USA CUN11 POST HARVEST National Pest Management Association (NPMA) 

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## 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 Har vest Use by NPMA (Submitted in 2009 for 2011 Use Season)

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR O F

NOMINATION:

T ABLE 1. Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION

Y EAR N OMINATION A MOUNT

2011 17,365 kilograms

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat we bsite under Decision Ex. I/4(8).)

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomi nation 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 Pa rty 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 paragra ph (a)(1) United States of America has determined t hat the specific use detailed in this Critical Use Nominati on is critical because the lack of availability of methyl bromide for this use would result in a significant market disru ption. ■ Yes  No

Signature Name Date

Title:USA CUN11 POST HARVEST National Pest Management Association (NPMA) 

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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 Ass ociation

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming conventi on see notes above) No. of kilobytes Date sent to Ozone

Secretariat USA CUN11 Post Harvest National Pest Management Ass ociationUSA CUN11 POST HARVEST National Pest Management Association (NPMA) 

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## METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONM ENT)

NATIONAL PEST MANAGEMENT ASSOCIATION

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICA L USE

This sector includes cheese and food processing pla nts 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 Fac ilities included in this application are: processed foods (such as chips, crackers, cookies a nd pasta), spices and herbs, and cheese processing plants. Methyl bromide is typically uti lized in processed food and feed facilities as a space fumigant for treating the facility 1 to 3 tim es 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 ensu re pest-free food and meet the strict requirements of the Food Sanitation Regulati ons. Cheese manufacturers may target their products during fumigations with methyl bromide whe n a mite infestation is identified by USDA inspection and a fumigation is ordered. Cheese doe s not have a technically and economically feasible alternative available. Whereas sulfuryl f luoride and phosphine are the primary alternatives in most commodities, they are unsuitab le for cheese facilities. Phosphine fumigations take much longer than methyl bromide fu migations 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 eff icacious 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 portio ns of the facilities that contain electronic components and have machinery with coppe r 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 wit h methyl bromide, although some may be present in the equipment during fumigation.

Food processing facilities in the United States hav e reduced the number of methyl bromide fumigations by incorporating many different techniq ues 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 applie d to both surfaces and cracks and crevices; spot treatments with heat or phosphine will be used in a reas that are suitable. Incoming ingredients are inspected for insect pests and may be treated w ith phosphine. These techniques do not disinfest a facility but are critical in monitoring and managing pests, and hopefully preventingUSA CUN11 POST HARVEST National Pest Management Association (NPMA) 

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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 th at may accomplish these tasks: methyl bromide and sulfuryl fluoride.

HERBS AND SPICES: Methyl bromide is requested for a few small mills w here 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 proces sing facilities in that there are silos, mixing areas, packaging areas, etc. These facilities util ize methyl bromide to target pests present in inaccessible areas of the structure, such as the eq uipment and buildings. The ingredients or finished products that may be stored on-site are no t targeted for fumigation. However, the problem in some of these small mills is that they a re all under one roof without any way to completely segregate the different areas.

Fumigants of choice for treating herb and spice com modities are ETO, PPO, irradiation and phosphine. These alternatives are not feasible to disinfect the facility itself.

See previous discussion on sulfuryl fluoride in foo d processing facilities.

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

and detailed in Table 2.

T ABLE 2. N OMINATION A MOUNT

Processed Foods Spices and Herbs Cheese

Processing Plants Sector Total /

Average

Quantity Requested for 2010: Amount (kgs) 33,527 2,439

1,812

37,778

Quantity Recommended by

MBTOC/TEAP for 2010 : Amount (kgs) 33,527 2,439

1,812

37,778

Amount (kgs) 33,527

2,439

1,812

37,778

Volume (1000 m 3 ) 1,676 122 91 1,889

Rate 20 20 20 20

Transition from 2010 Baseline Adjusted Value Percentage (%) -84% -84% 0% -82%

Amount (kgs) 

### 14,498

1,055

1,812

17,365

Volume (1000 m 3 ) 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 (BU NNI)

Transition Use Reduction Description SpreadsheetUSA CUN11 POST HARVEST National Pest Management Association (NPMA) 

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2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

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

, and where the alternatives are not economically fea sible. Sulfuryl fluoride is highly dependent upon temperature, so should a facility need fumigat ion 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. P hosphine can be explosive and is corrosive to many metals that are present in facilities, especia lly in the computers and other electronic process control instrumentation. Heat is dependent on several parameters: the structural composition, as different components expand and con tract 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 t he 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 su fficiently protected to prevent the formation of sulfuryl fluoride residues within the pasta prod ucts. 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, Beyon d Pesticides, and Environmental Working Group against the tolerances of sulfuryl fluoride i s still pending.

3. SUMMARY OF RECENT RESEARCH

Cheese There has been no research specific to cheese, as t hese facilities are only fumigated when mites are found during a USDA inspection. However, resea rchers investigating dry cured pork products are including cheese in their studies as t he 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 U SDA 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 fluori de, 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 effectiven ess of carbon dioxide and ozone against all life stages of both mold mites and red legged h am 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) 

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The results of sulfuryl fluoride efficacy investiga tions 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 mixtu re of adults and nymphs of mites and eggs, large larvae, pupae and adults of beetles. The exp eriments were conducted for 48 hours at 23° C at various concentrations of sulfuryl fluoride. Th e investigators achieved 100% mortality of redlegged ham beetle adults and pupae at about 4.0 g/m 3 

### , 100% mortality of larvae at 5.7 g/m 3



### . Eggs of red-legged ham beetles died at 24.0 g/m 3 

### 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/m 3 

### was necessary to obtain 100% mortality of adults and nymphs under the test conditions. Ho wever 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 structura l 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. M ill 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 a verage 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, al though there is no significant difference between spring and summer. There is a major reduct ion 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 (20 08).

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 rebou nd after fumigation. He found that season and pest density did have an impact on rebound. Re bound 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 bro mide in mill fumigations (Tsai, et al., 2008), it was found that methyl bromide killed RFB and Ind ianmeal moth (IMM) eggs better than sulfuryl fluoride. But that sulfuryl fluoride kill ed RFB and IMM pupae better than did methylUSA CUN11 POST HARVEST National Pest Management Association (NPMA) 

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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 w as found that rebound varied by both season and mill. One mill which responded only when criti cal 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 r ebound period. Fall fumigations took advantage of the lower ambient temperature by incre asing 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 sc hedules. The authors propose an increased dosage of sulfuryl fluoride or perhaps to use the f umigant 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 fluorid e, 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 cyani de. They provided data on the combination with hydrogen cyanide, but since cyanide is not reg istered for use in the U.S., it will not be

considered further. The authors also looked at Pul sed Fumigation. As the authors noted this method has a longer down time and potentially an MR L problem. The conclusion was that although these combinations may be clumsy or time c onsuming, there is still a potential that further research may be able to overcome these weak nesses. (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 exp osed to methoprene. The combination of esfenvalerate aerosol with an IGR like methoprene d oes 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. 20 08)

4. ECONOMIC INFEASIBILITY OF ALTERNATIVES

T ABLE 4. E CONOMIC S UMMARY FOR EACH A LTERNATIVE



### M ETHYL


### B ROMIDE


### A LTERNATIVE 

### E CONOMIC 

### S UMMARY



### H EAT



### T REATMENT Heat treatments are technically and economically fe asible in some cases. Most

insects do not survive more than 12 hours when expo sed to 45 o C or more than 5 minutes when exposed to 50 o C (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 po or penetrator of packaging, boxes, and commodities. Also, structure s with many concrete partitions are not good candidates for heat treatme nt because heat may not beUSA CUN11 POST HARVEST National Pest Management Association (NPMA) 

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M ETHYL


### B ROMIDE


### A LTERNATIVE 

### E CONOMIC 

### S UMMARY

evenly distributed; hence, efficacy is reduced.

Under laboratory conditions, brief exposure of comm odities to high temperatures may eliminate insects without adversel y affecting product quality. However, high heat can have an adverse affect on fo od quality (e.g., cheese).

For food processing facilities which are able to co nvert to heat treatment, there may be economic losses are from additional producti on downtimes in cold facilities due to longer fumigation time. There are other food processing

facilities in areas of United States where heat tre atment 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.



### P HOSPHINE 

### ( ALONE OR IN

COMBINATION 

### ) Although phosphine does kill insects, it is corrosi ve 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 c ontain copper. This alternative is already being used in the areas without electron ics and where temperatures are

not a factor.

Phosphine also requires a longer application time c ompared 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 c older winter months when, according to label directions, the minimum exposure periods increases to 8-10 days (plus two days for aeration) when commodity te mperature decreases to 5 o C

- 12 o C. Phosphine is not used when commodity temperatur e drops below 5 o C (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 phosph ine causes damage to the cheese, “melting of the cheese” and may cause acid residue, acrid off-odors and

affect flavor.



### I RRADIATION Although rapid and effective, irradiation alone may result in living insects left in the treated product. Treated insects are sterilize d and stop feeding but are not immediately killed. The high dosages necessary to cause immediate mortality in target insects may reduce product quality. Irradia tion also requires major capital expenditures and irradiated food are not widely acc epted by consumers.



### C ARBON



### D IOXIDE 

### ( HIGH

PRESSURE 

### ) Facilities in the United States are not airtight en ough 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.



### S ULFURYL


### F LUORIDE A portion of the food processing facilities can eco nomically convert to sulfuryl

fluoride. Other facilities cannot due to economic l osses that would result from higher treatment costs which arise at lower tempera tures. For a smallUSA CUN11 POST HARVEST National Pest Management Association (NPMA) 

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M ETHYL


### B ROMIDE


### A LTERNATIVE 

### E CONOMIC 

### S UMMARY

percentage, SF is not technically feasible due to c old temperatures. Adding heat to increase the efficacy of SF is also not an econo mically feasible option.



### Sulfuryl Fluoride

Results of the assessment of using sulfuryl fluorid e 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 a re 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 tec hnically feasible only in facilities that do not prepare mixed products (e.g., cake mixes).Fumigatio n with sulfuryl fluoride at lower temperatures controlling all pest life stages is in feasible due to prohibitively high application rates and minimal efficacy.

Heat Treatment

Potential economic losses were estimated for the fo od-processing facilities that have not been converted to heat treatment. This analysis only co vers cases where heat treatment is technically feasible; it does not cover situations where heat w ould 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.USA CUN11 Post Harvest National Pest Management Association Page 10 of 11TABLE5.ANNUALECONOMICIMPACTS OFMETHYLBROMIDEALTERNATIVES FORNPMASTRUCTURESNPMA Structures(Spices & Food Processors)1UnitsMeBr2SF2Heat: 7oCHeat: 29 oCSF + 7oC HeatTotal Operating Costs$/yearnananananaTotal Fumigation/Heat Costs$/year$ 24,000.00$ 30,000.00$ 70,000.00$ 150,000.00$ 100,000.00Quantity of Fumigant(One treatment per year)kgs/facility5221,134nananaFumigant cost (i.e., gas)$/year$ 9,000.00$ 15,000.00nana$ 15,000.00Other fumigation costs(i.e., labor, equip., etc.)$/year$ 15,000.00$ 15,000.00$ 70,000.00$ 150,000.00$ 85,000.00Other Operating Costs$/yearnananananaTime Lostdays00010Total Loss (MeBr to alt)$/year$ -$ 6,000.00$ 46,000.00$ 126,000.00$ 76,000.00Average Facility Loss per KgMeBr Requested$/kg MBrequestedna$ 11.50$ 88.18$ 241.55$ 145.701Analysis for a 28,317 cubic meter (1,000,000 cubicfoot) facility2Temperature at 29 degrees CUSA CUN11 Post Harvest National Pest Management Ass ociation Page 11 of 11



### CITATIONS

Arthur, F. H., E. A. Jenson, and J. R. Nechols. 20 08. Esfenvalerate plus methoprene aerosol to control the Indianmeal moth. Presented at MBAO, Or lando, Fl. November 2008. Available at: http://mbao.org

Campbell, J.F. 2008. Evaluating Impact of Structu ral fumigations on pest populations. Presented at MBAO, Orlando, Fl. November 2008. Av ailable at: http://mbao.org

Phillips, Thomas W., Md. Mahbub Hasaan, M. Jamie Ai kins, 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 overc ome the egg-weakness of sulfuryl fluoride

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

Available at: http://mbao.org

Tsai, W-T., L. J. Mason, K. E. Ieleji, and D. E. Ma ier. 2008. Sulfuryl fluoride and methyl bromide fumigations in Midwestern US flour mills. Presented at MBAO, Orlando, Fl.

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