Filename: USA CUE14 MBTOC Replies Aug I PAGE 1

NOMINATING PARTY : The United States of America

DATE: AUGUST 1 6 , 201 2

FILE NAME: USA CUE1 4 M BTOC REPLIES 08

- 201 2 _FINAL

BRIEF DESCRIPTIVE TI TLE : Methyl Bromide Critical Use Nomination for 201 4 , U.S. Replies to MBTOC Report (Submitted

in 201 2 for 201 4 Use Season)

CROP NAME (OPEN FIEL D OR PROTECTED): Strawberry F ruit 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 265 7 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 201 2 ) 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 U nited S tates 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 provide s the size of the aging rooms, theFilename: 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 f rom 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 year s 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 afte rnoon. 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 5 5 0.6 4 4

2 272 2.6 1 5

3 9 1 0.85 4

4 681 6.37 4

5 5 5 0.5 7 4

6 50 0.5 7 4

7 45 0.5 7 4

8 64 0.5 7 4

9 272 2.83 4

10 1,135 7.70 5

11 27 0.28 4

12 27 0.28 4

13 68 0.5 7 4

14 272 2.83 4

15 18 0.17 4

16 14 0.14 4

17 45 0.4 3 4

18 45 0.45 4

19 23 0.28 4

20 64 0.7 1 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 MeBrFilename: 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 abl e 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 ab le 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 so il disinfestation or organic production strategies.



### U.S. Reply

The U nited S tates is requesting that MBTOC recommend 415,067 kg the full amount as nominated for California strawberry fruit in the U.S. c rit ical u se n omination.

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 redu ced 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 F actor so the total amount of 1,3

- D available under the township cap will not change. Furthermore, t he 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 pest s 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 toFilename: 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 n eeded 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 application s to improve efficacy of pest cont rol. However as noted in the text box, MBTOC “ does ac cept 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 w ould use up the 1,3

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

than bed ded, 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 t he

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 appli cations with 1,3

- D and chlorop ic rin would require more chloropicrin than is allowed in most counties (see Table 2)

Growers using methy l bromide alternatives are seeing increased in stances 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 appl ications 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 an d 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 11 7 kg ai/ha (1 05 lb ai/acre) of 1,3

- dichloropropene are necessary for adequate weed control. Plant pathog ens 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) . T hose 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 H ectares 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 permit s 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 Salin as 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 appl ication

. 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.

Iodomet hane 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 upt ake 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 G overnment 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 org anic 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 farmer s 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 U nited S tates believes that this alter native 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 201 2)

“ 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 e ach unit costs approximately $30 0,000 , making the current costs of this technique prohibitive for use in this sector

.

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

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

a failure when field testing ASD for the control of Macrophomin a ( Muramoto , 2012)

. ThisFilename: 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 0.4 87 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 i t 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 Requir ements. 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,

Su bpart 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

Fenni more, S. A. and Ajwa, H. A. 2011. Totally impermeable fi lm retains fumigants, allowing lower application rates in strawberry. California Agriculture, October

- December, 2011.

Vol. 65:211

- 215. http://ucce.ucdavis.edu/files/reposit oryfiles/ca.E.6504p211

- 91055.pdf

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

. F umigant and strawberry variety evaluations in M acrophonina and F usarium F ields . 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 201 2

. 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_Vol

1.pdfFilename: 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