USA CUE15 Strawberry Replies to MBTOC March Page 1

NOMINATING PARTY: The United States of America

DATE: MARCH 27, 2013 

FILE NAME: USA CUE15 Strawberry Replies Final

BRIEF DESCRIPTIVE TITLE: Response to MBTOC March 7, 2013 Questions on 

Strawberry Fruit

SITE NAME (OPEN FIELD): Strawberry Fruit 

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Foreign Affairs Officer

Address: Office of Environmental Policy

U.S. Department of State

2201 C Street, N.W. Room 2726

Washington, D.C. 20520 U.S.A.

Telephone: (202) 647-3819

Fax: (202) 647-1052

E-mail: SanMartiniFM@state.gov

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Mark Hartman

Title: Acting 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) 308-0734

Fax: (703) 308-7042

E-mail: Hartman.Mark@epa.gov

MBTOC Question 1. In the CUN on page 15 it states that “Methyl bromide is not used on 

the majority of strawberry production fields (Table 2). Alternatives are effective and 

currently used in most of the growing areas (86.5%)”. Also in a paper of Mayfield & 

Norman (2012) it stated that “Alarming numbers in the CUNs sent to the Parties to the 

Montreal Protocol are not consistent with the success of California strawberry growers in 

aggregate as use of MeBr has been reduced. Nor are they consistent with basic economics. 

The ‘economic disruption’ standard of the CUE process was not intended to require the 

Parties to permit application of MeBr on new acreage to allow limitless expansion of a given 

industry using MeBr, and it is difficult to justify ongoing exemptions to support expansion 

rather than protect existing growers and growing regions. If all the new acres in production 

since 2005 are being managed profitably without MeBr, and existing acres are using less 

MeBr less often while overall and per acre yields and revenues rise steadily, it seems we have 

reached a point where alternatives are demonstrating successes for field strawberries in 

California”.
USA CUE15 Strawberry Replies to MBTOC March Page 2

Based on the above information, please, explain why the conclusion of the paper by Mayfield 

and Norman (2012) is not in agreement with the new CUN? 

U.S. Reply

While Mayfield and Norman (2012) pointed out that overall U.S. strawberry production 

has increased each year since 2004, our CUN noted (p 9) that the increase, at least in part, 

is due to the success of pest management and breeding programs that are a result of 

extensive research efforts to identify methyl bromide alternatives. The annual overall 

reduction in the methyl bromide nomination for California strawberries since 2004, 

suggests that the strategy of progressive reduction in methyl bromide allocation has been 

successful in enabling growers to reduce the aggregate use of methyl bromide in 

conjunction with other pest management methods for most strawberry production. 

Success of the methyl bromide phase-out for strawberry production depends on 

developing technically and economically feasible alternatives. 

The USG would like to emphasize that contrary to the statement by Mayfield and 

Norman, the USG does not, and never has, nominated “new” hectares of production. As 

MBTOC will note by reviewing historical nominations, nominated hectares have been 

calculated after accounting for ineligible “new” production land.

MBTOC highlighted a Mayfield and Norman statement: “If all the new acres in 

production since 2005 are being managed profitably without MeBr, and existing acres 

are using less MeBr less often while overall and per acre yields and revenues rise 

steadily, it seems we have reached a point where alternatives are demonstrating 

successes for field strawberries in California”.

Alternatives are “demonstrating successes” in some, or even many, situations, as can be 

seen in the reduction of methyl bromide use in California. However, for the nominated 

critical land where alternatives either cannot be used or have not acceptably managed 

Macrophomina and Fusarium, growers are at a distinct disadvantage that may not be 

obvious in state-wide or even county-wide production figures. While state-wide revenue 

may have increased over the years, for critical production land, overall costs to produce 

the crop have increased for all growers in general. 

It appears that the number of strawberry growers (based on dues paid to the California 

strawberry growers association) has declined from 470 in 2008, to 370 in 2012, indicating 

that small-scale growers may be disproportionately affected by the changing market 

conditions.

The Mayfield and Norman conclusion may lead a reader to the misperception that since 

some land can produce fruit without methyl bromide, all land can do so. The CUN is 

specific to land (not “new” land) 1) where Macrophomina and Fusarium have not been 

acceptably controlled with alternative fumigant methods, 2) where a transition period is 

necessary to implement use of straight chloropicrin where it has not been used 

extensively, but where it might be a feasible alternative, and 3) where township caps on 

1,3-D adversely impact its use as an alternative.

MBTOC Question 2. On page 3 of the CUN application for 2015 it states that the critical 

need for methyl bromide is because of township caps on 1,3-D, a transition period for 
USA CUE15 Strawberry Replies to MBTOC March Page 3

broadcast 100% chloropicrin or where Macrophomina and Fusarium have not been 

acceptably controlled with alternative fumigants.

Could you please provide a breakdown of the relative proportion that each factor above 

contributes to the critical need for methyl bromide?

Could you please explain what transition period and technical expertise will be required for 

application of 100% chloropicrin and why a long period of transition is required? This 

product is applied effectively in other regions of the world and this and similar formulations 

have been applied in strawberry production in California already?

U.S. Reply

The CUN is based on a calculation of aggregate critical need for methyl bromide. The 

USG does not have precise figures associated with each category.

A transition period was determined to be critical to strawberry production based on the 

historical lack of use of 100% chloropicrin in California. Furthermore, the reregistration 

effort by the state of California is separate from the overall federal (EPA) label for 

chloropicrin. As discussed in the CUN (p 7), the California Department of Pesticide 

Regulation (Cal DPR) is currently reviewing the registration of chloropicrin and 1,3-D 

and should announce its recommendations in early 2013. Based on the Cal DPR review 

the use conditions for chloropicrin and 1,3-D (e.g. buffers, reentry intervals, tarps, use 

rate, etc.) could change before 2015. In addition, the 1,3-D review could lead to changes 

in how the 1,3-D township caps are calculated. The unknown timing and extent of any 

changes may affect the biological and economic transition to chloropicrin and may 

include such use changes as buffer zones, types of tarps, use rates, etc. A potential new 

set of regulations for California will require a period of transition to growers who would 

like to use straight chloropicrin.

Several incidences of exposure to chloropicrin are being investigated. It is unclear the 

extent of the problem, but the occurrences highlight the need for a transition period for 

some growers and applicators who have never fumigated with 100% chloropicrin. In 

addition, growers may experience overlapping restrictions on the use of alternatives (such 

as township caps on 1,3-D).

A transition to 100% chloropicrin will involve many hectares, many of which are located 

adjacent to residential areas. A transition period is necessary to accommodate both 

technical and regulatory requirements to insure worker and bystander safety and effective 

pest control.

MBTOC Question 3. MBTOC is aware of other formulations and mixtures which are 

performing well in research trials and which no discussion is made in the nomination. This 

includes Pic-Clor 80, Pic-Clor60 and metham sodium and Paladin and the use with or without 

barrier films. Could you please explain why no discussion is provided on these alternatives 

in the nomination?

U.S. Reply

The CUN discussed all registered and potential alternatives in Section 2 (pp 3-6). The 

CUN has generally discussed alternatives in terms of active ingredients, rather than 

products, thus, we discuss the alternative 1,3-D/chloropicrin primarily without regard to 

formulation. 
USA CUE15 Strawberry Replies to MBTOC March Page 4

The USG is aware that efficacy may vary depending on formulation, but as formulations 

and products change with some frequency, it would be difficult to describe all 

formulations. Consequently, the CUN discussions are generally limited to active 

ingredients.

Specifically, the CUN did describe the economic situation with the use of Pic-Clor 60 

(see Table 4, p 10). 

There are no registrations for Pic-Clor 80 by national (EPA) or California (Cal DPR) 

regulatory authorities. Dimethyl disulfide (DMDS, Paladin®) is currently not registered 

for use in California, except with special experimental use labels for research field trials.

Its potential date of registration is unknown.

MBTOC Question 4. On page 3, specialists estimate that losses to Macrophomina and 

Fusarium may be 5% but no data is provided. Could you please provide further evidence of 

this information?

U.S. Reply

The 5% loss was an estimate based on grower information provided by the California 

Strawberry Commission. Two real-world examples of losses are provided below.

A grower (E. Terry) had severe Macrophomina and Fusarium in 2009, on a 14 acre block 

on his Ventura ranch (Table 1, below). He estimated that his net loss was $9,250 per acre 

for that block which had been treated for several years with drip applications of InlineTM 

(61% 1,3-dichloropropene plus 33% chloropicrin) with a total loss of $166,500. 

A grower (B. Reiman) had severe Fusarium at a summer plant field of strawberries in 

Ventura in 2012 (Table 1, below). He treated the 37 acre field with 200 lbs/acre

chloropicrin by drip. Losses to Fusarium were so severe in that field that he disked up 14 

acres before harvest and lost an average of $9,318 per acre with a total loss of $344,758.
USA CUE15 Strawberry Replies to MBTOC March Page 5

Table 1. Estimated losses due to soilborne diseases in methyl bromide-alternative treated ground, CSC 

March 2013

Summer Planting 2012 Fall planting 2009

Fusarium Fusarium and 

Macrophomina

Grower Bill Reiman/Ventura Edgar Terry/Ventura

Acres Planted 37 18

Varieties 3352 & 4053 ?

Fumigation Method Drip applied Chloropicrin Inline

Growing Costs incl. Admin/acre $21,277.00 $22,000.00

Harvest costs per box $4.25 $3.25

Box/cooling/marketing cost/box $3.00

Total Boxes harvested 61,457 54,000

Total acres harvested 23 18

Acres disked under due to Fusarium 14 0

Average return to ranch per box $11.45 $10.50

Total Revenue $703,682.65 $567,000.00

Total Grow and Admin costs $787,249.00 $396,000.00

Total Harvest Costs $261,192.25 $337,500.00

Total Net Profit/Loss $(344,758.60) $(166,500.00)

loss per acre with soilborne disease $ (9,317.80) $(9,250.00)

MBTOC Question 5. On page 3 of the nomination it describes that Koike reports that plant 

collapse due to Macrophomina and Fusarium has occurred in virtually all fields that have 

switched from methyl bromide and chloropicrin to alternative fumigant products and bed 

fumigation practices. Could you please provide data and any further evidence of the surveys 

conducted by Koike and the history of fumigation (including the method of fumigation that 

was used in the 3 years prior to the disease development? Please clearly specify the dosage 

rates of the fumigant/s, if the treatment was drip or shank applied and the treatment broadcast 

or strip treated. 

Could you please provide a copy of the publication by Koike et al. 2011?

U.S. Reply

The description was based on numerous diseased plant samples processed by the 

University of California Cooperative Extension Plant Diagnostic Laboratory in Salinas, 

California. After further investigation, it appears that this statement in the Koike study is 

based on observations and discussions with a number of local growers who reported the 

problem rather than on research or a statistical survey. The researchers, in cooperation 

with the California Strawberry Commission, are gathering data to help determine if this 

observation is correlated with the use of alternative fumigants.

A copy of Koike et al., 2011 will be provided.
USA CUE15 Strawberry Replies to MBTOC March Page 6

MBTOC Question 6. Noling and Cody (2012 a and b) report that a number of fumigants 

which when shank applied perform equally as well as methyl bromide when strip applied. 

No further discussion is provided on this information and its relevance to California. Could 

you please explain?

U.S. Reply

As noted in the CUN (p 4), the possible difference in efficacy between broadcast versus 

strip applications of 1,3-D are unclear for California production conditions. Different 

soil-type, season of production and soilborne problems in California compared to Florida 

make bed treatment less likely to succeed. Moreover, broadcast 1,3-D will likely change 

the calculation of township cap allowances due to an increased per hectare use of 1,3-D. 

While the example of studies from Florida (Noling and Cody [2012 a and b]) indicates

that in some situations application methods might affect efficacy, the Florida case may or 

may not be relevant to California conditions. California researchers are planning further 

evaluation of application methods.

MBTOC Question 7. On page 7 the CUN states that ‘Currently all of the county agricultural 

commissions...now have a process in place to allow the use of chloropicrin at rates up to 392 

kg/ha (350 lbs/acre)’. Has the adoption of this rate been considered in the calculation of the 

critical need for the nominated amount of methyl bromide and if so how?

U.S. Reply

Yes, the adoption of the higher rate was considered in the calculation of the nominated 

amount of methyl bromide. Hectares that could effectively use the higher rate of 

chloropicrin as an alternative were subtracted from the critical area. Please also see the 

reply to question 2.

MBTOC Question 8. On page 7, the text explains that Cal DPR is currently reviewing the 

registration of chloropicrin and 1,3-D. When is the outcome of this review anticipated?

U.S. Reply

The final action on chloropicrin by Cal DPR will not take place for several months 

(December, 2013 at the earliest for chloropicrin) and not until a public comment period 

has occurred, which has yet to be announced.

MBTOC Question 9. Table 4 on page 10 shows that 3 alternatives provide net revenues 

greater than methyl bromide, yet little discussion is provided on these products (steam, Pic at 

300lbs/acre and Pic-Clor 60). Could you please explain or provide further details. 

U.S. Reply

The CUN (pp 3-6) discussed 1,3-D/chloropicrin, chloropicrin, metam-sodium, steam, 

anaerobic soil disinfestations, resistant cultivars, and substrate systems. The CUN did not 

make an economic argument for the critical need for methyl bromide; rather, the 

economic assessment was included as part of a comprehensive evaluation that was 

conducted to evaluate the overall claim of a critical need for methyl bromide for a portion 

of the strawberry fruit industry. The CUN describes technical aspects in strawberry 

production that have a critical need for methyl bromide. 

a. Where Macrophomina and Fusarium have not been acceptably controlled with 

alternative fumigant methods, 
USA CUE15 Strawberry Replies to MBTOC March Page 7

b. Where a transition period is necessary to implement use of straight chloropicrin 

where it has not been used extensively, but where it might be a feasible 

alternative, and 

c. Where township caps on 1,3-D adversely impact its use as an alternative.

MBTOC Question 10. Has an economic study been conducted using the maximum rate of 

chloropicrin at 392kg/ha?

U.S. Reply

An updated assessment for the 392 kg/ha rate of chloropicrin has been conducted. Table 

4 of the CUN (p 10) presented information with 300 lb/acre (336 kg/ha). The additional 

56 kg/ha of the higher rate of chloropicrin (392 kg-336 kg) reduced profit margins from 

6% to 5%, due to the additional cost of material. The CUN considered that 336 kg/ha 

would be effective where the material could be used, thus, 392 kg/ha is also considered 

effective where it can be used. As noted, the CUN is for the portion of production land 

where 100% chloropicrin is not used and where it might be used after a transition period.

MBTOC Question 11. Is it possible to provide an expected timeline for MeBr phase out for 

this particular crop?

U.S. Reply

A definitive timeline will be difficult since, as noted previously, Cal DPR is reevaluating 

fumigants that the USG has considered feasible alternatives. The USG notes, however, 

that due to extensive work by California growers, extension specialists, and researchers 

the critical amount of methyl bromide has decreased annually.

MBTOC Question 12. As several references are difficult to obtain, is it possible to provide 

a full list of references on a disk or USB?

U.S. Reply

References will be provided in an acceptable format.