Filename USA CUE14 MBTOC REPLIES PART II 08

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NOMINATING PARTY : The United States of America

DATE: AUGUST 20 , 201 2

FILE NAME: USA CUE14 MBTOC REPLIES PART II 08

- 2012

BRIEF DESCRIPTIVE TI TLE : Methyl Bromide Critical Use Nomination for 2014, U.S. Replies to MBTOC Report (Submitted

in 2012 for 2014 Use Season)

CROP NAME (OPEN FIEL D OR PROTECTED): Dried Fruit Products

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Policy Advisor

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

- 3819

Fax: (202) 647

- 1052

E

- mail: SanMartiniFM@state.gov

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS: 

### Contact/Expert Person: Teung Chi n , Ph.D.

Title:

Address: U.S. Department of Agriculture Office of Pest Management Policy

1400 Ind e pendence Ave., S.W. Room 3871 (Mail Stop 0314) Washington DC, 20250 U.S.A. Telephone: (202) 222

- 8619

Fax:

E

- mail: teung.chin@ars.usda.gov



## Dried Fruit Products

MBTOC (TEAP 2012) recommends 0.487 tonnes for use in dried fruit and walnuts in 2014,

a 34 % decrease of the Party’s nominated amount. The recommendation is disaggregated into the following amounts: California walnuts 0.161 tonnes; dates 0 .325 tonnes and dried plum

board 0.001 tonne.



## U.S. Reply
As explained in more detail below, w e believe additional time is necessary for the industry to transition to the most appropriate alternatives in this sector. The United States is thereforeFilename USA CUE14 MBTOC REPLIES PART II 08

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req uesting that MBTOC recommend 254 kg, the full amount nominated for dried fruit (dried plums, figs, and raisins) in the 2014 U.S. critical use nomination. The U

. S

. response to
MBTOC’s suggested alternatives are discussed individually below

.

Alternative #1

– Phosphine

Because r apid throughput is needed, particularly during peak harvest periods to feed the processing lines,

S ulfuryl F louride (SF) or M ethyl B romide (MB) are the fumigants of choice due to their shorter fumigation times. The industry has a lready transitioned as much as it can to SF and phosphine. However, research by Walse et al. (2009) indicate s that under low temperatures and current label rates,

the efficacy of SF is inadequate against the eggs of the major stored product pests (dried fruit beetle, red flour beetle, and Indianmeal moth). Control of the egg stages of target pests is imperative. The USDA Agricultural Research Service is currently undertaking research to enhance the efficacy of SF on eggs using propylene oxide. The fac ilities that still require methyl bromide need more time for their transition as they are waiting for the outcome of this research , including a possible need for a regulatory review by

EPA

. A transition to SF , if egg control could be improved, rather than phosphine would allow the remaining facilities to avoid the need to purchase the chambers and other equipment retrofits needed for phosphine fumigation

Alternative # 2 Cold S torage Following H eat D rying to P revent R einfestation

.

T otal new cold storage construction cost s for prunes, raisins and figs would be substantial , even assuming the producer would not have to incur costs in acquiring land for that purpose. Cold storage also involves reoccurring costs related to consumption of electricity for cool ing and maintenance in addition to those

fixed construction costs

. Because of the need for staff to continually enter and exit the storage area throughout the shift (with two to three shifts per day) to feed the processing line

, stored product insects

can not be totally prevented were cold storage to be constructed

. Furthermore, e ven with cold storage, methy l bromide is needed because of the ineffectiveness of SF at cooler temperatures.

Alternative # 3

- Propylene Oxide

The current p ropylene oxide (PPO) label limits the size of chambers to 10,000 cubic feet, a size impractical for the tons of dried fruit involved. In addition, there is a 200 foot buffer requirement for use

of PPO in 10,000 cubic foot chambers

, which would negatively impact ongoing plant operations

. Furthermore, the label requirement 1 f or 8% PPO includes a minimum heat treatment of 100 o F (37.8 o C),

which would be costly.

PPO is more effective on the egg stage of many insect pest s of dried fruit than SF

. A s noted above, a

c ombination t

reatment of PPO and s ulfuryl fluoride is being researched by the USDA Agricultural

Research Service that could minimize disruption to the current dried fruit processing flow and retain current processing equipment without major modification

. This effort is being undertaken to establish an effective treatment using SF and PPO against eggs at 20 o C and under

, i.e

., during the cooler season. Changes in use patterns such as a fumigation with a combination of SF plus PPO or the use of PPO in larger chambers cou ld require regulatory review by the EPA to allow for label revisions.

1 http://www.epa.gov/pesticides/chem_search/ppls/047870

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Alternative # 4 Sulfuryl Fluoride (SF)

Sulfuryl fluoride (SF) is currently used on dried fruits and is effective during the warmer months

. However, at the current label rate, SF e xerts in adequate control at cooler temperatures (20 o C and under) during the cooler months against stored product pests such as the d ried f ruit b eetle. This is confirmed in

the Technology and Economic Assessment Panel ’s 201 1 Progress report, which notes that “ the target dosage rate of SF, typically a ct

- product of 1500 g h m

- 3 over 24h at 26 ° C, is insufficient to fully control eggs of some common species of stored product insect pests ” and that the “ temperature range of the current Fumiguide is limited t o temperatures above 20°C and below 40°C.” ( United Nations Environment Programme (2011). Special review on achieving control of pest eggs by sulfuryl fluoride

. In Report of the Technology and Economic Assessment Panel. Pages 109 and 112

. http://ozone.unep.org/Assessment_Panels/TEAP/Reports/TEAP_Reports/TEAP_Progress_Report_May_2 011.pdf ) Research is ongoing on how to apply lethal dosages to the insect eggs at lower temperature s

. The costs of r aising the temperature in the storage warehouses to allow for more effective treat ment of

dried fruit with SF under the current conditions would be expensive and additional time would be required to gai n experience with their use and to resolve logistical issues

.

Alternative # 5 C arbon D ioxide U nder P ressure

The d ried fruit industry ha s previously evaluate d the use of controlled atmosphere (CA) storage

. While an efficacious treatment

, the additional cost s render it no t economically viable. According to Dr. James Thompson, Agricultural Engineering

, UC Davis, construction costs for CA are 10% more than

conventional Normal Atmospheric Pressure ( NAP ) storage. Newer storage chambers could be retrofitted

at the additional costs but most of the industry’s chambers are too old to be retrofitted.

Alternative # 6 Aerosol Applications in Sites Where Products Are Processed, Bagged, and Stored.

The dried fruit industry has been using aerosol applications to control insects for several years. Consequently, the numbers of fumigations required have been reduced as a result of aerosol use in conjunction with pheromones and sanitation. For example, dried p lums now typically require only one fumigation per ye ar instead for three. Aerosol applications are effective to keep flying adult populations

down but are unable to penetrate into the centers of bins

, which is problematic. Aerosol applications of pyrethroids are applied when flying insects are detected , t ypically using p heromone traps. A m ating disruption pheromone for Indian Meal moth is also used but there is none currently registered for dried

fruit beetle or red flour beetle. In addition, producers follow good hygiene practices to reduce the risk of infestation. (For example, it is common practice to clean floors at least once a week with commercial floor cleaners.)

Summary of Research Projects and Results

Johnston, J.A.; Walse, S.S; Gerik, J.S. 2012. Status of Alternatives for Methyl Bromide in th e United

States. Outlooks on Pest Management. 2012, 23(2), 53

- 56.

Walse, S.S.; Tebbets, S.; Leesch, J.G. Multifactorial exploration of the insecticidal efficacy and degradation of sulfuryl fluoride in stored walnuts. Journal of Stored Product Research (i n press)

BRIEF The navel orangeworm (NOW), Amyelois transitella, is a pest of concern to countries that import inshell walnuts from California. The individual and interactive effect(s) of pressure, temperature, time, and sulfuryl fluoride (SF) dose on NOW egg mortality and residue off

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walnuts are quantitatively delineated; a multifactorial experiment was generated and the results were analyzed using Design Expert 7.0 (Stat

- Ease, Inc.). The mathematical models generated in this study can be used as predictive tool for ensuring that targeted mortality and minimum residues levels are achieved during individual fumigation events. This should be particularly useful to industry when “quarantine” control of insects (i.e., 99.9986% mortality) and MRL verification is required to move commodity through foreign trade and marketing channels.

Walse, S.S.; Tebbets, S.; Leesch, J.G. 2012. Ovicidal efficacy of sulfuryl fluoride to insect pests of

California dried fruit and nuts. California Agriculture (in press)

BRIEF Amyelois transitells (navel orangeworm), plodia interpunctella (Hübner)(indianmeal moth), Tribolium confusum (red flour beetle), and Carpophilus hemipterus (dried fruit beetle) were fumigated at 60 F for 24 h under normal atmospheric pressures as well as for 4 hours at a reduced pressure of 100 mmHg. Dose

- mortality responses for each species under both scenarios are presented and discussed in the context of the technical efficacy of sulfuryl fluoride as a postharve st methyl bromide alternative.

Walse, S.S; Hurley, M.; Wample, R.L.; Hartsell, P.; Pena, B.; Muhareb, J.; 2012. Efficacy of sulfuryl fluoride, propylene oxide and carbon dioxide fumigant mixture toward red flour beetle, T. castaneum. Journal of Stored Pr oduct Research (in press)

BRIEF A practical strategy is presented for overcoming the ovicidal deficiency of Sulfuryl Fluoride in stored product disinfestations. Sulfuryl Fluoride (SF), Propylene Oxide(PPO), and Carbon Dioxide(CO 2 ) mixtures were used for t he control of T. castaneum eggs and ovicidal activity was directly compared to fumigation with methyl bromide and sulfuryl fluoride alone.

Phillips, T., E. Thoms, J. DeMark, and S. Walse. 2012. Fumigation, Chapter 14. In Stored Product

Protection. KState Research and Extension publication S156. ( In press).

Hall, W.; Walse, S.S.; ( 2011 ) The capture and destruction of methyl bromide vapors following postharvest fumigation, Proceedings of Methyl Bromide Alternatives and Emissions

. Summary

a vailable at: http://mbao.org/2011/Proceedings/55HallW.pdf