## METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST -- COMMODITIES

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN12 POST HAVEST USE FOR COMMODITIES

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Post Harvest Use on Commodities (Submitted in 2010 for 2012 Use Season)

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF

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 ( KILOGRAMS )

2012 4,907

(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: John Thompson

Title: Division Director Address: Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2657 Washington, D.C. 20520

U.S.A. Telephone: (202) 647-9799 Fax: (202) 647-5947

E-mail: Thompsonje2@state.gov

Following the requirements of Decision IX/6 paragraph (a )(1) The 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 CUN12 POST HARVEST COMMODITIES 1CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger

Title: Division Director 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 CUN12 POST HARVEST: COMMODITIES

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 CUN12 POST HARVEST: COMMODITIES

* Identical to paper documents

USA CUN12 POST HARVEST COMMODITIES 2

## METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST -- COMMODITIES

1. SUMMARY OF NEED FOR METHYL BROMIDE

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. Methyl bromide is also used in situations requ iring rapid fumigation prior to shipping.

T ABLE 2. N OMINATION A MOUNT

California Dried

Plum Board California Walnut

Commission California Date

Commission Sector Total /
Average

Quantity Requested for 2011: Amount (kgs) 6,266 1,170 2,009 9,445

Quantity Recommended by

MBTOC/TEAP for 2011 : Amount (kgs) 3,317 620 1,063 5,000

Amount (kgs) 3,317 620 1,063 5,000

Volume (1000 m 3 ) 392 130 97 619

Rate 8 5 11 8

Transition from 2011 Baseline Adjusted Value Percentage (%) 0% 15% 0% -2%

Amount (kgs) 

### 3,317 527 1,063 4,907

Volume (1000 m 3 ) 138 12 51 201

Rate 24 45 21 24 Quantity Required for

2012 Nomination: Quantity Approved by Parties for

2011: SECTOR COMMODITIES



### 2. SUMMARIZE WHY KEY ALTE RNATIVES ARE NOT FEASIBLE

This sector includes walnut, dried fruit (prunes, raisins, figs), a nd dates, all of which are subject to infestation by several insect pe sts. Since infestation begins in the field, methyl bromide is used to rapidly fumigate harvested commodities on arrival at processing plants on a daily basis. Most fumigation occurs over several weeks, dur ing the peak production season, as the bulk of

the harvest moves from the field into storage and shi pping channels. Upon arrival from the field, each load is fumigated with methyl bromide in preparation for shipment to national and international markets. Any one load of comm odities is fumigated with methyl bromide only

once.

Research with sulfuryl fluoride ( SF) indicates that this fumigant is a potential methyl bromide alternative for walnuts, provided fumigation occurs at temperatures above 70 oF. Recent studies have shown that under vacuum or atmospheric c onditions, SF is effective against adult, pupal, and larval stages of insects infesting walnuts. The ovicidal efficacy of SF, however, exhibits a marked temperature dependence, making it less effec tive against the egg stages of at least four insect pests of dried fruit and nuts, at maximum label rates an d temperatures below 70 oF.

USA CUN12 POST HARVEST COMMODITIES 3

### Walnuts - Preliminary tests show that sulfuryl fluoride fumigation is comparable to methyl bromide fumigation in its ability to kill diapausing larvae of codling moth, Cydia pomonella

, inside walnuts. While codling moth eggs are so mewhat more tolerant than larvae to sulfuryl fluoride fumigation, they do not occur naturally on walnuts at the time of harvest. The navel

orangeworm, Amyelois transitella , is primarily a scavenger, but w ill also infest walnuts after hull split, especially in areas that support high orangeworm populations. Occasionally, larvae emerging from eggs laid directly on walnuts shor tly before harvest may penetrate and infest the nutmeat through cracks in the hul l. Although insect eggs are relatively more tolerant of fumigants than other life stages , sulfuryl fluoride fumigation is lethal to three-day navel orangeworm eggs when used at the rate of approximately 56.5 mg/L (3.5 lb/1,000 cubic feet) for 24 hours, at normal atmospheric pressure.

The applicants indicate that USDA/ARS in Parlier, California has shown th at SF does not readily kill egg stages of navel orangeworm or the eggs of several stored product insects at temperatures below 70 °F at or below maximum label rates. The applicants further observe that the walnut industry fumigates during 6 months of the year at or below 50 °F and provide supporting temperature data for the San Joaquin and Sacram ento Valleys of California. The applicants

believe that further research is needed on the ovicidal efficacy of SF at temperatures below 70 °F, as well as on the ovicidal efficacy of propylene oxide/SF combinations.

Dates - Methyl bromide is used primarily to co ntrol the carob moth and other insects infesting dates. Sulfuryl fluoride is currently labeled fo r use on dried dates, but most dates grown in the

California are harvested fresh. The California Da te Commission reports that it is currently testing the efficacy of sulfuryl fluoride on dates, with preliminary resu lts showing less than adequate egg kill, even when the amount used is twice that needed for a comparable methyl bromide fumigation.

Dried Fruit – SF is currently labeled for use on dried fruit for control of several insects. However, recent USDA research results presen ted at the 2009 MBAO m eeting, indicate that under low temperatures and current label rates the ovicidal efficacy of SF is inadequate against several dried fruit pests.

The potential use of sulfuryl fluoride for commod ity fumigation is unrelated to the use of this chemical for structure fumigation. In the fist case, it is the commodities themselves that are fumigated, only once, and just before being shippe d to their intended mark ets. In the second, it is a storage or food processing faci lity (i.e. a building) that is fu migated periodically, as needed

3. SUMMARY OF RECENT RESEARCH

Sulfuryl fluoride

Walnuts

Quick turn-around time for walnuts at harvest ti me is the primary justification for methyl bromide use in this sector. Vacuum fumigati on with methyl bromide may take 4-6 hours and atmospheric fumigation approximately 24 hours. The methyl bromide us e rate for this sector is 3

USA CUN12 POST HARVEST COMMODITIES 4

### lb/1,000 cubic feet. Phosphine gas fumigation take s approximately three days and is being used to fumigate walnuts in storage.

Sulfuryl fluoride has been shown to be effective against the adult, pupal, and larval stages of several insect pests of stored products, although somewhat less effective against the egg stage (Fields and White, 2002, Schneider et al ., 2003). Preliminary tests s how that sulfuryl fluoride fumigation is comparable to methyl bromide fumigation in its ability to kill diapausing larvae of codling moth, Cydia pomonella , inside walnuts (Leesch, undate d). Methyl bromide fumigation of in-shell walnuts has targeted primarily diapau sing codling moth larva because this is the most tolerant life stage that may infest the nut at ha rvest. Data recently submitted to EPA by Dow AgroSciences (Muhareb and Hartsell, undated) in dicate that vacuum fumi gation with sulfuryl

fluoride for four hours is effectiv e against diapausing codling moth larvae at rates of 25 mg/L (1.5 lb/1,000 cubic feet), at 15.6oC (60.1oF) and 17-20 mg/L ( 1.06 - 1.25 lb/1,000 cubic feet), at 25oC (77.0oF). While codling moth eggs are somewhat more tole rant than larvae to sulfuryl fluoride fumigation, they do not occur naturally on walnuts at the time of harvest (Wood, 1999; Zettler and Leesch, 2000; Ze ttler and Gill, undated).

The navel orangeworm, Amyelois transitella , is primarily a scavenger, but will also infest walnuts after hull split, esp ecially in areas that support high orangeworm populations. Occasionally, larvae emerging from eggs laid directly on walnut s shortly before harvest may penetrate and infest the nutmeat through cracks in the hull. A lthough insect eggs are relatively more tolerant of fumigants than other life stages , sulfuryl fluoride fumi gation has been shown to be lethal to three-day navel orangeworm eggs wh en used at the rate of approximately 56.5 mg/L (3.5 lb/1,000 cubic feet) for 24 hours, at normal atmo spheric pressure (Zettler and Gill, undated). USDA/ARS researchers plan to continue testing the efficacy and practicality of using sulfuryl fluoride, relative to methyl bromide, to contro l post-harvest pests of nuts and dried fruit. Sulfuryl fluoride thus appears to be an effective methyl bromide alternative for in-shell walnuts.

Dates

Methyl bromide is used to rapidly fumigate California dates at harvest time, when up to a million pounds per day are being harvested within a relatively tight timefr ame during the fall. Methyl

bromide is used on dates at the rate of 1.5 lb /cubic feet. Although several insect may infest dates, the carob moth, Ectomyelois ceratoniae , is the more damaging species. The majority of dates grown in the United States are fresh dates and sulfuryl fluor ide is currently labeled for use on dried dates only. Still, the California Date Commission, in collaboration with Dow AgroSciences, is currently testing sulfuryl fluoride as a methyl bromide replacement. The California Date Commission reports that it is currently testing the efficacy of sulfuryl fluoride on dates, with preliminary results showing less than adequate egg kill, even when the amount used is twice that needed for a compar able methyl bromide fumigation.

Dried Fruit

A quick turn-around time for dried fruit at harvest time is the primary justif ication for the current use of methyl bromide, at the rate of 1.5 lb/1,000 cubic feet. Phosphine gas is used for stored dried fruit fumigation. Sulfuryl fluoride is curren tly labeled for use on dried fruit for control of

USA CUN12 POST HARVEST COMMODITIES 5

### Indianmeal moth, raisin moth, Cadra figulilella , dried fruit beetles, Carpophilus hemipterus

, navel orangeworm, and other inse cts that infest these commoditi es. However, citing research results presented at the 2009 MBAO meeting (Wal se et al., 2009), the California Dried Plum Board notes that under low temperatures and curren t label rates SF efficacy is inadequate against dried fruit beetle, red flour beetle, and Indi anmeal moth eggs. According to the Dow AgroSciences Fumiguide, sulfuryl fluoride is effec tive against the Indianmeal moth when used at a rate of approximately 21 mg/L (1.3 lb/1,000 cubi c feet) at normal atmo spheric pressure, for 24 hours, at 80 oF (26.6oF). However, the appli cant counters that commodities cannot always be treated at 80 oF and that egg st ages of target pests may not alwa ys be controlled even at these

temperatures.

Sulfuryl fluoride and propylene oxide

Wample (2006) is investigating the feasibility of using sequential or combined treatments with sulfuryl fluoride and propylene oxide (PPO) as a methyl bromide alternative for control of pest of stored products. It is anticipated that this line of research will determine if combinations of sulfuryl fluoride and PPO will be more efficaci ous and cost effective than methyl bromide, especially regarding the egg stag e of several economically important insects that infest tree nuts

and dried fruit.

Propylene Oxide

The U.S. EPA has established tolerances for pr opylene oxide on prunes, figs, and raisins. However, no comparative efficacy data for commodity fumigation seems to be currently

available.

Electromagnetic Energy

Ongoing research focusing on the technical feasibility of using radio frequency energy to control insect pests infesting in-shell walnut s is yielding promising results. Wang et al. (2006) have demonstrated that radio frequency treatment ofwalnuts can achieve 100% mortality of fifthinstar navel orangeworm larvae at an average walnut surface temperatur e of 60°C. However, 60° C for more than a few seconds may shorten the walnut shelf life.

Phosphine

Most commodity operations in the U.S. curre ntly use phosphine, alone and in combination, whenever feasible. Phosphine is suitable for fumigating commodities in storage, where fumigation time is not a factor, but it is generally t oo slow for treating la rge commodity volumes that need to be processed rapidly. Phosphine its also corrosive to certain metals, and this characteristic limits its use in some processing plants, especially those outfitted with electronic sorting and processing control equipment

4. ECONOMIC INFEASIBILITY OF ALTERNATIVES

T ABLE 3. E CONOMIC S UMMARY FOR EACH A LTERNATIVE

USA CUN12 POST HARVEST COMMODITIES 6M ETHYL B ROMIDE
A LTERNATIVE E CONOMIC S UMMARY

P HOSPHINE Economic losses from additional production downtimes due to longer fumigation time and from capital expenditures required to adopt an alternative. Economic losses due to downtime with phosphine are persistent.

S ULFURYL
F LUORIDE SF is a viable alternative to MeBr; costs per lb are comparable but application rates may be higher. Walnuts have inelastic demand; cost increase may be passed to consumers. Higher application rates will not change.



### A separate economic analysis of alternatives was conducted for each commodities sub-sector; in each case, phosphine was not found to be economical ly feasible for any of the commodities. For phosphine, production downtime was estimated to be 84 days per year on average; total capital expenditures for electrical modifications due to co rrosive nature of phosphine was assumed to be $215 per 1000 m 3 

### . The potential economic losses associated with the use of phosphine mainly originate from the cost of production delay. The estimated economic losses are shown in Tables E.1 through E.3. The estimated economic losses as a percentage of net revenue are over 100% for all CUE applicants in the commodity sector; that is, all applicants experience negative net revenues with use of phosphine.

Walnuts

The United States walnut industr y is concentrated in the stat e of California where production averaged 332,000 short tons of walnuts per year from 2003-2007. The largest processor is the Diamond Foods in Stockton, Califor nia that processes walnut harvest from 1,700 growers in California – accounting for approximately 50% of the post-harvest market. 1 

### The United States is one of the world’s larges t exporters of both shelled and in-shell walnuts. 2 

### Both production and sales peak in the fall in anticipation of the holiday season in December. Approximately 25 percent of walnuts are sold in the shell. 3 

### Those that are packed and shipped to European market within a couple of days of th e fumigation treatment qualify for quarantine exemptions for Methyl

Bromide use. Those that are sold domestica lly or not immediately shipped may apply for a CUE. The remaining 75 percent of walnuts are pr ocessed further to create a variety of packaged shelled products. These walnuts must be fumigate d before they are put in long-term storage or continue in the processing chain due to the key pests

. Phosphine can be used for the 75 percent of walnuts that are allocated for packaged shelled products because turnaround time is not

crucial.

The economic analysis is conducted on a per 1,000 cubic meter basis. Phosphine for the in-shell product results in down-time that leads to decreased prices after market window. Sulfuryl fluoride results in slightly higher costs due to hi gher application rates but there is no additional downtime. Prices per lb for methyl bromide and sulfuryl fluoride are comparable. Use of sulfuryl fluoride results in a 1.65% decrease in net revenue assuming that no costs are passed on to the consumer. Given that walnuts have a pr ice elasticity of demand of -0.28 (Russo et al., 2008), the additional cost of SF fumigant gas could be passed on to the consumer.

1 http://www.diamondfo od s.com/growers/

2 http://www.fas.u sda.gov/ htp/horticulture /Tree%20Nuts/Walnuts.pdf

3

USA CUN12 POST HARVEST COMMODITIES 7T ABLE 4: A NNUAL E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES F OR W ALNUT

Walnuts Units MB Phosphine SF

Total Commodity Treated kg 301,548,208 301,548,208 301,548,208

1,000 cubic meters treated kcm 941.25 941.25 941.25

Avg Mkt Price $/kg $ 1.89 $ 1.55 1 $ 1.89

Gross Revenue $/kcm $ 6,635.34 $ 497,440.98 $ 606,635.34

Total Operating Costs $/kcm $ 531,233.52 $ 529,714.86 $ 532,479.97

Total Fumigation Cost (1x) $/kcm $ 6,934.61 $ 5,200.96 2 $ 7,220.40

Kg Fumigant per kcm kg/kcm 48.06 na 56.06

Fumigant Cost (i.e., gas) $/kcm $ 1,697.93 na $ 1,980.86 Other fumigation costs (i.e., tarps, etc.) $/kcm $ 5,236.68 $ 5,200.96 $ 5,239.54

Other Operating Costs $/kcm $ 524,298.90 $ 524,513.89 $ 525,259.57

Net Revenue $/kcm $ 75,401.83 $ (32,273.88) $ 74,155.36

Time Lost days 0 84 0

Total Loss (MeBr to alt) $/kcm $ - $ 107,675.71 $ 1,246.46

Loss per Lb MeBr Requested $/kg

MeBr $ - $ 2,240.66 $ 25.94

Loss as % of GR with MeBr na 17.75% 0.21%

Loss as % of NR with MeBr na 142.80% 1.65%

1 Time lost with phosphine is assumed to result in a lower av erage market price for walnuts because less would be treated during peak prices, and increa sed supply at other times w ould depress off-peak prices.

2 Total fumigation costs; breakdown for gas and operating costs not available.



### Dried Fruit The dried fruit industry has alrea dy replaced a large portion of methyl bromide with phosphine in processing dried fruits.

As in previous analyses, EPA reviewers estimated that having to rely on phosphine alone would require an additional 84 days treatment time. In addition to the production loss, there are increased costs from using phosphine. Additiona l expenditures are required to adopt phosphine for accelerated replacement of plan t and electronic equipment due to the corrosive nature of phosphine. The net effect of production losses and cost increases is shown in Table 3.

T ABLE 5: A NNUAL E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES F OR D RIED F RUIT

Dried Fruit Units MB Phosphine SF

Kgs of commodity Treated kg 405,882,980 292,235,746 1 405,882,980

USA CUN12 POST HARVEST COMMODITIES 81,000 cubic meters treated kcm 1,266.92 912.18 1,266.92

Avg Mkt Price $/kg $ 1.17 $ 0.96 $ 1.17

Gross Revenue $/kcm $ 374,457.83 $ 307,055.42 $ 374,457.83

Total Operating Costs $/kcm na na na

Total Fumigation Costs $/kcm $ 446.75 $ 544.28 $ 542.87

Quantity of Fumigant per unit Kgs/kcm 24.03 na 40.05

Fumigant Cost (i.e., gas) $/kcm $ 144.17 $ 144.17 $ 240.28 Other fumigation costs (i.e., tarps, etc.) $/kcm $ 302.59 $ 302.59 $

302.59

Other Operating Costs $/kcm na $ 97.52 na

Time Lost days 0 84 0

Total Annual Loss (MeBr to alt) $/kcm $ - $ 67,499.93 $ 96.11

Annual Loss per Lb MeBr Requested $/kg MB requested $ - $ 2,809.26 $ 4.00

Loss as % of GR with MeBr na 18.03% 0.03%

1 Time lost with phosphine is assumed to result in a lower dried fruit produced overall resulting in lower gross revenues.



### Dates An economic analysis was not done for dates becaus e sulfuryl fluoride is la beled specifically for “dates, dried” and efficacy tests have not been conduc ted for this alternative.

USA CUN12 POST HARVEST COMMODITIES 9

## CITATIONS

Fields, P. and N. D. G. White. 2002. Alternativ es to methyl bromide treatments for storedproduct and quarantine insects. Annual Review of Entomology 47:331-59.

Leesch, J.G. undated. The use of 3 fumigants on walnuts to control diapausing codling moth larvae. USDA-ARS report. At: http://www.mbao.org/1999airc/76leesch.pdf

Muhareb, J. and P. Hatsell. undate d. Laboratory evaluation of the t oxicity of sulfur yl fluoride in vacuum fumigations for diapausi ng larvae of the codling moth, Cydia pomonella , and larvae of the navel orangeworm, Amyelois transitella , in plugged walnuts. Dow AgroSciences internal report.

Phillips, T., P. Bolin, and G. Mb ata. 2006. Vacuum for post harvest disinfestation of insects from

durable and fresh commodities. CSREES Funded Post-harvest project. At: http://www.oardc.ohio- state.edu/nc213/PR06.pdf

Russo, C., Green, R.D. & Howitt, R.E. “Estim ation of Supply and Demand Elasticities of California Commodities”. Department of Agricultural and Resource Economics University of California, Davis, Working Paper No. 08-001, June 2008.

Schneider, S.M., E.N. Rosskopf, J.G. Leesch, D.O. Chellemi, C.T. Bull, and M.Mazzola. 2003. United States Department of Agriculture – Agricultural Research Service research on alternatives to methyl bromide: pre-plant a nd post-harvest. Pest Manag. Sci. 59:814-826.

Walse, S.S., J.G. Leesch, and S. Tebbets. 2009. The ovicidal efficacy of sulfuryl fluoride on insect pests of dried fruit a nd nuts. USDA/ARS, San Joaqui n Valley Agricultural Sciences Center, Parlier, CA 93648.

Wample, R.L. 2006. Efficacy with the combinati on of sulfuryl fluoride and propylene oxide as replacement for methyl bromide fumigation of stored food product. CSREES Funded Postharvest project. At: http://cris.csr ees.usda.gov/cgibin/starfinder/0?path=icgpmbtli nk.txt&id=anon&pass=&search=CG=*-51102- *%20and%20gy%3e1999&format=WEBTITLESG

Wang, S., M. Monzon, J.A. Johnson, E.J. Mitcham, and J. Tang. 2007. Industrial-scale radio frequency treatments for insect control in wa lnuts II: Insect mortal ity and product quality.

Postharvest Biol Technol 45:247-253.

Wood, M. 1999. Walnut pests fo iled by fumigant, studi es show. News & Events, USDA/ARS.

At: http://ars.usda.gov /is/pr/1999/991105.htm

Zettler, J.L. and J.G. Leesch. 2000. Sulfur yl fluoride: A disinf estation treatment for walnuts and almonds. USDA/ARS. Vol. 6, No. 2. At: http://www.ars.usda.gov/is/np/mba/apr00/sulf.htm

USA CUN12 POST HARVEST COMMODITIES 10USA CUN12 POST HARVEST COMMODITIES 11 

### Zettler, J.L. and R.F. Gill. undated. Sulfur yl fluoride: A disinf estation treatment for walnuts and almonds. USDA/ARS report. At: http://mbao.org/1999airc/108zettl.pdf