### USA CUN11 POST HARVEST – Structures Food Processing Plants Page 1 of 10



# 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 CUN11 POST HARVEST STRUCTURES - FOOD PROCESSING

PLANTS

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Post Har vest Use on Structures -- Food Processing

Plants (Submitted in 2009 for 2011 Use Season)

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR O F

NOMINATION:

T ABLE 

### 1. Q UANTITY OF 

### M ETHYL 

### B ROMIDE 

### R EQUESTED IN 

### E ACH 

### Y EAR OF 

### N OMINATION



### Y EAR 

### N OMINATION 

### A MOUNT 

### ( KILOGRAMS 

### )

2011 135,299

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat we bsite under

Decision Ex. I/4(8).)

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomi nation 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 Pa rty need not

re-submit that earlier information.

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Hodayah Finman

Title: Foreign Affairs Officer

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) 647-1123

Fax: (202) 647-5947

E-mail: finmanhh@state.gov

Following the requirements of Decision IX/6 paragra ph (a)(1) United States of America has determined t hat the

specific use detailed in this Critical Use Nominati on is critical because the lack of availability of methyl bromide for

this use would result in a significant market disru ption. ■ Yes 

###  No

Signature Name Date

Title:

### USA CUN11 POST HARVEST – Structures Food Processing Plants Page 2 of 10

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger

Title: Director (Acting)

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 CUN11 POST HARVEST STRUCTURES - FOOD PROCESSING

PLANTS 10

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS:

*Title of each electronic file (for naming conventi on see notes above) No. of

kilobytes Date sent to Ozone

Secretariat

USA CUN11 POST HARVEST STRUCTURES - FOOD PROCESSING

PLANTS

* Identical to paper documents

### USA CUN11 POST HARVEST – Structures Food Processing Plants Page 3 of 10



# METHYL BROMIDE CRITICAL USE RENOMINATION FOR

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONM ENT)

STRUCTURES

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICA L USE

Food processing facilities in the United States hav e 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 fa cility. Facilities are now being monitored for

pest populations, using visual inspections, pheromo ne traps, light traps, and electrocution traps.

When insect pests are found, facilities will attemp t 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 su itable. Incoming ingredients are inspected for

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

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

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

all these methods fail to control a pest problem, f acilities must rely on fumigation, to kill insects

within the processing equipment, bins, storage spac es and even the walls of the structure. There

are two primary fumigants available to this industr y that may accomplish these tasks: methyl

bromide and sulfuryl fluoride.

The USG has applied an aggressive transition rate w hich is reflected in the nomination amount

and detailed in Table 2.

T ABLE 

### 2: N OMINATION 

### A MOUNT

Rice Millers Pet Food

Institute North American

Millers Sector Total /

Average

Quantity Requested for 2010: Amount (kgs) 14,511 13,722

163,760

191,993

Quantity Recommended by

MBTOC/TEAP for 2010 : Amount (kgs) 14,511 13,722

144,790

173,023

Amount (kgs) 14,511

13,722

144,790

173,023

Volume (1000 m 3 ) 726

745

8,459

9,930

Rate 20

18

17

17

Transition from 2010 Baseline

Adjusted Value Percentage (%) -82% -56% -58% -63%

Amount (kgs) 

## 14,511

13,722

107,066

135,299

Volume (1000 m 3 ) 

## 726 745 5530 7001

Rate 

## 20

18

19

19 Quantity Approved by Parties for

2010:



## Quantity Required for

2011 Nomination: STRUCTURES 

## 2011 Methyl Bromide Usage Newer Numerical Index (BU NNI)

Transition Use Reduction Description Spreadsheet

SECTOR

### USA CUN11 POST HARVEST – Structures Food Processing Plants Page 4 of 10



## 2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

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

, and where the alternatives are not economically fea sible. Sulfuryl fluoride is highly dependent

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

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

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

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

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

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

which affect the ability to evenly distribute heate d 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 mate rials 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 interpretatio n is that all pet food products would need to be

removed from treatment areas or sufficiently protec ted to prevent the formation of sulfuryl

fluoride residues within the pet food products. Th is is also a factor for mills that produce mixes

(e.g. cake mixes, muffin mixes, etc.). This may su fficiently increase the costs and timing

considerations for sulfuryl fluoride use on a host of processed foods and ingredients.

3. RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES

Jim Campbell (2008) evaluated efficacy of structura l fumigations. He investigated trap catches

of Tribolium castaneum , red flour beetle (RFB), in two flour mills. Mill 1 had 8 methyl bromide

fumigations and 2 sulfuryl fluoride fumigations. M ill 2 had 11 methyl bromide fumigations.

The average trap capture was higher in Mill 1 than in Mill 2, with a reduction of 93% and 67%,

respectively, after fumigation. In addition, the a verage proportion of traps with RFB was

reduced after fumigation (62% and 66%, respectively ). Campbell (2008) also examined the

seasonal impact of fumigation efficacy. In Mill 1 he reports that the mean trap captures in

summer are higher than in either spring or fall, al though there is no significant difference

between spring and summer. There is a major reduct ion of in mean trap captures after

fumigation, regardless of time of year. Mill 2 has higher mean trap captures in the fall, but again

reduction after fumigation. Spring fumigations at Mill 1 results summarized in Table 3 below:

Table 3. Summary of Trap Capture Reductions by Cam pell (2008).

Reduction

Fumigant % Average Trap

Capture % Proportion of Traps with

Captures

Sulfuryl Fluoride, low rate 98 71

Sulfuryl Fluoride, high rate 96 93

Methyl Bromide, normal rate,

single 84 28

Methyl Bromide, normal rate, 92 55

### USA CUN11 POST HARVEST – Structures Food Processing Plants Page 5 of 10



## overall average

Campbell (2008) also presented data regarding rebou nd after fumigation. He found that season

and pest density did have an impact on rebound. Re bound was slower during the fall. The use

of aerosols and enhanced IPM also slowed rebound. This multiyear study has taken place in

only two flour mills, and needs to be demonstrated in other locations.

One study that compared sulfuryl fluoride and methy l bromide in mill fumigations (Tsai et al

., 2008) found that methyl bromide killed RFB and Indi anmeal moth (IMM) eggs more effectively

than sulfuryl fluoride, but that sulfuryl fluoride killed RFB and IMM pupae better than did

methyl bromide. There was no difference in the fum igants on the mortality of larvae and adults.

These were commercial fumigations, but rates and ex posure times were not reported. Rebound

in the mills in the study varied by both season and mill. For example, one mill which responded

only under critical conditions averaged a rebound r ate of eight months, whereas other mills had a

spring rebound average of three months. Summer pop ulations of flour beetle averaged a nearly

five-month rebound period. Fall fumigations took a dvantage of the lower ambient temperature

by increasing rebound periods to an average of seve n months. (Tsai et al ., 2008)

Reichmuth and Klementz (2008) have investigated how to improve the use of sulfuryl fluoride to

manage pest populations. They report that in Germa ny and UK that many mills have

considerable numbers of surviving pests despite str ict dosage schedules. The authors propose an

increased dosage of sulfuryl fluoride or perhaps to use the fumigant in combination with heat or

another chemical. They cite the methyl bromide CT for RFB as 5 g/m 3 

## in the laboratory but the

field (structural) requires 20g/m 3 

## . For sulfuryl fluoride, the CT for RFB post-embry onic is 113

gh/m 3 

## but eggs require 1,669 gh/m 3 

## . In addition to heat, the authors examine sulfury l fluoride

with phosphine, with carbon dioxide, with hydrogen cyanide. They provided data on the

combination with hydrogen cyanide, but since cyanid e is not registered for use in the U.S., it will

not be considered further. The authors also looked at Pulsed Fumigation. As the authors noted

this method has a longer down time and potentially an MRL problem. The conclusion was that

although these combinations may be clumsy or time c onsuming, there is still a potential that

further research may be able to overcome these weak nesses. (Reichmuth and Klementz, 2008)

Indianmeal moth is a ubiquitous stored product pest and information on aerosol efficacy on eggs

and larvae is limited. One investigation examined methoprene alone and in combination with

esfenvalerate (Arthur et al ., 2008). Percent mortality of IMM eggs exposed to esfenvalerate was

about 65% and about 65% when exposed to methoprene. Percent mortality of IMM larvae

exposed to esfenvalerate was 10% but 99.6% when exp osed to methoprene. The combination of

esfenvalerate aerosol with an IGR like methoprene d oes control eggs and larvae of IMM. In

addition to efficacy, an economic analysis was also conducted, which demonstrated that this

combination was cost effective.

### USA CUN11 POST HARVEST – Structures Food Processing Plants Page 6 of 10



## 4. ECONOMIC INFEASIBILITY OF ALTERNATIVES

T ABLE 

### 4. E CONOMIC 

### S UMMARY FOR EACH 

### A LTERNATIVE



### M ETHYL 

### B ROMIDE



### A LTERNATIVE 

### E CONOMIC 

### S UMMARY



### H EAT 

### T REATMENT 

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

treatment) may experience economic losses from addi tional production downtimes

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

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

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

S ULFURYL 

### F LUORIDE 

### A portion of the food processing facilities can eco nomically 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 sma ll percentage, SF is not technically

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

economically feasible option.



## Sulfuryl Fluoride

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

provided in Tables 2-4. For purposes of this analy sis, current prices of sulfuryl fluoride and

methyl bromide were assumed equal and plant tempera tures 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 temperat ures controlling all pest life stages is

infeasible due to prohibitively high application ra tes 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 fo od-processing facilities that have not been

converted to heat treatment. This analysis only co vers cases where heat treatment may

potentially be technically feasible, and does not c over situations where heat would degrade the

commodity being processed (those with fats and edib le 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.USA CUN11 POST HARVEST – Structures Food ProcessingPlants Page 7 of 10TABLE5.ANNUALECONOMICIMPACTS OFMETHYLBROMIDEALTERNATIVES FORRICEMILLER’SASSOCIATIONRice Millers1UnitsMeBr2SF2Heat: 7 oCHeat: 29 oCSF + 7 oC HeatTotal Operating Costs$/yearnananananaTotal Fumigation/Heat Costs$/year$ 24,300.00$ 30,000.00$ 70,000.00$ 150,000.00$ 100,000.00Quantity of Fumigant(One treatment per year)kgs/facility7031,134nananaFumigant cost (i.e., gas)$/year$ 9,300.00$ 15,000.00nana$ 15,000.00Other fumigation costs(i.e., labor, equip., etc.)$/year$ 15,000.00$ 15,000.00$ 70,000.00$ 150,000.00$ 85,000.00Other Operating Costs$/yearnananananaTime Lostdays00010Total Loss (MeBr to alt)$/year$ -$ 5,700.00$ 45,700.00$ 125,700.00$ 75,700.00Average Facility Loss per KgMeBr Requested$/kg MBrequestedna8.1165.00178.79107.671Analysis for a 28,317 cubic meter (1,000,000 cubicfoot) facility2Temperature 29.44 degrees CUSA CUN11 POST HARVEST – Structures Food ProcessingPlants Page 8 of 10TABLE6:ANNUALECONOMICIMPACTS OFMETHYLBROMIDEALTERNATIVES FORPETFOODINSTITUTEPet Food1UnitsMeBr2SF2Heat: 7 oCHeat: 29 oCSF + 7oC HeatGross Revenue$/year$ 33,176,000.00$ 33,176,000.00$ 33,176,000.00$ 33,060,000.00$ 33,176,000.00Total Operating Costs$/yearnananananaTotal Fumigation/Heat Costs$/year$ 9,612.50$ 11,637.50$ 17,500.00$ 37,500.00$ 29,137.50Quantity of Fumigant(One treatment per year)Kgs/facility/treatment18.4240.05nananaFumigant cost (i.e., gas)$/year$ 782.45$ 1,700.97nana$ 1,700.97Other fumigation costs(i.e., labor, equip., etc.)$/year$ 3,577.71$ 3,577.71$ 7,937.87$ 17,009.71$ 11,515.58Other Operating Costs$/yearnananananaTime Lostdays00010Total Loss (MeBr to alt)$/year$ -$ 2,025.00$ 7,887.50$ 27,887.50$ 19,525.00Average Facility Loss per KgMeBr Requested$/kg MBrequested$ -$ 109.93$ 428.17$ 1,513.88$ 1,059.92Loss as % of GR with MeBr0%0.01%0.02%0.08%0.06%1Analysis for a 28,317 cubic meter (1,000,000 cubicfoot) facility2Temperature 29.44 degrees CUSA CUN11 POST HARVEST – Structures Food ProcessingPlants Page 9 of 10TABLE7.ANNUALECONOMICIMPACTS OFMETHYLBROMIDEALTERNATIVES FORNORTHAMERICANMILLER’SASSOCIATIONNAMA**UnitsMeBr2SF2Heat: 7oCHeat: 29 oCSF + 7oC HeatTotal Operating Costs$/yearnananananaTotal Fumigation/Heat Costs$/year$ 13,001.75$ 26,932.75$ 70,000.00$ 150,000.00$ 96,932.75Quantity of Fumigantkgs/facility566.991,587.57nananaFumigant cost (i.e., gas)$/year$ 7,500.00$ 21,000.00nana$ 21,000.00Other fumigation costs(i.e., labor, equip., etc.)$/year$ 5,501.75$ 5,932.75$ 70,000.00$ 150,000.00$ 75,932.75Other Operating Costs$/yearnananananaTime Lostdays00010Total Annual Loss (MeBr toalt)$/year$ -$ 13,931.00$ 56,998.25$ 136,998.25$ 83,931.00Average Facility Loss per KgMeBr Requested$/kg MBrequested$ -$ 24.57$ 100.53$ 241.62$ 148.031Analysis for a 28,317 cubic meter (1,000,000 cubicfoot) facility2Temperature at 29.44 degrees C

### USA CUN11 POST HARVEST – Structures Food Processing Plants Page 10 of 10



## CITATIONS:

Adam, Brian D. 2007. Cost comparison of methyl brom ide and ProFume for fumigating a food

processing facility. A report to National Pest Mana gement Association and Dow AgroSciences.

Economic Consulting LLC.

Arthur, F. H., E. A. Jenson, and J. R. Nechols. 20 08. Esfenvalerate plus methoprene aerosol to contr ol

the Indianmeal moth. Presented at MBAO, Orlando, F l. November 2008. Available at:

http://mbao.org

Campbell, J.F. 2008. Evaluating Impact of Structu ral fumigations on pest populations. Presented at

MBAO, Orlando, Fl. November 2008. Available at: http://mbao.org

Reichmuth, C. and D. Klementz. 2008. How to overc ome the egg-weakness of sulfuryl fluoride –

combinations of control methods. Presented at MBAO , Orlando, Fl. November 2008. Available at:

http://mbao.org

Tsai, W-T., L. J. Mason, K. E. Ieleji, and D. E. Ma ier. 2008. Sulfuryl fluoride and methyl bromide

fumigations in Midwestern US flour mills. Presente d at MBAO, Orlando, Fl. Novermber 2008.

Available at: http://mbao.org