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 Harvest 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 products, such as country hams. These are 

produced primarily in the southern U.S. This sector has no known viable alternative currently 

available. 

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 

2011 3,730 kilograms 

(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: 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 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 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 convention see notes above) 

No. of 

kilobytes 

Date sent to Ozone 

Secretariat 

USA CUN11 Post Harvest Dry, Cured Pork Products 

 

 

 

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

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

DRY CURED PORK PRODUCTS 

1. SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL USE 

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 of 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 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 same level of pest control as methyl bromide. 

This industry is cooperating with university researchers to find technically and economically 

feasible alternatives to methyl 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 by researchers last year. Many use pheromone traps; however, these traps only used 

for monitoring purposes at this time (Arthur and Phillips, 2003). 

This industry currently has no known viable chemical alternative available. Although its IPM 

measures may have reduced the number of times fumigation is needed in some facilities, it has 

not eliminated the need for fumigation. Therefore, methyl bromide remains critical to this 

industry. 

TABLE 2. NOMINATION AMOUNT 

 Gwaltney of 

Smithfield 

 National Country 

Ham Association 

 Nahunta Pork 

Center 

 American Assoc. 

of Meat 

Processors 

 Sector Total / 

Average 

Quantity Requested for 2010: Amount (kgs) 709 726 91 2,939 4,465 

Quantity Recommended by 

MBTOC/TEAP for 2010 : Amount (kgs) 709 726 91 2,939 4,465 

Amount (kgs) 709 726 91 2,939 4,465 

Volume (1000 m3) 55 43 5 147 250

Rate 16 13 18 20 18 

Transition from 2010 Baseline 

Adjusted Value Percentage (%) 0% 0% 0% 0% 0%

Amount (kgs) 709 726 91 2,204 3,730 

Volume (1000 m3) 56 42 5 110 213

Rate 17 13 18 20 18 

2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

Transition Use Reduction Description Spreadsheet

HAM

Quantity Approved by Parties for 

2010:

Quantity Required for 

2011 Nomination:

SECTOR
USA 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 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, methyl bromide remains critical to this industry. 

3. RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES 

Researchers are investigating control of the arthropod pests on dry cured pork products. In the 

spring of 2007 a proposal was submitted to USDA CSREES Integrated Research, Education, and 

Extension Competitive Grants Program- Methyl Bromide 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 fluoride, 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 effectiveness of carbon dioxide and ozone against 

all life stages of both mold mites and red legged ham 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 investigations 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 mixture of adults and nymphs of mites and 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 redlegged ham beetle adults and pupae at about 4.0 g/m3

, 100% mortality of larvae at 5.7 g/m3. 

Eggs of red-legged ham beetles died at 24.0 g/m3 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/m3 was necessary to obtain 100% mortality 

of adults and nymphs under the test conditions. However 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-registered 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-product insect pest 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. 341-358. 

Phillips, Thomas W., Md. Mahbub Hasaan, M. Jamie Aikins, 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.