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 Harvest Use on Structures -- Food Processing 

Plants (Submitted in 2009 for 2011 Use Season) 

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF 

NOMINATION: 

TABLE 1. QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF NOMINATION

YEAR NOMINATION AMOUNT (KILOGRAMS) 

2011 135,299 

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

Decision Ex. I/4(8).) 

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination 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 Party 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 paragraph (a)(1) United States of America has determined that the 

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

this use would result in a significant market disruption. ■ 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 convention 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 ENVIRONMENT) 

STRUCTURES 

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL USE

Food processing facilities in the United States have 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 facility. Facilities are now being monitored for 

pest populations, using visual inspections, pheromone traps, light traps, and electrocution traps. 

When insect pests are found, facilities will attempt 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 suitable. Incoming ingredients are inspected for 

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

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

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

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

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

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

bromide and sulfuryl fluoride. 

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

and detailed in Table 2. 

TABLE 2: NOMINATION AMOUNT

 Rice Millers Pet Food 

Institute 

 North American 

Millers 

 Sector Total / 

Average 

Quantity Requested for 2010: Amount (kgs) 13,722 14,511 163,760 191,993 

Quantity Recommended by 

MBTOC/TEAP for 2010 : Amount (kgs) 13,722 14,511 144,790 173,023 

Amount (kgs) 13,722 14,511 144,790 173,023 

Volume (1000 m3) 745 726 8,459 9,930 

Rate 18 20 17 17 

Transition from 2010 Baseline 

Adjusted Value

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

Amount (kgs) 13,722 14,511 107,066 135,299 

Volume (1000 m3) 726 745 5530 7001

Rate 18 20 19 19 

Quantity Approved by Parties for 

2010:

Quantity Required for 

2011 Nomination:

STRUCTURES

2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

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 facilities, that are unsuitable for the alternatives, 

and where the alternatives are not economically feasible. Sulfuryl fluoride is highly dependent 

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

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

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

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

control instrumentation. 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. 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 materials 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 interpretation is that all pet food products would need to be 

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

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

(e.g. cake mixes, muffin mixes, etc.). This may sufficiently 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 structural 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. Mill 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 average 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, although there is no significant difference 

between spring and summer. There is a major reduction 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 Campell (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 rebound after fumigation. He found that season 

and pest density did have an impact on rebound. Rebound 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 methyl bromide in mill fumigations (Tsai et al., 

2008) found that methyl bromide killed RFB and Indianmeal 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 fumigants on the mortality of larvae and adults. 

These were commercial fumigations, but rates and exposure 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 rate of eight months, whereas other mills had a 

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

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

by increasing rebound periods to an average of seven 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 Germany and UK that many mills have 

considerable numbers of surviving pests despite strict 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/m3

 in the laboratory but the 

field (structural) requires 20g/m3

. For sulfuryl fluoride, the CT for RFB post-embryonic is 113 

gh/m3 but eggs require 1,669 gh/m3. In addition to heat, the authors examine sulfuryl fluoride 

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

combination with hydrogen cyanide, but since cyanide 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 consuming, there is still a potential that 

further research may be able to overcome these weaknesses. (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 exposed to methoprene. The combination of 

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

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

combination was cost effective. 
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4. ECONOMIC INFEASIBILITY OF ALTERNATIVES

TABLE 4. ECONOMIC SUMMARY FOR EACH ALTERNATIVE

METHYL BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

HEAT TREATMENT

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

treatment) may experience economic losses from additional production downtimes 

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

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

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

SULFURYL FLUORIDE

A portion of the food processing facilities can economically 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 small 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 fluoride as an alternative to methyl bromide are 

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

methyl bromide were assumed equal and plant temperatures 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 temperatures controlling all pest life stages is 

infeasible due to prohibitively high application rates 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 food-processing facilities that have not been 

converted to heat treatment. This analysis only covers cases where heat treatment may 

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

commodity being processed (those with fats and edible 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. 
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TABLE 5. ANNUAL ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FOR RICE MILLER’S ASSOCIATION 

Rice Millers 1 Units MeBr 2 SF 2 Heat: 7 oC Heat: 29 oC SF + 7 oC HeatTotal Operating Costs $/year na na na na na Total Fumigation/Heat Costs $/year $ 24,300.00 $ 30,000.00 $ 70,000.00 $ 150,000.00 $ 100,000.00 

Quantity of Fumigant (One treatment per year) kgs/facility 703 1,134 na na na Fumigant cost (i.e., gas) $/year $ 9,300.00 $ 15,000.00 na na $ 15,000.00 Other fumigation costs (i.e., labor, equip., etc.) $/year $ 15,000.00 $ 15,000.00 $ 70,000.00 $ 150,000.00 $ 85,000.00 

Other Operating Costs $/year na na na na na Time Lost days 0 0 0 1 0Total Loss (MeBr to alt) $/year $ - $ 5,700.00 $ 45,700.00 $ 125,700.00 $ 75,700.00 Average Facility Loss per Kg MeBr Requested 

$/kg MB 

requested na 8.11 65.00 178.79 107.67 

1 Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility 

2 Temperature 29.44 degrees C 
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TABLE 6: ANNUAL ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FOR PET FOOD INSTITUTE

Pet Food 1 Units MeBr 2 SF 2 Heat: 7 oC Heat: 29 oC SF + 7oC Heat Gross Revenue $/year $ 33,176,000.00 $ 33,176,000.00 $ 33,176,000.00 $ 33,060,000.00 $ 33,176,000.00 Total Operating Costs $/year na na na na na Total Fumigation/Heat Costs $/year $ 9,612.50 $ 11,637.50 $ 17,500.00 $ 37,500.00 $ 29,137.50 

Quantity of Fumigant (One treatment per year) 

Kgs/facilit

y/ 

treatment 18.42 40.05 na na na

Fumigant cost (i.e., gas) $/year $ 782.45 $ 1,700.97 na na $ 1,700.97 Other fumigation costs (i.e., labor, equip., etc.) $/year $ 3,577.71 $ 3,577.71 $ 7,937.87 $ 17,009.71 $ 11,515.58 

Other Operating Costs $/year na na na na na Time Lost days 0 0 0 1 0Total Loss (MeBr to alt) $/year $ - $ 2,025.00 $ 7,887.50 $ 27,887.50 $ 19,525.00 Average Facility Loss per Kg MeBr Requested 

$/kg MB 

requested $ - $ 109.93 $ 428.17 $ 1,513.88 $ 1,059.92 

Loss as % of GR with MeBr 0% 0.01% 0.02% 0.08% 0.06%

1 Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility 

2 Temperature 29.44 degrees C 
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TABLE 7. ANNUAL ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FOR NORTH AMERICAN MILLER’S ASSOCIATION 

NAMA** Units MeBr 2 SF 2 Heat: 7oC Heat: 29 oC SF + 7oC Heat Total Operating Costs $/year na na na na na Total Fumigation/Heat Costs $/year $ 13,001.75 $ 26,932.75 $ 70,000.00 $ 150,000.00 $ 96,932.75 

Quantity of Fumigant kgs/facility 566.99 1,587.57 na na naFumigant cost (i.e., gas) $/year $ 7,500.00 $ 21,000.00 na na $ 21,000.00 Other fumigation costs (i.e., labor, equip., etc.) $/year $ 5,501.75 $ 5,932.75 $ 70,000.00 $ 150,000.00 $ 75,932.75 

Other Operating Costs $/year na na na na na Time Lost days 0 0 0 1 0Total Annual Loss (MeBr to alt) $/year $ - $ 13,931.00 $ 56,998.25 $ 136,998.25 $ 83,931.00 Average Facility Loss per Kg MeBr Requested 

$/kg MB 

requested $ - $ 24.57 $ 100.53 $ 241.62 $ 148.03 

1 Analysis for a 28,317 cubic meter (1,000,000 cubic foot) facility 

2 Temperature at 29.44 degrees C 
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CITATIONS: 

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

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

Economic Consulting LLC. 

Arthur, F. H., E. A. Jenson, and J. R. Nechols. 2008. Esfenvalerate plus methoprene aerosol to control 

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

http://mbao.org 

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

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

Reichmuth, C. and D. Klementz. 2008. How to overcome 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. Maier. 2008. Sulfuryl fluoride and methyl bromide 

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

Available at: http://mbao.org