USA CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 1

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 CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING 

PLANTS

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

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

Plants (Submitted in 2011 for 2013 Use Season)

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF 

NOMINATION:

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

YEAR NOMINATION AMOUNT (KILOGRAMS)

2013 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 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 CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 2

Signature Name 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-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

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 CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING 

PLANTS

* Identical to paper documents
USA CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 3

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 methyl bromide 

fumigations by incorporating a variety of different techniques to control pests. The most critical 

strategy implemented is IPM, especially sanitation, and equipment design modifications to 

enable cleaning and inspection in all areas of a facility. Facilities are being monitored for pest 

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

When insect pests are found, facilities will attempt to contain the infestation with treatments of 

low volatility pesticides applied to both surfaces and cracks and crevices; spot treatments with 

heat or phosphine will be used in areas that are suitable. Incoming ingredients are inspected for 

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

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

critical in monitoring and managing pests, and 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: 

methyl bromide and sulfuryl 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. 

Sulfuryl fluoride, as ProFume®, remains registered in the US for the uses described in this 

nomination chapter. However, EPA has published a prepublication copy 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 CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 4

TABLE 2. NOMINATION AMOUNT

 Rice Millers 

 Pet Food

Institute 

 North American

Millers 

 Sector Total / 

Average

Quantity Requested for 2012: Amount (kgs) 14,511 13,722 107,066 135,299

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 7,256 13,722 53,533 74,511

Amount (kgs) 7,256 13,722 53,533 74,511

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

Rate 10 18 6 8

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -66% -66% -66% -66%

Amount (kgs)

 2,467 4,665 18,201 25,334

Volume (1000 m3) 123 233 910 1267

Rate 20 20 20 20

Quantity Approved by Parties for 

2012:

STRUCTURES

Quantity Required for

2013 Nomination:

SECTOR

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

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

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

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

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

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

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

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

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

which affect the ability to evenly distribute heated air; and the availability of convenient and 

economical sources of heat. In addition, heat may not be a viable option for treatment of food 

products or commodities (i.e. rancidity of edible oils). 

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

sulfuryl 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 protected 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-sulfuryl 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 sulfuryl fluoride fumigation.
USA CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 5

The industry reports that complete removal of non-sulfuryl fluoride treatable ingredients and 

product from the target facility would 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 space 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 addition, heat may be used in 

conjunction with sulfuryl 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 investment to purchase heaters, modify sprinkler systems, 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 

sulfuryl 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 refer to the links on EPA’s website: 

http://www.epa.gov/oppsrrd1/registration_review/sulfuryl-fluoride/evaluations.html. 

3. RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES

Fumigants

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 multiple steps, including: using phosphine without 

ammonia; used constant low concentrations of phosphine; painted exposed metals (i.e. copper 

and its alloys); and wrapped electronic equipment in plastics and injected fresh air. The results 

presented by Horn (2010) showed that efficacious levels of phosphine were maintained with 

their diluphos system. 

Hartzer, et al. (2010) compared methyl bromide, sulfuryl fluoride, and heat treatments in the 

Kansas State University flour mill. The efficacy results of the sulfuryl fluoride and methyl 

bromide treatments were not significantly different. However, the heat treatments were not as 

efficacious, having some adult and larval survival (Hartzer, et al., 2010). 

Arthur, et al. (2010) summarized the residual efficacy of pyrethrin 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% pyrethrin 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) reported 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 years. 
USA CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 6

They ensure outside sanitation around plants and warehouses. They also try to reduce 

introducing pests by 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 and 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 days to break the life cycle of stored product pests (which is typically about 45 days). 

(Holcomb and McLean, 2010)

4. ECONOMIC IMPACTS

TABLE 3. ECONOMIC SUMMARY FOR EACH ALTERNATIVE

METHYL BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

HEAT TREATMENT

For most facilities, i.e., those not constructed primarily of wood, it is feasible to switch to 

heat treatments. Some facilities experience better insect control with heat than fumigation 

due to leaky structures that allow gas to escape. 

SULFURYL FLUORIDE

Sulfuryl fluoride is an economically viable option 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 analyses are conducted – one for pet food facilities and one for other food 

processing facilities. Pet food facilities are conducted separately 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.

Sulfuryl fluoride is technically feasible only 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 food facilities 1

Methyl Bromide Heat Heat (after initial 

investment)

Size of facility 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 $ 18,358 $ (6,551)

% change in gross revenue from MeBr 0.05% -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) times 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 heaters and the cost of energy and materials for fumigation. 
USA CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 7

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 displays the economic analysis of transition to sulfuryl fluoride and heat from methyl 

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 $ 1,537,300 $ 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 $ 4,554,700 $ 4,554,400 $ 4,548,600 $ 4,561,100 

Change in cost from MeBr to alternative $ 300 $ 6,100 $ (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 heaters 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 facility is approximately 

$5,531 after the initial investment period in the heaters. 

CITATIONS: 

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. 
USA CUN13 POST HARVEST STRUCTURES - FOOD PROCESSING PLANTS Page 8

Arthur, F. H., A. E. Sutton, K. Y. Zhu, and J. F. Campbell. 2010. Residual efficacy of pyrethrinmethoprene aerosols on packaging surfaces. Presentation at MBAO, Nov. 2-5, 2010, Orlando, Fl. 

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

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/2010/66Horn.pdf.