## METHYL BROMIDE CRITICAL USE RENOMINATION FOR

POST-HARVEST USE TREATMEN T OF STRUCTURES – FOOD

PROCESSING PLANTS

NOMINATING PARTY: The United States of America

FILE NAME : USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING

PLANTS

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Post Harvest Use on Structures -- Food Processing Plants (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 135,299

(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 subm itted in this format, TEAP and MB TOC 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 origin al nomination. As this earlier information is retained by MBTOC, a Pa rty need not re-submit th at 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 2658 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 pa ragraph (a)(1) 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

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 1Signature Name Date

Title:

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

C ontact/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 STRUCTURES - FOOD PROCESSING

PLANTS

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 STRUCTURES - FOOD PROCESSING

PLANTS

* Identical to paper documents

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 2

## METHYL BROMIDE CRITICAL USE RENOMINATION FOR

POST-HARVEST USE TREATMEN T OF STRUCTURES – FOOD

PROCESSING PLANTS

STRUCTURES

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL USE (e.g. changes to requested exemption quantities, successful trialling or commerci alisation of alternatives, etc.)

Food processing facilities in the United States have reduced the number of methyl bromide fumigations by incorporating a variet y of different techniques to cont rol pests. The most critical strategy implemented is IPM, especially sani tation, and equipment design modifications to enable cleaning and inspection in all areas of a facility. Facilities are now being monitored for pest populations, using visual insp ections, pheromone traps, light tr aps, and electrocution traps. When insect pests are found, facili ties will attempt to contain the infestation with treatments of low volatility pesticides applied to both surfaces and cracks and crevices ; spot treatments with heat or phosphine will be used in areas that ar e suitable. Incoming ingr edients are inspected for insect pests and may be treated with phosphine if temperature and time are sufficient, or contaminated ingredients may be rejected. Thes e techniques do not disinf est a facility but are critical in monitoring and managing pests, and h opefully preventing outbreaks. However, when all these methods fail to control a pest problem, f acilities must rely on fumigation, to kill insects within the processing equipment, bins, storage spaces and even the walls of the structure. There are two primary fumigants available to this industry that may accomplish these tasks: methyl bromide and sulfuryl fluoride.

T ABLE 

### 2. N OMINATION 

### A MOUNT

Rice Millers Pet Food

Institute North American

Millers Sector Total /
Average

Quantity Requested for 2011: Amount (kgs) 14,511 13,722 107,066 135,299

Quantity Recommended by

MBTOC/TEAP for 2011 : Amount (kgs) 14,511 13,722 107,066 135,299

Amount (kgs) 14,511 13,722 107,066 135,299

Volume (1000 m 3 ) 726 745 8,459 9,930

Rate 20 18 13 14

Transition from 2011 Baseline Adjusted Value Percentage (%) 0% 0% 0% 0%

Amount (kgs) 

## 14,511 13,722 107,066 135,299

Volume (1000 m 3 ) 

### 726 762 5635 7123

Rate 

### 20 18 19 19 STRUCTURES

Quantity Approved by Parties for

2011:



### Quantity Required for

2012 Nomination: SECTOR

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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### 2. SUMMARI ZE WHY KEY ALTE RNATIVES ARE NOT FEASIBLE

This nomination is for facilities, or portions of facilities, that are unsuita ble for the alternatives, and where the alternatives are not economically f easible. Sulfuryl fluoride is highly dependent upon temperature, so should a facility need fumi gation during cold temperatures, this chemical may not be a cost-effective soluti on. Also, sulfuryl fluoride requi res higher dosages for egg kill, a paramount concern in certain f acilities. Phosphine can be expl osive 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 se veral parameters: the structural composition, as different components expand and co ntract at different rates; the building de sign/layout factors, which affect the ability to evenly distribute heat ed air; and the availability of convenient and economical sources of heat. In addition, heat may not be a viable option for treatment of food products or commodities.

In addition, there is some confus ion as to the materials that ma y be directly fumigated with sulfuryl fluoride. According to the ProfumeTM label pet food is not listed as a material approved for direct treatment. Therefore, the interpretatio n is that all pet food products would need to be removed from treatment areas or sufficiently pr otected to prevent the formation of sulfuryl fluoride residues within the pet food products. This is also a factor for mills that produce mixes (e.g. cake mixes, muffin mixes, etc.).

Millers have analyzed both tarping and removal of those ingr edients that cannot be legally treated with SF. Millers indicate that tarping is not practical because there could be dozens of ingredients in the facil ity. The ingredients are no t stored or grouped together based on whether or not they can be treated with SF. Thus, those ingr edients that cannot be tr eated would have to be staged together in an open area in order to be covered with a tarp. New facility construction or expansion is extremely expensive, so US facilities expand production by adding more equipment to the existing structure, making the floorspace very asset intensive. The industry claims that there is not sufficient unused space in whic h to stage non-treatable ingredients during fumigation.

MBTOC has suggested complete removal of non-SF tr eatable ingredients from the target facility. This would present significant logistical challenges, including multiple forklifts and forklift drivers, plus rented truck traile rs onto which the ingredients could be loaded. These trailers, full of non-treatable ingredients, woul d then be removed from the fac ility, most likely to available space in the parking lot. These added labor and tr ailer rental costs and costs associated with additional downtime needed to accomplish the ingred ient removal task may be high. An average facility might make 1.0 million pounds of product daily. The ingredient removal task might easily take an additional 6 hours to acco mplish. Thus, 250,000 pounds of product won’t be produced. Since these facilities typically run 24 h ours per day, seven days per week, the revenue lost on those 250,000 pounds of product cannot be made up by working overtime later.

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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### 3. RESE ARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES

Fumigants At the November 2009 Methyl Bromide Alterna tives Outlook Conference, the results of 2009 research conducted by Hartzer, et al, were presented. The 380,000 cubic foot mill at Kansas State University was fumigated 4 times in 2009 – twice each with methyl bromide and sulfuryl

fluoride.

Bioassays of all life stages of the red flour beet le were conducted from 25 locations in the mill.

The results were as follows:

Table 1. Summary of key resulting fumigati on parameters from the four experiments.

MB1 SF2 MB3 SF4

Starting time 6:40 PM May 6 th , 09 6:00 PM May 27 th , 09 2:50 PM Aug 11 th , 09 2:45 PM Aug 19 th , 09

Exposure (hr) 24 24 24 24
Total gas used (kg) 181.4 (400 lb) 567.0 (1250 lb) 159 (350 lb) 511 (1125 lb)

Indoor temp (C) 22 - 23 23 - 26 27 - 31 28 - 32
Outdoor temp (C) 15 - 29 14 - 26 19 - 34 16 - 27

Indoor RH (%) 39 - 50 34 - 44 40 - 60 40 - 55

Outdoor RH (%) 37 - 91 25 - 88 30 - 90 45 - 95
Avg wind spd (m/s) 1.65, 3.52, 7.12 3.67 2.16 3.0, 6.9

HLT (hr) 111, 16.4, 10.2 19.7 26 26.1, 9.9

Ct product (g-hr/m 3 ) 283 - 327 923 - 1191 268 - 318 663 - 1003


### Source: Hartzer, et al. 2009

Note that the average quantity of methyl bromide used was 170.2 kg (375 pounds). The average quantity of sulfuryl fluoride used was 539 kg ( 1187.5 pounds), or about 317 percent greater. This presents an obstacle to wider adoption of su lfuryl fluoride, as i ndustry efforts toward environmental sustainability discourage pesticide usage.

However, also note that in the first sulfuryl fluoride fumigation (SF2) the temperature in the mill was an average of 24.5oC (76.1oF). At this temper ature, the SF Fumiguide instructs the user to apply 768 kg (1,694 pounds) of the fumigant for optimal results, a requi rement of about 451 percent more gas than need ed with methyl bromide.

Thus, a 5.6oC (10oF) lower temp erature increased the required SF dosage by an additional 42

percent.

The results achieved with the lower dosage are in teresting. At the lower dosage level, mortality of red flour beetle eggs was found to be as low as 42 percent, with an average egg mortality of less than 84 percent. Mortality rates on all life stages for both methyl bromide fumigations and the sulfuryl fluoride fumigation c onducted at 30oC (86oF) were vi rtually 100 percen t. It is, of course, theoretically possible to introduce auxilia ry heat to bring the mill temperature up to a

level that would facilitate a more effective SF tr eatment. However, that creates additional costs to a treatment that is already significantly more expensive, as describe d below in “4. Economic Impacts.”

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### Heat In 2009, Brijwani, et al. conducted research at th e Kansas State University flour mill. They conducted two treatments, one in May and anothe r in August. Temperatures ranged from 50- 60oC (122-140oF).

At different locations within the mill it took from 9-22 hours (May treatment) and 6-22 hours (August treatment) to reach the target temperat ure of 50oC. Where mort ality was less than 100 percent, this was attributed to slow heating rates and/or not being able to hold temperatures

above 50oC for several hours.

Mortality of insects was 100 per cent for all life stages except for boxes in 9.2 percent of the compartments in the May treatm ent and 7.6 percent of the insect compartments in the August

treatment.

They concluded that heat is an effective treatmen t, so long as temperatures reach and are held at 50oC. The Kansas State University mill is nearly ne w, is of slipform concrete construction and is

small relative to the size of a co mmercial mill. Therefore it likely presents the best-case scenario for the effectiveness of high heat treatments. It would likely be more difficult to reach and hold that insecticidal temperature in a commercial mill, especially since most are older, constructed of various materials and are typically 1.0 – 2.0 milli on cubic feet in size. Achieving and holding the temperature at insecticidal levels in commerci al mills of that size would present significant technical and economical challenges.

4. ECONOMIC IMPACTS

The following measures or indicators may be used as a guide for providing such a description: (a) The purchase cost per kil ogram of methyl bromide and of the alternative; (b) Gross and net revenue with and without me thyl bromide, and with the next best alternative; (c) Percentage change in gross reve nues if alternatives are used; (d) Absolute losses per hectare relative to methyl bromide if alternatives are used; (e) Losses per kilogram of methyl bromide requested if alternatives are used; (f) Losses as a percentage of net cash revenue if alternatives are used; (g) Percentage change in profit marg in if alternatives are used.

T ABLE 

### 3. E CONOMIC 

### S UMMARY FOR EACH 

### A LTERNATIVE

M ETHYL B ROMIDE

A LTERNATIVE E CONOMIC S UMMARY

H EAT T REATMENT Food processing facilities located in cold clim ates (which are able to convert to heat treatment) may experience economic losses from additional production downtimes associated with heat-up time. Economic lo sses in cold weather facilities due to downtime with heat treatment are persistent. Howe ver, some facilities experience better insect control with heat than fumigation due to leaky structures that allow gas to escape.

S ULFURYL F LUORIDE A portion of the food processing facilities can economically convert to sulfuryl fluoride. Other facilities cannot due to economic losses that would result from higher treatment costs which arise at lower temperatures. Fo r a small percentage, SF is not technically feasible due to cold temperatur es. Adding heat to increase the efficacy of SF is also not an

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 6USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

### 7 economically feasible option.



### Sulfuryl Fluoride

Results of the assessment of usi ng sulfuryl fluoride as an alte rnative to methyl bromide are provided in Tables 2-4. For purpos es of this analysis, current prices of sulfuryl fluoride and methyl bromide were assumed equal and plant temperatures are 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 can be used and its use is not restricted. Fumigation with sulfuryl fluoride at lower temp eratures controlling all pest life stages is infeasible due to prohibitively high application rates and minimal efficacy. Sulfuryl fluoride is technically feasible only in facilities that do not prepare mi xed products (e.g., cake mixes) due to labeling.

Heat Treatment

Potential economic losses were estimated for th e food-processing facilitie s that have not been converted to heat treatment. This analysis only covers cases where heat treatment may potentially be technically feasible, and does not cover situations where heat would degrade the commodity being processed (those w ith 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.TABLE4.ANNUALECONOMICIMPACTS OFMETHYLBROMIDEALTERNATIVES FORRICEMILLER’SASSOCIATIONRice Millers1UnitsMeBr2SF2Heat: 7 oCHeat: 29 oCSF + 7 oC HeatTotal Operating Costs$/yearNananananaTotal Fumigation/Heat Costs$/year$ 24,300.00$ 30,000.00$ 70,000.00$ 150,000.00$ 100,000.00Quantity of Fumigant(One treatment per year)kgs/facility7031,134nananaFumigant cost (i.e., gas)$/year$ 9,300.00$ 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$ -$ 5,700.00$ 45,700.00$ 125,700.00$ 75,700.00Average Facility Loss per KgMeBr Requested$/kg MBrequestedNa8.1165.00178.79107.671Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility2Temperature 29.44 degrees CUSA CUN12POST HARVEST STRUCTURES - FOOD PROCESSING PLANTSPage8TABLE5:ANNUALECONOMICIMPACTS OFMETHYLBROMIDEALTERNATIVES FORPETFOODINSTITUTEPet Food1UnitsMeBr2SF2WarmFacility: Heatfrom 29.4oC to54.4oCCold Facility:Heat from4.4oC to 54.4oCCold Facility:SF + Heatfrom 4.4oC to29.4oCGross Revenue$/year$ 33,176,000$ 33,176,000$ 33,176,000$ 33,060,000$ 33,176,000Total Operating Costs$/yearnananananaTotal Fumigation/Heat Costs$/year$ 9,613$ 11,638$ 17,500$ 37,500$ 29,138Quantity of Fumigant(0.25 treatment per year)Kgs/facility/ treatment5221,134nananaFumigant cost (i.e., gas)$/year$ 1,725$ 3,750nana$ 3,750Other fumigation costs(i.e., labor, equip., etc.)$/year$ 7,888$ 7,888$ 17,500$ 37,500$ 25,388Other Operating Costs$/yearnananananaTime Lostdays00010Total Loss (MeBr to alt)$/year$ -$ 2,025$ 7,888$ 27,888$ 19,525Average Facility Loss per KgMeBr Requested$/kg MBrequested$ -$ 110$ 428$ 1,514$ 1,060Loss as % of GR with MeBr0%0.01%0.02%0.08%0.06%1Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facilityTemperature 29.44 degrees C (85 degrees F)USA CUN12POST HARVEST STRUCTURES - FOOD PROCESSING PLANTSPage9USA CUN12POST HARVEST STRUCTURES - FOOD PROCESSING PLANTSPage10TABLE6.ANNUALECONOMICIMPACTS OFMETHYLBROMIDEALTERNATIVES FORNORTHAMERICANMILLER’SASSOCIATIONNAMA**UnitsMeBr2SF2Heat: 7oCHeat: 29 oCSF + 7oC HeatTotal Operating Costs$/yearnananananaTotal Fumigation/Heat Costs$/year$ 13,001.75$ 26,932.75$ 70,000.00$ 150,000.00$ 96,932.75Quantity of Fumigantkgs/facility566.991,587.57nananaFumigant cost (i.e., gas)$/year$ 7,500.00$ 21,000.00nana$ 21,000.00Other fumigation costs(i.e., labor, equip., etc.)$/year$ 5,501.75$ 5,932.75$ 70,000.00$ 150,000.00$ 75,932.75Other Operating Costs$/yearnananananaTime Lostdays00010Total Annual Loss (MeBr toalt)$/year$ -$ 13,931.00$ 56,998.25$ 136,998.25$ 83,931.00Average Facility Loss per KgMeBr Requested$/kg MBrequested$ -$ 24.57$ 100.53$ 241.62$ 148.031Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility2Temperature at 29.44 degrees C

### CITATIONS:

Hartzer, M., B. Subra manyam, W. Chayaprasert, D. E. Maier, and S. Savoldelli. 2009. Methyl Bromide and Sulfuryl Fluoride Effectiveness Against Red Flour Beetle Life Stages. Presentation at Methyl Bromide Alternativ es Outlook Conference, San Diego, November

2009. Available at: http://mbao.org

.

Brijwani, M., B.Subramanyam, M. Hartzer, D. E. Maier, W. Chayaprasert, S. Savoldelli, P. Flinn, and J. Campbell. 2009. Efficacy of St ructural Heat Treatments Against Tribolium castaneum Life Stages. Presentation at Met hyl Bromide Alternatives Outlook Conference, San Diego, November 2009. Available at: http://mbao.org

.

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