METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

POST-HARVEST USE TREATMENT 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: 

TABLE 1. QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF NOMINATION

YEAR NOMINATION AMOUNT (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 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 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 paragraph (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 1
Signature Name Date 

Title: 

CONTACT 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 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 TREATMENT 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 commercialisation of alternatives, etc.)

Food processing facilities in the United States have reduced the number of methyl bromide 

fumigations by incorporating a variety of different techniques to control pests. The most critical 

strategy implemented is IPM, especially sanitation, 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 inspections, pheromone traps, light traps, and electrocution traps. 

When insect pests are found, facilities 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 are suitable. Incoming ingredients are inspected for 

insect pests and may be treated with phosphine if temperature and time are sufficient, or 

contaminated ingredients may be rejected. These techniques do not disinfest a facility but are 

critical in monitoring and managing pests, and hopefully preventing outbreaks. However, when 

all these methods fail to control a pest problem, facilities 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. 

TABLE 2. NOMINATION AMOUNT

 Rice Millers Pet Food 

Institute 

 North American 

Millers 

 Sector Total / 

Average 

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

Quantity Recommended by 

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

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

Volume (1000 m3) 745 726 8,459 9,930 

Rate 18 20 13 14 

Transition from 2011 Baseline 

Adjusted Value Percentage (%) 0% 0% 0% 0%

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

Volume (1000 m3) 726 762 5635 7123

Rate 18 20 19 19 

STRUCTURES

Quantity Approved by Parties for 

2011:

Quantity Required for 

2012 Nomination:

SECTOR

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 3
2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

This nomination is for facilities, or portions of facilities, that are unsuitable for the alternatives, 

and where the alternatives are not economically feasible. Sulfuryl fluoride is highly dependent 

upon temperature, so should a facility need fumigation during cold temperatures, this chemical 

may not be a cost-effective solution. Also, sulfuryl fluoride requires higher dosages for egg kill, 

a paramount concern in certain facilities. Phosphine can be explosive and is corrosive to many 

metals that are present in facilities, especially in the computers and other electronic process 

control instrumentation. Heat is dependent on several parameters: the structural composition, as 

different components expand and contract at different rates; the building design/layout factors, 

which affect the ability to evenly distribute heated 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 confusion as to the materials that may 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 interpretation is that all pet food products would need to be 

removed from treatment areas or sufficiently protected 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 ingredients that cannot be legally 

treated with SF. Millers indicate that tarping is not practical because there could be dozens of 

ingredients in the facility. The ingredients are not stored or grouped together based on whether or 

not they can be treated with SF. Thus, those ingredients that cannot be treated 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 which to stage non-treatable ingredients during 

fumigation. 

MBTOC has suggested complete removal of non-SF treatable ingredients from the target facility. 

This would present significant logistical challenges, including multiple forklifts and forklift 

drivers, plus rented truck trailers onto which the ingredients could be loaded. These trailers, full 

of non-treatable ingredients, would then be removed from the facility, most likely to available 

space in the parking lot. These added labor and trailer rental costs and costs associated with 

additional downtime needed to accomplish the ingredient 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 accomplish. Thus, 250,000 pounds of product won’t be 

produced. Since these facilities typically run 24 hours 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 4
3. RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES 

Fumigants 

At the November 2009 Methyl Bromide Alternatives 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 beetle were conducted from 25 locations in the mill. 

The results were as follows: 

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

MB1 SF2 MB3 SF4 

Starting time 6:40 PM May 6th, 09 6:00 PM May 27th, 09 2:50 PM Aug 11th, 09 2:45 PM Aug 19th, 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/m3

) 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 sulfuryl fluoride, as industry 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 temperature, the SF Fumiguide instructs the user to 

apply 768 kg (1,694 pounds) of the fumigant for optimal results, a requirement of about 451 

percent more gas than needed with methyl bromide. 

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

percent. 

The results achieved with the lower dosage are interesting. 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 conducted at 30oC (86oF) were virtually 100 percent. It is, of 

course, theoretically possible to introduce auxiliary heat to bring the mill temperature up to a 

level that would facilitate a more effective SF treatment. However, that creates additional costs 

to a treatment that is already significantly more expensive, as described below in “4. Economic 

Impacts.” 

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 5
Heat 

In 2009, Brijwani, et al. conducted research at the Kansas State University flour mill. They 

conducted two treatments, one in May and another 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 temperature of 50oC. Where mortality 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 percent for all life stages except for boxes in 9.2 percent of the 

compartments in the May treatment and 7.6 percent of the insect compartments in the August 

treatment. 

They concluded that heat is an effective treatment, so long as temperatures reach and are held at 

50oC. The Kansas State University mill is nearly new, is of slipform concrete construction and is 

small relative to the size of a commercial 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 million cubic feet in size. Achieving and holding the 

temperature at insecticidal levels in commercial 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 kilogram of methyl bromide and of the alternative; 

(b) Gross and net revenue with and without methyl bromide, and with the next best 

alternative; 

(c) Percentage change in gross revenues 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 margin if alternatives are used. 

TABLE 3. ECONOMIC SUMMARY FOR EACH ALTERNATIVE

METHYL BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

HEAT TREATMENT

Food processing facilities located in cold climates (which are able to convert to heat 

treatment) may experience economic losses from additional production downtimes 

associated with heat-up time. Economic losses in cold weather facilities due to downtime 

with heat treatment are persistent. However, some facilities experience better insect 

control with heat than fumigation due to leaky structures that allow gas to escape.

SULFURYL FLUORIDE

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. For a small percentage, SF is not technically 

feasible due to cold temperatures. Adding heat to increase the efficacy of SF is also not an 

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 6
USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 7

economically feasible option. 

Sulfuryl Fluoride

Results of the assessment of using sulfuryl fluoride as an alternative to methyl bromide are 

provided in Tables 2-4. For purposes 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 temperatures 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 mixed products (e.g., cake mixes) due to 

labeling. 

Heat Treatment

Potential economic losses were estimated for the food-processing facilities 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 with 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. 
TABLE 4. ANNUAL ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FOR RICE MILLER’S ASSOCIATION 

Rice Millers 1 Units MeBr 2 SF 2 Heat: 7 oC Heat: 29 oC Total Operating Costs $/year Na na na Total Fumigation/Heat Costs $/year $ 24,300.00 $ 30,000.00 $ 70,000.00 $ 150,000

Quantity of Fumigant (One treatment per year) kgs/facility 703 1,134 na Fumigant cost (i.e., gas) $/year $ 9,300.00 $ 15,000.00 na Other fumigation costs (i.e., labor, equip., etc.) $/year $ 15,000.00 $ 15,000.00 $ 70,000.00 $ 150,000

Other Operating Costs $/year Na na na Time Lost days 000Total Loss (MeBr to alt) $/year $ - $ 5,700.00 $ 45,700.00 $ 125,700Average Facility Loss per Kg MeBr Requested 

$/kg MB 

requested Na 8.11 65.00 178

1 Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility 

2 Temperature 29.44 degrees C 

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 8
TABLE 5: ANNUAL ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FOR PET FOOD INSTITUTE

Pet Food 1 Units MeBr 2 SF 2 

Warm 

Facility: Heat 

from 29.4oC to 

54.4oC 

Cold Facili

Heat from 

4.4oC to 54.

Gross Revenue $/year $ 33,176,000 $ 33,176,000 $ 33,176,000 $ 33,060,Total Operating Costs $/year na na na Total Fumigation/Heat Costs $/year $ 9,613 $ 11,638 $ 17,500 $ 37,

Quantity of Fumigant 

 (0.25 treatment per year) 

Kgs/facility

/ treatment 522 1,134 na 

Fumigant cost (i.e., gas) $/year $ 1,725 $ 3,750 na Other fumigation costs (i.e., labor, equip., etc.) $/year $ 7,888 $ 7,888 $ 17,500 $ 37,

Other Operating Costs $/year na na na Time Lost days 000Total Loss (MeBr to alt) $/year $ - $ 2,025 $ 7,888 $ 27,Average Facility Loss per Kg MeBr Requested 

$/kg MB 

requested $ - $ 110 $ 428 $ 1,

Loss as % of GR with MeBr 0% 0.01% 0.02% 0.0

1 Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility

Temperature 29.44 degrees C (85 degrees F)USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 9
USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 10

TABLE 6. ANNUAL ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FOR NORTH AMERICAN MILLER’S ASSOCIATION 

NAMA** Units MeBr 2 SF 2 Heat: 7oC Heat: 29 oTotal Operating Costs $/year na na na Total Fumigation/Heat Costs $/year $ 13,001.75 $ 26,932.75 $ 70,000.00 $ 150,00

Quantity of Fumigant kgs/facility 566.99 1,587.57 na Fumigant cost (i.e., gas) $/year $ 7,500.00 $ 21,000.00 na Other fumigation costs (i.e., labor, equip., etc.) $/year $ 5,501.75 $ 5,932.75 $ 70,000.00 $ 150,00

Other Operating Costs $/year na na na Time Lost days 000Total Annual Loss (MeBr to alt) $/year $ - $ 13,931.00 $ 56,998.25 $ 136,99Average Facility Loss per Kg MeBr Requested 

$/kg MB 

requested $ - $ 24.57 $ 100.53 $ 24

1 Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility 

2 Temperature at 29.44 degrees C 
CITATIONS: 

Hartzer, M., B. Subramanyam, 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 Alternatives 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 Structural Heat Treatments Against Tribolium 

castaneum Life Stages. Presentation at Methyl Bromide Alternatives Outlook Conference, 

San Diego, November 2009. Available at: http://mbao.org. 

USA CUN12 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 11