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 Officer

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 postharvest 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 treatment 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 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.” 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 companies 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, however, 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 company, 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 CUN. Cereal milling equipment is generally the same worldwide, so it is 

difficult for MBTOC to understand why heat would not adequately provide disinfestion or 

why it would damage food processing equipment in US mills. Please supply specific and 

detailed recent 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 financial, 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. Without 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 believes 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 recommend 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 differences 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 structures 

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 has 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 beetles 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 are 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 in the cured pork facilities. Please

provide an update by reporting 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 (m3) or 

range

Number of facilities 

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 time of pressure difference (e.g. 20 to 10 Pa 

(t1/2)) 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 difference 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 factor? 

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 MBTOC 

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 be 

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 scientists are grappling with 

a difficult challenge, would like to report that it can propose some other alternatives

which work with similar cured meat products in Europe. (Although we acknowledge that 

each country’s cured meat products have variations which 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 use of any kind of pesticide on hams is not 

approved.

In Spain and Germany, hams are dipped in a mixture of oil and lard at 90 ̊C to control 

mites. In these countries, the 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 procedures 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 Commodity 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 economic 

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 

largely 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 because 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