Filename: USA CUE14 MBTOC Replies Aug I PAGE 1

NOMINATING PARTY: The United States of America

DATE: AUGUST 16, 2012

FILE NAME: USA CUE14 MBTOC REPLIES 08-2012_FINAL

BRIEF DESCRIPTIVE TITLE:

Methyl Bromide Critical Use Nomination for 2014, U.S. Replies to MBTOC Report (Submitted 

in 2012 for 2014 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Strawberry Fruit and Dried Cured Pork

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: Susan Lewis

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) 308-8200

Fax: (703) 308-7042

E-mail: Lewis.Susan@epa.gov

Dried Meat Products

MBTOC (TEAP 2012) expects to be able to recommend MB for use in dry cured pork in 2014, but is currently 

unable to determine the correct volume of MB to recommend.

U.S. Reply

The United States is requesting that MBTOC recommend 3,730 kg for dried cured pork

products in the U.S. Critical Use Nomination for 2014. 

In May, 2012, Dr. Wes Schilling (Mississippi State University) sent out a questionnaire and 

26 entities responded concerning use of methyl bromide in their facilities (U.S. Country Ham 

Facility Questionnaire). The information collected provides the size of the aging rooms, the 
Filename: USA CUE14 MBTOC Replies Aug I PAGE 2

yearly amounts of methyl bromide used, and the number of fumigations per year, by facility 

as requested by MBTOC. Table 1 provides the results from the respondents.

The producers report they monitor the aging rooms for evidence of pests, and when signs of 

pests are present they make the decision to fumigate. Hams are produced daily so there are 

multiple crops per year and some hams are aged for up to two years which creates the 

potential for multiple pest outbreaks per year. Therefore, fumigations may occur more than 

once per year. Typically producers clean and seal the aging room on Friday. Gas is 

introduced after workers leave on Friday afternoon. The amount of methyl bromide listed 

includes additional gas added to adjust for any loss to ensure the required CT (Concentration 

Time) is maintained during treatment. Aeration usually begins on Sunday afternoon or early 

evening. 

Table 1. U.S. Country Ham Facility Questionnaire Conducted by Dr. Schilling, May 2012

Facility 

#

Maximum MeBr 

used per year (kg)

Aging Room Size 

(1,000 cubic meters)

Maximum number of 

fumigations per year

1 55 0.64 4

2 272 2.61 5

3 91 0.85 4

4 681 6.37 4

5 55 0.57 4

6 50 0.57 4

7 45 0.57 4

8 64 0.57 4

9 272 2.83 4

10 1,135 7.70 5

11 27 0.28 4

12 27 0.28 4

13 68 0.57 4

14 272 2.83 4

15 18 0.17 4

16 14 0.14 4

17 45 0.43 4

18 45 0.45 4

19 23 0.28 4

20 64 0.71 4

21 114 1.27 4

22 36 0.34 4

23 82 0.79 4

24 27 0.85 2

25 27 0.85 2

26 54 1.46 2

Total 3,664 kg MeBr 
Filename: USA CUE14 MBTOC Replies Aug I PAGE 3

Footnote: These numbers were rounded by Excel spreadsheet after conversion from the original U.S. 

units. 

The amount of methyl bromide nominated by the United States government is 3,730 kg. This 

amount is slightly larger than that reported as being used by the 26 producers that responded to 

the questionnaire given yearly variations in production, economics, pest pressure, and 

environmental conditions (e.g. weather). 

Strawberry fruit

MBTOC (TEAP 2012) recommends a reduced amount of 343.740 tonnes for use in strawberry fruit in California for 

2014. This is based on 170 kg/ha and 2,022 ha. 

The total reduction includes a 10% reduction of the 2013 CUE made by the Party and the further reduction (15.47%) 

made by MBTOC. The total reduction as calculated by MBTOC is based on; 

1) 261 ha (or 15%) of the expected area in 2013 affected by township caps on 1,3-D mixtures being able to 

transition to strategies using these fumigant mixtures. These include those which use less 1,3-D dose per unit 

area, including uptake of Pic-Clor 60, use of barrier films to reduce dosage rates with all 1,3-D formulations and 

rotation with broad acre fumigant strategies to improve the effectiveness of disease control. MBTOC notes that 

official databases report approximately 6,500 ha of strawberry fruit production using different formulations of 

1,3-D in 2010. 

2) 150 ha of the total nomination being able to uptake Pic straight formulations which are not restricted by 

permit conditions 

3) 270 ha of the total nomination being able to uptake methyl iodide 

4) 10 ha of the total nomination being able to uptake new technologies of either steam, anaerobic soil 

disinfestation or organic production strategies. 

U.S. Reply

The United States is requesting that MBTOC recommend 415,067 kg the full amount as 

nominated for California strawberry fruit in the U.S. critical use nomination. 

Alternative #1: MBTOC recommended a cut of 261 ha or 44,370 kg (261 ha * 170 kg/ha) based 

on uptake of 1,3-dichloropropene. 

The United States government nomination was for areas of high pest pressure where the 

alternatives cannot be used because of regulatory constraints. The amount of methyl bromide 

nominated was calculated based on using 100% of the 1,3-D township cap using Pic Clor 60 

for strawberry fruit in 2014. 

MBTOC has suggested that high barrier films could allow reduced rates of 1,3-

dichloropropene “MBTOC notes that low permeability (high barrier) films can be used on 

MB alternatives and that lower dose rates of 1,3-D with barrier films are effective (refs)”.

Use of high barrier films does not change the Application Factor so the total amount of 1,3-D 

available under the township cap will not change. Furthermore, the U.S. government has 

been unable to document this MBTOC assertion when, as is the case for California 

strawberries, pest pressure is high and the key pests include Macrophominia and Fusarium. 

On the contrary, research conducted in California by Fennimore and Ajwa (2011) indicate 

that the use of Totally Impermeable Film (TIF) did not improve weed control compared to 
Filename: USA CUE14 MBTOC Replies Aug I PAGE 4

standard films. Specifically, Table 1 in Fennimore and Ajwa (2011) shows that the only rate 

the authors found that provided for complete control with Pic-Clor 60 was at 300 lb/acre. 

Given that the U.S. nomination is only for those acres with high pest pressure, and that this is 

the same rate needed for high-pest pressure acres with standard film, the United States is 

unable to document a benefit in terms of a reduced rate relative to the use of standard film.

MBTOC suggested rotation with broadcast applications to improve efficacy of pest control. 

However as noted in the text box, MBTOC “does accept that reports (Koike et al., 2010) 

show that there is an association of these diseases in areas where drip applied fumigants are 

being used and that broad acre shank treatments with fumigants (e.g. 1,3-D/Pic mixtures, Pic 

and metham sodium) may be required to clean up infested fields”. As explained during our 

bilateral meeting in Beijing, broadcast shank treatments would use up the 1,3-D (Telone) 

township cap 2.7 times faster (given the larger area treated and higher Application Factor) 

than bedded, drip applications, thus having the perverse effect of requiring more rather than 

less methyl bromide to treat the fields with heavy pest infestations. At the same meeting the 

United States also explained that Ventura county (4,542 ha as listed in Table 3) does not 

allow any broadcast applications of 1,3-D. Broadcast applications with 1,3-D and 

chloropicrin would require more chloropicrin than is allowed in most counties (see Table 2)

Growers using methyl bromide alternatives are seeing increased instances of severe losses 

due to plant pathogens. Growers are using high label rates of the alternatives such as 1,3-D 

and chloropicrin as broadcast applications to control these pest problems. This reduces the 

amount of 1,3-D available within the township caps for those growers that are currently using 

methyl bromide. The amount of methyl bromide nominated was calculated based on using 

100% of the 1,3-D township cap using Pic Clor 60 for strawberry fruit in 2014. 

MBTOC recommended a cut of 261 ha to use 1,3-D plus chloropicrin which would use a 

large amount of the township caps. This would require the use of 49,110 kg above the 

Telone township caps. 

261 ha cut * 117 kg/ha of 1,3-D * 1.6 Application Factor = 49,110 kg of 1,3-D

(broadcast shallow shank application)

Alternative #2: MBTOC recommended a cut of 150 ha or 25,500 kg (150 ha * 170 kg/ha) 

based on uptake of chloropicrin straight formulations that are not restricted by permit conditions. 

Research by Daugovish et al (2011) have demonstrated that rates of 336 kg ai/ha (300 lb 

ai/acre) of chloropicrin did not provide season long control of Macrophomina or Fusarium. 

In this study (Table 2) all treatments were drip applied and provided yields that were 

substantially lower than the standard broadcast applications of methyl bromide plus 

chloropicrin. 
Filename: USA CUE14 MBTOC Replies Aug I PAGE 5

Table 2 Strawberry fruit yield, Ventura 2009-2010. Drip applications.

Treatment

(all applications were drip applied)

Rate (kg/ha) Yield (kg/plot)

Methyl bromide + chloropicrin

(formulation not given)

336 43

Pic Clor 60 (37% 1,3-D + 56% 

chloropicrin)

336 39 (9% yield loss)

Chloropicrin high 336 41 (5% yield loss)

Untreated control 0 29

Footnote: Daugovish et al 2010. Yield taken from 23, December 2009 through 26, May, 2010. Yields of 

these treatment were substantially lower than a broadcast application of methyl bromide plus chloropicrin in 

adjacent fields. 

Research by Fennimore and Ajwa (2011) have demonstrated that using Totally Impermeable 

Film (TIF) rates of 201 kg ai/ha (180 lb ai/acre) of chloropicrin in combination with 117 kg 

ai/ha (105 lb ai/acre) of 1,3-dichloropropene are necessary for adequate weed control. Plant 

pathogens were not monitored in this study. Rates of over 224 kg ai/ha up to 336 kg ai/ha 

would be needed for adequate plant pathogen control (Koike, et al 2009). Those rates have 

not been permitted in the counties where strawberries are grown (Table 3) and where methyl 

bromide is being requested. A cut based on straight chloropicrin is therefore not justifiable. 

The basis for such a cut is inconsistent with California regulations and the practice of 

agricultural commissioners given the required dose rates.

Table 3. Strawberry Hectares and Chloropicrin Permit Conditions for 2011 by District

Yearly 

hectares by 

District

Projected 2011

hectares grown 

per District

Chloropicrin Permit Conditions

Orange County / 

San Diego 564 No permits were developed to allow applications at rates above 200 lbs ai/acre.

Oxnard 4,524

Permits were only allowed for test applications (less than 

4.0 ha or 10 acre) at rates higher than 200 lbs/acre under 

TIF.

Santa Maria 4,120 No permits were developed to allow applications at rates 

above 200 lbs ai/acre. 

Watsonville /

Salinas 5,879

In Watsonville permits were only allowed for test 

applications (less than 4.0 ha or 10 acre) at rates higher 

than 200 lbs/acre under TIF.

In Salinas no permits were developed to allow applications 

at rates above 200 lbs ai/acre.

San Joaquin 59

No methyl bromide has been requested for this district. 

No permit restrictions are known but VOC regulations 

control the application method and time of application.

State Total 15,146

Footnote: Monterey, Orange, San Diego, San Luis Obispo, and Santa Barbara did not develop permit conditions 

to allow applications of chloropicrin at rates above 200 lbs/a in 2011. Santa Cruz and Ventura Counties have 

allowed test applications (less than 10 acres) with rates higher than 200 lbs/a under TIF. 
Filename: USA CUE14 MBTOC Replies Aug I PAGE 6

Alternative #3: MBTOC recommended a cut of 270 ha or 45,900 kg (270 ha * 170 kg/ha) based 

on uptake of iodomethane. 

Iodomethane is no longer registered in California and cannot be considered an alternative to 

methyl bromide. The full amount of this cut should therefore be restored.

Alternative #4: MBTOC recommended a cut of 10 ha or 1,700 kg (10 ha * 170 kg/ha) based on 

uptake of steam, anaerobic soil disinfestation, or organic production. During our bilateral 

meeting on 26 July 2012 MBTOC indicated that organic production was the key alternative to 

address. 

The U.S. nomination is only for areas of high pest pressure where we do not believe organic 

production represents a technically and economically feasible alternative. Organic 

production would require taking fields with high pest pressure that currently need methyl 

bromide : chloropicrin and converting them to an organic production system. However, the 

US Government has been unable to locate any published organic methods to control high 

levels of nematodes, plant pathogens and weeds present in the relevant areas. 

The “National Organic Program” requires that organic production fields have a very clearly 

defined list of allowed and prohibited substances. The use of pesticides such as methyl 

bromide is prohibited for a minimum of three years before the field can be certified and its 

crop sold as an organic crop. Therefore, growers would not be able to sell their crop from 

those fields as organically produced for three years. Organic farmers have been shown to 

produce 32,000 lbs per acre of fruit per season (Univ. of Cal. 2006) while conventional 

strawberry farmers produce 65,000 lbs per acre of fruit per season (Univ. of Cal. 2011) or a 

yield reduction of 50%. Given that the California request is for areas of high pest pressure, 

for which there is no currently known method of clearing of pests within U.S. organic 

production methods, that a minimum of three years is necessary before any crop raised on 

previously treated land can be designated as organic, and that yield is one-half of 

conventionally produced yields, the United States believes that this alternative is both 

technically and economically infeasible. 

Organic production systems are regulated under Title 7 Agriculture. Part 205-National 

Organic Program, Subpart B - Organic Production and Handling Requirements, (Code of 

Federal Regulations 2012)

“Have had no prohibited substances as listed in Section 205.105 applied to it for a period of 3 

years immediately preceding harvest of the crop.”

Steam fumigation is not yet considered an economically feasible alternative for California 

strawberry fruit production. The steam fumigation system currently available in California 

only treats 1 acre/day and each unit costs approximately $300,000, making the current costs 

of this technique prohibitive for use in this sector. 

Information available to us suggests that anaerobic soil disinfestation is used commercially in 

other countries only in greenhouse production systems. Recently in California there has been 

a failure when field testing ASD for the control of Macrophomina (Muramoto, 2012). This 
Filename: USA CUE14 MBTOC Replies Aug I PAGE 7

site also had problems with the irrigation system which may have been a contributing factor. 

While ASD holds promise for use in the future, further work is needed before it is ready for 

broad adoption to adapt the technique to commercial production practices in California, to 

ensure adequate control of key pests, and to validate the economics of the technique.

Dried Fruit

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. If it were to be provided, an 

updated phase out plan for dates and walnuts would inform MBTOC and Parties of the continued timing of its 

transition to alternatives. 

U.S. Reply

The United States will send a response to this interim recommendation separately.

CITATIONS

California Department of Pesticide Regulations. 2012. Division 6. Pesticides and Pest Control 

Operations. Chapter 2. Pesticides, Subchapter 4. Restricted Materials Article 4. Use 

Requirements. Available online at: http://www.cdpr.ca.gov/docs/legbills/calcode/020404.htm

Code of Federal Regulations. 2012. Title 7 Agriculture. Part 205-National Organic Program, 

Subpart B - Organic Production and Handling Requirements. Available online at:

http://www.law.cornell.edu/cfr/text/7/205.105 

Daugovish, O., S. Koike, T. Gordon, H. Ajwa and, D. Legard (2011) Macrophomina and 

Fusarium caused plant collapse: Fumigation and varieties. Available online at: 

http://www.mbao.org/2011/10Daugovish.pdf

Fennimore, S. A. and Ajwa, H. A. 2011. Totally impermeable film retains fumigants, allowing 

lower application rates in strawberry. California Agriculture, October-December, 2011. 

Vol. 65:211-215. http://ucce.ucdavis.edu/files/repositoryfiles/ca.E.6504p211-91055.pdf

Koike, S., T. Gordon, H. Ajwa, O. Daugovish, M. Bolda, D. Legard. 2009. Fumigant and 

strawberry variety evaluations in Macrophonina and Fusarium Fields. Available online at: 

http://mbao.org/2009/Proceedings/013DaugovishOSummaryPathogens.pdf

Muramoto, J. 2012. Personal communication. Aug. 14, 2012. Univ. of California Santa Cruz

TEAP (2012) Report of the Technology and Economic Assessment Panel, May 2012. Vol 1, 

Progress Report. Montreal Protocol on Substances that Deplete the Ozone Layer, United 

Nations Environment Programme, Nairobi. Available online at: 

http://ozone.unep.org/Assessment_Panels/TEAP/Reports/TEAP_Reports/TEAP_Progress_Report_May_Vol1.pdf
Filename: USA CUE14 MBTOC Replies Aug I PAGE 8

University of California. 2006. Sample costs to produce organic strawberries, Central Coast. 

Available online at http://coststudies.ucdavis.edu/files/strawberryorgcc06.pdf 

University of California. 2011. Sample costs to produce strawberries, South Coast Region. 

Available online at http://coststudies.ucdavis.edu/files/Strawberry_SC_VC_2011.pdf