United Nations Environment Programme

Methyl Bromide Technical Options Committee

 Structures and Commodities (SC)

 

 MBTOC Co-Chair:

 

 Ms Michelle Marcotte (Canada) email: marcotteconsulting@cogeco.ca

February 12, 2013

Mr Marco Gonzalez

Executive Secretary

UNEP Ozone Secretariat

and

Dr. Federico San Martini, Ph.D.

Foreign Affairs Officer

Office of Environmental Policy

U.S. Department of State

2201 C Street, N.W. Room 2657

Washington, D.C. 20520 

U.S.A.

E-mail: SanMartiniFM@state.gov

Dear Marco and Dear Frederico San Martini and colleagues,

 

MBTOC SC has completed its first level review of the US dates CUN. During this period some 

questions have been raised as described below. Part of the reason that MBTOC corresponds 

with Parties prior to making its recommendation is to ensure transparency and ensure the Party 

understands our trend of thought ahead of our report. Our letters are the result of a consensus 

process.

All sections of MBTOC will meet in London in early April and if you could deliver the answers to 

these questions ahead of that meeting we would appreciate it.

If any of our questions are unclear, or if you would like further information, please contact me. I 

will then confer with my colleagues and prepare an answer for you. 

Questions concerning moisture content of dates:

Information concerning the moisture content of dates, and also how to stabilize it, is key to the 

quality of dates during a fumigation, and of the choice of a fumigant. Understanding the moisture 

content of dates leads to an understanding of the true restriction to fumigation with phosphine. 

That is why we really need to understand it thoroughly. 

What is the range and the maximum Equilibrium Relative Humidity (e.r.h) or moisture content 

(m.c.) acceptable at harvest intake? Does e.r.h or m.c. vary over the harvest period and if so what 

are the contributing factors to this variation? 

Aerating the freshly harvested dates to even out differences in moisture content would avoid 

fumigation and allow phosphine to be used (with its longer treatment time). Do the dates ever 

have to be artificially dried to make them dry enough for ambient air storage? 
Questions concerning comparative volumes of product to be MB treated:

EPA proposed rule (Federal Register, 77 FR 74435, December 14, 2012) describes the Limiting 

Critical Conditions for methyl bromide use in 2013. These conditions report, among other things, 

that MB use for dates is only for California dates in Riverside County. We are wondering if it is 

this Limiting Critical Condition which explains the variance we see in data on total date harvest.

For example, the CUN (Table 4) reports total date harvest of 19,396 tonnes. But, recently 

released data by USDA-NASS gives 2012 California production as 31,100 tons (28,213 MT). 

Please provide the total harvest of dates for the entire State and/or county that is included in this 

CUN.

To assist you to understand the reasoning for this request, the CUN requests MB for 15,500 m3 

of dates, which MBTOC has to convert to tonnes and then determine the percentage of the total 

date harvest for which MB treatment is requested. 

Converting dates from m3 to tonnage requires knowledge of the date storage bins and the 

stowage factors. The CUN requests MB for 15,500 cu m of dates. At this point, MBTOC 

has estimated 400kg of dates in the storage boxes (assumed 1 m3 capacity) and assuming 

'under tarp' fumigation. With a 20% allowance for extra fumigated space for stacking and 

dunnage, 15,500 m3 of dates, as handled, is equivalent to about 5000 tonnes of dates. We 

believe the plastic boxes used for field storage of California dates may allow for more weight per 

cu m than does the wooden boxes used for other dried fruit in California, but seek confirmation of 

this.

Sources in California can supply more accurate figures and if so, we would appreciate receiving 

them. 

Questions concerning the impact of market timing on fumigation needs:

The CUN notes, ‘Commodity fumigation with methyl bromide is used primarily at harvest time, 

when rapid fumigation is needed to keep up with the large volumes of incoming commodities that 

need to be shipped to market in three days for maximum value.’

By this statement does the US actually mean that some portion of the harvest has to be quickly 

fumigated to get their crop to market within three days to achieve premium prices? When does 

the need for rapid marketing occur?

We ask this because other sources do not indicate a need for immediate marketing of dates, or a 

short market window. 

We are basing our statement on the following sources:

“Harvest Season: October 1 – December 15. This is reported in California Agricultural Statistics 

2011 Crop Year. Issued by USDA National Agricultural Statistics Service, California Field Office, 

October 31, 2012. USDA-NASS also reported the following in 2006 for California dates:

Usual Harvesting Dates

Begins Aug 15

Most Active Oct1 – Dec 15

Ends Mar 1

Usual Marketing Dates

Begins Aug 15

Most Active Oct 1 – Dec 20

Ends Mar 15

Source: Fruits and Tree Nuts: Blooming, Harvesting, and Marketing Dates, Agriculture

Handbook Number 729. USDA, National Agricultural Statistics Service. December 2006. 

Marketing Year: October 1 through September 30 of the following year. This is established by 

the California Date Commission Law and is consistent with Federal Marketing Order 987: 

California Dates.”
Therefore we ask for more detailed substantiation of this CUN statement, since it forms a key 

basis for the CUN.

Questions concerning treatment parameters:

Is fumigation with MB restricted to a particular time of year and/or variety?

What is the availability of, and size of, fixed fumigation structures?

The CUN notes that phosphine treatment takes longer than sulfuryl fluoride to fumigate dates (5 

to 7 days), and during this time the dates ferment, resulting in an off-flavor and an unmarketable 

product. MBTOC needs to know the moisture content of the dates because it seems possible that 

the aspect of this statement pertaining to potential damage done by longer fumigation is incorrect. 

A visit by MBTOC members and Dr. Walse (USDA) observed that the California date processor 

kept dates under MB fumigation for at least for 15 days. 

Questions concerning current and planned research on pest control for dates:

The CUN provides a bit of an indication of the planned research on MB alternatives for dates. 

However, we believe the CUN was written several months ago. At this time is it possible for the 

US to provide an update and more detail on the research being conducted this year and planned 

for next year on MB alternatives for dates?

Questions on fact checking - economics:

The table on page 4 of the CUN indicates a gross revenue of >US$32 million per tonne. This 

seems unlikely. We note that the ‘Non-citrus Fruits and Nuts 2012 Preliminary Summary 

(January 2013). USDA’s National Agricultural Statistics Service’ reports a 2011 price per tonne 

as US$1320 and a 2112 price per tonne of US$1340. Could the US please provide a correct 

number? 

Thank you for your consideration of our information request.

Yours sincerely,

Michelle Marcotte

MBTOC Co-Chair