USA CUN11 POST HARVEST -- Dry, Cured Pork Products Page 1 of 5



## METHYL BROMIDE CRITICAL USE RENOMINATION NOMINATION FOR STRUCTURES, COMMODITIES OR OBJECTS

NOMINATING PARTY: The United States of America

FILE NAME USA CUN11 POST HARVEST -- DRY, CURED PORK PRODUCTS

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Post Har vest Use on Dry Cured Pork Products (Submitted in 2009 for 2011 Use Season)

STRUCTURE, COMMODITY OR OBJECT TREATED:
This sector is for the production of cured meat pro ducts, such as country hams. These are produced primarily in the southern U.S. This secto r has no known viable alternative currently

available.

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR O F

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

2011 3,730 kilograms

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat we bsite under Decision Ex. I/4(8).)

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomi nation 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 Pa rty need not re-submit that earlier information.

NOMINATING PARTY CONTACT DETAILS: Contact Person: Hodayah Finman 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-mail: FinmanHH@state.gov

Following the requirements of Decision IX/6 paragra ph (a)(1) United States of America has determined t hat the specific use detailed in this Critical Use Nominati on is critical because the lack of availability of methyl bromide for

this use would result in a significant market disru ption. 

## ■ Yes  NoUSA CUN11 POST HARVEST -- Dry, Cured Pork Products Page 2 of 5

Signature Name Date

Title:

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger Title: Director (Acting) 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 USA CUN11 Post Harvest Dry, Cured Pork Products 5

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming conventi on see notes above) No. of kilobytes Date sent to Ozone

Secretariat USA CUN11 Post Harvest Dry, Cured Pork Products

* Identical to paper documentsUSA CUN11 POST HARVEST -- Dry, Cured Pork Products Page 3 of 5



## METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONM ENT)

DRY CURED PORK PRODUCTS

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL US E

Currently there are no known viable alternatives to methyl bromide for the dried meat industry: heat would alter the product, and phosphine may not control mites, a major pest. Sulfuryl fluoride received federal registration and has been tested for efficacy against the mites and other pests of cured meat products. Although mortality o f the red-legged ham beetle occurred at levels below maximum rates of sulfuryl fluoride, the same cannot be said for the ham mites (Phillips, et al., 2008). Control of the ham mites took three ti mes the legal limits of sulfuryl fluoride (Phillips, et al., 2008). At the time of this nomi nation there are no known registered alternatives for use on hams in the U.S. that provide the same l evel of pest control as methyl bromide.

This industry is cooperating with university resear chers to find technically and economically feasible alternatives to methyl bromide. In the me antime, this industry is using IPM techniques to manage their pest populations. All use sanitati on to keep their curing facilities clean. Several companies have modified their buildings to make the m more gas-tight. Some companies are eliminating grass, trees, and shrubs from their bui ldings and replacing it with gravel, as suggested by researchers last year. Many use phero mone traps; however, these traps only used for monitoring purposes at this time (Arthur and Ph illips, 2003).

This industry currently has no known viable chemica l alternative available. Although its IPM measures may have reduced the number of times fumig ation is needed in some facilities, it has not eliminated the need for fumigation. Therefore, methyl bromide remains critical to this industry.

T ABLE 

### 2. N OMINATION 

### A MOUNT

Gwaltney of

Smithfield National Country

Ham Association Nahunta Pork

Center American Assoc.

of Meat

Processors Sector Total / Average

Quantity Requested for 2010: Amount (kgs) 726 709

91

2,939

4,465

Quantity Recommended by

MBTOC/TEAP for 2010 : Amount (kgs) 726 709

91

2,939

4,465

Amount (kgs) 726

709

91

2,939

4,465

Volume (1000 m 3 ) 55 43 5 147 250

Rate 13

16

18

20

18

Transition from 2010 Baseline Adjusted Value Percentage (%) 0% 0% 0% 0% 0%

Amount (kgs) 

### 726

709

91

2,204

3,730

Volume (1000 m 3 ) 56 42 5 110 213

Rate 13

17

18

20

18 

## 2011 Methyl Bromide Usage Newer Numerical Index (BU NNI)

Transition Use Reduction Description Spreadsheet

HAM

Quantity Approved by Parties for

2010:

Quantity Required for

2011 Nomination:

SECTORUSA CUN11 POST HARVEST -- Dry, Cured Pork Products Page 4 of 5



### 2. SUMMARIZE WHY ALTERNATIVES ARE NOT FEASIBLE

This industry currently has no known viable chemica l alternative available. Although its IPM measures may have reduced the number of times fumig ation is needed, it has not eliminated the need for fumigation. Therefore, methyl bromide rem ains critical to this industry.

3. RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATI VES

Researchers are investigating control of the arthro pod pests on dry cured pork products. In the spring of 2007 a proposal was submitted to USDA CSR EES Integrated Research, Education, and Extension Competitive Grants Program- Methyl Bromid e Transitions by several meat scientists and an entomologist. This proposal was funded for the next three years.

There are several objectives to this multiple year research program: First is to determine the effectiveness of chemical controls (sulfuryl fluori de, phosphine, and methyl bromide) against all life stages of both mold mites ( Tyrophagus putrescentiae ) and red legged ham beetles ( Necrobia rufipes ). Second objective is to determine the effectiven ess of carbon dioxide and ozone against all life stages of both mold mites and red legged h am beetles. The third objective is to test the effects of sulfuryl fluoride, phosphine and methyl bromide on the quality and safety of the dry cured hams. The fourth objective is to conduct an economic analysis of the alternatives demonstrated to be technically viable alternatives for methyl bromide in this industry.

The results of sulfuryl fluoride efficacy investiga tions on Tyrophagous putrescentiae , ham mite,

and Necrobia rufipes , red-legged ham beetle, were presented at the 2008 MBAO Conference, in Orlando, Fl. The studies included eggs and a mixtu re of adults and nymphs of mites and eggs, large larvae, pupae and adults of beetles. The exp eriments were conducted for 48 hours at 23° C at various concentrations of sulfuryl fluoride. Th e investigators achieved 100% mortality of redlegged ham beetle adults and pupae at about 4.0 g/m 3 

### , 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. (Phillips, et al. 2008) Mortality of ham mites required higher concentrations of sulfuryl fluoride. A concentration of about 100.3 g/m 3 

### was necessary to obtain 100% mortality of adults and nymphs under the test conditions. Ho wever this concentration obtained only a 95% mortality of mite eggs. This is about three times the legal label rate. (Phillips, et al. 2008)

4. REGISTRATION UPDATE

No new chemicals have been registered nor de-regist ered since the last nomination.

5. ECONOMIC INFEASIBILITY OF ALTERNATIVES

An economic analysis was not conducted because this sector has no technically feasible

alternatives at this time.USA CUN11 POST HARVEST -- Dry, Cured Pork Products Page 5 of 5



### CITATIONS

Arthur, F. and T. W. Phillips. 2003. Stored-produ ct insect pest management and control, In: Food Plant Sanitation eds: Y. H. Hui, B. L. Bruinsm a, J. R. Gorham, W. Nip, P. S. Tong, and P. Ventresca. Marcel Dekker, Inc., New York, p p. 341-358.

Phillips, Thomas W., Md. Mahbub Hasaan, M. Jamie Ai kins, and M. Wes Schilling. 2008. Efficacy of sulfuryl fluoride to control ham mites and red-legged ham beetles. Presentation at MBAO, Orlando, Fl. November 12, 2008.