USA CUN1 5 POST HARVEST DATES 1



### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR POST

HARVEST

-- D ATES

NOMINATING PARTY : The United States of America

FILE NAME : USA CUN 1 5 POST HAVEST USE FOR DATES

BRIEF DESCRIPTIVE TI TLE OF NOMINATION :

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

20 1 4 for 20 1 5 Use Season)

QUANTITY OF METHYL B ROMIDE REQUESTED IN EACH YEAR OF

NOMINATION:

T ABLE 1 : Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION

Y EAR N OMINATION A MOUNT ( KILOGRAMS )

20 1 5 310 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 CUN1 5 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. En vironmental 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 CUN 1 5 POST DATES

* Identical to paper documentsUSA CUN1 5 POST HARVEST DATES 3



### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR POST

HARVEST

-- D ATES

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 con tinue to be available . For additional information, please refer to the links on EPA’s website: http://www.epa.gov/oppsrrd1/registration_review/sulfuryl

- fluori de/evaluations.html

.

T ABLE 2

. N OMINATION A MOUNT

Footnote: Lower amount of methyl bromide nominated based on a lower use rate of 20 kg/1,000 m 3

.

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

This sector comprise s 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 dur ing the fall. These dates are harvested by hand, and growers need to get them to the marketplace in three d ays for maximum

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

, Carpophilus hemipteru s
, and carob moth

, Ectomyelois ceratoniae

, are the mo st damaging species.USA CUN1 5 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, pup al, 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. Ho wever, Dr. Walse’s preliminary results using sulfuryl fluoride with the maximum label

allowed 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 (20 12 ) 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 6 0°F , 24 hours, and atmospheric pressure. Studies we re conducted to determine the efficacy of sulfuryl fluoride

toward carob moth eggs at 7 0°F and atmospheric pressure. Eggs of the dried fruit beetle are not
controlled at atmospheric pressure , 24 hours exposure, and temperature of 8 0°F , or below, given

the current label rates . I t takes longer to control these two insect pests with sulfuryl fluo ride 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 (CO 2 ) . 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% CO 2 showed a LD 95 of 432 mg

. h/l on red flour be etles ( RFB ) eggs and a LD 95 of 353 mg

. h/l on RFB larvae adding carbon dioxide increased the larval effi cacy 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

U nited S tates

.

Past data showed red flour beetle ( RFB ) larvae fumigated with PPO had an LD 95 using 606

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

LD 95 966 mg

. h/l,10% CO 2 was the most effective. Without CO 2 , combining the two fumigants together showed a LD 95 of 432 on RFB eggs and a LD 95 of 353 on RFB larvae. Adding 10%

CO 2 reduces the dosages by about two

- thirds of the fumigants used alone. The CO 2 a long with the synergy of the blend reduces cost, lowers environmental emission and provides greater safety (Muhareb 2009)

.USA CUN1 5 POST HARVEST DATES 5

Reichmuth and Klementz ( Barakat et al., 2009) discussed at the 2009 MBAO possible investigations to overcome the inability of sulf uryl 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. The ir 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 disappea rs. His results indicated that

full control was achieved at a concentration of 4.19 mg/l sulfuryl fluoride onl y 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 ( C T =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 f

or 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 m oth ( Ectomyelosis ceratonia ) or CM in f re shly harvested dates. Complete mortality of eggs and larvae was achieved with 332 oz

- h/MCF ( thousand cubic feet) (g

- h/m 3 ) CT dosage

of sulfuryl fluoride ( ProFume ® ) at 21°C (70°F) during a 1 4

- 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 c hamber fumigation needing a qu ick overnight turnaround

represents about 30% of the date production fumigation s . 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 2 007, 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 demonstrate d 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 s uperior (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 fumig ating dates in s torage.

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

- hourUSA CUN1 5 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 indus try.

4. E CONOMIC ANALYSIS OF TRANSITI ON TO ALTERNATIVES

T ABLE 3. E CONOMIC S UMMARY FOR EACH A LTERNATIVE

M ETHYL B ROMIDE
A LTERNATIVE E CONOMIC S UMMARY

P HOSPHINE P hosphine 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.

S ULFURYL
F LUORIDE SF is a viable alternative for many but not all pests found on dates. SF c osts less per kg

than MeBr, but application rates may be higher.

A n 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 i n 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.

D ates

The dried fruit industry has alrea dy replaced a large portion of me thyl bromide with phosphine and sulfuryl fluoride in processing dried fruits. The USG nomination for methyl bromide is

based on ly 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 1 5,500 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 CUN1 5 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 201 4 (kg) 3 2 5 Commodity Treated with 201 4 Authorized
MeBr (cu m) 1 5 ,5 00

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 $ 1 1 .02 Total cost of fumigant gas ($) $12,316 $3,421

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

1 Assumes rate of 1. 2 5 lbs/1,000 cu ft [2 0 g/cu m] for methyl bromide, 1. 2 5 lbs/1,000 cu ft [ 2 0 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 d ates 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, Oc t 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 CUN1 5 POST HARVEST DATES 8

Walse, Spencer 20 12

. Post harvest fumigation research at USDA

- ARS . USDA/ARS, San Joaquin Valley Agricultural Sciences Center, Parlier, CA 93648. Presentation at 20 12 MBAO, Nov. 6

- 8 , 20 12

, Orlando

, FL . Av ailable 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, No v. 10

- 12, 2009, San Diego,

CA. Available online at: http://mbao.org/2009/063Williams.pdf

.

Williams, R. and E. Thoms. 2008

. ProFume® gas fumigant u pdate: post

- h arvest c ommercial

a cceptance and p erformance in North America

. Presentation at 200 8 MBAO, Nov. 11

- 14, 2008, Orlando, Fl. Available at: http://mbao.org/2008/084Thoms.pdf