USA CUN15 POST HARVEST DATES 1

METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST -- DATES

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN15 POST HAVEST USE FOR DATES

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Post Harvest Use on Commodities (Submitted in 

2014 for 2015 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)

2015 310 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: Federico San Martini, Ph.D.

Title: Foreign Affairs Officer

Address: Office of Environmental Policy

U.S. Department of State

2201 C Street, N.W. Room 2657

Washington, D.C. 20520 

U.S.A.

Telephone: (202) 647-3819

Fax: (202) 647-1052

E-mail: SanMartiniFM@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that the 

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

this use would result in a significant market disruption. ■ Yes  No

Signature Name Date

Title: 
USA CUN15 POST HARVEST DATES 2

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Mark Hartman

Title: Acting 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) 308-0734

Fax: (703) 308-7042

E-mail: Hartman.Mark@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 CUN15 POST DATES

* Identical to paper documents
USA CUN15 POST HARVEST DATES 3

METHYL BROMIDE CRITICAL USE RENOMINATION FOR POSTHARVEST -- DATES

1. SUMMARY OF NEED FOR METHYL BROMIDE

Commodity fumigation with methyl bromide is used primarily at harvest time, when rapid 

fumigation is needed to keep up with the large volumes of incoming commodities that need to be 

shipped to market in three days for maximum value. 

Sulfuryl fluoride, as ProFume®, remains registered for the uses included in this nomination in the 

U. S. EPA has published a proposed order to revoke tolerances; however, for the purposes of 

this nomination, USG is assuming that sulfuryl fluoride will continue to be available. For 

additional information, please refer to the links on EPA’s website: 

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

TABLE 2. NOMINATION AMOUNT 

Footnote: Lower amount of methyl bromide nominated based on a lower use rate of 20 kg/1,000 m3.

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

This sector comprises palm dates, which are subject to infestation by several insect pests. Since 

infestation begins in the field, methyl bromide is used to rapidly fumigate harvested 

commodities. Dates are grown in Imperial and Riverside counties in California. Methyl 

bromide is used to rapidly fumigate California dates at harvest time, when up to 364,000 pounds 

per day are being harvested within a relatively tight timeframe during the fall. These dates are 

harvested by hand, and growers need to get them to the marketplace in three days for maximum 

value. Although several insects may infest dates, all life stages of the dried fruit beetle,

Carpophilus hemipterus, and carob moth, Ectomyelois ceratoniae, are the most damaging 

species. 

COMMODITIES

 California Date 

Commission 

Quantity Requested for 2014: Amount (kgs) 325

Quantity Recommended by 

MBTOC/TEAP for 2014 :

Amount (kgs) 325

Amount (kgs) 325

Volume (1000 m3) 15.5

Rate 21

Transition from 2014 Baseline 

Adjusted Value

Percentage (%) 5%

Amount (kgs) 310

Volume (1000 m3) 15.5

Rate 20

Quantity Required for 

2015 Nomination:

Quantity Authorized by Parties 

for 2014:

SECTOR
USA CUN15 POST HARVEST DATES 4

The California Date Commission reports that it is currently testing the efficacy of methyl 

bromide alternatives on dates, in collaboration with Dow AgroSciences and Dr. Walse of USDA

Agricultural Research Service. Research with sulfuryl fluoride indicates that it is currently the 

methyl bromide alternative with the greatest potential to rapidly disinfest California dates at 

harvest time (Walse 2013). Recent studies have shown that under vacuum or atmospheric 

conditions, sulfuryl fluoride is effective over the required treatment time against adult, pupal, and 

larval stages of stored product pests (Walse 2012). Work by Williams and Toms (2008) indicate 

excellent control of all stages of dried fruit beetle and carob moth with sulfuryl fluoride at label 

rates. However, Dr. Walse’s preliminary results using sulfuryl fluoride with the maximum labelallowed exposure show less than adequate egg kill at temperatures over the range 60-80 F for 

several species of stored product pests. Phosphine takes longer than sulfuryl fluoride to fumigate 

dates (5 to 7 days), and during this time the dates ferment, resulting in an off-flavor and an 

unmarketable product. 

3. SUMMARY OF RECENT RESEARCH 

Walse (2012) has demonstrated that nearly two-fold the maximum sulfuryl fluoride exposure 

allowed on the label is required for 95 percent control of carob moth eggs at 60°F, 24 hours, and 

atmospheric pressure. Studies were conducted to determine the efficacy of sulfuryl fluoride 

toward carob moth eggs at 70°F and atmospheric pressure. Eggs of the dried fruit beetle are not 

controlled at atmospheric pressure, 24 hours exposure, and temperature of 80°F, or below, given 

the current label rates. It takes longer to control these two insect pests with sulfuryl fluoride

compared to methyl bromide which makes it more difficult to get the fruit to market in a short 

period of time. 

Because temperatures at night can fall below 70°F, further research is needed to optimize the

ovicidal efficacy of sulfuryl fluoride. In addition, further research is needed to determine the 

efficacy that results from pairing sulfuryl fluoride with a more potent ovicide, such as propylene 

oxide. The Dried Fruit Association of California and Walse continue to conduct research on

combinations of PPO, sulfuryl fluoride and carbon dioxide (CO2). Muhareb’s (2009) 

presentation at the 2009 MBAO noted that combining the two fumigants at atmospheric pressure 

in a 1:1 molar ratio with 5-10% CO2 showed a LD95 of 432 mg.h/l on red flour beetles (RFB)

eggs and a LD95 of 353 mg.h/l on RFB larvae adding carbon dioxide increased the larval efficacy 

of the PPO+SF mixture. Hopefully, this will be true on other pests found on fresh dates. At this 

time propylene oxide is not registered for use on dates so this combination cannot be used in the 

United States.

Past data showed red flour beetle (RFB) larvae fumigated with PPO had an LD95 using 606 

mg.h/l SF is just the opposite requiring higher concentration x time (CT) product for the eggs, 

LD95 966 mg.h/l,10% CO2 was the most effective. Without CO2, combining the two fumigants 

together showed a LD95 of 432 on RFB eggs and a LD95 of 353 on RFB larvae. Adding 10% 

CO2 reduces the dosages by about two-thirds of the fumigants used alone. The CO2 along with 

the synergy of the blend reduces cost, lowers environmental emission and provides greater safety 

(Muhareb 2009). 
USA CUN15 POST HARVEST DATES 5

Reichmuth and Klementz (Barakat et al., 2009) discussed at the 2009 MBAO possible 

investigations to overcome the inability of sulfuryl fluoride to control the egg stage of many 

stored product pest insects. These included combinations of gases such as sulfuryl fluoride with 

phosphine or carbon dioxide. They also proposed using heat to increase the efficacy of sulfuryl 

fluoride. Their preliminary data demonstrated that these combinations show promise for many 

stored product pests of dried fruits and tree nuts. (Barakat et al., 2009) 

Reichmuth, also at the 2009 MBAO, presented data regarding sulfuryl fluoride efficacy on the

eggs of the rice moth Corcyra cephalonica. He showed that older eggs were more tolerant of 

sulfuryl fluoride than were the young eggs. His data show that by increasing the exposure time 

the difference between the ages of the eggs is reduced and disappears. His results indicated that 

full control was achieved at a concentration of 4.19 mg/l sulfuryl fluoride only after 5 days of 

fumigation (CT=120 x 4.19mgh/l=502mgh/l); 5.24 mg/l were sufficient to control all 

investigated eggs with exposure of 4 days (CT=503 mgh/l); and 5 days (CT=628 mgh/l), as well 

as three days old eggs with 3 d fumigation (CT=377 mgh/l). Three days fumigation served to 

kill all eggs of all ages with 6.24 mg/l (ct=449mgh/l). These ct-products are in range with 

corresponding values for lethal ct products for the other related stored product pest moths 

Ephestia kuehniella, Plodia interpunctella and Ephestia elutella (Barakat et al., 2009).

Williams (2009), of Dow AgroSciences, presented the results of sulfuryl fluoride investigations 

on carob moth (Ectomyelosis ceratonia) or CM in freshly harvested dates. Complete mortality 

of eggs and larvae was achieved with 332 oz-h/MCF (thousand cubic feet) (g-h/m3) CT dosage 

of sulfuryl fluoride (ProFume®) at 21°C (70°F) during a 14-h exposure (essentially 1.48 

lbs/MCF). Compare that to 1.5 lb/MCF of MB, for chambers with a moderate HLT (half loss 

time) of 20 h and a short, overnight exposure of 16 h (Williams, 2009). 

Williams (2009) reported that chamber fumigation needing a quick overnight turnaround 

represents about 30% of the date production fumigations. The remaining 70% of the fumigations 

occur in 5.0-MCF stacks of bins under tarps in the open yard, when time is not critical and the 

tarps may be kept sealed for weeks or even months. With the anticipated 50+ h HLT actually 

measured with the tarps in 2007, a fumigation using only 1.3 lb/MCF of ProFume would require 

16 h to achieve 300 oz-h/MCF for carob moth control. Further gas savings can occur by 

extending the exposure time. At 50-h HLT and 72-h exposure, a 300 oz-h/MCF CT dosage for 

ProFume can be achieved applying only 0.4 lb MCF (Williams, 2009).

Williams (2009) reported that the codling moth efficacy of sulfuryl fluoride at 300 oz-h/MCF CT 

dosages combined with good HLT, which can be achieved with good structural sealing 

techniques, and demonstrated that sulfuryl fluoride is an equivalent (weight: weight) alternative 

to methyl bromide in fresh dates for short-exposure overnight fumigations. When extended 

exposures are possible in tarped stacks, sulfuryl fluoride becomes superior (weight: weight) to 

methyl bromide. Williams (2009) concludes that his study demonstrates that in all aspects 

(technical, practical and economical), sulfuryl fluoride is a viable alternative to methyl bromide 

for control of codling moth when fumigating dates in storage.

Liu (2011) investigated the potential of oxygenated phosphine on insect pests of lettuce. Dr. Liu 

included a stored product pest, Indianmeal moth, in his investigations and found that a 48-hour 
USA CUN15 POST HARVEST DATES 6

fumigation in chambers with 30% oxygen content did result in significant mortality of larvae and 

eggs. This is only one study and much more research needs to be done, especially with dates. 

However, this could be an area of future research for the industry. 

4. ECONOMIC ANALYSIS OF TRANSITION TO ALTERNATIVES

TABLE 3. ECONOMIC SUMMARY FOR EACH ALTERNATIVE

METHYL BROMIDE 

ALTERNATIVE

ECONOMIC SUMMARY

PHOSPHINE

Phosphine is a viable alternative for walnuts and dried fruit in storage. However, this 

nomination is for fruit being shipped immediately to market not fruit in storage.

SULFURYL 

FLUORIDE

SF is a viable alternative for many but not all pests found on dates. SF costs less per kg

than MeBr, but application rates may be higher.

An economic analysis of alternatives was conducted for fresh dates. The economic analyses of 

transition to alternatives are based on the cost of transitioning an example amount of fresh dates

treated with methyl bromide or sulfuryl fluoride.

The analyses focus on the differences in the cost of fumigant gas and the cost of fumigation 

space (i.e., fumigation chambers) between methyl bromide and the sulfuryl fluoride. It does not 

take into account any losses that might occur due to differences in product performance (i.e., 

efficacy) against different life stages of the target pests. The cost to transition to SF is negligible 

for dates but will not control dried fruit beetle eggs in the time available.

Dates

The dried fruit industry has already replaced a large portion of methyl bromide with phosphine 

and sulfuryl fluoride in processing dried fruits. The USG nomination for methyl bromide is 

based only on areas where the industry needs to harvest and ship the fruit in a short period of 

time. 

The results of the economic analysis for dates are presented in Table 4 and 5. Sulfuryl fluoride is 

the only alternative considered for dates. A transition to sulfuryl fluoride will result in cost 

savings for the industry of approximately $9,000 per year per 15,500 cubic meter fumigation 

facility. SF will work for dates in storage but does not provide rapid enough control for dates 

being shipped immediately to market.
USA CUN15 POST HARVEST DATES 7

Table 4. Summary Information on Date Industry and Methyl Bromide 

Production and Value 

Commodity Metric Tons Produced per Year 19,396

Gross Revenue per Metric Ton $ 32,693,000 

MeBr Use 

MeBr Authorized by Parties 2014 (kg) 325

Commodity Treated with 2014 Authorized 

MeBr (cu m)

15,500

Table 5. Analysis of transition to alternatives for dates treated with methyl bromide

Methyl Bromide Sulfuryl 

Fluoride

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

Total gas needed for fumigation (kgs) 310 310

Price of fumigant gas ($ / kg) $ 39.68 $ 11.02

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

Cost difference between MeBr and alternative $ (8,895)

1 Assumes rate of 1.25 lbs/1,000 cu ft [20 g/cu m] for methyl bromide, 1.25 lbs/1,000 cu ft [20

g/cu m] for sulfuryl fluoride.

2 Differences from previous amount of gas caused by change of use rate for both MeBr and SF. In 

previous years rates of up to 24 g/cu m were used in the calculations.

5. CONCLUSION

Dates are subject to infestation by several pests. This nomination is for use on dates that depend 

upon a rapid fumigation during harvest. This nomination is only for the dates that are harvested 

and need to be sent to the market rapidly (within 3 days).

6. CITATIONS

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. 

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

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

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. 
USA CUN15 POST HARVEST DATES 8

Walse, Spencer 2012. Post harvest fumigation research at USDA-ARS. USDA/ARS, San 

Joaquin Valley Agricultural Sciences Center, Parlier, CA 93648. Presentation at 2012

MBAO, Nov. 6 - 8, 2012, Orlando, FL. Available online at: 

http://mbao.org/2012/52Walse.pdf

Walse, S. 2012. Personal communication. January 2013 

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