USA CUN 13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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## 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 CUN1 3 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methy l Bromide Critical Use Nomination for Post Harvest Use on Structures

-- Food Processing Plants (Submitted in 2011 for 201 3 Use Season) QUANTITY OF METHYL B ROMIDE REQUESTED IN EACH YEAR OF NOMINATION: T ABLE 1. Q UANTITY OF M ETHYL B ROMID E REQUESTED IN E ACH Y EAR OF N OMINATION



### Y EAR 

### N OMINATION 

### A MOUNT 

### ( KILOGRAMS 

### ) 201 3 25,334 kg (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 s ubmitted 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 earl ier 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 22 01 C Street, N.W. Room 2658 Washington, D.C. 20520 U.S.A. Telephone: (202) 647

- 9799 Fax: (202) 647

- 5947 E

- ma il: Thompsonje2@state.gov 

### Following the requirements of Decision IX/6 paragraph (a)(1) United St ates 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  NoUSA CUN 13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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Signature Nam e Date Title:
CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS: Contact/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

- ma il: Housenger.Jack@epa.gov LIST OF DO CUMENTS 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

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 CUN1 3 POST HARVEST ST RUCTURES

- FOOD PROCESSING PLANTS

* Identical to paper documentsUSA CUN 13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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## METHYL BROMIDE CRITICAL USE RENOMINATION FOR POST - HARVEST USE TREATMENT OF STRUCTURES

– FOOD

PROCESSING PLANTS
1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL Food processing facilities in the United States have reduced the number of methy l bromide fumigations b y incorporating a variet y 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 being monitored for pest popu lations, 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 reje cted. These techniques do not disinfest a facility but are critical in monitoring and managing pests, and preventing pest outbreaks. However, when all these methods fail to control a pest problem, facilities must still rely on fumigation, to kill insects in the processing equipment , bins, storage spaces and even the walls of the structure. There are two primary chemical fumigants available to this industry that may accomplish these tasks : methy l bromide and sulfury l fluoride. Heat, a non

- chemical option , is also used in this industry to disinfest facilities. USG is requesting methyl bromide for this sector to allow time for the industry to purchase equipment, modify

structures, and/or practice using alternatives. Sulfury l fluoride, as ProFume ® 

### , rem ains registered in the US for the uses described in this nomination chapter . However, EPA has published a prepublication cop y of the proposed order to revoke tolerances. For additional information, please refer to the links on EPA’s website: http://www.epa.gov/oppsrrd1/registration_review/sulfuryl

- fluoride/evaluations.html

.USA CUN 13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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T ABLE 2 . N OM INATION A MOUNT

Ri ce M iller s Pe t F ood In st it ut e No rth Am er ic an

Mi ller s S ec tor T otal / Av er age Qu an ti ty Re ques ted fo r 2012: Am ou nt (kg s) 14,511 13,722 107,066 135,299 Qu anti ty Re com me nde d by MB TO C/ TE

APfo r 2012 : Am ou nt (kg s) 7,256 13,722 53,533 74,511 Am ou nt (kg s) 7,256 13,722 53,533 74,511 Vo lu me (1000 m 3 ) 726 745 8,459 9,930 Rat e 10 18 6 8 Tr ans itio n fr om 2012 Ba se lin e Ad jus te d Val ue Pe rcen ta ge (% ) -66% -66% -66% -66%
Am ou nt (kg s) 

### 2, 467 4, 665 18, 201 25, 334 Vo lu me (1000 m 3 ) 

### 123 233 910 1267 Rat e 

### 20 20 20 20 Qu anti ty Appr oved by Par

ties fo r 2012: 

### STRU CTUR ES

Qu an tityR eq ui re d for 2013 N om

in atio n: SE CTOR



### 2. SUMMARIZE WHY KE Y ALTERNATIVES ARE N OT FEASIBLE T his nomination is for facilities, or portions of facilities, that are unsuitable for the alternatives, or where the alternatives are not economicall y feasible. Sulfuryl fluoride is highl y dependent upon temperature, so should a facility need fumigation during cold temperatures, this chemical may not be a cost

- effective solution. S ulfuryl fluoride requires higher dosages for egg kill, a paramount concern in certain facilities . Phosphine can be explosive and is corrosive to man y 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/lay out f actors, which affect the ability

to evenl y 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 (i.e. rancidity of edible oils)

. In addition, there is some confusion as to the materials that may be directly

fumigated with sulfury l fluoride. According to the Profume ® label pet food is not listed as a material approved for direct treatment. The intention of the label is to have as much product removed as possible prior to fumigation. This “incidental” fumigation has resulted in problems with label interpretation . Some companies insist that all pet food products would need to be removed from treatment areas or sufficiently prot ected to prevent the formation of sulfuryl fluoride residues on the pet food products. This is also a factor for mills that produce mixes (e.g. cake mixes, muffin mixes, etc.). Millers have reported that tarping off

- sulfury l fluoride label ingredients and product is not practical because there could be dozens of ingredients in the facility . The ingredients and products that cannot be treated would have to be staged together in an open area in order to be covered with a tarp. The industry claims that there is not sufficient unused space in which to stage unlabeled ingredients and product during a sulfury l fluoride fumigation.USA CUN 13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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The industry

reports that complete removal of non

- sulfuryl fluoride treatable ingredients and product from the target facility w ould present significant logistical challenges, including multiple forklifts and forklift drivers, plus rented truck trailers onto which the ingredients could be loaded. These trailers would then be removed from the facility , most likely to available spac e in the parking lot. A process that would add labor and trailer rental costs as well as costs associated with additional downtime needed to accomplish the ingredient removal task. Heat is an alternative that may be used in some facilities. In additio n, heat may be used in conjunction with sulfury l fluoride. However, facilities constructed primarily from wood, about 25 percent of the flour mills in the U.S. , may not be able to use heat because of warping of the wood. There is also a high initial inve stment to purchase heaters, modify sprinkler s ys tems, and educate personal on heat treatments. USG is requesting methyl bromide for this sector to allow time for the industry to purchase equipment, modify

structures, and/or practice using alternatives. The current registration of sulfury l fluoride, as ProFume ® 

### , remains unchanged in the US for the uses in this nomination. However, EPA has published a prepublication copy of the proposed order to revoke tolerances. For additional information, please refe r to the links on EPA’s website: http://www.epa.gov/oppsrrd1/registration_review/sulfuryl

- fluoride/evaluations.html

. 3. RESEARCH RESULTS SHOWING EFFICACY O F ALTERNATIVES Fu migants The 2010 MBAO presentations included reports of several structural alternatives to methyl bromide. One of those was by Horn (Horn, et al. 2010) regarding the use of Fosfoquim in structures. To manage corrosion they took multipl e steps, including: using phosphine without ammonia; used constant low concentrations of phosphine; painted exposed metals (i.e. copper and its alloy s); and wrapped electronic equipment in plastics and injected fresh air. The results presented b y Horn (20 10) showed that efficacious levels of phosphine were maintained with their diluphos sy stem. Hartzer, et al. (2010) compared meth yl bromide, sulfury l fluoride, and heat treatments in the Kansas State University

flour mill. The efficacy results of the su lfuryl fluoride and methy l bromide treatments were not significantl y different. However, the heat treatment s were not as efficacious, having some adult and larval survival (Hartzer, et al., 2010). Arthur, et al. (2010) summarized the residual efficacy of p yr ethrin plus insect growth regulators aerosols on red and confused flour beetles. Confused flour beetles were less susceptible to the aerosols than were red flour beetles. The aerosol mixtures provided residual control, up to 16 weeks, for the 3% p y

rethrin plus methoprene. Surface composition also affected the variation of residual control of the mixtures. The researchers found that plastic overwrap provided longer control than did paper bags. (Arthur, et al., 2010) Holcomb and McLean (2010) repo rted on an IPM approach in pet food processing plants and warehouses. The authors have had success in controlling pests in these facilities for over 5 ye ars.USA CUN 13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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They ensure outside sanitation around plants and warehouses. They also try to reduce introducin g pests b y inspecting incoming ingredients and goods to ensure they are “clean;” maintaining screens at windows and doors; and placing lights so that insects are not attracted to openings. Microsanitation and pest control access are stressed in Holcomb an d McLean’s (2010) IPM approach. Holcomb mentioned during his MBAO (2010) presentation that companies need to hire a sanitation team to ensure that the facility and all equipment could be thoroughly cleaned every 30 day s to break the life cy cle of stored p roduct pests (which is ty pically about 45 day s). (Holcomb and McLean, 2010) 4. ECONOMIC IMPACTS T ABLE 3. E CONOMIC S UMMARY FOR EACH A LTERNATIVE M ETHYL B ROMIDE A LTERNATIVE E CONOMIC S UMMARY

H EAT T REATMENT For most facilities, i.e., those not constructed p rim arily of wood, it is feasible to switch to

heat treatments. S om e facilities experience better insect control with heat than fumigation due to leaky structures that allow gas to escape. S ULFURYL F LUORIDE Sulfuryl fluoride is an economically viable op tion for most food processing facilities.

Exceptions include facilities that manufacture products not on the ProFume ® label, e.g. cake mixes , pet food facilities

. 

### Two economic anal ys es are conducted

– one for pet food facilities and one for other food p rocessing facilities. Pet food facilities are conducted separatel y because the industry supplied its own revenue data. For other facilities, the only available data was a budget for a 500,000 cubic foot flour mill. Sulfury l fluoride is technically feas ible onl y in facilities that do not prepare mixed products (e.g., cake mixes) due to labeling. Pet Food Facilities Table 4 . Analysis of transition to alternatives for pet f ood facilities 1 Methyl Bromide Heat Heat (after initial investment) Size of fa cility to be treated (cu m) 28,317 28,317 28,317 Total Revenues/Sales $ 40,600,000 $ 40,600,000 $ 40,600,000 Cost of Disinfestation $ 37,200 $ 55,600 $ 30,700 Change in cost from MeBr to alternative $ 1 8,358 $ (6,551) % change in gross revenue from MeBr 0.0 5%

- 0.02 % 1 Numbers may not add due to rounding; all figures are rounded to the nearest hundred. 2 Revenues from CUE application, based on value of average daily production ($116,000) t imes 350 operating days per year. 3 Disinfestation costs for methyl bromide based on figures from Adam et al. (2010), adjusted for changes in price of gas. Analysis assumes two fumigations per year for MeBr and three treatments per year of heat. Assumes gas price of $20.94 per kg and application rates of 24 kgs / tcm for methyl bromide. 4 Heat disinfestation costs came from TempAir. The first heat column assumes the facility is in an initial ten year investment phase when it is paying for the he aters and the cost of energy and materials for fumigation.USA CUN 13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 

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Initial cost of heaters for a 14,158 cubic meter facility is approximately $249,000, or $14,900 spread over ten years. The cost of energy and materials for each fumigation of a 28,317 cubic meter facility is approximately $10,229 after the initial investment period in the heaters. 

### Mills and Other Food Processing Facilities Revenue and cost data were available for a 14,158 cubic meter (500,000 cubic foot) flour mill. Table 5 display s the econo mic anal ys is of transition to sulfury l fluoride and heat from methy l bromide. Table 5. Analysis of transition to alternatives for mills and other food processors 1 Methyl Bromide Sulfuryl

Fluoride Heat Heat (after initial investment) Size of facility to be treated (cu m) 14,158 14,158 14,158 14,158 Total Revenues/Sales 2 $ 32,835,700 $ 32,835,700 $ 32,835,700 $ 32,835,700 Operating Costs $ 28,281,000 $ 28,281,300 $ 28,287,100 $ 28,274,600 Mfg and Sales Costs $ 1,537,30 0 $ 1,537,600 $ 1,543,400 $ 1,530,900 Disinfestation 3, 4 $ 23,000 $ 23,300 $ 29,100 $ 16,600 Cost of Goods Sold $ 26,743,700 $ 26,743,700 $ 26,743,700 $ 26,743,700 Net Revenue $ 4,5 54,700 $ 4,554,400 $ 4,548,600 $ 4,561,100 Change in cost from MeBr to alternative $ 300 $ 6,1 00 $ (6,400 ) % change in net revenue from MeBr

- 0.01%

- 0.13% 0.14% 1 Numbers may not add due to rounding ; all figures are rounded to the nearest hundred. 2 Revenues based on total cwt shipped of 2,450,000; Budget from Kenkel and Holcomb (2010), 10

- year avg, rounded to nearest hundred

. 3 Disinfestation costs for methyl bromide and sulfuryl fluoride based on figures from Adam et al. (2010), adjusted for changes in price of gas and size of facility. Analysis assumes two fumigations per year for both MeBr and SF and three treatments per year of heat. Assumes gas price of $20.94 per kg and application rates of 24 kgs / tcm for methyl bromide; $13.23 per kg 32 kgs / tcm for sulfuryl fluoride. 4 Heat disinfestation costs came from TempAir. The first heat column assumes the facility is in an initial ten year investment phase when it is paying for the heat ers and the cost of energy and materials for fumigation. Initial cost of heaters for a 14,158 cubic meter facility is approximately $125,000, or $12,500 spread over ten years. The cost of energy and materials for each fumigation of a 14,158 cubic meter f acility is approximately $5,531 after the initial investment period in the heaters.



### CITATIONS: Brijwani, M., B. Subramany am, M. Hartzer, D. E. Maier, W. Chay aprasert, S. Savoldelli, P. Flinn , and J. Campbell. 2009. Efficacy of structural heat treatments a gainst Tribolium castaneum l ife s tages. Presentation at Methy l Bromide Alternatives Outlook Conference, San Diego, November 2009. Available at: http://mbao.org/2009/066Brijwani.pdf

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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

. 

### Hartzer, M. Subraman ya m, B., Brijwani, M., Chay aprasert, W., and Maier , D. E. 2010. Methy l bromide, sulfuryl fluoride and heat: effectiveness against red flour beetle

. Presentation at MBAO, Nov. 2

- 5, 2010, Orlando, Fl. A vailable at: http://mbao.org/2010/67Hartzer.pdf

. Hartzer, M., B. Subramany am, W. Chay aprasert, D. E. Maier, and S. Savoldelli. 2009. Methyl Bromide and Sulfury l Fluoride Effectiveness Against Red Flour B eetle Life Stages. Presentation at Meth yl 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 meth yl 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 H orn diluphos sy stem . Presentation at MBAO, Nov. 2

- 5, 2010, Orlando, Fl. Available at: http://mbao.org/2010/66Horn.pdf

.