences between strains and species. Canadian Entomologist. 143: 504_517

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. 

Koike, S., Daugovish, O., Gordon, T., Ajwa, H., Bolda, M. and Legard, D. (2010). Biology and Managementof 

Macrophomina Disease of Strawberry. Californian Strawberry Commission Annual Production Research 

Report 2009-2010. http://www.calstrawberry.com/fileData/docs/Koike_2010_11_mac.pdf

Lopez-Aranda, J.,et al López-Aranda J M, Miranda L, Soria C, Domínguez P, Pérez-Jiménez R M, Zea T, Talavera, M 

Romero F, De Los Santos B, Medina-Mínguez J J, (2009). Strawberry Production in Spain: Chemical 

Alternatives to MB, 2009 results. 2009 Annual International Research Conference on Methyl Bromide 

Alternatives and Emissions Reductions.November 10-13, San Diego, California 

Lehms, M.; Baier, B.; Wurst, S.; Schöller, M.; Reichmuth, C., 2012: Zum Eiablageverhalten der vorratsschädlichen 

Milben Acarus siro und Tyrophagus putrescentiae auf verschiedenen Substraten und durch feinmaschige 
October 2012 MBTOC CUN Final Report 63

Gaze [Egg laying behaviour of the stored roduct pest mitesAcarus siro and Tyrophagus putrescentiae of 

different substrates and through fine mesh Nylon gaze]. In: Julius Kühn-Institut (Ed.), Julius-Kühn-Archiv, 

No 438, Proceedings of the 58. Deutsche Pflanzenschutztagung, 10. - 14. September 2012 in Braunschweig, 

Germany, ISBN978-3-930037, http://pub.jki.bund.de/index.php/JKA/article/view/670/2244, 500 pp., 75.

MBTOC (2011). Methyl Bromide Technical Options Committee., 2010 Assessment Report. UNEP, Nairobi, Kenya

Noling, J. W. and Cody, M. 2011. USDA-ARS Areawide Project: Large scale field demonstration trialing of methyl bromide 

alternatives in Florida strawberry 2010-11. Annual International Research Conference on Methyl Bromide 

Alternatives and Emissions Reductions (2011). 

http://mbao.org/2011/Proceedings/26NolingJAREAWIDE.pdf

Phillips, T.W. Hasan, M.M., Aikens, M.J., Schilling, M.W. (2008). Efficacy of sulfuryl fluoride to control ham mites and 

red-legged ham beetles. Annual International Research Conference on Methyl Bromide Alternatives and 

Emission Reduction, Orlando, FL, November 11th-14th

Porter, I.J., L. Trinder and D. Partington. (2006). Special Report Validating the Yield Performance of Alternatives to Methyl 

Bromide for Preplant fumigation. TEAP/MBTOC Special Report, UNEP Nairobi, May 2006 97pp.

Santos, B.M., J.P. Gilreath, J.M. López-Aranda, L. Miranda, C. Soria, and J.J. Medina. (2007). Comparing Methyl Bromide 

alternatives for strawberry in Florida and Spain. Journal of Agronomy 6(1): 225 – 227.

Su, L., Adam, B., Lusk, J., and Arthur F. (2012 in press). A comparison of auction and choice experiment: An application to 

consumer willingness to pay for rice with improved storage management. Department of Agricultural 

Economics, Oklahoma State University, 

Subramanyam Bh., Mahroof R., and Brijwani M. (2011). Heat treatment of grain-processing facilities for insect 

management: a historical overview and recent advances. Stewart Postharvest Review. Dec. 3:1 

Thomas, J. E., Van Sickle, J. J., Allen, L. H., Noling, J. W., and Dickson, D. W. (2011). Increasing efficacy and decreasing 

application rate of Telone C35 with carbonation and low permeable films. 

http://mbao.org/2011/Proceedings/76ThomasJ.pdf

Wijayaratne, L.K.W., Fields. P.G. Arthur, F.H. (2011) Effect of methoprene on the progeny production of Tribolium 

castaneum (Coleoptera: Tenebrionidae). Pest Management Science. 

Wijayaratne, L.K.W., and Fields, P.G. (2010) Effect of methoprene on the heat tolerance and cold tolerance of Tribolium 

castaneum (Herbst) (Coleoptera: Tenebrionidae). Journal of Stored Products Research. pp 1-8.

Yates, S, Papierknik S., Chellemi D, Wang D, Gao S, Hanson B, Ajwa H, Browne G, Kluepfel D. (2009). Update of film 

permeability measurements for USDA-ARS area-wide research project. In „Annual International Research 

Conference on MB Alternatives and Emissions Reductions‟Nov 10-13,San Diego, 2009.

Zveibil, A., Mor, N., Gnayem N. (2012) Survival, Host–Pathogen Interaction, and Management of Macrophomina 

phaseolina on Strawberry in Israel. Plant Disease 96: 265 - 272
64 October 2012 MBTOC CUN Final Report

ANNEX 1: Decision IX/6

1. To apply the following criteria and procedure in assessing a critical methyl bromide use for 

the purposes of control measures in Article 2 of the Protocol:

(a) That a use of methyl bromide should qualify as “critical” only if the nominating Party 

determines that:

(i) The specific use is critical because the lack of availability of methyl bromide for that 

use would result in a significant market disruption; and

(ii) There are no technically and economically feasible alternatives or substitutes 

available to the user that are acceptable from the standpoint of environment and 

health and are suitable to the crops and circumstances of the nomination;

(b) That production and consumption, if any, of methyl bromide for critical uses should be 

permitted only if:

(i) All technically and economically feasible steps have been taken to minimise the 

critical use and any associated emission of methyl bromide;

(ii) Methyl bromide is not available in sufficient quantity and quality from existing stocks 

of banked or recycled methyl bromide, also bearing in mind the developing countries’ 

need for methyl bromide;

(iii) It is demonstrated that an appropriate effort is being made to evaluate, 

commercialise and secure national regulatory approval of alternatives and 

substitutes, taking into consideration the circumstances of the particular nomination 

and the special needs of Article 5 Parties, including lack of financial and expert 

resources, institutional capacity, and information. Non-Article 5 Parties must 

demonstrate that research programmes are in place to develop and deploy 

alternatives and substitutes. Article 5 Parties must demonstrate that feasible 

alternatives shall be adopted as soon as they are confirmed as suitable to the Party’s 

specific conditions and/or that they have applied to the Multilateral Fund or other 

sources for assistance in identifying, evaluating, adapting and demonstrating such 

options;

2. To request the Technology and Economic Assessment Panel to review nominations and make 

recommendations based on the criteria established in paragraphs 1 (a) (ii) and 1 (b) of the present 

decision;

3. That the present decision will apply to Parties operating under Article 5 and Parties not so 

operating only after the phase-out date applicable to those Parties.

Para. 2 of Decision IX/6 does not assign TEAP the responsibility for determining the existence of 

“significant market disruption” specified in paragraph 1(a)(i).

TEAP assigned its Methyl Bromide Technical Options Committee (MBTOC) to determine whether 

there are no technically and economically feasible alternatives or substitutes available to the user that 

are acceptable from the standpoint of environment and health and are suitable to the crops and 

circumstances of the nomination, and to address the criteria listed in Decision IX/6 1(b).
October 2012 MBTOC CUN Final Report 65

Annex II Minority report on the critical use of methyl bromide, US strawberry fruit, 2014

Author: Janny Vos

Introduction

This minority report is produced to present a more precise and transparent approach to the assessment 

of the critical use of MB for US strawberry fruit, 2014, than is currently used by the MBTOC 

majority.

Nomination by the Party

US nominated 415.067 tonnes of methyl bromide for critical uses for strawberry fruit for 2014 and 

requested re-instatement of this amount following the MBTOC interim recommendation of 343.740 

tonnes (170 kg/ha on 2022 ha).

Economic considerations

The nomination was not based on economic arguments. It is noted however, that a recent economic 

study conducted in California (Mayfield and Norman, 20127) shows that, contrary to ex-ante industry 

claims, the years of exempted MB use have been years of rising yields, increased cropping areas, 

exports and revenues for Californian strawberry fruit growers, even when faced with a global 

recession and increased imports from Mexican growers.

Assessment

Details of the assessment are provided in the tables below, in particular in No. 11. It is concluded that 

a further annual transition of at least 470 ha can be expected with existing alternatives and under the 

current regulatory restrictions. 

Recommendation

Based on the assessment, a transition of at least 470 ha is recommended. Given the 2013 CUE area of 

2713 ha, the 2014 critical area should therefore be reduced to no more than 2243 ha, and at 170 kg/ha 

the 2014 critical use should be reduced to 381.310 tonnes at most.

Tables showing review and assessment

Annex I (A) of MOP16 (32): Exemptions must fully comply with Dec IX/6 and other relevant 

decisions, and are intended to be limited to the levels needed for critical-use exemptions, temporary 

derogations from the phase-out of methyl bromide in that they are to apply only until there are 

technically and economically feasible alternatives that otherwise meet the criteria in decision IX/6. 

MBTOC should take a precise and transparent approach to the application of the criteria.

Dec XXI/11(9): MBTOC is requested to summarise in the table on its recommendations for each 

nomination information on adherence with each criterion set out in decision IX/6(1)(a)(ii) and (b)(i) 

and (b)(iii) and other relevant decisions of the Parties. Decision IX/6 requests the TEAP to review 

nominations and make recommendations based on the criteria established in paragraphs 1 (a) (ii) and 

1 (b) of Decision IX/6, which includes the three parts of 1 (b), namely 1(b)(i),(ii) and (iii).

 

7 Mayfield, E.N. and Norman, C.S. (2012) Moving away from methyl bromide: Political economy of pesticide 

transition for California strawberries since 2004. Journal of Environmental Management 106: 93-101. Doi: 

10.1016/j.jenvman.2012.04.009 
66 October 2012 MBTOC CUN Final Report

No Decision 

agreed by the 

Parties

The applicant demonstrates that 

...

Indicators of performance Review and assessment, including the extent to which information was provided 

to MBTOC8

1 IX/6(1)(a)(ii); 

and XXI/11(9)

... there are no technically and 

economically feasible alternatives

or substitutes available to the user 

that are acceptable from the 

standpoint of environment and 

health and are suitable to the crops 

and circumstances of the 

nomination

Number of alternatives listed in 

the Party‟s “MB Alternatives 

Database” (see No 9 below); 

reductions in number of 

facilities, farmers or land using 

MB; alternatives present in 

other regions or countries for 

the same purpose

The US Methyl Bromide Alternatives Database of 2005 reported that at that time 4 

chemical alternatives (1,3-D, Pic, MS, Terbacil) to methyl bromide were registered for 

use on strawberry fruit in US as well as 3 combinations (1,3-D + Pic, 1,3-D + Pic + 

MS, Pic + MS), and that a further 2 chemical alternatives (dazomet and iodomethane) 

were under consideration. Alternatives are listed by the US on 

http://www.epa.gov/ozone/mbr/alts.html (EPA 20 Feb 2012). CUN2013 reported 

registration of MI in California in 2010, but in 2012 MI was removed from the market.

Currently, technically and economically feasible alternatives include (CUN2014 and 

CalDPR-PUR):

 9 alternatives to MB and their combinations, available and registered in 

California and that can be used as alternatives to MB (see 

http://www.epa.gov/ozone/mbr/alts.html) :

o 1,3-D

o PIC

o 1,3-D + PIC

o Dazomet 

o MI

o Metam sodium (MS)

o 1,3-D + PIC + MS

o Terbacil (?)

o MS + PIC

 

8 Annex I (A) of MOP16 (10): MBTOC should categorize the nomination as “unable to assess” if there is insufficient information to make an assessment, and clearly explain what information was 

missing. Annex I (A) of MOP16 (28): The onus remains on the nominating Party to provide sufficient information in order for MBTOC to be able to assess whether critical-use nominations comply fully with Dec 

IX/6.
October 2012 MBTOC CUN Final Report 67

No Decision 

agreed by the 

Parties

The applicant demonstrates that 

...

Indicators of performance Review and assessment, including the extent to which information was provided 

to MBTOC8

 Alternatives to MB that do not require registration but are available (CUN2014):

o Organic strawberry fruit production

o Steaming on plots smaller than 10 acres

o Resistant cultivars, with resistance to Macrophomina or Fusarium

available, but not against all soil pests simultaneously

 Combinations of alternatives

o Cultivar Camarosa with drip applied 1,3-D/pic provides comparable 

yields to MB (CUN2014); 

o Non-chemical alternative used in buffer zones.

CUN2014 says: “Expansion of alternative methods .... to areas currently considered 

critical for methyl bromide will occur and effective alternatives are available. Factors 

that may affect farmer transition to alternatives include regulatory restrictions, 

perception of the consequences of methyl iodide use, results of the effectiveness of nonfumigant technologies, and remedies to biological issues, such as the emergence of 

Macrophominia phaseolina and Fusarium oxysporum as major pests in some areas.”

The applicant has not demonstrated that technically and economically feasible 

alternatives or substitutes are NOT available to the user that are acceptable from the 

standpoint of environment and health and are suitable for strawberry fruit production in 

California. 

2 IX/6(1)(b)(i); 

and XXI/11(9)

... all technically and economically 

feasible steps have been taken to 

minimize the MB critical use

Dosage minimized, VIF used 

and others. 

The nomination is for a dose rate of 170 kg/ha, as it was in the nominations for 2012 

and 2013 (sources: CUN2012, CUN2013, CUN2014). With barrier films the MBTOC 

standard presumption for strawberry is 12.5 gm-2 for pathogens with film and 20 gm-2 

without film.
68 October 2012 MBTOC CUN Final Report

No Decision 

agreed by the 

Parties

The applicant demonstrates that 

...

Indicators of performance Review and assessment, including the extent to which information was provided 

to MBTOC8

In 2010, the overall average dosage used across strawberry fruit producing counties 

was 208 kg/ha, with a predominant formulation of 57% MB (77% of applications), 

although lower formulations of 33% and 50% are used as well (6% of applications). It 

is noted though that formulations of 67% and 98% are still used in a significant number 

of applications (17% of applications) (Source: CalDPR-PUR).

California regulation prohibits use of VIF use in MB application (see 3).

Applicant has therefore partly demonstrated that all steps have been taken to 

minimize the MB critical use.

3 IX/6(1)(b)(i); 

and XXI/11(9)

...all technically and economically 

feasible steps have been taken to 

minimize MB emissions

Gas tightness recorded and 

improved, recapture in place, 

VIF, tarpaulins ...

CUN2014 does not mention any steps taken to minimize MB emissions. 

California regulation prohibits use of VIF with MB, but allows use of high barrier with 

MB (http://www.cdpr.ca.gov/docs/emon/methbrom/tarps.pdf, and these can reduce 

buffer zones. It is however not clear in how far barrier films are used. 

Applicant has therefore not demonstrated that it has taken all steps to minimize any 

associated emissions of MB.

4 IX/6(1)(b)(ii); ... existing stocks of MB are not 

sufficient in quantity and quality 

and therefore new production 

should be permitted by the Party

Stocks reported in the 

Accounting Framework Report; 

Applicant report on stocks

CUN14 requests 415,067 kg which is well within the range of 1,800,000 kg of stocks. 

Decision IX/6(1)(b)(ii) requires the applicant to demonstrate that existing stocks of MB 

are not sufficient in quantity and quality and therefore new production should be 

permitted by the Party. The applicant has not done this and therefore stocks are 

presumed to be available and new MB is not necessary to meet this need.

5 IX/6(1)(b)(iii); ... an appropriate effort is being 

made to evaluate, commercialise 

Research programme in place to 

commercialize and gain 

Results of US studies highlight the promising potential for alternatives to methyl 

bromide, including non-chemical alternatives. Technologies such as steam 
October 2012 MBTOC CUN Final Report 69

No Decision 

agreed by the 

Parties

The applicant demonstrates that 

...

Indicators of performance Review and assessment, including the extent to which information was provided 

to MBTOC8

and XXI/11(9) and secure national regulatory 

approval of alternatives and 

substitutes

regulatory approval for each 

alternative

(Fennimore, 2011b), soilless production with substrates and landscape fabrics (Thomas 

et al., 2011a; Cabrera et al., 2011), cultivar selection (Daugovish et al., 2011a), buffer 

zone management (Daugovish et al., 2011c), anaerobic soil disinfestations (Daugovish 

et al., 2011b; Shennan et al., 2011; Rosskopf et al., 2011), biofumigation (Mazzola, 

2011), and innovative applications pesticides (Sances et al., 2011; Daugovish and 

Fennimore, 2011; Thomas et al., 2011b). Transition from methyl bromide is expected 

to continue with the refinement of these new technologies being funded by USDA 

nationwide. However, applicant feedback shows little or no expectation of take-up of 

non-chemical alternatives by 2014, or evidence of scaled-out extension on IPM 

messages or of chemical alternatives. 

Applicant has demonstrated that an appropriate effort is being made to evaluate 

alternatives and substitutes, however there is no evidence that the applicant makes 

appropriate effort to commercialise alternatives and substitutes.

6 IX/6(1)(b)(iii); 

and XXI/11(9)

... a research programme is in place 

to develop alternatives and 

substitutes

Research programme in place, 

results of programme, 

performance of programme

See (5) above

Applicant has demonstrated that a research programme is in place to develop

alternatives and substitutes.

7 IX/6(1)(b)(iii); 

and XXI/11(9)

... a research programme is in place 

to deploy alternatives and 

substitutes

Method to ensure alternatives 

are installed by the end users

See (5) above

Applicant has not demonstrated that a research programme is in place to deploy

alternatives and substitutes.

8 Annex I (A) of

MOP16 (21)

Parties are invited to include in 

their nominations, information on 

their determination that the specific 

use is critical because the lack of 

availability of methyl bromide for 

that use would result in a 

significant market disruption

Check box at the beginning of 

the application Form shows 

„Significant Market Disruption‟ 

is checked/ticked by the 

applicant; information provided 

if checked?

Yes, box checked by applicant. 

However, a new and key economic study conducted in California (Mayfield and 

Norman, 20121) indicates that the years of exempted MB use have been years of rising 

yields, increased cropping areas, exports and revenues for Californian growers of 

strawberry fruit. 

There is no evidence of significant market disruption.
70 October 2012 MBTOC CUN Final Report

No Decision 

agreed by the 

Parties

The applicant demonstrates that 

...

Indicators of performance Review and assessment, including the extent to which information was provided 

to MBTOC8

9 Dec ExI/3, 

paragraph 9(h)

TEAP is requested to assess, 

annually where appropriate, any 

critical-use nomination made after 

the end of 2006 in the light of the 

Methyl Bromide Alternatives 

Database

9 alternatives to MB and their combinations are available and registered in 

California and can be used as alternatives to MB that are technically and economically 

feasible (see 1). It is recommended that the Alternatives Database submitted to the 

Parties should be updated with the most recent available information.

10 Dec ExI/3, 

paragraph 9(h)

TEAP is required to compare 

annually the quantity of MB 

requested and recommended in the 

nomination, for each pre-harvest 

and post-harvest use, with the 

[National] Management Strategy

submitted by the Party

What is stated in the Party‟s 

NMS? What is the date of the 

NMS? What is stated in the 

nomination? Comments that 

compare MS and nomination 

statements

The first US National Management Strategy stated that “additional acreage or 

production volume of a commodity must be accomplished using a MB alternative”. In 

the update on this US National Management Strategy for MB in 2009, the US 

explicitly reports in the section on strawberry fruit: “Strawberry growers have been 

replacing methyl bromide or reducing its use rates in all production areas” and 

“California growers have a critical need for methyl bromide to treat fields where 

alternatives are not available due to regulations or to complete a fumigation program 

that includes a once per three year treatment with methyl bromide to manage two new 

diseases (Macrophomina and Fusarium oxysporum)”. 

It is noted that no stepwise MB phase-out plan is presented in the US NMS. It is also 

noted that CUN2014 still refers to the need for MB because of regulatory constraints 

and to manage the same two new diseases, although several years have passed since 

the first report of these new disease problems in strawberry fruit production. There is a 

lack of information in CUN2014 to substantiate the incidence and severity of these 

new diseases as well as evidence that available MB alternatives do not sufficiently 

control them.

It is recommended that the NMS should be updated.

11 Annex I (A) of 

MOP16 (35)

In situations where MBTOC 

recommends a nomination on 

grounds that it is necessary to have 

a period for adoption of 

MBTOC to provide calculations 

on the basis of information 

obtained from the nominating 

Party, the supplier, the 

Information was not provided of enterprises that need to transition in order to adopt 

MI/Pic or other alternatives. MI/Pic is no longer for sale in the USA hence this is no 

longer an alternative. Information was not provided on expected uptake of each of the 

other alternatives from 2011 to 2014. However, calculations can be made for some of 
October 2012 MBTOC CUN Final Report 71

No Decision 

agreed by the 

Parties

The applicant demonstrates that 

...

Indicators of performance Review and assessment, including the extent to which information was provided 

to MBTOC8

alternatives, the basis for 

calculating the time period must be 

explained fully in the TEAP report 

and take fully into account the 

information provided by the 

nominating Party, the supplier, the 

distributor or the manufacturer. 

Relevant factors for such a 

calculation include the number of 

enterprises that need to transition, 

e.g., the number of fumigation and 

pest control companies, estimated 

training time assuming full effort, 

opportunities for importing 

alternative equipment and expertise 

if not available locally, and costs 

involved.

distributor or the manufacturer. these alternatives on the basis of information from the applicant and public databases 

such as the California Strawberry Commission Survey and the California DPR –

Pesticide Use Report:

1. Further uptake of 1,3-D through adoption of new formulations and barrier films:

 Use of high barrier films can reduce the dose rate and will allow more hectares 

treated under the township caps. However, suitable data have not yet been found;

 Data are available on 1,3-D use area, numbers of applications, amounts chemical 

applied, etc, until 2010. In 2010, 6,422 ha of strawberry fruit were treated with 

1,3-D in California (DPR-PUR). In that year, some growers used Inline (228 

applications at an average dose rate of 182 kg/ha) and other growers used 

PicClor60 (333 applications at an average dose rate of 112 kg/ha). The overall 

application of 1,3-D on strawberry fruit was 874,217 kg. 

 USG provided information to MBTOC during its 2012 spring meeting:

o The accumulated total kg 1,3-D that 35 townships can get is (35 * 40,974 

=) 1,434,090 kg. It could be assumed that non-strawberry crops consume 

a significant amount of this township cap. 

o 1,3-D bed-top drip applications can be calculated at 75 kg/ha and an AF of 

1.16, which means that per township 40,974 / (75*1.16) = 471 ha could 

be treated 

o 1,3-D shank applications can be calculated at 125 kg/ha with an AF of 

1.9, which means that per township 40,974 / (125*1.9) = 173 ha could be 

treated 

 Assuming that the 2010 strawberry 1,3-D use amount of 874,217 kg is the overall 

township cap for strawberry fruit (we don‟t know whether there is further room for 

more use), then an overall maximum area of 874,217 / (75*1.16) = 10,048 ha

could be drip-treated with PicClor60. As MBTOC has agreed, some growers may 

need broadcast application, so a complete shift to PicClor60 drip should not be

expected. Nevertheless, given these figures it is not unrealistic to expect further 

expansion of the 1,3-D treated area of strawberry fruit. 

 Average additional uptake of 1,3-D/Pic since 2003 has been 632 ha / year. A 

transition of a third to half of this historical uptake would lead to a total area under 

1,3-D in 2014 of below 7500 ha, well below the margin described above. 

Therefore, an additional annual transition to 1,3-D on an extra 211 ha or more 

can be expected.
72 October 2012 MBTOC CUN Final Report

No Decision 

agreed by the 

Parties

The applicant demonstrates that 

...

Indicators of performance Review and assessment, including the extent to which information was provided 

to MBTOC8

2. Further uptake of Pic-straight with dose rates below the regulatory restrictions:

 In 2010, 2,405 ha strawberry fruit used Pic Straight, almost exclusively in 

Orange/San Diego and Oxnard districts (DPR-PUR). Applicant implies that 

permits are needed when Pic Straight is applied at rates above 200 lbs/acre. In 

2010, the applied dose rates are on average 181 kg/ha which is well below 200 

lbs/acre = 224 kg/ha. 

 Given the trend in adoption of Pic Straight over previous years (average additional 

uptake of 198 ha/year since 2003) under existing regulatory barriers, further 

adoption of Pic straight on strawberry fruit should be expected. An additional 

annual transition to Pic-Straight can be expected of on an average extra 198

ha.

3. Further uptake of non-chemical alternatives

 Organic production is expected in new areas of production, as we know that 

strawberry fields are often rotated in the area. The organic strawberry area 

increased from 245 ha in 2003 to 790 ha in 2012, and so increased on average 61 

ha per year over the past 9 years. It is not unrealistic to expect that this trend will 

continue over the next years

 Research has produced successful results of steam and ASD. Some organic 

growers will adopt these methods, which are expected to be attractive too for 

treatment of buffer zones where chemical treatments are restricted.

 Steam: new boilers of much lower costs and much improved speed are now 

operational in Germany and elsewhere, in use in horticulture and tree nurseries, 

mushroom growing, viniculture and weed control in city cleaning. 

 An additional annual transition to non-chemical alternatives can be expected 

of at least 61 ha.

4. Further uptake of other alternatives, such as IPM which could include use of 

metam sodium in combination with crop rotation and/or use of resistant varieties.

 Data are unavailable to calculate potential further uptake of other alternatives.

Conclusion: A feasible additional annual adoption of 211 ha 1,3-D, 198 ha Pic-Straight 

and at least 61 ha non-chemical can be expected, which adds up to an annual 

transition of at least 470 ha. For lack of data, this calculation excludes any further 

transitions to other (combinations of) alternatives.
October 2012 MBTOC CUN Final Report 73

No Decision 

agreed by the 

Parties

The applicant demonstrates that 

...

Indicators of performance Review and assessment, including the extent to which information was provided 

to MBTOC8

12 Ex.I/4(3)(b) Requires the use of expedited 

procedures, where possible, to 

develop, register and deploy 

technically and economically 

feasible alternatives. 

Is there evidence of expedited 

procedures? What are the 

procedures for registering new 

alternatives? Are they faster 

than normal registration 

methods? Are the procedures in 

place locally and not just at the 

national level?

No evidence of expedited procedures
74 October 2012 MBTOC CUN Final Report

SUMMARY: US Strawberry fruit CUN2014

Source Criteria CUN 

assessment 

outcome

Source Criteria CUN 

assessment 

outcome

Source Criteria CUN 

assessment 

outcome

IX/6(1)(a)(ii); 

and XXI/11(9)

Technically and 

economically 

feasible 

alternatives

Alternatives are 

available

IX/6(1)(b)(iii); 

and XXI/11(9)

Evaluate, 

commercialise 

and secure 

national 

regulatory 

approval of 

alternatives

Partly done Annex I (A) of 

MOP16 (21)

Significant 

market 

disruption

No evidence, 

contrary is 

argued in 

literature

IX/6(1)(b)(i); 

and XXI/11(9)

Minimize the 

methyl bromide 

critical use

Partly done IX/6(1)(b)(iii); 

and XXI/11(9)

... a research 

programme is in 

place to develop 

alternatives

In place Dec ExI/3, 

paragraph 9(h)

Methyl Bromide 

Alternatives 

Database

No update

IX/6(1)(b)(i); 

and XXI/11(9)

Minimise 

emissions

No effort made IX/6(1)(b)(iii); 

and XXI/11(9)

... a research 

programme is in 

place to deploy 

alternatives

Not in place Dec ExI/3, 

paragraph 9(h)

National 

Management 

Strategy

No update

IX/6(1)(b)(ii) Stocks Stocks are 

available

Annex I (A) of 

MOP16 (35)

Period of 

adoption 

calculations

No information 

provided, in 

2014 an 

additional 

adoption on 470 

ha is expected

Ex.I/4(3)(b) Expedited 

procedures

No information 

provided
October 2012 MBTOC CUN Final Report 75

ANNEX III - Part A: Trend in MB Preplant Soil Nominations and Exemptions

List of nominated (2005 – 2014) and exempted (2005 – 2013) amounts of MB granted by Parties under the CUE process for each crop. 

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

Australia Cut Flowers –

field 40.000 22.350 18.375 22.350

Australia Cut flowers –

protected 20.000 10.425

Australia

Cut flowers, 

bulbs – protected 

Vic

7.000 7.000 6.170 6.150 7.000 7.000 3.598 3.500

Australia Strawberry Fruit 90.000 67.000

Australia Strawberry 

runners

35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.790 29.760 29.760 35.750 37.500 35.750 35.750 29.790 29.790 23.840+ 

5.95 29.760 29.760

Belgium Asparagus 0.630 0.225 0.630 0.225

Belgium Chicory 0.600 0.180 0.180 0.180

Belgium Chrysanthemums 1.800 0.720 1.120

Belgium Cucumber 0.610 0.545 0.610 0.545

Belgium Cut flowers –

other 6.110 1.956 4.000 1.956

Belgium Cut flowers –

roses

1.640

Belgium Endive (sep from 

lettuce) 1.650 1.650

Belgium

Leek & onion 

1.220 0.155 0.660
76 October 2012 MBTOC CUN Final Report

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

seeds

Belgium Lettuce(& 

endive) 42.250 22.425 25.190

Belgium Nursery

Not 

Predictabl

e

0.384 0.900 0.384

Belgium Orchard pome & 

berry 1.350 0.621 1.350 0.621

Belgium Ornamental 

plants 5.660 0.000

Belgium Pepper & egg 

plant 5.270 1.350 3.000 1.350

Belgium Strawberry 

runners

3.400 0.900 3.400 0.900

Belgium Tomato 

(protected) 17.170 4.500 5.700 4.500

Belgium Tree nursery 0.230 0.155 0.230 0.155

Canada Strawberry 

runners (PEI) 14.792 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.596 5.261 (a)14.792 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.261

Canada Strawberry runners (Quebec) 1.826 1.826 (a) 1.826 1.826

Canada Strawberry runners (Ontario) 6.129 6.129

France Carrots 10.000 8.000 5.000 8.000 8.000 1.400

France Cucumber 85 revised 

to 60 60.000 15.000 60.000 60.000 12.500

France Cut-flowers 75.000 60.250 12.000 60.000 52.000 9.600
October 2012 MBTOC CUN Final Report 77

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

France Forest tree 

nursery

10.000 10.000 1.500 10.000 10.000 1.500

France Melon 10.000 10.000 7.500 6.000

France

Nursery: 

orchard, 

raspberry

5.000 5.000 2.000 5.000 5.000 2.000

France Orchard replant 25.000 25.000 7.500 25.000 25.000 7.000

France Pepper

Incl 

in.tomato 

cun

27.500 6.000 27.500 6.000

France Strawberry fruit 90.000 86.000 34.000 90.000 86.000

France Strawberry 

runners

40.000 4.000 35.000 40.000 40.000 28.000

France

Tomato (and 

eggplant for 

2005 only)

150(all 

solanaceo

us)

60.500 33.250 125.000 48.400

France Eggplant 27.500 33.250 48.400

Greece Cucurbits 30.000 19.200 30.000 19.200

Greece Cut flowers 14.000 6.000 14.000 6.000

Greece Tomatoes 180.000 73.600 156.000 73.600

Israel Broomrape 250.000 250.000 125.000 12.500 12.500 250.000 250.000 125.000 12.500

Israel Cucumber - protected new 2007 25.000 18.750 18.750 12.500 25.000 18.750 - 15.937

Israel Cut flowers –

open field 77.000 67.000 80.755 53.345 42.777 42.554 23.292 77.000 67.000 74.540 44.750 34.698 28.554
78 October 2012 MBTOC CUN Final Report

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

Israel Cut flowers –

protected 303.000 303.000 321.330 163.400 113.821 72.266 52.955 303.000 240.000 220.185 114.450 85.431 63.464

Israel Fruit tree 

nurseries 50.000 45.000 10.000 50.000 45.000 7.500

Israel Melon –

protected & field 148.000 142.000 140.000 87.500 87.500 87.500 35.000 125.650 99.400 105.000 87.500 87.500 70.000

Israel Potato 239.000 231.000 137.500 93.750 75.000 239.000 165.000 137.500 93.750 75.000

Israel Seed production 56.000 50.000 22.400 56.000 28.000 NR

Israel Strawberries –

fruit (Sharon) 196.000 196.000 176.200 64.125 52.250 47.500 28.500 196.000 196.000 93.000 105.960 42.750

Israel

Strawberries –

fruit (Sharon & 

Ghaza)

57.063

Israel Strawberry 

runners (Sharon) 35.000 35.000 20.000 15.800 13.570 13.500 35.000 35.000 28.000 31.900 15.825

Israel

Strawberry 

runners and fruit 

Ghaza

87.875 67.500 67.500 34.000 47.250

Israel

Strawberry 

runners (Sharon 

& Ghaza)

22.320

Israel Tomatoes 90.000 22.750

Israel Sweet potato 95.000 20.000 20.000 111.500 95.000 20.000
October 2012 MBTOC CUN Final Report 79

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

Italy Cut flowers 

(protected) 250.000 250.000 30.000 250.000 187.000 30.000

Italy Eggplant 

(protected) 280.000 200.000 15.000 194.000 156.000

Italy Melon 

(protected) 180.000 135.000 10.000 131.000 131.000 10.000

Italy Pepper 

(protected) 220.000 160.000 67.000 160.000 130.000 67.000

Italy Strawberry Fruit 

(Protected) 510.000 400.000 35.000 407.000 320.000

Italy Strawberry 

Runners 100.000 120.000 35.000 120.000 120.000 35.000

Italy Tomato 

(protected) 1300.000 1030.00 418.000 871.000 697.000 80.000

Japan Cucumber 88.300 88.800 72.400 68.600 61.400 34.100 29.120 26.162 88.300 88.800 72.400 51.450 34.300 30.690 27.621

Japan Ginger – field 119.400 119.400 112.200 112.100 102.200 53.400 47.450 42.235 119.400 119.400 109.701 84.075 63.056 53.400 47.450

Japan Ginger –

protected 22.900 22.900 14.800 14.800 12.900 8.300 7.770 6.558 22.900 22.900 14.471 11.100 8.325 8.300 7.036

Japan Melon 194.100 203.900 182.200 182.200 168.000 90.800 77.600 67.936 194.100 203.900 182.200 136.650 91.100 81.720 73.548

Japan Peppers (green 

and hot) 189.900 200.700 169.400 162.300 134.400 81.100 68.260 61.101 187.200 200.700 156.700 121.725 81.149 72.990 65.691

Japan Watermelon 126.300 96.200 94.200 43.300 23.700 15.400 13.870 12.075 129.000 98.900 94.200 32.475 21.650 14.500 13.050

Malta Cucumber 0.096 0.127

Malta Eggplant 0.128 0.170
80 October 2012 MBTOC CUN Final Report

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

Malta Strawberry 0.160 0.212

Malta Tomatoes 0.475 0.594

New 

Zealand Nursery material 1.085 1.085 0

New 

Zealand Strawberry fruit 42.000 42.000 24.78 42.000 34.000 12.000

New 

Zealand

Strawberry 

runners

10.000 10.000 5.720 8.000 8.000 6.234

Poland Strawberry 

Runners 40.000 40.000 25.000 12.000 40.000 40.000 24.500

Portugal Cut flowers 130.000 8.750 50.000 8.750

Spain Cut Flowers –

Cadiz 53.000 53.000 35.000 53.000 42.000

Spain Cut Flowers –

Catalonia 20.000 18.600 12.840

17

20.000

15.000 43.490

(+Andalucia) (+Andalucia)

Spain Pepper 200.000 155.000 45.000 200.000 155.000 45.000

Spain Strawberry Fruit 556.000 499.290 80.000 556.000 499.290 0.0796

Spain Strawberry 

Runners 230.000 230.000 230.000 215.000 230.000 230.000 230.000

UK Cut flowers 7.560 6.050

UK Ornamental tree 

nursery

12.000 6.000 6.000 6.000
October 2012 MBTOC CUN Final Report 81

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

UK

Strawberry (& 

raspberry in 

2005)

80.000 63.600 68.000 54.500

UK Raspberry 

nursery

4.400 4.400 54.500

USA Chrys. 

Cuttings/roses 29.412 29.412 0

USA Cucurbits – field 1187.8 747.839 598.927 588.949 411.757 340.405 218.032 59.500 11.899 1187.800 747.839 592.891 486.757 407.091 302.974 195.698 59.500

USA Eggplant – field 76.761 101.245 96.48 79.546 62.789 34.732 21.561 6.904 1.381 76.721 82.167 85.363 66.018 48.691 32.820 19.725 6.904

USA Forest nursery 

seedlings 192.515 157.694 152.629 133.140 125.758 120.853 106.043 192.515 157.694 122.032 131.208 122.060 117.826 93.547

USA Ginger 9.2 9.2 0

USA Orchard replant 706.176 827.994 405.415 405.666 314.007 226.021 203.591 18.324 6.230 706.176 527.600 405.400 393.720 292.756 215.800 183.232 18.324

USA Ornamentals 210.949 162.817 149.965 138.538 137.776 95.204 70.178 48.164 48.164 154.000 148.483 137.835 138.538 107.136 84.617 64.307 48.164

USA

Nursery stock -

fruit trees, 

raspberries, roses

45.789 64.528 12.684 51.102 27.663 17.954 7.955 1.591 0.541 45.800 64.528 28.275 51.102 25.326 17.363 7.955 1.591

USA Peppers – field 1094.782 1498.53 1151.751 919.006 783.821 463.282 212.775 28.366 1094.782 1243.542 1106.753 756.339 548.984 463.282 206.234

USA Strawberry fruit 

– field 2468.873 1918.40 1733.901 1604.669 1336.754 1103.422 1023.471 753.974 531.737 415.067 2052.846 1730.828 1476.019 1349.575 1269.321 1007.477 812.709 678.004 415.067

USA Strawberry 

runners

54.988 56.291 4.483 8.838 8.837 7.381 7.381 3.752 3.752 54.988 56.291 4.483 8.838 7.944 4.690 + 2.018 6.036 3.752
82 October 2012 MBTOC CUN Final Report

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

USA Tomato – field 2876.046 2844.985 2334.047 1840.1 1406.484 994.582 336.191 54.423 10.741 737.584 2476.365 2065.246 1406.484 1003.876 737.584 292.751 54.423

USA Turfgrass 352.194 131.600 78.040 52.189 0 131.600 78.04 0

USA Sweet potato 224.528 18.144 18.144 18.144 14.515 8.709 18.144 18.144 14.515 11.612

USA Research 2.768 2.768
October 2012 MBTOC CUN Final Report 83

ANNEX IV– Part B: Trends in MB Structural and Commodity Nominations and Exemptions

List of nominated (2005- 2014) and exempted (2005 - 2013) amounts of MB granted by Parties under the CUE process for each commodity. 

Party Industry Total CUN MB Quantities Total CUE MB Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

Australia Almonds 1.900 2.100 1.900 2.100

Australia Rice 

consumer 

packs

12.300 12.300 10.225 9.200 9.2 7.82 5.66 3.653 2.374 1.187 6.150 6.150 9.205 9.200 7.820 6.650 4.870 3.653 1.187

+1.8

Belgium Artefacts and 

structures

0.600 0.307 0.590 0.307

Belgium Antique 

structure & 

furniture

0.750 0.199 0.319 0.199

Belgium Churches, 

monuments 

and ships' 

quarters

0.150 0.059 0.150 0.059

Belgium Electronic 

equipment

0.100 0.035 0.100 0.035

Belgium Empty silo 0.050 0.043 0.050 0.043

Belgium Flour mill see 

mills below

0.125 0.072 See mills 

below

0.072

Belgium Flour mills 10.000 4.170 9.515 4.170

Belgium Mills 0.200 0.200 0.200 0.200

Belgium Food 

processing 

facilities

0.300 0.300 0.300 0.300
84 October 2012 MBTOC CUN Final Report

Party Industry Total CUN MB Quantities Total CUE MB Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

Belgium Food 

Processing 

premises

0.030 0.030 0.030 0.030

Belgium Food storage 

(dry) structure

0.120 0.120 0.120 0

Belgium Old buildings 7.000 0 .306 1.150 0.306

Belgium Old buildings 

and objects

0.450 0.282 0 0.282

Belgium Woodworking 

premises

0.300 0.101 0.300 0.101

Canada Flour mills 47.200 34.774 30.167 28.650 26.913 22.878 14.107 11.020 7.848 5.044 (a)47 34.774 30.167 28.65 26.913 22.878 14.107 11.020 5.044

Canada Pasta 

manufacturing 

facilities

(a) 10.457 6.757 6.067 4.740 4.740 2.084 (a) 10.457 6.757 6.067 4.740 3.529

Canada Commodities 0.068

France Seeds sold by 

PLAN-SPG 

company

0.135 0.135 0.100 0.135 0.135 0.096

France Mills 55.000 40.000 8.000 40.000 35.000 8.000

France Rice 

consumer 

packs

2.000 2.000 2.000 2.000

France Chestnuts 2.000 2.000 1.800 2.000 2.000 1.800

Germany Artefacts 0.250 0.100 0.250 0.100
October 2012 MBTOC CUN Final Report 85

Party Industry Total CUN MB Quantities Total CUE MB Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

Germany Mills and 

Processors 

45.000 19.350 45.000 19.350

Greece Dried fruit 4.280 3.081 0.900 4.280 3.081 0.450

Greece Mills and 

Processors 

23.000 16.000 1.340 23.000 15.445 1.340

Greece Rice and legumes 2.355 2.355

Ireland Mills 0.888 0.611 0.888

Israel Artefacts 0.650 0.650 0.600 0.650 0.6500

Israel Dates (post 

harvest)

3.444 3.444 2.200 1.800 2.100 3.444 2.755 2.200 1.800 2.100 1.040

Israel Flour mills 

(machinery & 

storage)

2.140 1.490 1.490 0.800 0.300 2.140 1.490 1.040 0.312 0.300

Israel Furniture–

imported

1.4220 1.4220 2.0420 1.4220 0

Italy Artefacts 5.500 5.500 5.000 5.225 0 5.000

Italy Mills and 

Processors

160.000 130.000 25.000 160.000 65.000 25.000

Japan Chestnuts 7.100 6.500 6.500 6.300 5.800 5.400 5.350 3.489 3.317 7.100 6.800 6.500 6.300 5.800 5.400 5.350 3.489

Latvia Grains 2.502 2.502

Netherlands Strawberry runners post 

harvest

0.120 0.120 0.120 0 0.120

Poland Medicinal 

herbs & dried 

mushrooms as 

dry 

commodities

4.000 3.560 1.800 0.500 4.100 3.560 1.800 1.800
86 October 2012 MBTOC CUN Final Report

Party Industry Total CUN MB Quantities Total CUE MB Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

Poland Coffee, cocoa 

beans

(a) 2.160 2.000 0.500 2.160 1.420 1.420

Spain Rice 50.000 42.065

Switzerland Mills & 

Processors

8.700 7.000 8.700 7.000

UK Aircraft 0.165 0.165

UK Mills and 

Processors

47.130 10.195 4.509 47.130 10.195 4.509

UK Cereal processing plants 8.131 3.480 (a) 8.131

UK Cheese stores 1.640 1.248 1.248 1.640 1.248 1.248

UK Dried 

commodities 

(rice, fruits 

and nuts) 

Whitworths

 2.400 1.256 2.400 1.256

UK Herbs and 

spices

0.035 0.037 0.030 0.035 0.037

UK Mills and 

Processors 

(biscuits) 

2.525 1.787 0.479 2.525 1.787

UK Spices 

structural 

equip.

1.728 1.728 0 0.479

UK Spices stored 0.030 0.030 0

UK Structures 

buildings 

(herbs and 

spices)

3.000 1.872 0.908 3.000 1.872 0.908
October 2012 MBTOC CUN Final Report 87

Party Industry Total CUN MB Quantities Total CUE MB Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2005 2006 2007 2008 2009 2010 2011 2012 2013

UK Structures, 

processors 

and storage 

(Whitworths)

1.100 0.880 0.257 1.100 0.880 0.257

UK Tobacco 

equipment

0.523 0.050

UK Woven 

baskets

0.770 0.770

USA Dried fruit 

and nuts 

(walnuts, 

pistachios, 

dried fruit and 

dates and 

dried beans)

89.166 87.719 91.299 67.699 58.912 19.242 10.041 2.419 0.822 0.740 89.166 87.719 78.983 58.921 45.623 19.242 5.000 2.419 0.740

USA Dry 

commodities/ 

structures 

(cocoa beans) 

61.519 61.519 64.028 52.256 51.002 61.519 55.367 64.082 53.188

USA Dry 

commodities/ 

structures 

(processed 

foods, herbs 

and spices, 

dried milk and 

cheese 

processing 

facilities) 

NPMA

83.344 83.344 85.801 72.693 66.777 37.778 17.365 0.200 83.344 69.118 82.771 69.208 54.606 37.778 17.365

USA Smokehouse 

hams (Dry 

cure pork 

products) 

(building and 

product)

136.304 135.742 40.854 19.669 19.699 4.465 3.730 3.730 3.730 3.730 67.907 81.708 18.998 19.699 18.998 4.465 3.730 3.730 3.730

USA Mills and 

Processors 

536.328 505.982 401.889 362.952 291.418 173.023 135.299 74.51 25.334 22.800 483.000 461.758 401.889 348.237 291.418 173.023 135.299 74.510 22.800

USA Research 0.159 0.159
88 October 2012 MBTOC CUN Final Report