## United Nations Environment Programme Methyl Bromide Technical Options Committee

Structures and Commodities (SC)

MBTOC Co

- Chair:

Ms Michelle Marcotte (Canada) email: marcotteconsulting@comcast.net

February 11 , 2011

Marco Gonzalez

Executive Director

UNEP Montreal Protocol

And

Federico San Martini, Ph.D. Foreign Affairs Of ficer Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2657 Washington, D.C. 20520

U.S.A.

E

- mail: SanMartiniFM@state.gov

Dear Marco, Frederico and Team USA,

MBTOC SC has completed its first level of review of the postha rvest CUNs. Our intial review resulted in some questions pertaining to the structural

, cured pork and commodity

CUNs

.

Additionally, MBTOC has noted, with appreciation, the improved financial data included

in the CUNs.

Questions on Structural CUN

MBTOC has signficant concerns about the lack of necessary information included in this

CUN.

CUNs submitted to MBTOC for this use in 2010, 2011 and 2012, give an identical summary of the alternatives. As you will see in the thrust of the questions below,

MBTOC asks the US to supply specific and detailed recent results on progress on trials and commercial adoption of alternatives, specifically giving examples of what techniques

have worked or not worked over these three years.

Concerning the use of heat treatm ent in mills and food processing structures, The CUN says the use of heat is constrained by its effect on some structures, its cost effectiveness and ready availability (CUN page 3, para 1). The CUN also notes (CUN page 4, section 2) that, “Heat is depende nt on several parameters: the structuralcomposition, 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 econo mical sources of heat.” MBTOC responds that this comment has been included in the CUN for several years and yet adoption of heat treatment in other mills worldwide has progressed, commercial heat equipment is widely available from a variety of American com panies and knowledge of how to safely control

heat treatments is now considerable. Please provide specific, detailed and recent information showing success or lack of success in adopting heat or in obtaining

economical sources of heat.

MBTOC notes, howe ver, that full and/or partial heat treatment of milling structures and equipment is the alternative of choice in many Canadian mills even those with wooden structures. American and Canadian mills are often owned and operated by the same

multi

- national comp any, so it is difficult to understand why heat would work in one mill and not another. Please supply specific and recent results of successful or not successful attempts to adopt heat treatment in the mills and food processing structures

included in this C UN. Cereal milling equipment is generally the same worldwide, so it is difficult for MBTOC to understand why heat would not adequately provide disinfest ion or why it would damage food processing equipment in US mill s . Please supply specific and

detailed r ecent results of successful and not successful attempts to adopt heat treatment (either full site of partial heat treatment) in the mills and food processing structures

included in the CUN.

CUN page 3, sector 1 says, “USG is requesting methyl bromide for this sector to allow time for the industry to purchase equipment, modify structures, and/or gain experience using alternatives.” If MBTOC has misunderstood the thrust of the CUN and if in fact the reason for the request for MB for this sector is financia l, then more information is requested. While appreciating the improved financial information provided in this year’s CUN, MBTOC notes that although, in both cases, costs of treatment increase, this increase is only a miniscule fraction of gross margins. Wi thout having been provided information to the contrary, MBTOC believes that one would also want to look at the proportionate change in costs, if an argument for the critical need for MB was to be made on economic (financial) grounds. Currently , MBTOC beli eves that in both the cases discussed in the CUN, proportionate change in costs would also be small. MBTOC does not find the nomination to be based on economic grounds, and with the current status of information provided, it would be difficult to recommen d an exemption on economic grounds. If the US believes our understanding of this matter is inadequate, please provide sufficient information showing the impact of the increased costs on business or industry disruption.

The nomination shows that the cost of changing to a heat treatment rather than using MB would result in an overall cost saving to the mill, when the mill purchases its own equipment and that assessment is made after the initial investment period. As the alternative to MB appears to offer the opportunity for the mill to operate cost effectively, what reasons do mill owners provide for using the more expensive option of MB fumigation?

It could be that mill structure, size, or other parameters are different in US mills and that

these diffe rences have been demonstrated to negatively affect the ability of US mills and food processors to adopt alternatives. But if so, please provide information on the size, construction, construction materials and age of the mills and food processing structure s which still need MB; it this information is not available, please explain why. Provide the technical or financial reports which demonstrate why the mills and structures included in the CUN have not been able to adopt alternatives to this point.MBTOC has an ongoing problem with all the US postharvest submissions in that we are

not told how much MB is actually being used, either in total or for any particular sector. Not knowing this, how can we predict what the genuine need will be in even the current year, let alone in two years time? Can this information be sent to us? If not, why is this

information not available ?

Please report the quantity of MB stocks that are held by each structural sector. If this

information cannot be made available to MBTOC please expain why.

Questions Pertaining to Cured Pork CUN

MBTOC is concerned to note that there does not appear to have been a decrease in MB CUN request during the last four years in spite of improvements in sanitation and

establishment of IPM. Why h as there been no decrease in MB requirement over 4 years in spite of expected improvements due to IPM proceedures?

According to the CUN, “ concentrations lower than 15 g/m3 MB could be used to achieve 100 % mortality of all life stages for red legged beetle s and levels less than 8 g/m3 could be used to achieve 100 % mortality in all life stages of ham mites at the bench top level (Sekhon, et al. 2009b; Phillips, 2009)”. We note, however, that the BUNNI dosage rate in the CUN ranges from 13 to 20 g/M3. Why ar e these higher dosage rates considered

necessary ? Why does the dosage rate vary between the four cured pork associations when the pests remain the same between facilities in each of the four associations?

Over the years, the CUN has reported improvements i n the cured pork facilities. Please provide an update by report ing the gas tightness of each cured pork facilities, using the

format from the nomination for fixed facilities:

Type of construction and approximate age in years Vol (m 3 ) or

range Number of f acilities e.g. 5 silos Gas

- tightness

estimate*

1

2

..45

Add more rows if required *Give gas

- tightness estimates where possible according to the following gas

- tightness scale: ‘A’

- less than 25% gas loss within 24 hours or half loss ti me of pressure difference (e.g. 20 to 10 Pa
(t 1/2 )) greater than 1 minute; ‘B’

– 25

- 50% gas loss within 24 hours or half loss time of pressure difference greater than 10 seconds; ‘C’

– 50

- 90% gas loss within 24 hours or half loss time of pressure differenc e 1

- 10 second: ‘D’

– more than 90% gas loss within 24 hours or a pressure half

loss time of less than 1 second.

According to the CUN , the reported a volume of area to be treated is 214,000M3. How much commodity will be treated and what is the stowage fa ctor?

Please report the quantity of MB stocks that are held by each cured pork facility and/or Association (Gwaltney, National Country Ham, Nuhunta Pork Centre, and American Assoc. of Meat Processors). If this information can not be made available to MBTO C please expain why.MBTOC acknowledges that this commodity and CUN present unusual challenges; we

continue to review the progress of the multi

- university research team with interest. MBTOC has been concerned that the phosphine treatment would prove to b e inadequate against mites. It is possible that changing treatment parameters or careful

conduct of successive treatments (allowing egg hatch between fumigations) might be avenues of investigation.

MBTOC members, knowing that the Party and its research sc ientists are grappling with a difficult challenge, would like to report that it can propose some o ther alternatives which work with similar cured meat products in Europe. (Although we acknowledge that each country’s cured meat products have variations whic h may affect infestation issues.) proposed:

Different types of Ham products are produced in Spain (in the south

- Jabugo, in the Pyrenees

– Serrano), France (Bayonne), Italy (Parma). Similar mite problems but no MB

is used in these areas. In the EU the u se of any kind of pesticide on hams is not approved.

In Spain and Germany, hams are dipp ed in a mixture of oil and lard at 90  ̊ C to control
mites. In these countries, t he mites are excluded mechanically from the ham by use of fine mesh gauze.

CA could be used but since the ham storage structures also require disinfestations, then adoption of CA would require a fast investment in new cured pork storage facilities.

There are also p rocedure s to avoid mite problems: IPM, fumigation of empty structures

with PH3 and other authorized pesticides, strict control of the relative humidity during the process (initial 75 % to allow salt penetration and afterwards gradually decrease to 65%), and control of moulds in the ham surface.

Questions Pertaining to Commodit y CUN

CUN Page 1, Section 1 says, “The USG is requesting methyl bromide for this sector to allow time for the industry to purchase equipment, build chambers, modify structures, and/or develop experience using alternatives.” MBTOC notes that the new econom ic data show that alternatives cost more, and that in the case of phosphine on walnuts the

actual costs increase threefold. This leads MBTOC to consider that perhaps the CUN is largel y based on financial concerns. In the absence of other information to the contrary, MBTOC, however, believes that the increased costs represent a miniscule proportion of the gross margin. If the USG believes MBTOC has incorrectly understood this situation, we ask the US to provide data on the proportionate change in costs becau se currently we believe these would be small. In summary, MBTOC does not find the nomination has adequately demonstrated the economic grounds for the application , and so it would be difficult to recommend an exemption on economic grounds alone

.

MBTOC SC will meet in Berlin Germany Feb 28

– March 1. We would appreciate your response so that we can circulate it before our meeting.

Thank you,

Michelle Marcotte

MBTOC Co

- Chair