USA CUN11 POST HARVEST National Pest Management Association (NPMA) Page 1 of 11

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

POST-HARVEST USE TREATMENT BY NATIONAL PEST 

MANAGEMENT ASSOCIATION 

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN11 POST HARVEST NATIONAL PEST MANAGEMENT 

ASSOCIATION (NPMA)

BRIEF DESCRIPTIVE TITLE OF NOMINATION: 

Methyl Bromide Critical Use Nomination for Post Harvest Use by NPMA (Submitted in 2009 

for 2011 Use Season) 

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF 

NOMINATION: 

TABLE 1. QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF NOMINATION

YEAR NOMINATION AMOUNT 

2011 17,365 kilograms 

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat website under 

Decision Ex. I/4(8).) 

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on 

which the Party’s first-year exemption was approved, as well as any supplementary information provided by the 

Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not 

re-submit that earlier information. 

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Hodayah Finman 

Title: Foreign Affairs Officer 

Address: Office of Environmental Policy 

 U.S. Department of State 

 2201 C Street, N.W. Room 2658 

 Washington, D.C. 20520 

 U.S.A. 

Telephone: (202) 647-1123 

Fax: (202) 647-5947 

E-mail: finmanhh@state.gov 

Following the requirements of Decision IX/6 paragraph (a)(1) United States of America has determined that the 

specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for 

this use would result in a significant market disruption. ■ Yes  No 

 

Signature Name Date 

Title: 
USA CUN11 POST HARVEST National Pest Management Association (NPMA) Page 2 of 11

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger 

Title: Director (Acting) 

Address: Biological and Economic Analysis Division 

 Office of Pesticide Programs 

 U.S. Environmental Protection Agency 

 1200 Pennsylvania Avenue, N.W. Mailcode 7503P 

 Washington, D.C. 20460 

 U.S.A. 

Telephone: (703) 308-8200 

Fax: (703) 308-7042 

E-mail: Housenger.Jack@epa.gov

 

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE: 

1. PAPER DOCUMENTS: 

Title of paper documents and appendices 

No. of pages Date sent to Ozone 

Secretariat 

USA CUN11 Post Harvest National Pest Management Association 

 

 

 

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: 

*Title of each electronic file (for naming convention see notes above) 

No. of 

kilobytes 

Date sent to Ozone 

Secretariat 

USA CUN11 Post Harvest National Pest Management Association 

 

 
USA CUN11 POST HARVEST National Pest Management Association (NPMA) Page 3 of 11

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

NATIONAL PEST MANAGEMENT ASSOCIATION 

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL USE 

This sector includes cheese and food processing plants treated by National Pest Management 

Association (NPMA) members and are not included in the Commodity or in the Food Facilities 

Chapters of the US nomination. Food Processing Facilities included in this application are: 

processed foods (such as chips, crackers, cookies and pasta), spices and herbs, and cheese 

processing plants. Methyl bromide is typically utilized in processed food and feed facilities as a 

space fumigant for treating the facility 1 to 3 times per year. As the need arises, methyl bromide 

is also used for trailer fumigations of product or packaging material. These facilities are under 

intense pressure from many insect pests as well as rodents. 

CHEESE: Methyl bromide fumigation for cheese occurs to ensure pest-free food and meet the 

strict requirements of the Food Sanitation Regulations. Cheese manufacturers may target their 

products during fumigations with methyl bromide when a mite infestation is identified by USDA 

inspection and a fumigation is ordered. Cheese does not have a technically and economically 

feasible alternative available. Whereas sulfuryl fluoride and phosphine are the primary 

alternatives in most commodities, they are unsuitable for cheese facilities. Phosphine 

fumigations take much longer than methyl bromide fumigations and are not a feasible alternative 

when rapid fumigations are needed; is corrosive to certain metals; is limited by temperature. 

Sulfuryl fluoride has been determined not to be efficacious on mites. Therefore, sulfuryl fluoride 

will not be able to replace methyl bromide in this sector. Also, adoption of not in kind 

alternatives, such as controlled atmospheres, cold, and carbon dioxide under pressure, would 

require major investments for appropriate treatment units and /or retrofitting of existing cheese 

manufacturing facilities. 

FACILITIES: Primarily this sector is treating only the portions of the facilities that contain 

electronic components and have machinery with copper and copper alloy parts. These facilities 

are under intense pressure from many insect pests. The majority of these food processors do not 

target any of their commodities to be fumigated with methyl bromide, although some may be 

present in the equipment during fumigation. 

Food processing facilities in the United States have reduced the number of methyl bromide 

fumigations by incorporating many different techniques to control pests. The most critical 

strategy implemented is IPM, especially sanitation, in all areas of a facility. Facilities are now 

being monitored for pest populations, using visual inspections, pheromone traps, light traps and 

electrocution traps. When insect pests are found, facilities will attempt to contain the infestation 

with treatments of low volatility pesticides applied to both surfaces and cracks and crevices; spot 

treatments with heat or phosphine will be used in areas that are suitable. Incoming ingredients 

are inspected for insect pests and may be treated with phosphine. These techniques do not 

disinfest a facility but are critical in monitoring and managing pests, and hopefully preventing 
USA CUN11 POST HARVEST National Pest Management Association (NPMA) Page 4 of 11

outbreaks. However, when all these methods fail to control a pest problem, facilities must rely 

on fumigation, to kill insects within the equipment and even the walls of the structure. There are 

two primary fumigants available to this industry that may accomplish these tasks: methyl 

bromide and sulfuryl fluoride. 

HERBS AND SPICES: Methyl bromide is requested for a few small mills where herbs and 

spices are blended into packages (such as for pizza mixes) that are then added to pre-packaged 

goods. These facilities are similar to food processing facilities in that there are silos, mixing 

areas, packaging areas, etc. These facilities utilize methyl bromide to target pests present in 

inaccessible areas of the structure, such as the equipment and buildings. The ingredients or 

finished products that may be stored on-site are not targeted for fumigation. However, the 

problem in some of these small mills is that they are all under one roof without any way to 

completely segregate the different areas. 

Fumigants of choice for treating herb and spice commodities are ETO, PPO, irradiation and 

phosphine. These alternatives are not feasible to disinfect the facility itself. 

See previous discussion on sulfuryl fluoride in food processing facilities. 

The USG has applied an aggressive transition rate which is reflected in the nomination amount 

and detailed in Table 2. 

TABLE 2. NOMINATION AMOUNT 

 Processed Foods Spices and Herbs 

 Cheese 

Processing Plants 

 Sector Total / 

Average 

Quantity Requested for 2010: Amount (kgs) 2,439 33,527 1,812 37,778 

Quantity Recommended by 

MBTOC/TEAP for 2010 : Amount (kgs) 2,439 33,527 1,812 37,778 

Amount (kgs) 2,439 33,527 1,812 37,778 

Volume (1000 m3) 1,676 122 91 1,889

Rate 20 20 20 20

Transition from 2010 Baseline 

Adjusted Value

Percentage (%) -84% -84% 0% -82%

Amount (kgs) 1,055 14,498 1,812 17,365 

Volume (1000 m3) 725 53 91 869

Rate 20 20 20 20 

SECTOR

NPMA

Quantity Approved by Parties for 

2010:

Quantity Required for 

2011 Nomination:

2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

Transition Use Reduction Description Spreadsheet
USA CUN11 POST HARVEST National Pest Management Association (NPMA) Page 5 of 11

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

This nomination is for facilities, or portions of facilities, that are unsuitable for the alternatives, 

and where the alternatives are not economically feasible. Sulfuryl fluoride is highly dependent 

upon temperature, so should a facility need fumigation during cold temperatures, this chemical 

may not be a cost-effective solution. In addition sulfuryl fluoride requires higher dosages for egg 

kill, a paramount concern in certain facilities. Phosphine can be explosive and is corrosive to 

many metals that are present in facilities, especially in the computers and other electronic 

process control instrumentation. Heat is dependent on several parameters: the structural 

composition, as different components expand and contract at different rates; the building 

design/layout factors, which affect the ability to evenly distribute heated air; and the availability 

of convenient and economical sources of heat. Also heat may not be a viable option for 

treatment of food products or commodities. 

There are also some regulatory issues with sulfuryl fluoride related to the commodities that may 

be directly fumigated. For example, according to the Profume® label pasta is not listed as a 

material approved for direct treatment. Therefore, the interpretation is that all pasta products 

would need to be removed from treatment areas or sufficiently protected to prevent the formation 

of sulfuryl fluoride residues within the pasta products. This may sufficiently increase the costs 

and timing considerations for sulfuryl fluoride use on a host of processed foods and ingredients. 

The objection by the Fluoride Action Network, Beyond Pesticides, and Environmental Working 

Group against the tolerances of sulfuryl fluoride is still pending. 

3. SUMMARY OF RECENT RESEARCH 

Cheese

There has been no research specific to cheese, as these facilities are only fumigated when mites 

are found during a USDA inspection. However, researchers investigating dry cured pork 

products are including cheese in their studies as the arthropod pests are the same. For the 

convenience of MBTOC, the research information from the US nomination for dry cured pork 

products appears below. 

In the spring of 2007 a proposal was submitted to USDA CSREES Integrated Research, 

Education, and Extension Competitive Grants Program- Methyl Bromide Transitions by several 

meat scientists and an entomologist. This proposal was recently funded for the next three years. 

There are several objectives to this multiple year research program: First is to determine the 

effectiveness of chemical controls (sulfuryl fluoride, phosphine, and methyl bromide) against all 

life stages of both mold mites (Tyrophagus putrescentiae) and red legged ham beetles (Necrobia 

rufipes). Second objective is to determine the effectiveness of carbon dioxide and ozone against 

all life stages of both mold mites and red legged ham beetles. The third objective is to test the 

effects of sulfuryl fluoride, phosphine and methyl bromide on the quality and safety of the dry 

cured hams. The fourth objective is to conduct an economic analysis of the alternatives 

demonstrated to be technically viable alternatives for methyl bromide in this industry. 
USA CUN11 POST HARVEST National Pest Management Association (NPMA) Page 6 of 11

The results of sulfuryl fluoride efficacy investigations on Tyrophagous putrescentiae, ham mite, 

and Necrobia rufipes, red-legged ham beetle, were presented at the 2008 MBAO Conference, in 

Orlando, Fl. The studies included eggs and a mixture of adults and nymphs of mites and eggs, 

large larvae, pupae and adults of beetles. The experiments were conducted for 48 hours at 23° C 

at various concentrations of sulfuryl fluoride. The investigators achieved 100% mortality of redlegged ham beetle adults and pupae at about 4.0 g/m3

, 100% mortality of larvae at 5.7 g/m3. 

Eggs of red-legged ham beetles died at 24.0 g/m3 of sulfuryl fluoride, well below the maximum 

label rate. (Phillips, et al. 2008) Mortality of ham mites required higher concentrations of 

sulfuryl fluoride. A concentration of about 100.3 g/m3

 was necessary to obtain 100% mortality 

of adults and nymphs under the test conditions. However this concentration obtained only a 95% 

mortality of mite eggs. This is about three times the legal label rate. (Phillips, et al. 2008) 

Facilities

Jim Campbell (2008) evaluated efficacy of structural fumigations. He investigated trap catches 

of Tribolium castaneum, red flour beetle (RFB), in two flour mills. Mill 1 had 8 methyl bromide 

fumigations and 2 sulfuryl fluoride fumigations. Mill 2 had 11 methyl bromide fumigations. 

The average trap capture was higher in Mill 1 than in Mill 2, with a reduction of 93% and 67%, 

respectively, after fumigation. In addition, the average proportion of traps with RFB was 

reduced after fumigation (62% and 66%, respectively). Campbell (2008) also examined the 

seasonal impact of fumigation efficacy. In Mill 1 he reports that the mean trap captures in 

summer are higher than in either spring or fall, although there is no significant difference 

between spring and summer. There is a major reduction of in mean trap captures after 

fumigation, regardless of time of year. Mill 2 has higher mean trap captures in the fall, but again 

reduction after fumigation. Spring fumigations at Mill 1 results summarized in Table 3 below: 

Table 3. Summary of Trap Capture Reductions by Campell (2008). 

Reduction 

Fumigant % Average Trap Capture % Proportion of Traps with 

Captures 

Sulfuryl Fluoride, low rate 98 71 

Sulfuryl Fluoride, high rate 96 93 

Methyl Bromide, normal rate, 

single 84 28 

Methyl Bromide, normal rate, 

overall average 92 55 

Campbell (2008) also presented data regarding rebound after fumigation. He found that season 

and pest density did have an impact on rebound. Rebound was slower during the fall. The use 

of aerosols and enhanced IPM also slowed rebound. This multiyear study has taken place in 

only two flour mills, and needs to be demonstrated in other locations. 

In a comparison of sulfuryl fluoride and methyl bromide in mill fumigations (Tsai, et al., 2008), 

it was found that methyl bromide killed RFB and Indianmeal moth (IMM) eggs better than 

sulfuryl fluoride. But that sulfuryl fluoride killed RFB and IMM pupae better than did methyl 
USA CUN11 POST HARVEST National Pest Management Association (NPMA) Page 7 of 11

bromide. There was no difference in the fumigants on the mortality of larvae and adults. These 

were commercial fumigations, but rates and exposure times were not reported. In addition, 

rebound was also investigated in these mills. It was found that rebound varied by both season 

and mill. One mill which responded only when critical conditions existed averaged a rebound 

rate of 8 months, whereas other mills had a spring rebound average of 3 months. Summer 

populations of flour beetle averaged a 4.8 months rebound period. Fall fumigations took 

advantage of the lower ambient temperature by increasing rebound periods to an average of 7 

months. (Tsai, et al., 2008) 

Reichmuth and Klementz (2008) have investigated how to better use sulfuryl fluoride to manage 

pest populations. They report that in Germany and UK that many mills have considerable 

numbers of surviving pests despite strict dosage schedules. The authors propose an increased 

dosage of sulfuryl fluoride or perhaps to use the fumigant in combination with heat or another 

chemical. They cite the methyl bromide CT for RFB as 5 g/m3 in the laboratory but the field 

(structural) requires 20g/m3. For sulfuryl fluoride, the CT for RFB post-embryonic is 113 gh/m3 

but eggs require 1,669 gh/m3. In addition to heat, the authors examine sulfuryl fluoride with 

phosphine, with carbon dioxide, with hydrogen cyanide. They provided data on the combination 

with hydrogen cyanide, but since cyanide is not registered for use in the U.S., it will not be 

considered further. The authors also looked at Pulsed Fumigation. As the authors noted this 

method has a longer down time and potentially an MRL problem. The conclusion was that 

although these combinations may be clumsy or time consuming, there is still a potential that 

further research may be able to overcome these weaknesses. (Reichmuth and Klementz, 2008) 

Indianmeal moth is a ubiquitous stored product pest and information on aerosol efficacy on eggs 

and larvae is limited (Arthur, et al. 2008). This investigation examined methoprene alone and in 

combination with esfenvalerate. Percent mortality of IMM eggs exposed to esfenvalerate was 

about 65% and about 65% when exposed to methoprene. Percent mortality of IMM larvae 

exposed to esfenvalerate was 10% but 99.6% when exposed to methoprene. The combination of 

esfenvalerate aerosol with an IGR like methoprene does control eggs and larvae of IMM. In 

addition to efficacy, an economic analysis was also conducted, which demonstrated that this 

combination was cost effective. (Arthur, et al. 2008) 

4. ECONOMIC INFEASIBILITY OF ALTERNATIVES 

TABLE 4. ECONOMIC SUMMARY FOR EACH ALTERNATIVE

METHYL 

BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

HEAT 

TREATMENT

Heat treatments are technically and economically feasible in some cases. Most 

insects do not survive more than 12 hours when exposed to 45oC or more than 5 

minutes when exposed to 50oC (Fields, 1992). In very cold regions, heat is 

costly and production time is lost for heat up. In old facilities, high heat could 

inflict structural damage. Also, this approach is not feasible for treating 

commercial-scale commodity volumes, as heat is a poor penetrator of 

packaging, boxes, and commodities. Also, structures with many concrete 

partitions are not good candidates for heat treatment because heat may not be 
USA CUN11 POST HARVEST National Pest Management Association (NPMA) Page 8 of 11

METHYL 

BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

evenly distributed; hence, efficacy is reduced. 

Under laboratory conditions, brief exposure of commodities to high 

temperatures may eliminate insects without adversely affecting product quality. 

However, high heat can have an adverse affect on food quality (e.g., cheese). 

For food processing facilities which are able to convert to heat treatment, there 

may be economic losses are from additional production downtimes in cold 

facilities due to longer fumigation time. There are other food processing 

facilities in areas of United States where heat treatment is not feasible. 

Economic losses due to downtime with heat treatment are persistent. However, 

some facilities experience better control with heat than fumigation due to leaky 

structures that allow gas to escape. 

 

PHOSPHINE 

(ALONE OR IN 

COMBINATION) 

Although phosphine does kill insects, it is corrosive to metals, especially copper 

and its alloys (bronze and brass); these metals are important components of the 

electronics that run the manufacturing equipment. In addition, some equipment 

(e.g., motors, mixers, etc.) has metal parts that contain copper. This alternative 

is already being used in the areas without electronics and where temperatures are 

not a factor. 

Phosphine also requires a longer application time compared to methyl bromide. 

Phosphine fumigation takes 3-10 days, depending on temperature, compared to 

1 day for MB (Hartsell et al., 1991, Zettler, 2002, Soderstrom et al., 1984, 

phosphine labels). An additional 2 days are needed for outgassing phosphine. 

Phosphine fumigation is least feasible during the colder winter months when, 

according to label directions, the minimum exposure periods increases to 8-10 

days (plus two days for aeration) when commodity temperature decreases to 5oC 

- 12 oC. Phosphine is not used when commodity temperature drops below 5oC 

(Phosphine and Eco2fume® labels). Phosphine is not a suitable alternative to 

methyl bromide when rapid fumigations are needed to meet customer timelines. 

Resistance to this fumigant has also been reported for several stored product 

pests. Furthermore, cheese makers claim that phosphine causes damage to the 

cheese, “melting of the cheese” and may cause acid residue, acrid off-odors and 

affect flavor. 

IRRADIATION

Although rapid and effective, irradiation alone may result in living insects left in 

the treated product. Treated insects are sterilized and stop feeding but are not 

immediately killed. The high dosages necessary to cause immediate mortality in 

target insects may reduce product quality. Irradiation also requires major capital 

expenditures and irradiated food are not widely accepted by consumers. 

CARBON 

DIOXIDE (HIGH 

PRESSURE) 

Facilities in the United States are not airtight enough for modified atmospheres 

or carbon dioxide to be effective primarily due to age of the facility; specifically, 

most facilities are more than 25 years old. 

SULFURYL 

FLUORIDE

A portion of the food processing facilities can economically convert to sulfuryl 

fluoride. Other facilities cannot due to economic losses that would result from 

higher treatment costs which arise at lower temperatures. For a small 
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METHYL 

BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

percentage, SF is not technically feasible due to cold temperatures. Adding heat 

to increase the efficacy of SF is also not an economically feasible option. 

Sulfuryl Fluoride

Results of the assessment of using sulfuryl fluoride as an alternative to methyl bromide are 

provided in Table 4. For purposes of this analysis, current prices of sulfuryl fluoride and methyl 

bromide were assumed equal and plant temperatures are assumed to be 29.44 degrees centigrade 

(85 degrees Fahrenheit). This analysis only covers cases where sulfuryl fluoride is a technically 

feasible alternative to methyl bromide and its use is not restricted by label instructions or state 

regulations. For example, sulfuryl fluoride is technically feasible only in facilities that do not 

prepare mixed products (e.g., cake mixes).Fumigation with sulfuryl fluoride at lower 

temperatures controlling all pest life stages is infeasible due to prohibitively high application 

rates and minimal efficacy. 

Heat Treatment

Potential economic losses were estimated for the food-processing facilities that have not been 

converted to heat treatment. This analysis only covers cases where heat treatment is technically 

feasible; it does not cover situations where heat would degrade the commodity being processed 

(those with fats and edible oils). 

Production downtime is estimated at one additional day for cold facilities due to longer heat-up 

period. Costs of heat treatment include all labor, transportation, and fuel. Fuel used is generally 

propane and could increase significantly with fuel costs. See Table 5 below. 
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TABLE 5. ANNUAL ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FOR NPMA STRUCTURES

NPMA Structures (Spices & Food Processors) 1 Units MeBr 2 SF 2 Heat: 7oC Heat: 29 oC SF + 7oC Heat Total Operating Costs $/year na na na na na Total Fumigation/Heat Costs $/year $ 24,000.00 $ 30,000.00 $ 70,000.00 $ 150,000.00 $ 100,000.00 

Quantity of Fumigant (One treatment per year) kgs/facility 522 1,134 na na na Fumigant cost (i.e., gas) $/year $ 9,000.00 $ 15,000.00 na na $ 15,000.00 Other fumigation costs (i.e., labor, equip., etc.) $/year $ 15,000.00 $ 15,000.00 $ 70,000.00 $ 150,000.00 $ 85,000.00 

Other Operating Costs $/year na na na na na Time Lost days 0 0 0 1 0Total Loss (MeBr to alt) $/year $ - $ 6,000.00 $ 46,000.00 $ 126,000.00 $ 76,000.00 Average Facility Loss per Kg MeBr Requested 

$/kg MB 

requested na $ 11.50 $ 88.18 $ 241.55 $ 145.70 

1 Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility 

2 Temperature at 29 degrees C 
USA CUN11 Post Harvest National Pest Management Association Page 11 of 11 

CITATIONS 

Arthur, F. H., E. A. Jenson, and J. R. Nechols. 2008. Esfenvalerate plus methoprene aerosol to 

control the Indianmeal moth. Presented at MBAO, Orlando, Fl. November 2008. Available at: 

http://mbao.org 

Campbell, J.F. 2008. Evaluating Impact of Structural fumigations on pest populations. 

Presented at MBAO, Orlando, Fl. November 2008. Available at: http://mbao.org 

Phillips, Thomas W., Md. Mahbub Hasaan, M. Jamie Aikins, and M. Wes Schilling. 2008. 

Efficacy of sulfuryl fluoride to control ham mites and red-legged ham beetles. Presentation at 

MBAO, Orlando, Fl. November 2008. Available at: http://mbao.org

Reichmuth, C. and D. Klementz. 2008. How to overcome the egg-weakness of sulfuryl fluoride 

– combinations of control methods. Presented at MBAO, Orlando, Fl. November 2008. 

Available at: http://mbao.org 

Tsai, W-T., L. J. Mason, K. E. Ieleji, and D. E. Maier. 2008. Sulfuryl fluoride and methyl 

bromide fumigations in Midwestern US flour mills. Presented at MBAO, Orlando, Fl. 

Novermber 2008. Available at: http://mbao.org