USA CUN 13 POST HARVEST

-- Dry , Cured Pork Products Page 1



### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR POST
HARVEST
-- DRY CURED PORK PRODUCTS

NOMINATING PARTY : The United States of America FILE NAME USA CUN 13 POST HARVEST
-- DRY, CURED PORK PROD UCTS BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methy l Bromide Cr itical Use Nomination for Post Harvest Use on Dry Cured Pork Products (Submitted in 20 11 for 201 3 Use Season) STRUCTURE, COMMODITY OR OBJECT TREATED: This sector is for the production of cured meat products, such as country hams. These are produced prima rily

in the southern U.S. This sector has no known viable alternative currentl y available. QUANTITY OF METHYL B ROMIDE REQUESTED IN EACH YEAR OF NOMINATION:
T ABLE 1 : Q UANTITY OF M ETHYL B ROMIDE REQUESTED IN E ACH Y EAR OF N OMINATION

Y EAR N OMINATION A MOUNT ( KILOGRAMS ) 201 3 3,730 (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 or iginal 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: Foreign Affairs Officer 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

- 1123 Fax: (202) 647

- 5947 E

- ma il: ThompsonJH@state.gov Following the requirements of Decision IX/6 paragraph (a)(1) United States of America has determined that the specific use detaile d 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

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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 DOCUMENTS SENT TO THE OZ ONE 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 Ham

* Identical to paper documentsUSA CUN 13 POST HARVEST

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### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR POST
HARVEST
-- DRY CURED PORK PRODUCTS 1. SUMMAR

Y OF NEED FOR METHYL BROMIDE AS A CRITICAL USE Currently there are no viable alternatives to methy l bromide for the dried meat industry : heat would alter the product , and phosphine may not control mites, a major pest . Sulfury l fluoride rec eived federal registration and has been tested for efficacy against the mites and oth er pests of cured meat products

. Although mortalit y of the red

- legged ham beetle occurred at levels below maximum rates of sulfury l fluoride, the same cannot be said for the ham mites (Phillips, et al., 2008). Control of the ham mites took three times the legal limits of sulfuryl fluoride (Phillips, et al., 2008). At the time of this nomination there are no known registered alternatives for use on hams in the U.S. that provide the sam e level of pest control as methy l bromide. This industry

is cooperating with universit y researchers to find technicall y and economically feasible alternatives to methy l bromide. In the meantime, this industry is using IPM techniques to manage their pest populations. All use sanitation to keep their curing facilities clean. Several companies have modified their buildings to make them more gas

- tight. Some companies are eliminating grass, trees, and shrubs from their buildings and replacing it with gravel , as suggested b y researchers in 2008 . Many use pheromone traps; however, these traps onl y used for monitoring purposes at this time (Arthur and Phillips, 2003). This industry

currentl y has no viable chemical alternative available. Although its I PM me asures may have reduced the number of times fumigation is needed in some facilities, it has not eliminated the need for fumigation. Therefore, methy l bromide remains critical to this industry

.
T ABLE 2 . N OMINATION A MOUNT

Gwal tn ey of Smit hf ield Na ti on al

Co unt ry H am As soc iat ion Na hunt a Pork

Cent er Am er ic an

As so c. of Mea t Proce ssor s S ec tor T otal / Aver age Qu an ti ty Re quested fo r 2012: Am ou nt (kg s) 726 709 91 2,204 3, 730 Qu anti ty Re co mme nded by MB TO C/ TE

AP fo r 2012 : Am ou nt (kg s) 726 709 91 2,204 3, 730 Am ou nt (kg s) 726 709 91 2,204 3, 730 Vo lum e (1000 m 3 ) 56 42 5 110 213 Rat e 13 17 19 20 18 Tr ans itio n from

2 012 Ba se lin e Ad jus te d Val ue Pe rcent age (%) 0% 0% 0% 0% 0%
Am ou nt (kg s) 726 709 91 2,204 3, 730 Vo lum e (1000 m 3 ) 36 35 5 110 187 Rat e 20 20 20 20 20 HAM

Qu anti ty Appr ove d by Pa rt ie s fo r 2012:

Qu an tity R eq uir ed for 2013 N om

in ation : SE CTORUSA CUN 13 POST HARVEST

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2. SUMMARIZE WHY ALTERNATI VES ARE NOT FEASIBLE This industry

currentl y has no known viable chemical alternative available. Although its IPM measures may

have reduced the number of times fumigation is needed, it has not eliminated the need for fumigation. Therefore, meth yl bromid e remains critical to this industry

.
3. RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES R esearchers are currently investigating the control of arthropod pests that infest dry cured pork products during the aging process

. In the spring of 2007 , a p roposal was submitted to the USDA CSREES Integrated Research, Education, and Extension Competitive Grants Program

- Methyl Bromide Transitions by several meat scientists and an entomologist. This proposal was funded from 2007 to 2010 . A no

- cost extension was granted for 2010

- 2011, and additional funding has been provided through the Southern R egions I ntegrated P est M anagement Center to continue research efforts for 2010 and 2011. In addition, a grant will be submitted to the USDA in 2011 to seek funds to continue research with respect to potential alternatives to methy l bromide for use in the dry cured pork industry . All of th e research projects listed above and below are being conducted in conjunction with the National Country Ham Association, The Americ an Association of Meat Processors, individual ham producers, and fumigant companies. There were several objectives to the research project that was funded b y the USDA MBT program from 2007

- 2010. The first objective was to determine the effectiveness of chemical controls (sulfury l fluoride, phosphine, and methy l bromide) against all life stages of both mold mites ( Tyrophagus putrescentiae ) and red legged ham beetles ( Necrobia rufipes ). The second objective was to determine the effectiveness of carbon di oxide and ozone against all life stages of both mold mites and red legged ham beetles. The third objective was to test the effects of sulfury l fluoride, phosphine and methy l bromide on the quality and safet y of the dry

cured hams. The fourth objective wa s to conduct an economic analy sis of the alternatives demonstrated to be technicall y viable alternatives for methyl bromide in this industry

. The results of sulfury l fluoride efficacy investigations on Tyrophagous putrescentiae , ham mite, and Necrobia r ufipes , red

- legged ham beetle, were presented at the 2008 MBAO Conference, in Orlando, F L . The studies included eggs and a mixture of adults and large ny mphs of mites and the eggs, large larvae, pupae and adults of beetles. The experiments were conducted for 48 hours at 23° C at various concentrations of sulfuryl fluoride. The investigators achieved 100% mortality of red

- legged ham beetle adults and pupae at about 4.0 g/m 3 , and 100% mortality of larvae at 5.7 g/m 3 . Eggs of red

- legged ham beetles died at 24.0 g/m 3 of sulfuryl fluoride, well below the maximum label rate (Phil lips et al. , 2008). Mortality of ham mites required much higher concentrations of sulfury l fluoride. A concentration of about 100.3 g/m 3 was necessary to obtain 100% mortality

of adu lts and ny

mphs under the test conditions. However , this concentration obtained only a 95% mortality

of mite eggs. This is about three times the legal label rate of sulfury l fluoride (Phillips et al. , 2008) and thus indicates that sulfuryl fluoride is not a viable alternative to methy l bromide for controlling ham mites. In addition, results also indicated that l evels of residual fluoride and sulfury l fluoride in the hams were linearl y related to fumigant concentration and that use of high concentrations o f sulfuryl fluoride (72 g/m 3 orUSA CUN 13 POST HARVEST

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greater) and multiple fumigations could potentially lead to high concentrations of sulfury l fluoride and fluoride in the ham (Sekhon et al., 2010a). The results of carbon dioxide, phosphine, methyl bromide and ozone effica cy investigations on Tyrophagous putrescentiae , ham mite, and Necrobia rufipes , red

- legged ham beetle, were presented at the 2009 MBAO Conference, in San Diego, CA (Sekhon et al. , 2009a, b; Phillips, 2009, Sehkon et al

. , 2010b, 2010c). The studies include d eggs and a mixture of adults and ny mphs of mites and eggs, large larvae, pupae and adults of beetles. The experiments were conducted for variable times at 23° C at various concentrations of carbon dioxide, phosphine, methy l bromide and ozone. The inves tigators achieved mortality of all life stages of mites with a concentration of 60 % carbon dioxide with 144 hr of exposure (Sekhon et al. , 2009a; Phillips, 2009 ; Sehkon et al

. , 2010b). However, fumigation with carbon dioxide would likely not be applicabl e since ham structures are not air

- tight and 144 hr is too long of a time to fumigate the hams. In addition, a carbon dioxide concentration (> 80 %) with an exposure time of 144 hrs was necessary

to cause 100 % mortality for all life stages of red legged ham beetles (Sekhon, et al. 2009a; Phillips, 2009 ; Sehkon et al, 2010b). In addition, there may be higher numbers of ham mites that can hide in the crevices of the ham that may be able to survive during CO 2 fumigation. Investigators achieved 100 % mort ality of all life stages of red legged ham beetles and ham mites with 48 hours exposure of 400 and 1000 ppm of phosphine, respectively (Sekhon, et al. 2009b; Phillips, 2009; Sekhon et al., 2010 c ). In addition, residual phosphine concentrations in dry cure d hams that were fumigated for 48 hrs at 1000 ppm were below 0.01 ppm, the legal residual limit in stored food products (Sekhon, et al. 2009b; Sekhon et al., 2010 c ), and consumer panelists could not detect differences between control and phosphine fumigate d samples at 1000 ppm (Sekhon et al. 2009b ; Sekhon et al., 2010 c ). Therefore, phosphine can now be considered a potential alternative to methy l bromide for controlling arthropod pests of southern dry cured hams. Further testing with a greater number of m ites has indicate d that a greater concentration of phosphine (>1000 ppm) is likely necessary to kill substantial mite infestations. In addition, commercial applications of phosphine are planned for 2010

- 2011 to determine the efficacy of using phosphine at the plant level. The effectiveness of phosphine will be evaluated through the use of both bioassay s (with ham present) and on hanging hams in a simulated dry cured ham aging room. Other portions of this research include the economical anal ys is of using phosphine in comparison to methy l bromide, if it is effective at eradicating mites. Commercial applicators and agricultural economists are working with us on this portion of the research. Additional items that will be researched in the future (if fundin g is obtained) include the effect of multiple fumigations on the sensory quality and residual concentration of phosphine in ham, and the effectiveness of using phosphine in dry

cured ham facilities. Many processors have indicated that they would be willin g to help evaluate the efficacy of phosphine (at controlling ham mite infestations) in their plant as part of a research project, which trul y demonstrates the willingn ess of the industry to do every thing that they

can to help determine if potential alternatives to methy l bromide exist. In addition, we have commitments from Universities and a commercial applicator to help implement phosphine fumigation in dry cured ham facilities for this research to take place.USA CUN 13 POST HARVEST

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Ozone concentrations of greater than 150 pp m for 48 hrs were able to achieve 100 % mortality of ham beetles and mite s at the bench top level (Sekhon et al. , 2009b; Phillips, 2009 ; Sekhon et al., 2010 b ). Consumers also could not determine sensory differences between control hams and those that were fumigated with ozone at 175 ppm for 48 hrs (Sekhon et al., 2010b)). However, ozone is not able to penetrate surfaces well and therefore may not work well in real world applications since ham mites could potentially penetrate into crevices in the meat and ham beetles bore through the meat tissue. R esearch that was conducted b y one dry cured ham processor indicated that the use of ozone in a commercial setting was not effective at eradicating ham mite infestations, which was likely due to the inability

of the ozone to penetrate the surface of the ham and the ability of mites to find places to hide where the ozone did not reach. However, ozone may play a role in integrated pest management to help minimize infestations and enhance sanitation since it would sanitize areas in the plant as well as equipment that could potentially

harbor bugs and pathogens. Further research ha s recently been conducted on the effects of low pressure and low ox ygen concentration on the mortality of Tyrophagous putrescentiae ( mold m ites ) . Exposure of mites to low oxy gen with pressure (25 mmHg; approx. 3.0% O 2 ) at 23°C for 144 hrs or greater was effective at eradicating more than 95 % of each mite life stage (Hasan et al., 2010). However, testing with a larger number of mites and un der commercial conditions would need to be conducted to determine if this technology could be considered a potential alternative to methy l bromide. Its limitations include length of application, ability of mites to hide within meat crevices, and difficult y in implementing at the plant level. There is still no definitive alternative for meth yl bromide for the dry cured ham industry

at this point in time. Research is still ongoing with phosphine, and controlled atmosphere, but more research and commercia l applications need to be conducted before an y of these treatments/fumigants can be considered alternatives to methy l bromide for treatment of ham (mold) mites. 4. REGISTRATION UPDATE No new chemicals have been registered nor de

- registered since the la st nomination. 5. ECONOMIC INFEASIBILITY OF ALTERNATIVES An economic anal ys is was not conducted because this sector has no technically feasible alternatives at this time

.
CITATIONS Arthur, F. and T. W. Phillips. 2003. Stored

- product insect pes t management and control, In: Food Plant Sanitation eds: Y. H. Hui, B. L. Bruinsma, J. R. Gorham, W. Nip, P. S. Tong, and P. Ventresca. Marcel Dekker, Inc., New York, pp. 341

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Hasan, M.M., Phillips, T.W., Aikins, J.M., Schilling, M.W. 2010. Contro lled atmosphere treatments to control arthropod pests of American dry cured hams. Annual International Research Conference on Methy l Bromide Alternatives and Emission Reduction, Orlando, FL, November 1 st

- 5 th Phillips, T.W. Hasan, M.M., Aikens, M.J., Schil ling, M.W. 2008. Efficacy of sulfuryl fluoride to control ham mites and red

- legged ham beetles. Annual International Research Conference on Meth yl Bromide Alternatives and Emission Reduction, Orlando, FL, November 11 th

- 14 th Phillips, T.W. 2009. Personal Communication. Sekhon, R.K., Schilling, M.W., Phillips, Hasan, M.M., Aikens, M.J, Mikel, W.B. 2009. Chemical Composition of Dry Cured Hams Fumigated with Carbon Dioxide. Annual International Research Conference on Meth yl Bromide Alternatives and Emission Reduction, San Diego, CA, November 10 th

- 13 th Sekhon, R.K., Schilling, M.W., Phillips, Hasan, M.M., Aikens, M.J, Mikel, W.B. 2009. Chemical composition of dry cured hams fumigated with phosphine. Annual International Research Conference on Methy l Bromide A lternatives and Emission Reduction, San Diego, CA, November 10 th

- 13 th Sekhon, R.K., Schilling, M.W., Phillips, T.W., Hasan, M.M., Aikens, M.J. Mikel, W.B. 2010a. Sulfury l fluoride fumigation effects on the safet y, volatile composition, and sensory quality of dry cured ham. Meat Science. 84(3):505

- 511. Sekhon, R.K., Schilling, M.W., Phillips, T.W., Hasan, M.M., Aikens, M.J., Nannapaneni, R., Mikel, W.B. 2010. Effects of carbon dioxide and ozone treatments on the volatile composition and sensory

quality of dry cured ham. J. Food Science. 75(5): 452

- 458. Sekhon, R.K., Schilling, M.W. , Phillips, T.W., Hasan, M.M., Aikens, M.J., Corzo, A. Mikel, W.B. 2010. Effects of phosphine and methy l bromide fumigation on the volatile flavor profile and sensory

quality of d ry cured ham. Meat Science. 86(2):411

- 417.