### METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST -- DRY CURED PORK PRODUCTS

NOMINATING PARTY: The United States of America

FILE NAME USA CUN12 POST HARVEST -- DRY, CURED PORK PRODUCTS

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Post Harvest Use on Dry Cured Pork Products (Submitted in 2010 for 2012 Use Season)

STRUCTURE, COMMODITY OR OBJECT TREATED:
This sector is for the production of cured m eat products, such as country hams. These are produced primarily in the southern U.S. This sector has no known viable alternative currently

available.

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF

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 )

2012 3,730

(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: John Thompson

Title: Division Director 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) 647-9799 Fax: (202) 647-5947

E-mail: Thompsonje2@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

USA CUN12 POST HARVEST -- Dry, Cured Pork Products Page 1Signature Name Date

Title:

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

C ontact/Expert Person: Jack Housenger

Title: Division 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: 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 CUN12 Post Harvest Dry, Cured Pork Products

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 CUN12 Post Harvest Dry, Cured Pork Products

* Identical to paper documents

USA CUN12 POST HARVEST -- Dry, Cured Pork Products Page 2

### METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST -- DRY CURED PORK PRODUCTS

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

Currently there are no viable alte rnatives to methyl bromide for the dried meat industry: heat would alter the product, and phosphine may not cont rol mites, a major pest. Sulfuryl fluoride received federal registration and has been tested for efficacy against the m ites and other pests of cured meat products. Although mortality of the re d-legged ham beetle occurred at levels below maximum rates of sulfuryl fluoride, the same cannot be said for the ham mites (Phillips, et al., 2008). Control of the ham mites took three times the legal limits of sulfuryl fluoride (Phillips, et al., 2008). At the time of this nomination ther e are no known registered alternatives for use on hams in the U.S. that provide the same le vel of pest control as methyl bromide.

This industry is cooperating with university rese archers to find technically and economically feasible alternatives to methyl bromide. In the meantime, this industry is using IPM techniques to manage their pest populations. All use sanitati on to keep their curing facilities clean. Several companies have modified their buildings to ma ke them more gas-tight. Some companies are eliminating grass, trees, and shrubs from thei r buildings and replacing it with gravel, as suggested by researchers last year. Many use pheromone traps; however, these traps only used for monitoring purposes at this time (Arthur and Phillips, 2003).

This industry currently has no viab le chemical alternative availa ble. Although its IPM measures may have reduced the number of times fumigatio n is needed in some facilities, it has not eliminated the need for fumigation. Therefore, met hyl bromide remains critical to this industry.

T ABLE 2. N OMINATION A MOUNT

Gwaltney of

Smithfield National Country

Ham Association Nahunta Pork

Center American Assoc.

of Meat

Processors Sector Total /
Average

Quantity Requested for 2011: Amount (kgs) 726 709 91 2,204 3,730

Quantity Recommended by

MBTOC/TEAP for 2011 : Amount (kgs) 726 709 91 2,204 3,730

Amount (kgs) 726 709 91 2,204 3,730

Volume (1000 m 3 ) 56 42 5 110 213

Rate 13 17 19 20 18

Transition from 2011 Baseline Adjusted Value Percentage (%) 0% 0% 0% 0% 0%

Amount (kgs) 726 709 91 2,204 3,730

Volume (1000 m 3 ) 56 42 5 110 213

Rate 13 17 18 20 18 HAM

Quantity Approved by Parties for

2011:

Quantity Required for

2012 Nomination: SECTOR

USA CUN12 POST HARVEST -- Dry, Cured Pork Products Page 32. SUMMARIZE WHY ALTERNATIVES ARE NOT FEASIBLE

This industry currently has no known viable chemical alternative availa ble. Although its IPM measures may have reduced the number of times fu migation is needed, it has not eliminated the need for fumigation. Therefore, methyl br omide remains critical to this industry.

3. RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES

Researchers are investigating cont rol of the arthropod pe sts on dry cured pork products. In the spring of 2007 a proposal was submitted to USDA CS REES Integrated Research, Education, and Extension Competitive Grants Program- Methyl Bromide Transitions by several meat scientists and an entomologist. This proposal wa s funded for the next three years.

There are several objectives to this multiple year research program: First is to determine the

effectiveness of chemical contro ls (sulfuryl fluoride, phosphine, a nd methyl bromide) against all life stages of both mold mites ( Tyrophagus putrescentiae ) and red legged ham beetles ( Necrobia rufipes ). Second objective is to determine the e ffectiveness of carbon dioxi de and ozone against all life stages of both mold mites and red legged ham beetles. The third objective is to test the effects of sulfuryl fluoride, phosphine and methyl bromide on the quality and safety of the dry cured hams. The fourth objective is to conduct an economic analysis of the alternatives demonstrated to be technically viable alterna tives for methyl bromide in this industry.

The results of sulfuryl fluorid e efficacy investigations on Tyrophagous putrescentiae , ham mite,

and Necrobia rufipes , red-legged ham beetle, were presen ted at the 2008 MBAO Conference, in Orlando, Fl. The studies included eggs and a mixture of adults and large nymphs of mites and the eggs, large larvae, pupae and adults of beetles. The experiments were conducted for 48 hours

at 23° C at various concentra tions of sulfuryl fluoride. The investigator s achieved 100% mortality of red-legged ham beetle adults and pupae at about 4.0 g/m 3 , 100% mortality of larvae at 5.7 g/m 3 . Eggs of red-legged ham beetles died at 24.0 g/m 3 of sulfuryl fluoride, well below the maximum label rate (Phillips, et al. 2008). Mortality of ham mites required much higher concentrations of sulfuryl fluoride. A concentration of about 100.3 g/m 3 was necessary to obtain 100% mortality of adults and nymphs under the te st conditions. However this concentration obtained only a 95% mortality of mite eggs. Th is is about three times the legal label rate (Phillips, et al. 2008) and thus indi cates that sulfuryl fluoride is not a viable alternative to methyl bromide for controlling ham mites.

The results of carbon dioxide, phosphine, methyl bromide and ozone efficacy investigations on Tyrophagous putrescentiae , ham mite, and Necrobia rufipes , red-legged ham beetle, were presented at the 2009 MBAO Conference, in San Diego, CA (Sekhon, et al. 2009a, b; Phillips, 2009). The studies included eggs and a mixture of adults and nymphs of mites and eggs, large larvae, pupae and adults of beetles. The experi ments were conducted for va riable times at 23° C at various concentrations of carbon dioxide, phosphine, methyl bromide and ozone. The investigators achieved mortality of all life stages of mites wi th a concentration of 60 % carbon dioxide with 144 hr of exposure (Sekhon, et al . 2009a; Phillips, 2009). However, fumigation with carbon dioxide would likely not be applicable since ham stru ctures are not air-tight and 144

USA CUN12 POST HARVEST -- Dry, Cured Pork Products Page 4hr is too long of a time to fumigate the hams. In addition, a carbon diox ide concentration (> 80 %) with an exposure time of 144 hrs was necessary to cause 100 % mortality for all life stages of red legged ham beetles (Sekhon, et al. 2009a; Phillips, 2009). Investigators achieved 100 % mortality of all life stages of red legged ham beetles and ham mites with 48 hours exposure of 400 and 1000 ppm of phosphine, respectively (Se khon, et al. 2009b; Phillips, 2009). In addition, residual phosphine concentrations in dry cured hams that were fumigated for 48 hrs at 1000 ppm were below 0.01 ppm, the legal residual limit in stored food products (Sekhon, et al. 2009b), and consumer panelists could not detect differe nces between control and phosphine fumigated samples at 1000 ppm (Sekhon, et al. 2009b). Theref ore, phosphine can now be considered a potential alternative to methyl bromide for co ntrolling arthropod pests of southern dry cured hams. However, phosphine fumigation needs to be evaluated at the plant level to evaluate its

effectiveness and economic feasib ility in real world applicati ons. In addition, phosphine has some potential shortcomings such as corrosion of metal and potential pest resistance by mites which could lead to an increase in required conc entrations and exposure times when compared to laboratory testing. Phosphine is also not currently registered fo r use with dry cured hams so registration would need to be approved before it could be used by the industry. Ozone also showed potential for use as a fumigant. Ozone co ncentrations of greater than 150 ppm for 48 hrs were able to achieve 100 % mortality of ham b eetles and mites at the bench top level (Sekhon, et al. 2009b; Phillips, 2009). Consumers also coul d not determine sensory differences between control hams and those that were fumigated w ith ozone at 175 ppm for 48 hrs (Schilling, 2009). However, ozone is not able to penetrate surface s and therefore may not work well in real world applications since ham mites coul d potentially penetrate into meat surfaces and ham beetles bore through the meat tissue. Theref ore, further testing needs be conducted at the plant level to determine if ozone can be considered a potential a lternative to methyl bromide. Ozone is also an

effective sanitizer and would bene fit processors as part of thei r integrated pest management program since it would sanitize areas in the plan t as well as equipment that could potentially harbor bugs and pathogens.

Researchers also tested the e fficacy of methyl bromide against ham mites and red legged ham

beetles. Researchers determined th at concentrations lower than 15 g/m 3 could be used to achieve 100 % mortality of all life stages for red le gged beetles and levels less than 8 g/m 3 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). This reveals that fumigation levels should be tested at the plant level to determine if levels could be decreased from the 24 g/m 3 that is commonly used in the industry. This may not be possible at the plant level since many buildings ar e not air tight but should still tested to attempt to reduce methyl bromide use as much as possible.

One alternative that could be i nvestigated is the method reported from Spain on dipping infested

hams into a mixture of hot lard and oil at 90 o C. U.S. researchers wi ll need to receive more details on the methods for oil dipping and then de sign an experimental prot ocol to address this for efficacy against ham mites and ham beetles, and also for any adverse effect against ham products.

4. REGISTRATION UPDATE

No new chemicals have been registered nor de-registered since th e last nomination.

USA CUN12 POST HARVEST -- Dry, Cured Pork Products Page 5USA CUN12 POST HARVEST -- Dry, Cured Pork Products Page 6 5. ECONOMIC INFEASIBILITY OF ALTERNATIVES

An economic analysis was not conducted becaus e this sector has no technically feasible

alternatives at this time.

CITATIONS

Arthur, F. and T. W. Phillips. 2003. Stored-product insect pest management and control, In: Food Plant Sanitation eds: Y. H. Hui, B. L. Br uinsma, J. R. Gorham, W. Nip, P. S. Tong, and P. Ventresca. Marcel Dekker, Inc., New York, pp. 341-358.

Phillips, Thomas W., Md. Mahbub Hasaan, M. Ja mie Aikins, and M. Wes Schilling. 2008. Efficacy of sulfuryl fluoride to control ham m ites and red-legged ham beetles. Presentation at MBAO, Orlando, Fl. November 12, 2008.

Phillips, T.W. 2009. Personal Communication.

Schilling, M.W. 2009. Personal Communication.

Sekhon, R.K., Schilling, M.W., Phillips, T.W., Hasan, M.M., Aikens, M. J., Mikel, W.B. 2009a. Chemical Composition of dry cured ha ms fumigated with carbon dioxide.

Sekhon, R.K., Schilling, M.W., Phillips, T.W., Ha san, M.M., Aikens, M.J., Mikel, W.B. 2009b. Chemical Composition of dry cured hams fumigated with phosphine.