# MONTREAL PROTOCOL

ON SUBSTANCES THAT DEPLETE

THE OZONE LAYER



# UNEP

R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC 

# A SSESSMENT 

# P ANEL



# OCTOBER 2012

E VALUATION OF 

# 2012 C RITICAL 

# U SE 

# N OMINATIONS FOR 

# M ETHYL



# B ROMIDE AND 

# R ELATED 

# M ATTERS



# F INAL 

# R EPORT

### ii October 2012 MBTOC CUN Final Report 

# UNEP

OCTOBER 20 12 R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC



# A SSESSMENT 

# P ANEL



# E VALUATION OF 

# 2012 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE AND 

# R ELATED 

# M ATTERS



# F INAL 

# R EPORT

### 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

E VALUATIONS OF 

# 2012 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE AND 

# R ELATED 

# M ATTERS

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 fr om:
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

htt p://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 Progra mme (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, wo rker 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 addi tional 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 MB TOC 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 whatsoeve r 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 Brom ide 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 Mi nuto (Ita ly); 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 (S C) 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 Sanson e (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 (Australi a); Ken Vick (USA) and Eduardo Willink (Argentina).

MBTOC Economist: Nick Vink (South Africa)

### October 2012 MBTOC CUN Final Report 

### v 

# O CTOBER 

# 2012 R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC



# A SSESSMENT 

# P ANEL



# E VALUATIONS OF 

# 2012 C RITICAL 

# U SE 

# N OMINATIONS FOR



# M ETHYL 

# B ROMIDE AND 

# R ELATED 

# M ATTERS



# F IN AL 

# R EPORT

### October 2012 MBTOC CUN Final Report 

### vi 

# UNEP

O CTOBER 

# 2012 R EPORT OF THE



# T ECHNOLOGY AND 

# E CONOMIC



# A SSESSMENT 

# P ANEL



# MBTOC FINAL CUN R EPORT



# – O CTOBER 

# 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 In ternational 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 O ptions Committee, Quarantine and Pre

shipment 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 o f 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 Vola tile 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 NOMINAT IONS FOR METHYL BROMIDE

................................ ................ 9

1.2.1. M ANDATE



### ................................ ................................ ................................ ................................ .. 9

1.2.2 F ULFILMENT OF 

### D ECISION 

### IX/6

................................ ................................ ................................ .. 9

1.2.3 R EPORTING OF 

### MB C ONSUMPTION FOR 

### C RITICAL 

### U SE



### ................................ ............................. 10

1.2.4 T RENDS I

N 

### M ETHYL 

### B ROMIDE 

### U SE FOR 

### CUE S SINCE 

### 2005

................................ ...................... 10

1.2.5 D ISCLOSURE OF 

### I NTEREST



### ................................ ................................ ................................ ........ 11

1.2.6 A RTICLE 

### 5 ISSUES



### ................................ ................................ ................................ .................... 11

1.2.7 C ONSIDERATION OF 

### S TOCKS



### , D ECISION 

### E X 

### .1/4 (9 F 

### )

................................ ................................ . 12

1.3 EVALUATIONS OF CUNS

– 2012 ROUND FOR 2014 EXEMPTIONS

................................ ... 17

1.3.1 C RITICAL 

### U SE 

### N OMINATIONS 

### R EVIEW



### ................................ ................................ ...................... 17

1.3.2 A CHIEVING 

### C ONSENSUS



### ................................ ................................ ................................ ............ 18

1.4 MBTOC SOILS: FINAL EVALUAT IONS OF 2012 CRITICA L USE NOMINATIONS FO R

METHYL BROMIDE FOR 2 014

................................ ................................ ........................ 19

1.4.1 C RITICAL 

### U SE 

### N OMINATIONS SUBMITTED



### ................................ ................................ ................. 19

1.4. 2 CUN ASSESSMENT FOR PREPL ANT SOIL USES



### ................................ ................................ ............ 19

1.4. 3 I SSUES 

### R ELATED TO 

### CUN A SSESSMENT FOR 

### P REPLANT 

### S OIL 

### U SE



### ................................ .......... 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 R EGISTRATION OF ALTER NATIVES FOR PREPLANT USES



### - D ECISION 

### E X 

### I/4 (9 I 

### ) AND 

### (9 J 

### )

........... 21

1.4. 5 S USTAINABLE ALTERNATI VES FOR PREPLANT USE S



### ................................ ................................ ... 21

1.4. 6 S TANDARD PRESUMPTIONS USED IN ASSESSMENT O F NOMINATED QUANTITI ES



### . ........................ 21

1.4. 7 A DJUSTMENTS FOR STAND ARD DOSAGE RATES USI NG 

### MB/P IC FORMULATIONS



### ....................... 24

1.4. 8 U SE 

### /E MISSION REDUC TION TECHNOLOGIES



### - L OW PERMEABILITY BARR IER FILMS AND

DOSAGE REDUCTION



### ................................ ................................ ................................ ................ 24

1.5 MBTOC

- STRUCTURES AND COMMO DITIES

– FINAL CUN REPORT

................................ . 36

1.5.1 P ROCESS USED BY 

### MBTOC SC TO CONDUCT 

### CUN RE



### - REVIEWS



### ................................ ............. 36

1.5.2 R ESOURCING ISSUES IN 

### 2012 AND IN COMING YEARS



### ................................ ............................... 36

1.5.3 D ETAILS OF EVALUATION S



### ................................ ................................ ................................ ...... 37

1.6 ACTIVITY REPORT FOR 2012 AND WORK PLAN FOR 2013

................................ ............... 60

1.6.1 A CTIVITY REPORT FOR 

### 2012

................................ ................................ ................................ ..... 60

1.6.2 W ORK PLAN AND INDICAT IVE BUDGET FOR 

### 2013

................................ ................................ ..... 60

1.7 REFERENCES:

................................ ................................ ................................ ................................ 62

ANNEX 1: DECISION I X/6

................................ ................................ ................................ ...................... 64

ANNEX II : MINORITY REPORT

............................................................ .....................71

A NNEX I I I

- PART A: TREND IN MB PREPLANT SOIL NOMINA TIONS AND EXEMPTIONS 75

ANNEX I V

- PART B: TRENDS IN MB STRUCTURAL AND COMMO DITY NOMINATIONS AND

EXEMPTIONS

................................ ................................ ................................ ...................... 8 3

### 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 (A ustralia, 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) provid es new updated recommendations for the CUNs for which the Parties provided further information or requested reassessment after the 32 nd 

### OEWG, 2) lists the CUNs for which interim assessments have not changed and 3) provides information on the CUNs from Part ies 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 Decision s 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

ha ve increased or fallen within the sector due to a range of circumstances. MBTOC notes that stock volumes have significantly decreased in recent years.

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

the C UNs. 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 w ith 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 consum ption (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 Anne x 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 th e 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 technicall y 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 a ll 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 su ggested 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 Cr itical 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 Feb ruary each year

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

Decision 

## XVII/9 of the 17 th 

## MOP specifically requests TEAP and its MBTOC to “ report for 2005 and annually thereafter, for each agreed critical use category, the amount of methyl

b romide 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 Meetin g 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 strawberr y 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 M OP authorised 2 90.878 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 auth orised 1855.2 tonnes for a wide range of crops and commodities
in 2011 (Annex III and IV). In their allocation r egulation for 2011 critical uses , the Party reported that

in 2011 1,382.206 tonnes had been approved for pre

- plant soil uses and 117.794 tonnes f or 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 we ll 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 trend s 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 thi s 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 t rends 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 201 2, 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 asse ssment 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 t o 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 p rocedures 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 cont rolled 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 nationa l 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 furt her 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

rem aining 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

- versio n 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 wit h 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 e ach
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 ava ilable 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

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

under Decision XVI/6 . T he 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 MO P 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 5 94.995 594.995 546.861 48.134

New Zea land 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: Q uantities 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 th e 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 201 4

. Blue lines indicate the trend in of CUN nominated and the

red lines the amount CUE methyl bromide approved by the Parties

### 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 201 4 in nominated p ostharvest industries from 2005 to 201 4

. Blue lines indicate the trend in of CUN nominated and the red

lines the amount CUE methyl bromide approved by the Parties

### October 2012 MBTOC CUN Final Report 

### 16 Table 1

- 4. Summary of Critical Use Nomi nations 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

+
1 9MOP) 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 5 3.897 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 Community 1 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 2 67.000 239.746 219.609 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 [45 3.711 ]

* Not yet available.

1 Members 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 Unite d Kingdom

2008

– Poland, Spain

### October 2012 MBTOC CUN Final Report 

### 17



## 1.3 Evaluations of CUNs

– 2012 round for 2014 exemptions

D etailed 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 ru nner 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, Part ies 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 d uring the first meeting progress reports were prepared and „Disclosure of Interest‟ declarations updated. At the 32 nd 

### OEWG meeting in Bangkok, MBTOC held bilateral meeting s 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 vi ew 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 24 th 

### 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

201 4 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, t he 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 gene ral 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 request ed 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. I n considering the CUNs submitted in 2012, as in previous rounds, both MBTOC subcommittees applied as much as possible the standards

### October 2012 MBTOC CUN Final Report



### 18 contained in Annex I of the final report of 16 MOP, and, where relevant, the standard presumptions given below. In particular, MBTOC soug ht 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 fo r 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 cr op 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 ex tent 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 releva nt 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 re

reviews electronically.

All the inf

ormation 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 reassessm ent were

consid ered by the relevant sub

- committee

The coordinating Co

- Chair (s) provided a summary of all the comments received to the sub

committee, 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 c onsensus position s 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 focuse s mainly on the

reassessed CUNs.

During the final assessme nts, o ne MBTOC S oils member disagreed with the position of the sub

committee on one CUN; consensus was achieved for the rest of the soils CUNs. The postharvest sub

committee of MBTOC achieved consensus on its nominations. T he minority view submitted by th e 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 201 2 , MBTOC Soi ls 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 indicate d issues related to the interim assessments and subsequently sent further information and requests for reassessment.



## 1 .4. 2 CUN re assessment for preplant soil uses

In summary, in the final assessment

, the Australian and Canadian CUNs were unchanged from th e 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 201 4



## 1.4.4 Issues R elated to CUN As sessment for P replant S oil U se

Key issues which influenced asse ssment 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 fo r 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 rest rictions on use of high rates of Pic (greater than 200 kg/ha (20 g/m 2 

### )) 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 treat ed.

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

201 4 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 f

ruit 415.067 [ 343.740 ] [ 389. 640 ]

TOTAL 450.088 [ 375.574 ] [ 421. 4 74 ]

### October 2012 MBTOC CUN Final Report



### 20 

## 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 p roduction 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 h as 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 assessm ent, 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 t hat 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 mi ndful 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 P arty 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 C alifornia, 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 formula tions of methyl iodide in USA 3 

### , 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
registrant

4 

### ”.



### At the O EWG, 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 c ontinues 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 rega rd, 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/releas e/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 other wise 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), th e 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 on ly 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 Austral ia, 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

environm entally 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 t hese 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 17 th 

### MOP. Studies and reports to

5 Press release. 20 March 2012. Arysta LifeScience Suspends MIDAS in the United States

.

### October 2012 MBTOC CUN Final Report



### 22 support them have bee n provided in previous reports and were revised for some sectors after consideration by the Parties at the 19 th 

### 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 co ntinues to accept a maximum rate of 200 kg/ ha (20 g/m 2 

### ) 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/m 2 

### ) 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 cer tified 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 purpos e 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/m 2 with barrier films (VIF or equiva lent);

for mixtures of MB/Pic are 12.5 to 17.5 g MB/m 2 for 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 depe ndent 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/P ic 98:2. Nominated amount adjusted for
use with MB/Pic 67:33 (or
similar). Where Pic or Pic

containing 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 h ectares, 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 Maxim um MB Dosage Rate (g/m 2 

### ) 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 Barri er films

– Pathogens 

### 20 20 20 20

No Barrier films

- Nut sedge 

### 26 26 26 26

* Maximum rate unless certification specifies otherwise

### October 2012 MBTOC CUN Final Report



### 24 

## 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 M B (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/m 2 

### ) with mixtures of 30:70 or 33:67 mixtures (at 250 kg/ha or 25 g/m 2 

### ) or 100 kg/ha (10 g/m 2 

### ) of MB in 250 kg/ha (25 g/m 2 

### ) 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/m 2 

### )

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

* No te: Trials from 1996 to 200 8 ( previous CUN reports ) show that a dosage of 10g/m 2 

### (e.g. MB/Pic 50:50 at 200kg/ha with low permeability b arrier Films) is technically feasible for many situations and equivalent to the standard dosage of >20g/m 2 

### using standar d 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 soi l 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

tech nologies 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 al low 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 miti gation 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 re duction credits. These credits are specific for each fumigant and tarp. The most impermeable tarps to chemical fumigants results in a maximum buffer zone credit of 60%, which may allow for a larger quantity of the alternative chemical to be used. Applica tors of fumigants can obtain more information on the appropriate buffer reduction

credit at http://www.epa.gov/pesticides/reregistration/soil_fumigants/factsheets/sfm

- buffer

- zones

2012.pdf

. . Buffer zone credits apply to soil fumigant products such as MB/P ic (but not in California),

P ic , 1,3

- D/P ic , and P ic , 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 alt ernatives 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

- reg istration. 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 string ent 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.

### October 2012 MBTOC CUN Final Report 

### 26 Table 1

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

Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

201 2 8 CUE for

2013 9 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 con siders the timeframe for reduction could be advanced by one year and encourages the Party to consider a faster transition tha n stated in the

nomination. MBTOC considers that soilless culture is a technique used widely throughout the world for production o f 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 t he 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 sui tability of the technology for runner production. The party reported that the cost of change to soilless culture is significant. The party indicated that the 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 withd rawal 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 su ccessful 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 a nd 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 r unner 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 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

201 2 8 CUE for

2013 9 CUN for

2014 MBTOC rec

for 2014



### 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, Cyper us spp ). The Party also states that MB:Pic 50:50 at a MB dose of 25 g/m 2 

### is required to meet certification standards. Although this quantity exceeds MBTOC‘s standard presumption of 20 g/m 2 

### , the lower rate is unregistered. MBTOC acknowledges the

notificati on 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 conside rs, 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 feasib le 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% transit ion to soil

- less substrates for early generation runners in 2014. Victorian Strawbe rry 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 supp ort the registrati on. 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 w ith regulatory obstacles.

### October 2012 MBTOC CUN Final Report 

### 28 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for 2013 9 CUN for

2014 MBTOC rec

for 2014

C anada Strawberry

runners (PEI) 6.840 6.840 7.9 95 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 nominate d by the Party. MBTOC considers that soilless culture is widely used around the world for strawberry runner production and i s 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 en tire use of MB for this purpose. MBTOC accepts that its cost effectiveness for other gener ations 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 overco me regulatory restrictions that

cu rrently 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 th is 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. T hey 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/h ectare) when machinery and equipment costs are included (Chaudhary and Nabj, 2011). A complete analysis of the potential cap ital costs for the grower in PEI to transition to soilless culture in greenhouses for its transition stock would thus be needed. D espite the fact that foundation stock yields are reported to increase significantly through greenhouse production, Canada has concerns that the logistics of soille ss 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 nomin ated amount.

After consideration of production methods adopted by strawberry runner producers around the world and transition made to soilless p roduction 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 re dundant if a suitable alternative, such as chloropicrin was regi stered. MBTOC notes that dazomet, metam sodium and metam potassium are registered and considers that in the absence of any ot her suitable chemical alternative that more effort be made to evaluate these products at PEI. MBTOC notes that whilst the reducti on 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 pl an to phase out the remaining use of methyl bromide.

### October 2012 MBTOC CUN Final Report 

### 29 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for 2013 9 CUN for

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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 Environ ment 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 r eductions 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 wi th 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 t he 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 standa rds for export. MB TOC considers that soilless culture is suitable at least for foundation stock. MBTOC notes that other Parties have adopted a number of che mical alternatives (ie. methyl iodide/chloropicrin, chloropicrin combined with herbicides and 1,3

- D/Pic) for strawber ry 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 reev aluation 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 register ed, 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 be tter comply with Decision IX/6 by examining the feasibility of expanding soilles s 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.

### October 2012 MBTOC CUN Final Report 

### 30 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for 2013 9 CUN for

2014 MBTOC rec

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

 Dec. IX/6 b(i) Emissio n 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 th is time. A groundwater study for chlor opicrin has been submitted by the registrant to PEI and federal authorities.

### October 2012 MBTOC CUN Final Report 

### 31 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for 2013 9 CUN for

2014 MBTOC rec

for 2014

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 f inal 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 17 0 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 m anufacturer ( Arysta) and thus is no longer available in California. Further, the Party suggests that organic production is not a replacement for areas of high p est pressure and that steam is extremely costly.

In view of MI withdrawal from the market, the majority of M BTOC (all but one member) agreed with consensus to recommended reinstat ing 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 Pic

C lor 60 (a 33% reduction from the standard rate) led to fruit yields and weed control similar to dosages of 336 kg/ha of Pic

- C lor 60 with stan dard 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 c oncentrations, 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 pr event use of chloropicrin in some counties. Also barrier films again offer opportunities to reduce dosage rates wi th 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 appea rs that the lower

rate falls within the restrictions of most counties and would allow chlor o picrin 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 t hat a small proportion of the existing production can transition to organics and maintains its initial recommendation for transiti oning 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 with in 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

### October 2012 MBTOC CUN Final Report 

### 32 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

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### boilers with improved treatment speed are available in several countries and in use in horticulture and tree nurseries, mushr oom 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 regulato ry restrictions,

recommend ed no more than 381.310 tonnes and that the nomination be reduce d to a critical area of no more than 2243 ha and a use rate of 170 kg/ha in 2014 (See Annex II)

Original Nomination by the Party:

The Party nominated 415.067 tonnes of methyl bromi de 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/m 2 

### which conforms to the MBTOC standard presu mptions 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 sp ecific basis tor this proposed reduction.

Circumstances of the Nomination:

The Party states that Californian growers have a critic al need for methyl bromide to treat fields where the primary alter native, 1,3

- D/chloropicrin, cannot be used

due to townsh ip 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 Californ ia 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 un safe if they have been produced on methyl iodide

- treated land.

The Par ty 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 ful ly 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 yie ld 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 re ducing 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 countie s and

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

Carbonation of 1,3

- D/chloropicrin fo rmulations may help to reduce the overall use of 1,3

- D by increasing its dispersal in the soil while providin g yields comparable to methyl bromide (Thomas et al., 2011b). In Florida trials (Noling and Cody, 2011), most alternative fumigants evaluated produced yields which

### October 2012 MBTOC CUN Final Report 

### 33 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for 2013 9 CUN for

2014 MBTOC rec

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### were statistically equivalent to that of methyl bromide chloropicrin 50/50 (320 lb/[treated ] acre). Co

- formulated f umigants 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 leve l 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 dat a 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 mat ter 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 applicatio n of steam in flowers, there is no commercial application of steam in strawberry production oth er 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 cont inued 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 worki ng 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. Sub strate 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 (Oxn ard, Watsonville/Salina s 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, name ly 1,3

- D, Pic and metam have been widely a dopted in these production districts. State

- wide in California, the CSC survey expects 15,535 ha strawberry fruit in 2012. The Californian Depart ment 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 fr om 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 appl ication, and therefore discourage reduction of MB dose rates as well as emission control through use of these fi lms (eg VIF, SIF and TIF).

### October 2012 MBTOC CUN Final Report 

### 34 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

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### MBTOC acknowledges that the alternatives have been significantly adopted in all counties in t he past 4 years, which indicates their technical and economic feasibility. MBTOC understands that regulatory restrictions, township cap s on 1,3D and maximum r ate 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 under stands 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 MBTO C. The total reduction as calculated by MBTOC is based on;

1) 261 ha (or 15%) of the expected area in 2013 affected by township cap s 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 s team, 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 eno ugh evidence to directly support the relationship between th e 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. , 20 10) 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.

M BTOC notes that the available literature shows promising non MB management strategies for these diseases. Disease susceptibi lity varies between cultivars and some of the currently used strawberry varieties show good levels of resistance although not for b oth 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 Isra el 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 a l., 2012). At tention should also be given to efficiency in fumigant delivery and distribution to all bed areas to delay plant collapse at the most susceptible zo nes such as bed sides (Koike et al., 2010; Daugovish et al., 2011). An integrated management strategy for th ese 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 cult ivars,

### October 2012 MBTOC CUN Final Report 

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2006 2 CUE for

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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 y ears since 2006. In 2010,

almost 100 tonnes more MB was used than was exempted for this partic ular 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 wid er use of 50:50 formulations, which still allow for comp lying 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 u se 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 wa s $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 variat ion 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 alter natives are economically feasible. However, in the case of steam, the costs that are presented are based on small plots (10 a cres 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 th e 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 effor t in the different production districts.

1 1ExMOP and 16MOP; 2 16MOP+2ExMOP+17MOP; 3 MOP17+MOP18; 4 MOP18+MOP19; 5 MOP19+MOP20; 6 MOP20+MOP21; 7 MOP21+MOP22; 8 MOP22, 9 MOP23

### 2012 MBTOC Report on 2012 CUNs: Final Recommendatio ns



### 36 

## 1

. 5 MBTOC

- S tructures and Commodities

– Final CUN Report

At the Open Ended Working Gr oup in Montreal, in July 201 2 , 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 techn ical 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 Pa rties requested and

pr ovided 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 tha t 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

- con sidered by each member of the relevant

sub

- committee

, who then submitted their own assessment comments, and then discuss ed the various

views

. Originally, e ach member of the relevant sub

- committee was asked to send their review/position

to the relevant Co

- c hair(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

for ming a consensus position by the drafting of proposed text boxes and recommendations. Sub

committee members then further discussed, commented on and made changes to the proposal until a consensus was reached. The agreed text box and recommendation was agai n circulated to obtain consensus (or agreement not to disagree) by each member of the sub

- committee . The c onsensus position s of each sub

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

committee findings.

The results of the re

- rev iews 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.

Par ties can request a re

- review if they disagree with MBTOC‟s first

- review recommendations, and by providing additional info rmation supporting their CUN.

### 2012 MBTOC Report on 2012 CUNs: Final Recommendatio ns 

### 37

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

- reviews

have been f

ew, 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 re

review 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 aspec t 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 P arties 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 in formation 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 p ork 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.

### 2012 MBTOC Report on 2012 CUNs: Final Recommendatio ns



### 38 Table 1

- 10 . Summary of the final recommendations by MBTOC

- SC (in square brackets) for

CUE’s for postharvest uses of MB (tonnes) for 201 4 submitted in the 201 2 round.

Country and Sector Nominated in

2012 Recommendation for

2014

Australia. Package d 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 201 2 for2014

Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 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 reca ptured.

The Party indicates that the applicant is pursuing the adoption of phosphine for treatment of rice in silo bins and in fumiga tion chambers. They are planning to fumigate milled rice in silo and conduct chamber fumigations on packaged rice. As expla ined 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 const ruction 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 appl ications 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 w as far belo w 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 th e Party to continue its

### October 2012 MBTOC CUN Final Report 

### 40 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 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 pa ckaging 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 fai rly 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 thei r 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, t he 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 succ essful if there are enough openings. Improvements i n pest control will improve rice quality and a recent report indicates that consumers may be inclined to pay more for rice wh en improved pest control techniques have been used (Su et al, 2012, in press)

Tribolium and Plodia complaints indicate post

- proces s 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. A s part of the reason suppo rting its request for MB for packaged rice, the Party cites product returns costing $AU 3,440 in 2009 related to pest infestation of pr oduct. The Party notes that reducing these claims has been a focus of the rice company for the past several years and tha t 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; t his 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) an d Bell (2011) detailed, these holes can easily allow larvae and even small adults of certain pest species access to infe st 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 silo s and chambers to allow it to complete transition to phosphine.

### October 2012 MBTOC CUN Final Report 

### 41 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 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 o f 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 post harvest 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.

### October 2012 MBTOC CUN Final Report 

### 42 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 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 5.04 4 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 t h at are particularly large structures are the remaining methyl bromide users. The CUN states that the amount requested is only sufficient for a single t reatment of up to 5 of the 11 mills in the application, 6 fewer than last year‘s application due to trans fer 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 fum igated. The listed mills are processing semolina or are very large mills with internal grain storages. Mills with internal gr ain 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 ins ect 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 mill ers. 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 consi ders 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

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 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 wh ich have significantly improved gastightness in some mills. Evaluation of alternatives to methyl bromide in progress include: heat treatments; ECO 2 

### Fume (carbon dioxide and phosphine mixed in gas cylinders), sulfuryl fluoride (SF) (but only if there is no f ood 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 cor rosion 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 re sults of current trials with SF have indicated poorer tha n 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 s ignificant 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, t he intensifying regulatory pressure in North America to improve food safety by eliminating al l 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 pest s. 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 cont inent.

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 natur al flu oride 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 repo rts; 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 inve stment 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 an d ensure the standards for dosage rate are met.

### October 2012 MBTOC CUN Final Report 

### 44 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 CUN for

2014 MBTOC

rec. for

2014



###  Dec. IX/6 b(iii) Research progra m : 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 decis ion 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

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 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 recommend s 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: Ca lifornia walnuts 0.161 tonnes; dates 0.325 tonnes and dried plum board 0.001 tonne. However, the Party then requested the recommend ation 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 ind ustry has already transitioned as much as it can to SF and phosphine

Fumigatio n with phosphine takes approximately three days, a time which is said to disrupt market flow and shuts down the processing ar ea. There are concerns that the use of phosphine would eventually result in some corrosion of electrical and electronic equipment i n 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 cubi c 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 lab el requirement for 8% PPO

includes a minimum heat treatment of 100 o 

### F (37.8 o 

### C), which would be costly

— but which MBTOC believes should be achievable.

### October 2012 MBTOC CUN Final Report 

### 46 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 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 co mbination treatment of PPO and sulfuryl fluoride is being researched by the USDA Agricultural Research Service that could minimize disruption to the current dried fruit processi ng flow and retain current processing equipment without major modification. Thi s effort is being undertaken to establish an effective treatment using SF and PPO against eggs at 20

o 

### C 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 ef ficacious for walnuts and dried fruit, but the Party has documented temperatures at or below 50°F in San Joaquin and Sacramen to 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 requir ed 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 fumig ations.

MBTOC Review and Assessment:

Upon review of the information submitted by the Party pertaining to research results, logistics and economics of the alternat ives, including difficulties obtaining efficacy in killing the eggs of pests in dried fruit, a nd 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 c hanges 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

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 CUN for

2014 MBTOC

rec. for

2014



### the dried plum board segments of this nomination.

MBTOC believes sup plemental 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 M BT OC 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 say ing, ―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 fu rther 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 pr event re

- inf estation and propylene oxide (when used to reduce bacteria and mold, insect pests will also be killed) are alternatives that could be used for the c ommodities 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 re

infestation is the reason for these stored commod ity 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 p ossible, 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. C ommodity 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 an d 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 t hen have been a dequate 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 bromid e alternatives for postharvest applications, but fu ll 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.interpuncte lla 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 pr oducts are

### October 2012 MBTOC CUN Final Report 

### 48 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

2013 9 CUN for

2014 MBTOC

rec. for

2014



### 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 a llow 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 t he California Plum Boa rd section

of this CUN.

MBTOC currently agrees with the information provided on dates, the lack of effective alternatives which would result in a mar ketable product, the assessment of the research results, and the research plan.

MBTOC Comments on Eco nomics 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 pr ice 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 r esulting 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 r esults 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 t heir 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 t o incur costs in acquiring land for that purpose. Cold storage also involves

### October 2012 MBTOC CUN Final Report 

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2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

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### reoccurring costs related to consumption of electricity for cooling and maintenance in addition to those fixed construction c osts.‖

Concerning the use of propylene oxide, the Par ty said, ― Furthermore, the label requirement 6 

### for 8% PPO includes a minimum heat treatment of 100 o 

### F (37.8

o 

### C), 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 ex perience 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 u se of controlled atmosphere (CA) storage. While an efficacious treatmen t, 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. N ewer storage chambers

cou ld 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 thes e alternatives.

C omments 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 dio xide 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 registere d 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

### October 2012 MBTOC CUN Final Report 

### 50 Country Industry CUE for

2005 1 CUE for

2006 2 CUE for

2007 3 CUE for

2008 4 CUE for

2009 5 CUE for

2010 6 CUE for

2011 7 CUE for

2012 8 CUE for

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2014

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 m illing, 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

Circumstan ces 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 p rocessing 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

su fficiently high temperature for an appropriate exposure period to kill all stored product pests present. The company concern ed is trying to determine how to address the problem of a heat sink in that mill. Another company has encountered difficulties att ributed 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 dam aged 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 appropriat e 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 heate rs 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

supp lemental 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 al lowed for use in mills and rice processing but not allowed for contact of pet food and for t he 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

### October 2012 MBTOC CUN Final Report 

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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 t hese 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 eq uipment, bins, storage spaces, and

even the walls of the structure.

T here are two primary chemical fumigants available to this industry that may accomplish these tasks: methyl bromide and sulfur yl fluoride. Heat is the other main alternative. Sulfuryl fluoride is more sensitive to temperature and is less efficacious on ins ect 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 w ith heat sinks). This nomination is for facilities, or portions of fac ilities, 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 tre atment to a much greater extent than American mi lls. 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 m ethod of pest control that works in all instances. For example, representatives of some of these types of companies re ported 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 o f the United States has a problem

### October 2012 MBTOC CUN Final Report 

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### with prevailing winds preve nting 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 CO 2 

### in some Canadian mills, but the use of phosphine can be a cause o f concern because of the potential of corrosion of electronic components and the likelihood of development of pest resistance when there are repea ted applications of short exposures at raised temperatures which result in survival.

Research in mills has fo cussed 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 reg ulatory ap proval). 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 effect iveness 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 tr eatments 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 a nd 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 i s 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 pe t 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 infe station (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. Microsa nitation 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 coul d be thoroughly clean ed 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 efficien t 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 res earch reported above, and the use of heat, MBTOC signals that unless significant new, specific a nd 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

### October 2012 MBTOC CUN Final Report 

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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 pr oportionate 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 dif ficult 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 pest s, 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) Appro priate 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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2005 1 CUE for

2006 2 CUE for

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United

States Cured pork 67.907 40.854 18.998 19.669 18.998 4.465 3.73 3.7 30 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 r epresents a 34%

reduction over the nominated amount.

Nomination by the Par ty:

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 wa s used, the Party maintained their originally nominated amount with the following statement. ―The amount of methyl bromide nominated by the United States government is 3,7 30 kg. This amount is slightly larger than that reported as being used by the 26 pro ducers 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 S outhern 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 pest s 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., 20 08). 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 alternativ e to methyl bromide for treatment of ham (mold) mites.

T here 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 t hey can power wash with steam and bleach. While this has not eliminated the pest s, it does take longer before hams are infested with mites, ham beetles and/or ham skippers.

### October 2012 MBTOC CUN Final Report 

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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 br omide 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

ag ing 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 ef fective 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 th is 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 recommen dation 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 numbe r 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 fumigate d 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, t he 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 s upplied 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 f acility 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 T ime) 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 require d for good practise.

Additionally, although three facilitie s 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 l ength 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

### October 2012 MBTOC CUN Final Report 

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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 requirem ent 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 ac hieve this reduction by improving facility gastightness and through IPM improvements. With improved gastightness, air circulation and temperature can be incre ased 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 da ta; we believe there are only a few MB applicators working in this sector. We would like an explanation for any increase o f 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 ga stightness. We have read with interest the advances being made in sanitation a nd 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 rep eated 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 rep ort that it can propose some

oth er alternatives which work with similar cured meat products in Europe. (Although we acknowledge that each country‘s cured mea t products have variations which may affect infestation issues.). Different types of Ham products are produced in Spain (in the sou th

- 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 a ny 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 th e process (initial 75 % to allow salt

p enetration and afterwards gradually decrease to 65%), control of moulds in the ham surface. Updating the old ham houses to mo dernize 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 demonstrat ed 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 putresce ntiae . 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 th e 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

US 1



### Facility # US 1



### Maximum MeBr used per year (kg) US 1



### Aging Room Size (1,000 cubic meters) US 1



### Maximum number of fumigations per year MBTOC Recommendation 2



### (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 2 0.4

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 conversi on 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 pro gram 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 ongoin g 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; 2 16MOP+2ExMOP+17MOP; 3 MOP17+MOP18; 4 MOP18+MOP19; 5 MOP19+MOP20; 6 MOP20+MOP21; 7 MOP21+MOP22; 8 MOP22, 9 MOP23

### October 2012 MBTOC CUN Final Report



### 60 

## Activity Report 2012 and Workplan for 201 3

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 32 nd 

### 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 T ianjing 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

- re views 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 critica l 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 Par ties 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 nominatio ns 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 appointe d 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 usu al 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 pre

arranged teleconference, or through meetings w ith 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

 T o 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

1 non

- 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

- T EAP 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 t o 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 fu rther 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 addit ional 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 an y proposed new standard presumptions to be applied by MBTOC

 conduct any bilateral consultations requested by Parties

 draft work plan and budget for MBTOC for 20 1 3 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

m ember) 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

### October 2012 MBTOC CUN Final Report



### 62 1.7 References:

Ajwa, H., Fennimore, S., Browne, G.,Martin, F.,Trout, T., Duniway, J. Shem

- Tov, S. and Daugovish, O. (2005).

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., Riudav ets, J., and Kavallieratos N.G., (2011) Preventing stored

- product insect infestations in packaged

food 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 co ntrol: 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 sp ecies 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 a nd 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: Pr oc Ann Int Res

C onf on MeBr Alternatives and Emission Reductions. San Diego, CA, Oct. 31

– Nov. 2 , 20 11. 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, 2 011, 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 stra wberry.

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 Internati onal Resear ch

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 St ructural 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 s imulate 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 ra tes 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, F lorida, 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.pd f

. Koike, S., Daugovish, O., Gordon, T., Ajwa, H., Bolda, M. and Legard, D. (201 0 ). 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 Emissio ns 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 fei nmaschige

### 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. Deuts che Pflanzenschutztagung, 10.

- 14. September 2012 in Braunschweig,
Germany, ISBN 978

- 3

- 930037

, http://pub.jki.bund.de/index.p hp/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 meth yl bromide

alternatives in Florida strawberry 2010

- 11. Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions (2011). http://mbao.org/2011/Proceed ings/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

Emissi on Reduction, Orlando, FL, November 11th

- 14th

Porter, I.J., L. Trinder and D. Partington. (2006). Special Report Validating the Yield Performance of Alternatives to Methy l

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 Brijw ani 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). I ncreasing 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 Triboli um

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

- w ide 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

### October 2012 MBTOC CUN Final Report



### 64 

## 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 cons umption, 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 a vailable 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,

c ommercialise 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, ins titutional 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 Partie s 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 it s 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 suitabl e 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 m inority report i s 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, 2012 7 

### ) 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.

A ssessment

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.

R ecommendation

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.

Table s showing review and assessme nt

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 o f 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 de cision 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

### October 2012 MBTOC CUN Final Report 

### 66 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 MBTOC 8



### 1 IX/6 (1)(a)(ii);

and XXI /11(9) ... there are no technically and

e conomically 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 Alte rnatives

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

chem ical 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 categor ize 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 cr itical

- 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 MBTOC 8



###  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 alternativ es 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 non

fumigant 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 accep table 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 o f 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.

### October 2012 MBTOC CUN Final Report 

### 68 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 MBTOC 8



### 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 regulat ion 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 h ow 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 with in 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

- c hemical 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 MBTOC 8



### and XXI /11(9) and secure nationa l 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., 2 011b). 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 ev idence 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 eff

ort 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 deve lop

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 substitute s.

8 Annex I (A) of

MOP16 (21) Parties are invited to include in

their nominations, information on their determination that the specif ic

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, 2012 1 

### ) indicates that the years of exempted MB use have been years of rising yields, increased cropping ar eas, exports and revenues for Californian growers of strawberry fruit.

There is no evidence of significant market disruption.

### October 2012 MBTOC CUN Final Report 

### 70 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 MBTOC 8



### 9 Dec ExI/3

, paragraph 9(h) TE AP 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 a nd 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
[Nati onal] 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 hav e 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

t hat 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 t he 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 s ubstantiate 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 ca lculations

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 l onger 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 MBTOC 8



### 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 tha t 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 informat ion 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 red uce 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 s trawberry 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 ov erall 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

- strawbe rry 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.

### October 2012 MBTOC CUN Final Report 

### 72 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 MBTOC 8



### 2. Further uptake of Pic

- straight with d ose 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 19 8 ha/year since 2003) under existing regul atory 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 19 8

ha.

3. Further uptake of non

- chemical alternatives

 Organic production is expect ed 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 unreali stic 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 addition al 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 una vailable to calculate potential further uptake of other alternatives.

Conclusion: A feasible additional annual adoption of 211 ha 1,3

- D, 19 8 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 MBTOC 8



### 12 Ex.I/4 (3)(b) Requires the use of expedit ed

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 registrat ion methods? Are the procedures in place locally and not just at the

national level? No evidence of expedited procedures

### October 2012 MBTOC CUN Final Report 

### 74 SUMMARY: US Strawberry fruit CUN2014

Source Criteria CUN

assessment

outcome Source Criteria CUN

assessment

outcome Source Crit eria 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

I X/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

a lternatives 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 d eploy

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 N o 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 I I I

- 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

Belgiu m 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

### October 2012 MBTOC CUN Final Report 

### 76 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 1 2.500

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 27.5 00 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

solana ceo 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 14.0 00 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

### October 2012 MBTOC CUN Final Report 

### 78 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 303.000 303.000 321.330 163.400 113.82 1 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 Stra wberries

–

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) 35.00 0 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 1 82.200 182.200 168.000 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

J apan 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

### October 2012 MBTOC CUN Final Report 

### 80 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 42.0 00 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 230.000 230.000 230.000 215.0 00 230.000 230.000 230.000

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,

rasp berries, 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 54.9 88 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

### October 2012 MBTOC CUN Final Report 

### 82 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 7 37.584 292.751 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 I V

– 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 Quant ities 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

### October 2012 MBTOC CUN Final Report 

### 84 Party Industry Total CUN MB Quant ities 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 0.1 20 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 2.08 4 (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 Quant ities 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) 3.4 44 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

mush rooms as dry

commodities 4.000 3.560 1.800 0.500 4.100 3.560 1.800 1.800

### October 2012 MBTOC CUN Final Report 

### 86 Party Industry Total CUN MB Quant ities 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

spi ces 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 Quant ities 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 1 9.242 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

### October 2012 MBTOC CUN Final Report 

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