Summary of the US EPA Analysis

of the Methyl Bromide Critical Use Exemption for Use in 2015

APPLICANTS

CUE 0015: CA Dried Plum Board

CUE 0030: CA Walnut Commission 

MBTOC REQUESTED DATA:

MBTOC: data must be provided to demonstrate that supplemental heater cannot be used to increase 

the efficacy of SF

MBTOC: after 10 years, efforts must have been made to prevent re-infestation in storage or ability 

to use something other than MBr 

EPA ANALYSIS: 

Technical:

Insufficient evidence to estimate number of facilities with high pest pressure

Insufficient evidence to estimate loss of commodity due to pests

Walnut applicant supplied ambient low temperatures during winter, but not warehouse/commodity 

temperature.

New pest feeds on mold, and requires high relative humidity to survive--occurrence indicates 

sanitation problem, not need for MBr. 

Stored product pests not active at temperatures near 55°F; in fact, USDA recommends storage at 

55°F or below for insect & pathogen prevention. No evidence that fumigation at these temperatures 

is critical. 

Data indicate Sulfuryl Fluoride (SF) effective against key pests. Low temperature data demonstrate 

lack of performance on pest eggs (esp. dried fruit beetle (DFB); but storage/harvest temperatures 

not provided. Also variable results in studies. 

Applicants told MBTOC during Fall 2010 conference call that 90+% of industry had transitioned 

to SF because MBr was either too expensive or unavailable. 

Economic (Walnut Example):

SF treatment for a facility is $4,000 less than MeBr

SF treatment plus heat is $4,000 more expensive than MeBr (due to cost of equipment) despite 

the fact that the cost of the heat is somewhat offset by the reduced need for sulfuryl fluoride

A yearly program with 2 SF treatments added to 1 SF treatment plus heat is ~ $ 4,000 less than 3 

treatments of MeBr per year

Net revenue for fumigated quantities is over $440 million dollars per year so cost difference is 

0.00% of gross revenue (less than 1/100th of a percent).

Regulatory Constraints:

None; SF registered for these uses. 

Emissions:

Reduction of number of fumigations indicative of reducing emissions

Market Disruption:

No evidence to demonstrate market disruption.

Synopsis of Alternatives

Sulfuryl Fluoride (SF)

Works well on post-embryonic life stages; matches MBr at higher temperatures; egg kill reduced 
at lower temperatures, esp. for dried fruit beetle and carob moth; extended exposure time can 

significantly reduce concentration; increase temperature can reduce concentration; combination 

of time, temperature & concentration.

No significant cost difference (activities & material cost) similar or less than MBr

Commodities in storage do not have time constraints

Currently registered for these uses (Proposed regulatory actions published in 2011 and 2012; no 

Final Rule)

Phosphine (PH3)

Needs more time than MBr or SF; some stored product pests resistant; needs much less gas than 

MBr

Because of time constraint not an option at peak harvest; but for storage is an option

Stored commodities should not require a rapid turn-around time

Cheaper than MBr, but to accommodate through-put during harvest, more fumigation chambers 

required (10-15x more)

No regulatory constraints

Propylene Oxide

Very effective on insect eggs

More expensive

Regulatory constraints: maximum volume is 10,000 ft3, commodity must be heated to 100°F

Table 1. Analysis of transition to alternatives for walnuts (metric). 

Methyl Bromide Sulfuryl Fluoride Phosphine

Cubic meters to be treated (example) 7,450 7,450 7,450

Total gas needed for fumigation (kg) 179 239 30

Price of fumigant ($/kg) 39.68 11.02 9.37

Total cost of fumigant gas ($) 7,103 2,631 280

Cost difference between MBr & alternative 

($) --- (4,472) (6,824)

Assumes rate of 24 g/cu m for MeBr, 32 g/cu m for SF, 4 g/cu m for PH3). 

Temperatures at harvest are fairly high so rates should be similar. 

EPA CONCLUSION:

Dried fruit (dried plums, figs, raisins, and walnuts) in storage not critical. The industry 

has mostly converted to SF, and no market disruption has occurred. Time is not critical 

in storage therefore, product treated with SF or PH3 can be held for relatively long 

periods of time without impacting industry and SF or PH3 can be used. 

OTHER CONSTRAINTS

Fluoride Action Network, Environmental Work Group, and Beyond Pesticides have petitions 

requesting the cancellation of tolerances for Sulfuryl Fluoride. USEPA is currently addressing 

public comment related to a proposed rule to grant the stay of tolerances. 

The Proposed Order granting objections to tolerances for Sulfuryl Fluoride was published. No 

Final Rule has been published.

REFERENCES:

Stored Product Protection. 2012. Eds: DW Hagstrum, TW Phillips, and G Cuperus. K-State Research 

and Extension. http://www.ksre.ksu.edu/bookstore/pubs/S156.pdf Several Chapters including but limited 

to: 
Burks, CS, and JA Johnson. Biology, behavior, and ecology of stored fruit and nut insects. Chapter 

3, p 21-31.

Arthur, FH and B Subramanyam. Chemical Control in Stored Products. Chapter 9, p. 95-100. 

Barakat, D. A., D. Klementz, and C. Reichmuth, 2009. Response of Eggs of Corcyra cephalonica 

towards Sulfuryl Fluoride. Presentation at 2009 MBAO, Nov. 10-12, 2009, San Diego, CA. 

Available online at: http://mbao.org/2009/061Reichmuth.pdf. 

Burks, Charles S. and L.P.S. Kuenen. 2011. Monitoring Indianmeal moth in the presence of mating 

disruption. Presentation at the 2011 Annual International Research Conference on Methyl Bromide 

Alternatives, San Diego, CA, Oct 31-Nov 2, 2011. Available at: 

http://mbao.org/2011/59Burks.pdf. 

Emekci, Mevlut (55) 2010. The efficacy of sulfuryl fluoride against egg stage of the dried fruit beetle.

Presentation at 2010 MBAO, Nov. 1-5, 2010, Orlando, Fl. Available at: 

http://mbao.org/2010/55Emeki.pdf. 

Ferizli, Guray (56) 2010. Does sulfuryl fluoride and heat combination overcome the egg weakness of 

almond moth? Presentation at 2010 MBAO, Nov. 1-5, 2010, Orlando, Fl. Available at:

http://mbao.org/2010/56Ferizli.pdf. 

Hosoda, Ed. 2009. California ProFume Update, 2009. Presentation at 2009 MBAO, Nov. 10-12, 2009, 

San Diego, CA. Available online at: http://mbao.org/2009/069Hosada.pdf. 

Hosoda, Ed. 2008. Eco2Fume® and VaporPH3OS®. Presentation at 2008 MBAO, Nov. 11-14, 2008, 

Orlando, Fl. Available at: http://mbao.org/2008/125Hosoda.pdf

Johnson, Judy. 2012. High Temperature CO2 Treatments for inshell walnuts. 2012 MBAO, Orlando, 

Florida, November 6-8, 2013. Presentations number 37 available at: http://mbao.org/. 

Liu, Yong-Biao. 2011. Potential of oxygenated phosphine fumigation for postharvest pest control. 

Presentation at the 2011 Annual International Research Conference on Methyl Bromide 

Alternatives, San Diego, CA, Oct 31-Nov 2, 2011. Available online at: 

http://mbao.org/2011/53Liu.pdf. 

Muhareb, Jeannette. 2009. Evaluation of Combining Sulfuryl Fluoride, Propylene Oxide & CO2 for 

Stored Product Insect Control. Presentation at 2009 MBAO, Nov. 10-12, 2009, San Diego, CA. 

Available online at: http://mbao.org/2009/064Muhareb.pdf. 

Russo, C., Green, R.D. & Howitt, R.E. “Estimation of Supply and Demand Elasticities of California 

Commodities”. Department of Agricultural and Resource Economics University of California, 

Davis, Working Paper No. 08-001, June 2008.

Walse, S. 2011. Postharvest Fumigation Research at USDA-ARS-SJVASC. Presentation at 2011

MBAO, Oct.31-Nov 2, 2011, San Diego, CA. Available online at: 

http://mbao.org/2011/68Walse.pdf

Walse, Spencer, J.G. Leesch, and S. Tebbets. 2009. Ovicidal Efficacy of Sulfuryl Fluoride to StoredProduct Pests of Dried Fruits. USDA/ARS, San Joaquin Valley Agricultural Sciences Center, 

Parlier, CA 93648. Presentation at 2009 MBAO, Nov. 10-12, 2009, San Diego, CA. Available 

online at: http://mbao.org/2009/060Walse.pdf. 

Walse, Spencer. 2012. (52) - Postharvest Fumigation Research at USDA-ARS.2012 MBAO, Orlando, 

Florida, November 6-8, 2013. Presentations number 52 available at: http://mbao.org/. 

Williams, Robert. 2009. Control of Carob Moth (Ectomyelosis ceratonia) in Fresh Dates Fumigated with 

ProFume®. Presentation at 2009 MBAO, Nov. 10-12, 2009, San Diego, CA. Available online at: 

http://mbao.org/2009/063Williams.pdf. 

Williams, R. and E. Thoms. 2008. ProFume® gas fumigant update: post-harvest commercial acceptance 

and performance in North America. Presentation at 2008 MBAO, Nov. 11-14, 2008, Orlando, Fl. 

Available at: http://mbao.org/2008/084Thoms.pdf
APPLICANTS

CUE 0059: CA Date Commission

MBTOC REQUESTED DATA:

MBTOC: data must be provided to demonstrate that supplemental heater cannot be used to increase 

the efficacy of Sulfuryl Flouride (SF)

EPA ANALYSIS: 

Technical:

Data indicate SF effective against most key pests. However, data demonstrate lack of performance 

on pest eggs (esp. dried fruit beetle (DFB) and carob moth) which may be present throughout 

harvest. 

Dates harvested and sent to market within 3 days; longer fumigation time results in loss of quality. 

Data to quantify this loss would be helpful in defending this to MBTOC. 

Economic:

The price of MBr is about 3.5 times more expensive than SF by pound. 

Even at higher application rates, SF would be less expensive than MBr

Regulatory Constraints:

None; SF registered for these uses. 

Active Research Program:

Presentations by Dr. Spencer Walse USDA/ARS at MBAO

Emissions:

Reduction of number of fumigations indicative of reducing emissions

Market Disruption:

Without MBr fresh dates cannot be delivered to market.

Synopsis of Alternatives

Sulfuryl Fluoride (SF)

Works well on post-embryonic life stages and matches MBr at higher temperatures; 

Insufficient for DFB and carob moth egg kill; extended exposure time cannot accommodate 

harvest to market timeframe

No significant cost difference (activities & material cost) similar or less than MBr

Currently registered for this use (Proposed regulatory actions published in 2011 and 2012; no 

Final Rule)

Phosphine (PH3)

Needs more time than MBr or SF; some stored product pests resistant; needs much less gas than 

MBr

Because of time constraint (PH3 takes more time than MBR) not an option during harvest to 

market timeframe; but for storage/processed dates is an option

No regulatory constraints

Propylene Oxide

Not registered for dates.

Very effective on insect eggs

More expensive

Regulatory constraints: maximum volume is 10,000 ft3, commodity must be heated to 100°F
Economic Analysis of transition to SF for dates treated with MBr (metric). 

Methyl Bromide Sulfuryl Fluoride

Cubic meters to be treated (example) 15,500 15,500

Total gas needed for fumigation (kg) 310 310

Price of fumigant ($/kg) 39.68 11.02

Total cost of fumigant gas ($) 12,316 3,421

Cost difference between MBr & alternative ($) --- (8,892)

Assumes rate of 1.25 lb/1,000 cu ft (20 g/cu m) for both MBr and SF. 

Because temperatures at harvest, rates should be equivalent. 

EPA CONCLUSION:

MBr remains critical for freshly harvested dates, which the industry is trying to get to 

market in 3 days. DFB and carob moth eggs could be present on these harvested dates

and studies by Walse show that SF does not kill the eggs of these pests in the time needed 

at legal concentrations. 

OTHER CONSTRAINTS

Fluoride Action Network, Environmental Work Group, and Beyond Pesticides have petitions 

requesting the cancellation of tolerances for Sulfuryl Fluoride. USEPA is currently addressing 

public comment related to a proposed rule to grant the stay of tolerances. 

The Proposed Order granting objections to tolerances for Sulfuryl Fluoride was published. No 

Final Rule has been published.

REFERENCES:

Kadar, AA and AM Hussein. 2009. Harvesting and postharvest handling of dates. International Center 

for Agricultural Research in the Dry Areas. Available at: 

http://postharvest.ucdavis.edu/files/71533.pdf. 

Nay, JE and TM Perring. 2008. Influence of host plant stages on carob moth (Lepidoptera:Pyralidae) 

development and fitness. Environ. Entomol. 37(2):568-574. 

Park, J-J and TM Perring. 2010. Development of a binominal sampling plan for the carob moth 

(Lepidoptera: Pyralidae), a pest of California dates. J. Econ. Entomol. 103(4):1474-1482. 

Vetter, RS, S Tatevossian, and TC Baker. 1997. Reproductive behavior of the female carob moth 

(Lepidoptera: Pyralidae). Pan-Pacific Entomologist 73(1):28-35. 

Walse, Spencer. 2012. Postharvest Fumigation Research at USDA-ARS. 2012 MBAO, Orlando, Florida, 

November 6-8, 2013. Presentation number 52 available at: http://mbao.org/. 

Yahia, EM. 2004. Date. USDA-ARS-Ag Handbook #66: Commercial Storage of Fruits, Vegetables, 

and Florist and Nursery Stocks. Available at: http://www.ba.ars.usda.gov/hb66/059date.pdf. 

Accessed: August 13, 2012. 
APPLICANTS

CUE 0023: U.S. Rice Federation

CUE 0027: Pet Food Institute (PFI)

CUE 0031: North American Millers’ Association (NAMA)

MBTOC REQUESTED DATA:

Data must be provided to demonstrate that supplemental heat cannot be used to increase the efficacy of 

Sulfuryl Fluoride (SF)

New, specific, and detailed data showing that IPM and heat is not effective for pet food establishments is 

required

EPA ANALYSIS

Technical: 

Published data demonstrates not statistically significant difference between MBR and SF or heat treatments.

Insufficient evidence to estimate number of facilities with high pest pressure 

Insufficient evidence to estimate loss of product due to pests 

Insufficient evidence that alternatives are not effective 

Economic thresholds need to be determined for each pest 

Economic:

Cost of alternatives generally less than cost of methyl bromide (except for heat alone); even for heat alone 

in first year cost is ~ 1% of net revenue

Cost of heat plus SF similar to cost of SF alone; added cost of heat largely offset by reduced use of SF

Regulatory:

No regulatory constraints: SF is still registered for these sites.

Active Research: 

Presentations at 2012 MBAO demonstrated research at rice mills

Emissions:

Reduction of fumigations indicative of emissions reduction 

Market Disruption:

Insufficient evidence of significant market disruption

Synopsis of Alternatives

Sulfuryl Fluoride (SF):

Effective for pests in these structures and commodities

Highly effective on post-embryonic insects, but egg kill requires increased dosage, increased temperature, 

increased time of exposure, and/or combination.

Comparative Product Performance studies –no statistical difference between SF & MeBr.

Majority of fumigations take place from end of May to early September.

No significant difference in costs; SF is much less per pound and increased concentration at lower 

temperatures does not result in higher costs.

Currently registered

Heat:

Technically feasible and effective for some structures, but not appropriate for many wooden structures

Several comparative performance studies indicate no statistical difference between heat and MeBr

Small reductions in net revenue are possible and more likely in smaller mills when considering the cost of 

investment in equipment.* 

No regulatory constraints

SF + Heat:
May be an option for some producers

Microsanitation:

Mechanical control technique that is labor intensive; 

May have potential for replacing disinfestation but research has not been published

IPM strategies, including use of insecticides/fogging may be used to manage stored product pests

*Based on economic analysis from CUN for 2013

OTHER CONSTRAINTS and CONSIDERATIONS

Fluoride Action Network, Environmental Work Group, and Beyond Pesticides have petitions requesting the 

cancellation of tolerances for Sulfuryl Fluoride. 

The Proposed Order granting objections to tolerances for Sulfuryl Fluoride was published. No Final Rule 

has been published.

EPA CONCLUSION:

SF is currently registered for these facilities. Heat is also available for this industry. SF is cost effective. 

There is no evidence that MBr is a critical need in this industry. 

REFERENCES:

Adam, B. D., Bonjour, E. L., & Criswell, J. T. (2010). Cost Comparison of Methyl Bromide and Sulfuryl 

Fluoride (ProFume®) for Fumigating Food Processing Facilities, Warehouses, and Cocoa Beans. 10th

International Working Conference on Stored Product Protection, 27 June-2 July 2010, Portugal, Estoril 

Congress Center. Available at http://pub.jki.bund.de/index.php/JKA/article/viewFile/495/446. Accessed 

July 19, 2010. 

Arthur, F. H., A. E. Sutton, K. Y. Zhu, and J. F. Campbell. 2010. Residual efficacy of pyrethrin-methoprene 

aerosols on packaging surfaces. Presentation at MBAO, Nov. 2-5, 2010, Orlando, Fl. Available at: 

http://mbao.org/2010/64Arthur.pdf. 

Arthur, Frank H., L. Ted Wilson, Yubin Yang, James F. Campbell, Tanja McKay, Brian Adam, and Thomas E. 

Reagan. 2011a. Insect pest management in rice mills. Presentation at the 2011 Annual International 

Research Conference on Methyl Bromide Alternatives, San Diego, CA, Oct 31-Nov 2, 2011. Available at: 

http://mbao.org/2011/57Arthur%201.pdf. 

Arthur, F. H., J. F. Campbell, E. A. Fontenot. 2011b. Efficacy of Insecticide Treatments on Resident Populations 

of the Red Flour Beetle. Presentation at the 2011 Annual International Research Conference on Methyl 

Bromide Alternatives, San Diego, CA, Oct 31-Nov 2, 2011. Available at: 

http://mbao.org/2011/58Arthur%202.pdf. 

Arthur, FH and EA Fontenot. 2012.Residual activity of methoprene and novaluron as surface treatments to 

manage the flour beetles, Tribolium castaneum and Tribolium confusum. Journal of Insect Science 12:95 

Available at: http://www.insectscience.org/12.95. 

Beckett, S. J., Fields, P. G., & Subramanyam, Bh. (2007). Disinfestation of Stored Products and Associated 

Structures Using Heat. In J. Tang, E. Mitcham, S. Wang, & S. Lurie (Eds.), Heat Treatments for 

Postharvest Pest Control Theory and Practice (pp. 182-237). CABI International, Wallingford, UK. 

[online] Available at http://home.cc.umanitoba.ca/~fieldspg/fields/heat-rev.pdf. Accessed July 15, 2010.

Brijwani, M., B.Subramanyam, M. Hartzer, D. E. Maier, W. Chayaprasert, S. Savoldelli, P. Flinn, and J. 

Campbell. 2009. Efficacy of structural heat treatments against Tribolium castaneum life stages. 

Presentation at Methyl Bromide Alternatives Outlook Conference, San Diego, November 2009. Available 

at: http://mbao.org/2009/066Brijwani.pdf. 
Campbell,JF. 2010. Impact of structural fumigation on pest populations in food processing facilities. 

Presentation at MBAO, Nov. 2-5, 2010, Orlando, Fl. Available at: http://mbao.org/2010/63Campbell.pdf. 

Campbell, James 2012. Evaluating Structural Fumigation Efficacy in Rice Mills. Presentation 42, 2012 MBAO, 

Orlando, Florida, November 6-8, 2013. Presentations available at: http://mbao.org/. 

Campbell, James . 2012. - Spatial Pattern in Aerosol Insecticide Deposition in a Flour Mill. Presentation 43, 

2012 MBAO, Orlando, Florida, November 6-8, 2013. Presentations available at: http://mbao.org/. 

Hartzer, M. Subramanyam, B., Brijwani, M., Chayaprasert, W., and Maier, D. E. 2010. Methyl bromide, sulfuryl 

fluoride and heat: effectiveness against red flour beetle. Presentation at MBAO, Nov. 2-5, 2010, Orlando, 

Fl. Available at: http://mbao.org/2010/67Hartzer.pdf. 

Hartzer, M., B. Subramanyam, W. Chayaprasert, D. E. Maier, and S. Savoldelli. 2009. Methyl Bromide and 

Sulfuryl Fluoride Effectiveness Against Red Flour Beetle Life Stages. Presentation at Methyl Bromide 

Alternatives Outlook Conference, San Diego, November 2009. Available at: 

http://mbao.org/2009/072Hartzer.pdf. 

Holcomb, M. and M. McLean. 2010. An IPM approach to methyl bromide replacement: in pet food processing 

plants and warehouses. Presentation at MBAO, Nov. 2-5, 2010, Orlando, Fl. Available at: 

http://mbao.org/2010/65Holcomb.pdf. 

Horn, P., Horn, F. and Rogers, M. 2010 Automated structural fumigations with phosphine using the Horn 

Diluphos System. Presentation at MBAO, Nov. 2-5, 2010, Orlando, Fl. Available at: 

http://mbao.org/2010/066HornP.pdf. 

Kenkel, P., & Holcomb, R. 2004. Flour Milling Feasibility Template. Oklahoma State University. [online] 

Available at: agecon.okstate.edu/coops/files/flour_milling_template_4-5-2004.xls. Accessed July 13, 2010. 

McKay, Tanja 2012. Integrated Insect Pest Management in Rice Mills. Presentation 41, 2012 MBAO, Orlando, 

Florida, November 6-8, 2013. Presentations available at: http://mbao.org/. 

Ranville, M. and Cook, C. 2011. Assessment of Impacts on Flour Mill Operators of a Stay in Sulfuryl Fluoride 

Food Tolerances. U.S. Environmental Protection Agency. 

Stored Product Protection. 2012. Eds: DW Hagstrum, TW Phillips, and G Cuperus. K-State Research and 

Extension. http://www.ksre.ksu.edu/bookstore/pubs/S156.pdf Several Chapters including but limited to: 

Mahroof, RM and DW Hagstrum. Biology, behavior, and ecology of insects in processed commodities. 

Chapter 4, p. 33-43.

Campbell, JF, J Perez-Mendoza, and J Weier. Insect Pest Mangement Decisions in Food Processing 

Facilities. Chapter 19, p. 219-232. 

Adam, BD and C Alexander. Economics of IPM Decisions. Chapter 28, p. 317-325. 

Walse, Spencer. 2012. Postharvest Fumigation Research at USDA-ARS. Presentation 52, 2012 MBAO, 

Orlando, Florida, November 6-8, 2013. Presentations available at: http://mbao.org/. 
APPLICANTS

CUE 0033: Gwaltney-Smithfield CUE 0057: National Country Ham Association

CUE 0075: Nahunta CUE 0076: American Association of Meat Producers

MBTOC REQUESTED DATA:

Evidence must be provided to demonstrate that facilities have improved gas tightness 

Evidence must be provided to demonstrate all efforts to reduce frequency of fumigations have been 

made by facility

“Fuller” nomination

EPA ANALYSIS: 

Technical 

Evidence provided demonstrate that neither sulfuryl fluoride (SF) nor phosphine (PH3) are effective 

in reducing mites

Evidence provided indicates producers with high pest pressure 

Economic

No technically feasible alternative identified; therefore, no economic analysis conducted

Regulatory Constraints:

None; no alternatives identified. 

Active Research Program

Presentations by Dr Wes Schilling & Dr. Tom Phillips at MBAO

Very active research program investigating chemical and non-chemical means of control

Processors very cooperative with researchers and eager to participate in studies

Emissions Reduction

Reduction of number of fumigations may be indicative of reducing emissions

Market Disruption:

Without MBr this type of ham would not be available for consumers.

SYNOPSIS OF ALTERNATIVES:

Sulfuryl Fluoride:

Currently registered and effective for ham skippers & red-legged ham beetles 

Does not control mites at label rates, even in the laboratory

Phosphine:

Is effective for ham skippers & red-legged ham beetles 

Laboratory studies indicate control of mites; 

Field studies have not provided control of mites. 

Much corrosion of metals (copper, silver, and their alloys) occurred during trials, resulting in 

substantial costs for replacements. 

OTHER CONSTRAINTS and CONSIDERATIONS

Country hams are premium product and pest damage is not acceptable to consumers. 

Temperatures and humidity for appropriate aging of country hams must be maintained and are also 

ideal for pest survival. 

EPA CONCLUSION:

EPA concludes a strong and defensible case for this sector based on the following:

o No technically feasible alternative has been identified to control mites

o No IPM strategy has been identified to control mites

o Very active research program, with support from producers 
APPLICANT 

CUE 0004: Michigan Tomato, CUE 0005: Michigan Cucurbits, 

CUE 0061: Michigan Pepper, CUE 0062: Michigan Eggplant

EPA ANALYSIS 

No one alternative was deemed to be effective for all pest problems but a review of multiple year data 

indicated that the alternatives in various combinations provide control equal or superior to methyl bromide 

plus chloropicrin. Applicant would need to provide summarized multiple year data to show yield or economic 

impacts. Qualitative descriptions of impacts alone are not sufficient.

Insufficient information to estimate percent of acres with high pest pressure. 

Qualitative descriptions of the failures of alternatives need to contain more detailed information on crop, 

alternative tested, minimum or maximum label rate used, and type of negative impact (e.g. yield loss, 

phytotoxicity, poor pest control, etc.). 

Insufficient information has been provided to demonstrate that fall fumigation is not feasible because of 

deer and rodent damage to tarps and drip lines. Not clear why this issue cannot be mitigated in other 

ways, or how many acres are affected.

Synopsis of Alternatives

1,3-Dichloropropene + chloropicrin or 

1,3-D + chloropicrin + metam sodium

Several research studies show this can effectively suppress soilborne diseases and nematodes. 

This includes the key pathogens cited by MI (P. capsici, F. oxysporum) (Hausbeck and Glaspie 

2010). 

MI claims this alternative causes a 14 day plantback delay in cold spring soils. Economic impact 

analysis summarized below. Fall fumigation is recommended by MSU and could alleviate 

plantback delay regardless of the fumigant used.

DMDS + chloropicrin

Research trials in Michigan (Hausbeck and Glaspie 2010) and the southeastern U.S. (Freeman 

and McAvoy 2011) indicate acceptable yield/quality with this alternative. Rates can be reduced 

under TIF tarps, according to new research.

DMDS should be tested in early season MI application scenario to provide yield/quality data.

Data has not been provided on plantback delays compared to MeBr plus chloropicrin under cool 

soil conditions.

Fluopicolide 

A registered fungicide that is effective on P. capsici and registered for drip application use on 

vegetable crops. Could improve pathogen control beyond that provided by fumigation alone. 

Resistance could be a problem with this fungicide (Lu et al. 2011), but apparently this has not 

occurred in Michigan as yet. 

Non-fumigant alternatives: Anaerobic soil disinfestation (ASD), cover crops (Brassicas, hairy 

vetch) 

Research work suggests these alternatives could provide control for specific fields and growers 

facing relatively low pest pressure. 

ECONOMIC ANALYSIS 

EPA estimates a loss in gross revenue of about 9-11%, which is offset by significantly lower fumigant 

costs resulting in a loss as a percent of gross revenue of about 3%. See the tables below. These estimates 

are based on: cost data from the CUE application, seasonal tomato and cucumber prices, 6% yield loss, 

and 7 day planting delay. 
Early production of fresh vegetables provides a niche market offering premium prices with fresh produce 

scarcity for a limited time. The high input costs are offset by high prices they receive during this early 

production phase. Data from statistical sources do not fully show higher or lower prices but only average 

prices received for a crop. EPA considered the price data from Ngouajio, Rebekah and Ron 2011.

Table 1. Michigan vegetable price information from different sources, Ngouajio et al 2011 data used.

Crop Source of Data

Early 

Season 

Price

Later 

Season 

Price

Percent

Decrease

Tomato CUE application $15.50 $11.35 27%

Tomato (Ngouajio, Struck, and Goldy, 2011)*** $18.00 $13.00 28%

Cucumber USDA NASS monthly prices $29.77 $21.97 26%

Cucumber Receipts from MI growers, average $12.25 $7.46 39%

Cucumber (Ngouajio, Struck, and Goldy, 2011)*** $24.00 $15.00 38%

***Ngouajio Mathieu, Struck Rebekah, and Goldy Ron. 2011. 

Table 2. Estimated economic impact on Michigan tomatoes from the use of alternatives. 

Michigan Tomatoes

CUE# 12-04

Methyl 

Bromide

1,3-D + 

Pic

Georgia 

3 Way DMDS

Yield 25 lb boxes per acre 1,525 1434 1525 1525

% Yield Loss 0% 6% 0% 0%

Plant Delay days compared to baseline 0 7 7 7

Price per 25 lb box

First Week after Early Harvest 10% of yield $18.00

2nd Week 10% of yield $16.00 $16.00 $16.00 $16.00

3rd Week 10% of yield $14.00 $14.00 $14.00 $14.00

Rest of Season $13.00 $13.00 $13.00 $13.00

Weighted Average Price per 25 lb box $13.90 $13.40 $13.40 $13.40

Gross Revenue per acre $21,198 $19,209 $20,435 $20,435

Loss $1,989 $763 $763

% of Gross Revenue 9.4% 3.6% 3.6%

Metric

Yield Loss (%) 0% 6% 0% 0%

 Yield Kg per Hectare 42,732 40,168 42,732 42,732

× Average Price per Kg (us$) $1.23 $1.18 $1.18 $1.18 

= Gross Revenue per Hectare (us$) $52,380 $47,466 $50,496 $50,496 

% loss of gross revenue 9.4% 3.6% 3.6%

- Operating Costs per Hectare (us$) $43,167 $39,712 $42,667 $41,624 

= Net Revenue per Hectare (us$) $9,213 $7,754 $7,829 $8,872 

Five Loss Measures

1. Loss per Hectare (us$) $0 $1,459 $1,384 $342 

2. Loss per Kilogram of Methyl Bromide (us$) $0 $8.14 $7.72 $1.90

3. Loss as a Percentage of Gross Revenue (%) 0% 2.8% 2.6% 0.7%

4. Loss as a Percentage of Net Operating Revenue (%) 0% 16% 15% 4%

5. Operating Profit Margin (%) 18% 16% 16% 18%
Table 3. Estimated economic impact on Michigan cucumber from the use of alternatives. 

Michigan Cucumbers

CUE# 12-05

Methyl 

Bromide

1,3-D + 

Pic

Georgia 

3 Way DMDS

Yield crate (1 1/9 bushel = 55 lb) per acre 733 689 733 733

% Yield Loss 0% 6% 0% 0%

Plant Delay days compared to baseline 0 7 7 7

Early Season (3 weeks)

% of Yield 30% 20% 20% 20%

Price per 55 lb crate $24.00 $24.00 $24.00 $24.00

Rest of Season

% of Yield 70% 80% 80% 80%

Price per 55 lb crate $15.00 $15.00 $15.00 $15.00

Weighted Average Price per crate $17.70 $16.80 $16.80 $16.80

Gross Revenue per acre $12,981 $11,582 $12,321 $12,321

Loss $1,399 $660 $660

% of Gross Revenue 10.8% 5.1% 5.1%

Metric

Yield Loss (%) 0% 6% 0% 0%

 Yield Kg per Hectare 45,212 42,499 45,212 45,212

× Average Price per Kg (us$) $0.71 $0.67 $0.67 $0.67 

= Gross Revenue per Hectare (us$) $32,077 $28,619 $30,446 $30,446 

% loss of gross revenue 10.8% 5.1% 5.1%

- Operating Costs per Hectare (us$) $32,496 $30,143 $32,441 $31,399 

= Net Revenue per Hectare (us$) ($419) ($1,524) ($1,995) ($953)

Five Loss Measures

1. Loss per Hectare (us$) $0 $1,105 $1,577 $534 

2. Loss per Kilogram of Methyl Bromide (us$) $0 $7.04 $10.05 $3.40

3. Loss as a Percentage of Gross Revenue (%) 0% 3.4% 4.9% 1.7%

4. Loss as a Percentage of Net Operating Revenue (%) 0% -264% -377% -128%

5. Operating Profit Margin (%) -1% -5% -7% -3%

REFERENCES

Freeman, J. and T. McAvoy. 2011 Reduced rates of dimethyl disulfide in combination with totally 

impermeable film mulch. Proceedings of the 13th Methyl Bromide Alternatives Outreach 

Conference. Available online at:

http://www.mbao.org/2011/Proceedings/35FreemanJDMDSTIF.pdf.

Granke, L.L., Hausbeck, M.K. & Cortright, B.D. 2009. Methyl bromide alternatives for control of 

Phytophthora crown and root rot of summer squash, 2008. Plant Dis. Mgmt. Reports. 3:V014.

Hausbeck, M.K. and S.L. Glaspie. 2010. Evaluation of fumigants for control of Phytophthora crown 

and root rot on summer squash, 2009. Plant Dis. Mgmt. Reports. 4:V055.

Lu, X.H., Hausbeck, M.K., Liu, X.L., & Hao, J.J. 2011. Wild type sensitivity and mutation analysis 

for resistance risk to fluopicolide in Phytophthotra capsici. Plant Dis. 95:1535-1541.

Ngouajio M., S. Rebekah, and G. Ron. 2011. Low Tunnels for Early Vegetable Production and High 

Profits, Michigan State University. Available online at: http://glvwg.ag.ohiostate.edu/documents/LowTunnelPresentationNgouajio.pdf
APPLICANT: 

CUE: 0024 California Strawberry Commission

APPLICANT ASSERTIONS

Township caps on 1,3-dichloropropene (1,3-D) prevent its use on some of the requested acres

Emergence of Macrophomina and Fusarium in some locations where 1,3-D drip applications have been 

used for a few seasons

CSC estimated a 5% yield loss when diseases emerge in production fields using drip-applied 1,3-D

Infested acres that affect production are estimated by CSC to range from 2-10% depending on pathogen 

and production region

CSC submitted a transition plan

EPA ANALYSIS: 

Macrophomina and Fusarium have been most commonly recovered from Santa Barbara 

(Macrophomina), Ventura (Macrophomina and Fusarium) and Orange (Macrophomina) counties

In 2010 and 2011, Macrophomina and Fusarium were detected for the first time in the central coast 

production region (Monterey and Santa Cruz counties)

o According to Koike et al. (2012), “virtually all of these plant collapse situations involve 

fields that have switched from methyl bromide + chloropicrin to alternative fumigant 

products and bed fumigation practices.” 

(http://www.calstrawberry.com/fileData/docs/Koike_2010_11_mac.pdf)

Information was not available regarding the efficacy of broadcast treatments of 1,3-D/chloropicrin in 

California

o Gordon et al. (2012) found that inadequate distribution of dripped fumigant resulted in significant 

differences in Fusarium populations in locations within the bed

(http://www.calstrawberry.com/fileData/docs/Gordon_2010_11_Mac_Fus.pdf 2012)

o In Florida, 1,3-D/chloropicrin distribution even with two drip tapes were inferior to shank 

applications (http://www.mbao.org/2012/Proceedings/27NolingJ%20AreaWide%202012.pdf)

Acreage within townships over the cap for 1,3-D would be eligible for CUE methyl bromide

o Broadcast 1,3-D may increase impact of township versus drip applications

ECONOMIC ANALYSIS: 

Where there are restrictions on use of alternatives (e.g., township caps) or lack of efficacy (e.g., 

unmanageable diseases), losses can be as high as -37% of net revenue

Where alternatives have been used they have generally been effective at preventing yield losses and, 

therefore, there would not appear to be losses from transitioning to alternatives

o Economic returns with alternatives are at least as high as with MeBr—this is because the 

alternatives are less expensive

OTHER CONSTRAINTS and CONSIDERATIONS

Some acres appear to be affected by township restrictions on the use of 1,3-D. Chloropicrin is a feasible 

alternative to MeBr where permits have been granted. The California Department of Pesticide Regulation 

(Cal DPR) is currently reviewing the registration of chloropicrin and 1,3-D and should announce its 

recommendations in early 2013. Based on the Cal DPR review the use of conditions for chloropicrin 

and 1,3-D (e.g. buffers, reentry intervals, tarps, use rate, etc.) could change before 2015. In addition, the 

1,3-D review could lead to changes in how the 1,3-D township caps are calculated.

EPA CONCLUSION:
The CUE nomination for MeBr was for production areas where 1) 1,3-D is limited by township caps, 

2) where a transition period is needed for the use of broadcast 100% chloropicrin, or 3) where 

Macrophomina and Fusarium have not been acceptably controlled with alternative fumigant 

methods. There is an expectation that there will continue to be a reduced critical need for MeBr in 

the near future as advances are made 1) in safely applying 100% chloropicrin, 2) in strategies to 

improve efficacy in applying 1,3-D, and 3) in transitioning from experimental to commercial use of 

non-chemical tools, such as steam, anaerobic soil disinfestations, and substrate production.
APPLICANT: 

CUE 0034: California Strawberry Nursery Association

EPA ANALYSIS: 

If 1,3-D township caps are restrictive the applicant should document those areas or townships impacted.

A Special Local Need (SLN) label for Telone II allows dual application of 1,3-D as described in NIPM 

#7, Schedule C, Chart I

 This SLN allows for the use of Telone II at the rates defined in Schedules B, C, or D using a dual 

application method in accordance with the Regulations for the Nursery Stock Nematode Control 

Program, California Code of Regulations (CCR) Title 3 Sections 3055 to 3055.6 and 3640.

 Label was approved 8/28/2012 and is effective until 7/21/2017

(http://www.cdms.net/ldat/ld02E006.pdf) 

Growers could use a combination of methyl bromide for quarantine situations and 1,3-D plus 

chloropicrin for non-quarantine situations to meet certification requirements. 

ECONOMIC ANALYSIS: 

No information was submitted concerning actual losses or market disruption.

OTHER CONSTRAINTS and CONSIDERATIONS

Requested 47 acres should be clearly defined to support critical designation. Nursery stock must receive 

certification for stock to be sold.

EPA CONCLUSION:

It was not possible to determine a critical need for MeBr for strawberry nurseries based on lack of feasible 

alternatives or market disruption. Telone label allows its use in accordance with NIPM #7 certification 

standards. 
APPLICANT: 

CUE 0035: California Association of Nurseries and Garden Centers

EPA ANALYSIS: 

If 1,3-D township caps are restrictive the applicant should document those areas or townships impacted.

A Special Local Need (SLN) label for Telone II allows dual application of 1,3-D as described in NIPM #7 

 This SLN allows for the use of Telone II at the rates defined in Schedules B, C, or D using a dual 

application method in accordance with the Regulations for the Nursery Stock Nematode Control 

Program, California Code of Regulations (CCR) Title 3 Sections 3055 to 3055.6 and 3640.

 Label was approved 8/28/2012 and is effective until 7/21/2017 

(http://www.cdms.net/ldat/ld02E006.pdf)

Growers could use a combination of methyl bromide for quarantine situations and 1,3-D plus 

chloropicrin for non-quarantine situations to meet certification requirements. 

ECONOMIC ANALYSIS: 

No information was submitted concerning actual losses or market disruption.

OTHER CONSTRAINTS and CONSIDERATIONS

Requested 30 acres should be clearly defined to support critical designation. Nursery stock must receive 

certification for stock to be sold.

EPA CONCLUSION:

It was not possible to determine a critical need for MeBr for tree nurseries based on lack of feasible 

alternatives or market disruption. Telone label allows its use in accordance with NIPM #7 certification 

standards. 
APPLICANTS: 

CUE 0013: California Grape & Tree Fruit League—Stone Fruit replant

CUE 0014: California Grape & Tree Fruit League—Raisin and Table Grape replant

CUE 0043: Almond Hullers and Processors Association—Almond replant

CUE 0029: California Walnut Commission & Walnut Marketing Board—Walnut replant

APPLICANT ASSERTIONS

1. Township caps on 1,3-D prevent its use on some acres

2. Soil moisture requirements (<12%) reduce use of 1,3-D on some acres (use of 1,3-D @330 lb/A) + 

chloropicrin (170 lb/A) is effective, except where moisture is >12%)

3. VOC rules limit applications in San Joaquin Valley to unfavorable soil temperature after November 1 

(MB is more forgiving in colder soils)

4. Almond and walnut have shifted to MB application to individual holes to replace dead trees in recently 

established orchards; applicants stated that no other fumigant can be used due to inability of rigs to 

maneuver within an existing orchard in a small area. 

a. Browne (email statement 12-12-2012) stated that 5’ injection of 1,3-D for tree replacement in 

individual holes “...would make the treatment undesirable and perhaps ineffective unless a large 

diameter auger or backhoe lowers bulk density of soil around injection. A 3’ requirement seems 

ok, but still rather deep, assuming efficient equipment has been developed to inject it.”

5. Primary pests are nematodes and replant problem and alternatives to MB are generally not effective for 

requested sites

6. Armillaria rot is a pest of almond, grape, and stone fruit production and requires MB in infested orchard 

locations (estimated to infest 2-5% of replant sites) 

EPA ANALYSIS 

If 1,3-D township caps are restrictive the applicant should document those areas or townships impacted.

Alternatives are very effective for most conditions; clay soils with high moisture may be mitigated with 

deep ripping so that many sites can effectively use 1,3-D (e.g., Caprile and McKenry, 2007; 

http://cemerced.ucdavis.edu/newsletters/October_200723186.pdf )

 Description of particular conditions and identify land area(s) where alternatives are not 

effective

We have received no data substantiating lack of efficacy if 1,3-D is used in compliance with VOC 

regulations

 Growers may fumigate in suboptimal soil temperatures to use higher rainfall to meet soil moisture 

requirements and due to VOC regulations—although impact on efficacy is unknown (see Beede et al.,

2012-- http://www.mbao.org/2012/Proceedings/63BeedeB.pdf)

 Beede et al. (2012, see link above) stated that Pacific Areawide studies indicate that TIF may help solve 

emissions issue

Research with single hole treatment to replace individual trees in an established orchard did not 

appear to warrant a critical need for methyl bromide

 Lacked a description and accounting for the actual acreage requesting critical use of MB

o There was some impression that MB might only be used if cost is lower, thus suggesting that MB 

is preferred, but not necessarily critical

 If technical aspects prevent the use of alternative treatments for individual tree replacement, provide a 

description of technical aspects and limitations of, for example, 5 ft injection of alternative (e.g., 1,3-D). 

o It was not made clear why 5 ft injection cannot be done (versus is not being done)

o Detailed description of technical difficulties of deep injection (e.g., MB protocol for Armillaria

calls for injection to 3 ft—that should be technically feasible? Why not 5 ft?)
 Both chloropicrin and 1,3-D are labeled for application to individual holes for replacement of trees in 

existing orchards

o Applications stated that rigs for alternatives cannot maneuver in fewer than 2-acre areas

o Description should be provided describing the technical aspects of MB vs. alternative application 

under these conditions

 Numerous published reports indicate efficacy for spot treatments. These results, if not applicable to the 

critical need for MB, need to be addressed

o Browne (2011) found adequate (although not optimal) control of Prunus Replant Disease with 

spot fumigation at tree sites (http://mbao.org/2011/Proceedings/32BrowneG.pdf)

o Browne (2009) found that preplant spot treatments have “maintained very good tree growth with 

large savings in fumigant, compared to strip and broadcast treatments” 

(http://www.mbao.org/2009/Proceedings/033BrowneGmbao2009fin.pdf)

o 1,3-D/chloropicrin or chloropicrin is as effective or more effective than MB against nematodes 

and replant problem according to data of trials from several seasons (see Beede et al., 2012--

http://www.mbao.org/2012/Proceedings/63BeedeB.pdf; Browne et al., 2012--

http://www.mbao.org/2012/Proceedings/19BrowneG.pdf; Jhala et al., 2012—Pest Management 

Science 668:225-230, http://onlinelibrary.wiley.com/doi/10.1002/ps.2249/pdf)

o “It seems clear that for the most prevalent replant problems [replant disease and nematodes] 

combinations of alternative fumigants and horticultural practices have effectively replaced MB.” 

(Beede et al., 2012-- http://www.mbao.org/2012/Proceedings/63BeedeB.pdf)

o For almond/stone fruit, “Chloropicrin and mixtures of it with 1,3-dichloropropene (i.e., Telone 

C35, Pic-clor 60)... prevent PRD [Prunus replant disease] and often do so more effectively than

MB or 1,3-dichloropropene (Telone II) alone.” (Browne et al., 2011; 

http://mbao.org/2011/Proceedings/32BrowneG.pdf)

o For walnut: “The untreated plots remain highest in lesion numbers, and the Telone II plus 

chloropicrin plot remains the lowest.” (Beede et al., 2011; 

http://mbao.org/2011/Proceedings/22BeedeB.pdf)

o Pacific Area-Wide Project (Almonds/stone fruit) found significantly greater yields with 

chloropicrin, 1,3-D/chloropicrin, and PicClor 60 as compared to MB (Browne, 2011 MBAO 

presentation)

o Steam technology is in development for individual hole treatment; it may be effective, but 

appears to require further evaluation (e.g., Hanson et al., 2011; 

http://ucanr.edu/blogs/UCDWeedScience/blogfiles/5828.pdf)

o In University of California trials supported by the Almond Board of California, spot fumigation 

treatments of chloropicrin using the irrigation system installed for the replant trees was effective 

in preventing replant disease (Almond Board website, 

http://www.almondboard.com/Growers/orchardmanagement/PestManagement/Fumigatio

n/Pages/default.aspx)

We have no data substantiating losses caused by Armillaria with alternative treatments compared 

to methyl bromide

 Will require supporting data and description of impact:

o To indicate that MB ameliorates the disease for certain defined areas where Armillaria is known 

to be severe and where orchards have contended with Armillaria infestation—and ideally, 

compare to areas where alternatives have been used unsuccessfully where Armillaria infestation 

was severe

 Extension information indicates that eradication of Armillaria is rarely achieved with any fumigant 

(e.g., http://www.ipm.ucdavis.edu/PMG/r602100811.html)

o Describe conditions where MB is critical and has led to successful orchard replant in infested 

areas, whereas use of alternatives have resulted in failure
 Chloropicrin, metam-sodium (forms MITC), and sodium tetrathiocarbanate (Enzone®) (forms carbon 

disulfide) are registered and, for example, are recommended by UC Pest Management Guidelines 

against Armillaria (e.g., http://www.ipm.ucdavis.edu/PMG/r602100811.html; 

http://www.ipm.ucdavis.edu/PMG/r302100811.html)

o Required description of registered alternatives and if registered alternatives are not effective, 

supporting information that MB will prevent adverse impacts

ECONOMIC ANALYSIS 

Description and supporting information addressing the following:

 The available data show that alternatives to methyl bromide are available and effective.

 Numerous field trials indicate alternatives to methyl bromide are effective, therefore, there would not 

appear to be substantial losses from transitioning to the alternatives.

 When the alternatives are as effective as methyl bromide, the economic returns with alternatives are at 

least as high as with methyl bromide—this is because the alternatives are less expensive than methyl 

bromide.

 Research from 2011 MBAO indicates significant economic return and higher yields with 1,3-

D/chloropicrin compared to MB. For example, for almond “The ranking from most efficient to least 

efficient by fumigant is the same for the strip, strip plus tarp, and broadcast treatments with Telone II 

the most efficient and Methyl Bromide the least efficient for each category of treatments.” In peaches, 

highest income and greatest yield was from 1,3-D/pic (Telone C35) strip treatment (Klonsky, 2011; 

http://mbao.org/2011/Proceedings/23KlonskyK.pdf)

 If yields with 1,3-D and chloropicrin are equal to those with MB, then the present value of the returns to 

the orchard with these alternatives are estimated to be at least as high as with MB. Although the 

available research does not substantiate yield losses with the alternatives, if yields with alternatives 

were lower, the losses could be large. The estimates are based on the UC Davis crop and return studies, 

using the estimates of costs for methyl bromide and the alternatives from the CUE applications.

EPA CONCLUSION

It was not possible to determine a critical need for MB for orchard replant based on lack of feasible 

alternatives or market disruption:

In spite of assertions of impacts from township caps on 1,3-D, townships have not been 

identified that are affected by restrictions on 1,3-D use.

Published research show that for the most prevalent replant problems (Prunus replant disease 

and parasitic nematodes) combinations of alternative fumigants and cultural practices have 

effectively replaced methyl bromide (Browne et al., 2012; Wang et al., 2010; Beede et al., 

2012).

Registered alternatives are available for individual-hole treatments. For example, in University 

of California trials supported by the Almond Board of California, spot fumigation treatments of 

chloropicrin using the irrigation system installed for the replant trees was effective in 

preventing replant disease (Almond Board website, 

http://www.almondboard.com/Growers/orchardmanagement/PestManagement/Fumigation/Pages/default.aspx). 

Soil preparation procedures are available to enable effective treatment with alternatives even in 

soils with high moisture content (Caprile and McKenry, 2007, 

http://cemerced.ucdavis.edu/newsletters/October_200723186.pdf) 

The economic returns with alternatives are at least as high as with methyl bromide—this is 

because the alternatives are less expensive than methyl bromide. For example, significant 
economic returns and higher yields were reported with 1,3-D/chloropicrin compared to MB 

(e.g., Klonsky et al., 2011). 

No data have been submitted substantiating losses experienced due to Armillaria rot with the 

best, registered alternative control methods compared to methyl bromide. Replant in soils 

infested with Armillaria is not ideal under any circumstance. While methyl bromide has been 

a treatment for infested soils, fumigants (including methyl bromide) are not eradicative, 

although they may provide suppression in a limited treatment area. Where orchards must be 

planted in infested soils recommended, cultural practices, rootstock selection, soil preparation, 

herbicides, fallow/cover crops, and chloropicrin and other soil treatments, have been 

recommended by UC Pest Management Guidelines, and others. 
APPLICANT

CUE 0018: California Cut Flower Commission

CUE 0078: Florida Cut Flower 

EPA ANALYSIS 

No one alternative is deemed to be effective for all pest problems but a review of multiple year data indicated that 

the alternatives provide equal or superior control to methyl bromide plus chloropicrin. Applicant would need to 

provide summarized multiple year data to show yield or economic impacts. Qualitative descriptions of impacts 

alone are not sufficient.

Insufficient information to estimate percent of acres with high pest pressure. 

Regulatory impacts would need to be clearly defined and compared to the current methyl bromide plus 

chloropicrin label restrictions. 

Qualitative descriptions of the failures of alternatives need to contain information on crop or ornamental species, 

alternative tested, minimum or maximum label rate used, and type of negative impact (e.g. yield loss, 

phytotoxicity, poor pest control, etc.). 

Synopsis of Alternatives

1,3-dichloropropene (Telone) plus Chloropicrin

Research demonstrates excellent results. High rates of 1,3-D alone under VIF can provide pathogen and 

weed control equal to MeBr:Pic (Jhala 2012). PicChlor 60 Calla lily yields and pathogen control equivalent 

to MeBr:Pic (Gerik 2012b).

Economic analysis indicates that for CA calla lilly and ranunculus there was not loss as a percent of gross 

revenue. For FL there was no loss data provided. Price is lower than MeBr:chloropicrin.

Suitable for use in areas without karst topography.

1,3-dichloropropene (Telone) plus Chloropicrin plus Metam sodium (e.g. In-Line plus Vapam, InLine followed by kPam)

Research demonstrates excellent results. Applicant listed Vallad (MBAO 2010) yield equal to MeBr:Pic in 

tomato.

Calla lilies stand not impacted by pathogens by Pythium control better than Fusarium control, Inline better 

than PicChlor and KPam improved disease control (Gerik 2012a) Weed, pathogen, and ranunculus bulb 

yield better than MeBr:Pic when drip applied. Gladiolus - most alternatives equivalent to MeBr:Pic for yield 

and Fusarium. (Gerik 2012b).

Economic analysis indicates that for CA there was not loss as a percent of gross revenue. For FL there was 

no loss as a percent of gross revenue. Price is lower than MeBr:chloropicrin.

Suitable for use in areas without karst topography.

Dimethyl Disulfide (DMDS) plus Chloropicrin (Paladin TM)

Research demonstrates excellent results. Yields equal to MeBr:Pic but Fusarium control not as effective. 

Applicant sent tomato data where yield equal to MeBr:Pic but herbicide needed (Vallad 2010). 

Nematode control equal to MeBr:Pic in FL (Kokalis-Burelle 2012). Gladiolus - DMDS equivalent to 

MeBr:Pic for yield and Fusarium. (Gerik 2012b)

Insufficient multiple year data to conduct economic analysis but low yield loss should lead to a low 

economic impact.

Registered in FL but not CA. Can be used in areas of karst topography

Effective alternative that requires TIF type plastic tarps because of odor issues.

Anaerobic Soil Disinfestation (ASD)

Research demonstrates good results, more pests and pathogens need to be tested. Nematode and weed 

control equal to MeBr:Pic in FL (Kokalis-Burelle 2012).

Only preliminary data available for CA or FL. Ornamental yield equal to MeBr:Pic in FL (Kokalis-Burelle 
2012). Insufficient multiple year data to conduct economic analysis but low yield loss should lead to a low 

economic impact.

No regulatory constraints - could be part of an organic program. 

ECONOMIC ANALYSIS 

Economic considerations in fumigant selection does not make a compelling case for a critical need, i.e., if 

MeBr is available, but not used because of lack of funds, yet the course continues to operate, there is a 

suggestion that MeBr may be desirable, but not critical to the operation.

ECONOMIC IMPACT (LOSSES)

California Economic Analysis for Calla Lily and Ranunculus

Florida Economic Analysis for Lilies

CA Cut Flower 

 Calla Lily Ranunculus Calla Lily Ranunculus Ranunculus Ranunculus 

Item Year 1 Per Year Per Year Per Year Per Year Per Year Per Year

Yield Loss per Acre* 0% 0% 0% 15% 0% 0% 0%

UNITS

Loss per Acre $/A $ - $ - $ 3,185.43 $ (1,047) $ (775) $ (3,384)

Loss per Pound of Methyl Bromide $/lb $ - $ - $ 14 $ (4) $ (3) $ (14)

Loss as a % of Gross Revenue % 0% 0% 8% -5% -4% -17%

Loss as a % of Net Operating Revenue % 0% 0% -10% 17% 13% 56%

Profit Margin % -73% -31% -95% -26% -27% -14%

Fumigation Costs per Hectare $ 8,509 $ 11,862 $ 3,432 $ 9,274 $ 9,946 $ 3,499

Yield Loss % 0% 0% 15% 0% 0% 0%

Yield per Hectare 17,514 42,700 14,887 42,700 42,700 42,700

Price per Unit $ 5.88 $ 1.13 $ 5.88 $ 1.13 $ 1.13 $ 1.13

Gross Revenue Per Hectare $/ha $ 102,983 $ 48,251 $ 87,536 $ 48,251 $ 48,251 $ 48,251

Operating Costs per Hectare $/ha $ 178,089 $ 63,306 $ 170,513 $ 60,719 $ 61,391 $ 54,944

Net Operating Revenue Per Hectare $/ha $ (75,106) $ (15,056) $ (82,977) $ (12,468) $ (13,140) $ (6,693)

Loss per Hectare $/ha $ - $ - $ 7,871 $ (2,587) $ (1,916) $ (8,363)

Loss per Kilogram of Methyl Bromide $/kg $ - $ - $ 30 $ (10) $ (7) $ (32)

Loss as a % of Gross Revenue % 0% 0% 8% -5% -4% -17%

Loss as a % of Net Operating Revenue % 0% 0% -10% 17% 13% 56%

Profit Margin % -73% -31% -95% -26% -27% -14%

 METHYL BROMIDE 1,3-D + Pic ASD

 3-Way (1,3-

D+pic+metam 

sodium) 

FL Cut Flowers- Lilies 1,3-D+pic 3-Way ASD

Item Year 1 Per Year Per Year Per Year Per Year

Yield Loss per Acre* 0% 0% 0% 0% 0%

Total Operating Costs per Acre $ 111,051 $ 111,051 $ 110,004 $ 110,276 $ 107,667

Net Operating Revenue per Acre $ 6,549 $ 6,549 $ 7,596 $ 7,324 $ 9,933

UNITS

Loss per Acre $/A $ - $ (1,047.09) $ (775.21) $ (3,384.25)

Loss per Pound of Methyl Bromide $/lb $ - $ (2.62) $ (1.94) $ (8.46)

Loss as a % of Gross Revenue % 0% -0.9% -0.7% -2.9%

Loss as a % of Net Operating Revenue % 0% -16% -12% -52%

Profit Margin % 6% 6% 6% 8%

Yield Loss % 0% 0% 0% 0%

Yield per Hectare 31,135 31,135 31,135 31,135

Price per Unit $ 9.33 $ 9.33 $ 9.33 $ 9.33

Gross Revenue Per Hectare $/ha $ 290,596 $ 290,596 $ 290,596 $ 290,596

Operating Costs per Hectare $/ha $ 274,413 $ 271,826 $ 272,498 $ 266,051

Net Operating Revenue Per Hectare $/ha $ 16,182 $ 18,770 $ 18,098 $ 24,545

Loss per Hectare $/ha $ - $ (2,587) $ (1,916) $ (8,363)

Loss per Kilogram of Methyl Bromide $/kg $ - $ (5.77) $ (4.27) $ (18.65)

Loss as a % of Gross Revenue % 0% -0.9% -0.7% -2.9%

Loss as a % of Net Operating Revenue % 0% -16% -12% -52%

Profit Margin % 6% 6% 6% 8%

 METHYL BROMIDE 
REFERENCES

Gerik, J.S., S.R. Dangi, H. Ajwa. 2012a. Calla lily production with methyl bromide alternatives Year 2. Methyl 

Bromide Alternatives Outreach Conference.

Gerik, J.S., S.R. Dangi, H. Ajwa. 2012b. Technology Transfer Methods for Adoption of Methyl Bromide 

Alternatives in California Cut Flower and Bulb Crops. Methyl Bromide Alternatives Outreach 

Conference.

Holzinger, J. 2012. Letter stating methyl bromide is critical for flower production in Florida. Email sent from Erin 

Rosskopf of USDA on Dec. 10, 2012. 

Jhala, A.J., S. Gao, J.S. Gerik, R. Qin and B. D Hanson. 2012 Effects of surface treatments and application shanks 

on nematode, pathogen and weed control with 1,3-dichloropropene. Pest Manag Sci 2012; 68: 225–230 

Kokalis-Burelle, N. and E. N. Rosskopf. 2012. Alternatives to methyl bromide for nematode control in ornamental 

crops. Methyl Bromide Alternatives Outreach Conference.

Rainbolt, C.M. B.D. Hanson, S.A. Fennimore, and J.S. Gerik. 2010. Steam disinfestation as a methyl bromide 

alternative in California cut flower nurseries. Reference cited by applicant. Methyl Bromide Alternatives 

Outreach Conference.

Rosskopf, E.N., N. Kokalis-Burelle, E. and O. Nissen, B. Hartman, E. Skvarch, R. McSorley, T.J. Swaford, S.

Brooks, K. Register, C. Owens. Evaluation of currently available alternatives to methyl bromide for 

ornamental crop production in Florida. Available online at 

http://mbao.org/2010/Proceedings/082RosskopfAAWP.pdf 

Vallad, G., A.W. MacRae, T. Jacoby, and J. W. Noling. MBAO 2010. Sustainability of Methyl Bromide 

Alternatives – Tomato and Pepper Initial Crop, Reference cited by applicant. Methyl Bromide 

Alternatives Outreach Conference.
APPLICANT: Golf Course Superintendents Association of America (CUE 12-0055) 

EPA ANALYSIS 

To substantiate a critical need, a description of industry standard(s) must indicate that either the entire golf 

industry requires MeBr for acceptable turf after reconstruction, or only a portion of the reconstruction projects 

per year use MeBr. If only a portion require MeBr it is unclear how that portion is determined.

Data must provide a clear and consistent picture of critical needs

 Worksheet 2-B states that <0.04% of total golf course acreage requires fumigation, with 3 acres per 

facility on average that are fumigated out of a total of 1,504,210 acres of maintained turfgrass

o This calculates to 200 facilities (x 3 acres/facility=600 acres, therefore, 0.04%) claimed to have a 

critical need for MeBr, yet usage data submitted for MeBr indicates that an average of 79 

facilities per year use MeBr

o If critical needs for MeBr are for 200 facilities, data must be able to support that request, and the 

data appear to give inconsistent needs—a clear description must be presented

 Worksheet 2-C states that there are a total of 16,052 facilities. The 200 facilities that have requested 

MeBr, therefore, make up 1.25% of the total.

o If a course reconstruction lasts for 20 years, is it correct to assume that approximately 800 

reconstruction projects might be required per year (16,052/20)?

o 20 years is significantly longer than other applicants have claimed for MeBr efficacy. Does 

GCSAA have data to substantiate this duration for efficacy? 

o If this is a correct assumption, why do 200 facilities require MeBr as critical, whereas the other 

600 facilities do not? If this is not a correct calculation, please explain. Again, data show that an 

average of 79 facilities used MeBr.

o If reconstruction lasts fewer than 20 years, presumably even more facilities would require 

fumigation per year. What methods are used in facilities that do not use MeBr?

If the entire industry considers MeBr as critical, supporting data must be presented, such as usage data showing 

that MeBr is the only option available and alternatives (such as dazomet, metam-sodium, etc.) have not been 

successfully used, such that turf is unacceptable for play and cause adverse economic impacts. 

If only a portion of the industry has a critical need for MeBr (as suggested in the usage data submitted—i.e., 

~79 facilities per year fumigate with MeBr) then a description with supporting data should be presented to 

differentiate those cases where MeBr is critical to maintain the course, and the majority of construction 

situations where non-MeBr methods are used successfully.

Aspects to consider in an application might include, for example:

 Since it appears that the major pests are off-type grasses (as indicated in the application), state how many 

facilities on average per year would undergo some type of construction, resurfacing, or renovation that 

would require herbicidal treatment (fumigant and/or herbicide)? 

 What portion of total construction projects has a critical need for MeBr annually and what are the 

specific problems?

 Of the facilities that do not require MeBr to successfully maintain their businesses, why can they use 

alternatives that are unavailable to the critical needs facilities?

 If not all projects use MeBr, what do the other projects use or do?

For example, are there differences in pest issues, climate conditions, playing seasons, topography, 

etc. that would account for the need for MeBr in some facilities, but not others. This should be 

clearly described.

ECONOMIC ANALYSIS 

An economist familiar with golf course operations and the golf industry may be able to provide a description of

the important economic aspects that need to be addressed. 
Economic considerations in fumigant selection does not make a compelling case for a critical need, i.e., if 

MeBr is available, but not used because of lack of funds, yet the course continues to operate, there is a 

suggestion that MeBr may be desirable, but not critical to the operation.

For the golf industry, a “yield loss” might be described as increased downtime, or loss of business due to 

the course being shutdown during construction. 

An application might describe and provide support for any extenuating factors that applicant would want to be 

considered.

Economic aspects of golf course operations may be different from many sectors that apply for CUE 

nominations. For example, farm crop yield losses have been clearly defined and examples are familiar, 

whereas losses associated with golf course operations may not be obvious. In addition, “downtime loss” 

is an important variable in golf course impact analysis, but may not be a familiar concept to the Parties. 

According to our analysis, however, the cost differences between MeBr and the alternatives are 

insignificant compared to downtime costs.

Regarding the notion of yield loss, perhaps one might think of the number of rounds played or the number 

of memberships per year as the annual “production” of a golf course, which can be valued at the market 

price of $xx per 18-hole round. If the data were presented regarding the number of rounds played, on 

courses treated with and without MeBr, the estimation of the economic loss caused by the unavailability 

of MeBr might be feasible. 

Supporting evidence might be included that would demonstrate that pest pressure (e.g., off-type grasses) 

causes golfers reduce playing time or play at a different course, thus creating market disruption for an 

individual course that is included in the application

This might include, for example, reduced or cancelled membership from affected courses

Supporting evidence might be included that would demonstrate that alternatives lead to more frequent 

resurfacing and therefore, greater adverse economic impacts. 

Quantitative, rather than qualitative, information should be provided.

Analysis based on the data provided by GCSAA indicates that the cost differences between MeBr 

and the alternatives do not significantly contribute to the economic impact, compared to the 

downtime losses.

The application might include sufficient evidence that would demonstrate that alternatives lead to 

more frequent resurfacing; again, this should be quantitative data

As mentioned above, the interpretation of the economic impact analysis depends on understanding the unique 

features (e.g., downtime) of golf course operations, which may not be obvious to everyone. 

EPA CONCLUSION

More than 10 years after the CUE process began, the Parties demand robust and data-supported nominations. The 

GCSAA has indicated that they are committed to providing data and other information regarding their industry to 

best describe and support their request for a CUE for MeBr. While the U.S. Government declined to put forward 

the GCSAA request for 2015, any subsequent requests will be thoroughly evaluated.

REFERENCES

Chellemi, D.; B. Unruh, J. Mirusso, No date provided. Evaluation of soil fumigant retention under various solid 

tarp application methods. No source listed by applicant. 

Clark. M. 2005. Gas and grass. Methyl bromide helps Troon G&CC get great greens fast. Golf Course 

Management. January 2005.

Davis, D.J. 2002. Gas and grass. An olde Florida course made new. Golf Course Management. January 2002.

Teuton, T.C., J.B. Unruh, B.J. Brecke, G.L. Miller, and T.C. Mueller. 2005. Hybrid Bermudagrass (Cynodon 

dactylon (L.) Pers. × C. transvaalensis Burtt-Davy) Control with Glyphosate and Fluazifop. Applied 

Turfgrass Science. January 19, 2005.

Unruh, J.B., B.J. Brecke, J.A. Dusky, J.S. Godbehere. 2002. Fumigant alternatives for methyl bromide prior to 

turfgrass establishment. Weed Technology, 2002. 16:379-387.
Unruh, B. 2005. Banned in the U.S.A. Grounds Maintenance.

Walker, R. (108). 2008. - Basamid + Eptam: Replacement for Methyl Bromide in Warm-Season Sod Production. 

Methyl Bromide Alternatives Outreach Program.

Walker, R.H. (35) 2007. Replacements for Methyl Bromide in a Centipedegrass-Based Sod Rotation System. 

Methyl Bromide Alternatives Outreach Program.