UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D

. C

. 20460 

### MAY 3 0 20}3

MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

SUBJECT:

### B~~D**Che~ical Pr~file** **~or R~gistration** **Re~ie;~z** Bromide (053201) Wtlham Chism, Seruor B10log1st

# ; FROM:

THRU: Biological Analysis Branch

### ~ Cynthia Doucoure, Environmental Protection Specialist Science Information and Analysis Branch Derek Berwald, Economist**~ ~**  \I\A \. Economic Analysis Branch 

### I) v**v\.~** Biological and Economic Anal sis Division (7503M

TO: S. Bartow, Chemical Review Manager Risk Management and Implementation Branch 4 Pesticide Reevaluation Division (7508P)

Product Review Panel date: March 3, 20 14

Page 1 of12INTRODUCTION The purpose ofthis document is to convey usage information and a broad overview of the pe st management roles ofpesticides that are beginning to undergo registration review. The anticipated audience consists of the team of E PA staff currently evaluating the registration status of methyl bromide (bromomethane), and stakeholders including users ofthe chemical, registrants ofthe chemica l, and the general public. This document build s upon the data BEAD provide s in the Label Use Information System (LUIS) reports and the Screening Level Usage Analysis (SLUA) for Registration Review. The document is based on information and data available to BEAD as of February 2013. Methyl bromide, a broad spectrum fumigant that can be used as an acaricide, antimicrobial, fungicide , herbicide, insecticide , nematicide , and vertebrate control, was initially registered in the U.S. in 1961. There was a RED (Reregistration Eligibility Decision) for commodity uses in 2006, RED for soil uses in 2008, and a RED amendment for soil uses in 2009. The REDs imposed new restrictions on methyl bromide use, including the cancellation of use on several sites, implementation of buffer zones, and requirements for Fumigant Management Plans. These new re strictions will likely result in changes in use patterns that are not reflected in the current data. Montreal Protocol Because methyl bromide is an ozone depleting substance its production is co ntro lled under the the Montreal Protocol on Substances that Deplete the Ozone Layer (Protocol) and the Clean Air Act (CAA). All uses except critically exempted uses and quarantine and preshipment uses were phased out in January 1, 2005. For the year 2013 the United States government was approved to consume (product ion p lus imports minus exports) approximately 1.2 million lbs. for critical uses. For critical exemption use in 2015 the U.S. government only nominated strawberry f ruit in California, fresh dates, and country ham for approximately 830,000 lbs. The U.S. consumes approximately 4 million lbs. ofmethyl bromide every year for quarantine and preshipment uses , the production of which is not controlled by the Montreal Protocol and is expected to continue. Future Uses Information available to BEAD suggests that in the future use and usage of methyl bromide will be limited to quarantine and preshipment sites (for soil, commodities, and structures) and a few critical use exemption sites. In addition, because ofthe mitigation measures to improve worker and bystander safety and the increasing cost ofmethyl bromide BEAD anticipate s that use will continue to de cline from current levels. HISTORY OF BEAD ASSESSMENTS FOR METHYL BROMIDE BEAD has evaluated methyl bromide extensively, both as part of the reregi stration and tolerance assessment processes for the fumigants, and as an input for the Critical Use Exemption process , where information about the value ofmethyl bromide and the availability of alternat ives for pest control are important issues.

Page 

### 2 of12Methyl bromide, in combination with chloropicrin, has b een applied as a preplant fumigant to a wide variety of crops. In general , past BEAD analyses have found methyl bromide to have substantial benefits. The conclusion to BEAD's 

### Summary of Assessments of th e Benefits ofSoil Fumigation with Methyl Bromide in Crop Production stated: In some cases, methyl bromide makes production viable where pest pressure would otherwise be too great and the product would either be destroyed by pests (soil fumigation for strawberry fruit) or the quality would be substantially reduced. BEAD assessed a selection ofcrops, representing those with the highest fumigant usage in terms of sh are of crop area treated and total pounds applied. The benefits are generally divided between producers , who benefit from higher net operating revenue , and consumers, who benefit from increased supply and lower prices ( Cook and Wyatt, 2007). The methyl bromide Screening Level Usage Analysis (EPA , 20 12) shows several additional uses (pepper, strawberry, and tomato) from 2003 to 2010 where the percent crop treated is over 25% of the crop sugges ting that when the assessment was conducted there were high benefits associated with its use. While that was true at the time , the phaseout of agricultural uses of methyl bromide becaus e of the Montreal Protocol on Substances that Deplete the Ozone layer has continued. Over time , smaller acreages and fewer crops were nominated as critical uses for which methyl bromide could be used, these reductions are reflected in usage data (Figure 1
- 5). Although past BEAD work on the benefits of methyl bromide focused on crops for which there was a critical use exemption or for which use was allowed for preshipment quarantines, most of these uses are no longer relevant. The most recent nomination for critical use exemptions (nominations made in January 2013 for 2015 use) , included only three sectors: soil use on strawberry fruit in California, and post-harvest use on dry cured ham and fresh dates in California, where the vast majority of remaining use is for strawberries. The strawberry use may be replaced with increased use of chloropicrin over the next several years, which would leave quarantine uses (exempt from the phaseout) as the remaining significant uses of methyl bromide. These would include u ses such as timb er, nursery stock, etc. The EPA allowed some soil uses that do not meet the definition of a "critical use ," a "quarantine application ," or a " pre-shipment application " with the exception ofthe following u ses: (1) soi ls to be planted with, fresh market peppers and tomatoes grown in California, Vidalia onions grown in Georgia, ginger grown in Hawaii (use allowed until December 31, 20 12); (2) soils on golf course s and athletic/recreational fields for resurfacing/replanting ofturf (use allowed until December 31, 2013), and (3) caneberries and tobacco seedling trays (use allowed until December 31, 2014). Alt ernatives to methyl bromide include combinations of other fumigants to replace one treatment of methyl bromide. For many of the critical use exemption nominations in past years, iodomethane was considered likely to become an important alternative. However, agricultural uses of iodomethane were cancelled by the registrant in 2012 , which leave s growers with fewer alternatives. In the fall of 2010 dimethyl disulfide (Paladin 

### TM) another soil fumigant was registered by the EPA. Page 3 of12Past evaluations of methyl bromide have shown high value to growers relative to the alternatives. The high cost and dwindling availability ofmethyl bromide, along with exp erience and research over time have allowed the development of viable alternative pest control programs for many crops. For soil uses the alternatives consist of fumigants such as: chloropicrin plus 1,3- dichloropropene , chloropicrin plus 1 ,3 -dichloropropene plus metam sodium/potassium, or dimethyl disulfide or the non-fumigant option of anaerobic soil disinfestation. For post-harvest uses the alternatives consist of fumigants such as sulfuryl fluoride or propylene oxide or nonfumigant options such as better sanitation or heat treatments.


### COMMON FORM ULATIONS AND APPLICATION METHODS Methyl bromide is commonly formulated as pressurized gas and applied as a preplant soil fumigant using soil injection equipment (shank/chisel), hot gas method (methy l bromide is forced through a heat exchanger into the drip tubing under tarps), or as a tree hole treatment using handheld eqtripment. Most soil uses of methyl bromide also have chloropicrin co-applied (as a warning agent or another active ingredient). Methyl bromide is also used for food and nonfoo d commodity fumigation treatments using cyli nders and fumigation chambers, as well as structural/space fumigation ofcommercial shipping containers, storage and warehouse premi ses, and transportation facilities.


### USE SITES Agricultural Sites with Critical Use Exemptions (CUEs) for Preplant Soil Uses: Uses that have a CUE are allowed access to newly produced methyl bromide and stocks of methyl bromide produced before 2005 (the first year of control). In 2013, methyl bromide is registered for use as a preplant soil fumigant on the following crops (with CUEs) in the field or in greenhouses: eggplant, cucurbits (including muskmelons, cantaloupes , watermelon, cucumber, squash, pumpkin, and gourds), forest nursery seedlings, orchard nursery seedlings (raspberry, deciduous trees, roses) , strawberry nurseries, orchard replant (walnuts, almonds, stone fruit, table and raisin grapes, wine grapes), ornamentals, peppers, strawberry fruit, sweet potato slips, and tomato (grown for fresh market). For use in 2015 the U.S. government nominated soil fumigation for strawberry fruit in California, post-harvest fumigations for fresh dates in California and country ham for critical use exemptions. Agricultural Crops without CUEs: Uses without a CUE are only allowed access to stocks of methyl bromide produced before 2005. In 2013 methyl bromide is also registered for Group II uses (see History page 3 which describes how they will be removed over time) such as caneberries (raspberries, blackberries, boysenberries), golf courses and athletic/recreational fields for resurfacing/replanting ofturf, and tobacco seedling trays even though they do not have a CUE. US DA-APHIS Quarantine and Preshipment COPS) Uses:
Page 4 of12Methyl bromide may be used on soils of any crop or non-crop site as part of a quarantine program established by the USDA-APHIS under the Plant Protection Act. Preshipment fumigations must take place within 21 days of shipment to meet quarantine requirements ofthe importing country
. Other Quarantine Uses (not US DA-APHIS): Methyl bromide 

### is registered for other quarantine uses where all production from the treated fields will be shipped to areas where a plant regulatory authority requires material to be fre

. e of quarantine pests , including the fo llowing: forest seedlings (conifer and hardwood seedlings for reforestation and Christmas tree seedlings), nursery stock, roses, strawberry transplants, sweet potato slips, caneberry and blueberry, fruit and nut trees , garlic transplants , onion transplants, vineyard stock, seed potato, tobacco seed beds, food crop transplants, and other wild cultivated trees, shrubs, vine and forbs, ornamental plants (caladiums, chrysanthemums, flowe r bulbs, flowering plants, ornamental grasses, rhizomes , shrubs, trees , and other perennial and annuals), turf or sod. Post Harvest Food Commodities and Structural/Non-food Commodities with CUEs: Methyl bromide is registered for post harvest treatment of commodities (e.g. country hams , dates, figs, raisins, walnuts) and non-food uses (e.g. logs for export). It is also used for treatment ofenclosed spaces and structures used to process , transport, store, or handle food such as flour mills, feed mills , sp ice mills, textile mills , warehouses , boxcars, fumigation vaults, flat or upright bulk grain storage, tobacco warehouses, food processing plants and cargo ships.

USAGE Agricultural Use Trend. 1998-2011 (soil) Available data on use of methyl bromide in the U.S., from private market surveys, show that the overall pounds a.i. applied decreased steadily between 1998 and 2011 as shown in Figure 1

. A similar trend was found for the total area treated (acres) with methyl bromide as shown in Figure 2. Approximately 20,500,000 pounds of methyl bromide were applied on average annually to 94,000 acres at an overall average application rate of218 lbs ai/acre. With the strong downward trend in use , these averages are higher than current use.

Page 5 of12Figure 1: Methyl bromide: Pounds A.I. Applied to the soil , 1998

- 20 1 1

"C .!!! a. Q. C( 

## < "' "C c :I 0 1:1.

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Year Source: EPA Proprietary Data, 1998-2011
Figure 2. Methyl bromide: Total Area (acres) Treated, 1998-2011

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Year Source: EPA Proprietary Data, 1998-2011

Page 

### 6 of12Agricultural Use 2007-2011 During the 2007-2011 timeframe, approximately 7 , 500,000 pounds of methyl bromide were applied on average annually to 60,000 acres at an overall average application rate of 125 lbs ai/acre. Figure 1 and 2 show the substantial drop in soil usage from 1998 to the present which was driven by the phase-out and higher rates of chloropicrin being co-applied with methyl bromide. The top crops in terms ofpounds a.i. applied during this period were strawberries (45%), tomatoes (28%), and peppers (4%) as shown in Figure 3 below. The top crops in terms oftotal area treated were the same; however, the percentage ofthe area of strawberries was lower than the percentage ofpounds a.i. applied , implying higher than average a.i. rates of application. Conversely, the percentages ofthe total area of peppers and tomatoes treated were higher than the percentage ofpounds a.i. applied, implying a lower than average a.i. rate of application as shown in Table 1 below. The difference in the pounds applied is also related to the meth od of application. Many of th e vegetable crops such as peppers and tomato app ly methyl bromide as a strip treatment**(~60%** of the area is treated) while strawberry crops are treated with a broadcast treatment (1 00% of the area is treated). The top states in terms of pounds a.i. app lied during this period were Florida (47%), California (41 %) and North Carolina (6%) as shown in F igure 4 below.
Figure 3. Methyl bromide Use: Top Crops, 2007-2011 r--------- -- ------------ ------ ---. 

## Pounds A. I. Applied Total Area Treated

Source: EPA Proprietary Data, 2007

-2011. Note: Other crops include almonds, caneberries , cantaloupes, cherries, cucumbers , wine grapes , onions , oranges, peaches, s quas h , tobacco, walnuts, and watermelons. See SLUA for more details (EPA, 2012).

t 1yJ rom1 e se on op rops: verage 

### .. ae, - Table 1. Me h l b "d 

# u T C A A I R t 2007 20 11 Crop Avg. AI Rate (lbs a.i./acre) Strawberries 160 Tomatoe s 100 Peppers 

### 81 Source: EPA Propnetary Data, 2007-2011 Page 7 of12The top states in terms of pounds a.i. applied during this p eriod were Florida ( 4 7% ), California (41 %) , and N orth Carolina ( 6%). However, the percentage of the total area treated with methyl bromide in California was lower than the pounds a.i. applied , implying higher than average a.i. rates of application , primarily because of use on strawberries. In North Carolina, the percentage ofthe total area treated was only slightly lower than the pounds a.i. applied, implying nearly average rates of application where use is generally on cantaloupes, cucumbers, peppers, squash, tobacco , and watermelons. In Florida, the percentage of the total area treated was higher than the pounds a.i. applied, implying slightly lower than average a.i. rates of application on peppers, strawberries , and tomatoes. BEAD reviewed available sources for other usage information and found that USDA NASS surveyed use of methyl bromide in Nursery and Floriculture in 2006 and 2009 as shown 

### in Table 2 below. Table 

### 2. M h 

### 1B et 1y 'd U . N romt e sem ursery & Fl

. ul one ture Avg. A.I. Rate Year Lbs A.I. Applied (lb/acre) 2006 363,600 161 2009 943 , 700 230 Source : USDA NASS , Agncultural Chemtcal Usage Report s, 2006 and 2009

Figure 4. Methyl bromide Use: Top States, 2007-2011 

# r------- ------------------------. Pounds A.l. Applied OTHER

S%

Source: EPA Proprietary Data, 2007

- 2011. 

## Total Area Treated

N ote: Other states that use methyl bromide include GA, MI , NY , PA, SC , VA , and WA.
Agricultural Usae:e by Crop Reporting District Another measure of usage is the use intensity. In this analysis , the use intensity is expressed as the pounds a.i. applied per I 000 acres of land in farms. This differs from the application rate, which is expressed as the pounds a.i. applied per treated area. Figure 5 spatially represents Page 

### 8 of12

### methyl bromide 's use intens ity in the U.S., which is relatively gr eater in California and Florida, reflecting the concentration of use on strawberries and vegetables.
Figure 5. Met hyl Bromide Use Intensity by Crop Reporting District (2007- 20 11)

Average Pounds Per 1,000 Ac res of Farmland

- <16

- 16-40 C) 4 1- 137

- 138-278

- 279-800

This is a map of agricu l tural pesticide usage at the Crop Reporting District (CRD) level prepared by BEAD for use in the Environmental Fate and Effects Div isio n documents. These map s are used to help visualize where the pesticide being consider ed is most likel y to be used and can be helpful in scenario selection and placi ng the exposure assessment in co ntext. CRDs are boundaries cr eated by USDA NASS which are aggr egates of counties. Pesticide usage is displayed as average pound s (for the years 2007-2011) per 1,000 acres of farmland in a CRD to normalize for the variation in farmland between CRDs. Farmland acreage was obtained f rom USDA (2007). Fa rml and or " land in farm s" is defined as follows: The acreage designated as " land in farms" consists primarily of agricultural land use d for crops, pasture , or grazing. It also includes woodland and wasteland not actually under cultivati on or used for pasture or grazing, provided it was part of the farm operator ' s total operation. Large acreages of wood l and or wasteland he ld for no nagricultural purposes were deleted from individual rep orts during the 

### Page 9 ofl2edit pro cess. Land in farms include s CRP , WRP, FWP, and CREP 1 acres. Land in farms is an operating unit concept and includes land owned and operated as well as land rented from others. Land used rent free was reported as land rented from others. All grazing land, except land used under government permits on a per-head basis, was included as " land in f

arms " provided it was part of a farm or ranch. Land under the exclusive use of a grazing association was r eported by the grazing association and included as land in farms. All land in American Indian reservation s used for growing crops , grazing livestock, or the potential of grazing live stock was included as land in farms. Land in reservations not reported by reservation , individual American Indians or non-Native Americans was reported in the name ofthe cooperative group that used the land. In many instances , an entire American Indian reservation was reported as one farm (USDA, 2007). Usage is based on private market surveys of pesticide use in agriculture (Proprietary Data, 2007

- 2011). The survey data are limited to the states that represent the top 80

- 90% of acreage for the indi vidual crops, therefore , use may be occurring in regions outside the scope of the survey. CRDs showing no usage of pesticides may be due to either the lack of pesticide use in the region or non-participation in the agricultural surveys. In addition, across the years , there may be variations in the specific crops included in the CRD survey. This may result in a lower annual average for the CRD. This map displays ratio data (i.e., average pounds per 1,000 acres of farmland) summarized at a very high-level. Readers are strongly cautioned against trying to over interpret the map without examination of the underlying data. The underlying data may explain some of the many reasons that a C rop Reporting District may ha ve a high value for a particular active ingredient such as significant acreage (compared with the CRD as a whole) of a crop or crops with a high application rate and frequency of application. The reader should pay particular attention to the figure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepared for a different chemical. Scale and units of measurement do matter and may be different between maps. Sources: Proprietary Data

. 2007-20 II. US DA, 2007. Census of Agriculture. Online: http: //www.agcensus.usda.gov / Publications/2007/ index.asp

. Quarantine and Preshipment Use The Montreal Proto col on Substances that Deplete the Ozone Layer (Protocol) and the Clean Air Act (CAA) do not control the use ofmethyl bromid e for quarantine and preshipment uses.
1 C RP: Conservation Reserve Program; WRP: Wetland Reserve Program; FWP: Farmable Wetlands Program ; CREP: Conservation Reserve Enhancement Program Page 

### 10 of12Another measure of usage is consumption [(U.S

. production + imports) minus exports] ofmethyl bromide for quarantine and preshipment uses as shown in Figure 6. While specific usage by site or state is available consumption is tracked under the Clean Air Act and the data demonstrates that usage has decreased since 1999. Figure 6. Methyl Bromide Quarantine and Preshipment Consumption: Pounds A.I. , 1999- 2011

,....., .&1 '-' J. 

# =**~ ~**  12 ,000,000 10,000 , 000 8,000,000 6,000,000
4 , 000 , 000
2 ,000,000
01 999 2 000 2001 20 02 2003 2004 2005 2006 2007 2008 2009 20 1 0 2011 Year Sourc e: United Nations Environmental Programme , Ozone Secretariate , Accessed at http: //montreal-protocol.org/new site /en/ozone data tools access.php

Under the CAA quarantine fumigations are conducted to meet quarantine or phytosanitary standards of an official government organization (e.g

. a country, of state phytosanitary board for nursery crops, etc.) Preshipment fumigations are those conducted to meet official quarantine standards and must take place wit hin 21 days of shipment. Fumigation s with methyl bromide under US DA/APHIS supervision include : grape , asparagus , pineapple , cut flowers and greenery , yams, kiwi, lemon , plant propagative materials , log s , bamboo , and tile. BIOLOGICAL ASPECTS RELEVANT TO METHYL BROMIDE Methyl bromide is a non-selective fumigant biocide. It is used as a preplant soil fumigant to kill so il dwelling pests. It is used in combination with chloropicrin as a preplant soil fumigant to kill soil-borne pests. The recent decrease in methyl bromide use (1998-2011) for soil fumiga tion has led to an increase in the acres trea ted with chloropicrin, 1 ,3

- dichloropropene, metam sodium or potassium, and dimethyl disulfide. The increased use of other fumigants may be masked by the trend to use lower use rates and more strip or bed treatments instead of broadcast fumigations. The non- agric ult ural (po s t

-harvest) use ofmethyl bromide is to control pe s ts in structures , on stored commodities (dried fruits and nuts) , and on imported food and non - food items . As use of 

### methyl brom ide for post

-harvest fumigations is decreasing the use of sulfuryl fluoride and p h osphine are increasing. Page 11 

### of 12

### CONCLUSION/ROLE OF METHYL BROMIDE IN PEST CONTROL The use ofmethyl bromide has s ignificantly decreased over time due to its potent ial to destroy the ozone layer and its controls under the Montreal Protocol and regulations under the CAA. CUE nominations by the U

. S. government have declined substantially with its use considered critical for soil use before plan ting strawberry fruit and post-harvest use on fresh dates and ham. In 

### addition, its use at current levels for quarantine and preshipment i s expected to continue into the future. INFORMATION THAT MAY BE USEFUL FOR BEAD'S FUTURE WORK ON METHYL BROMIDE Add itio nal information on typical postharve st, quarantine , and non-agricultural uses of methyl bromide would improve future BEAD assessments ofthe importance ofmethyl bromide and may be required as part of the reg istration review for this pesticide. Useful data would include , but not limited to, usage data (app lication timing, application rate, application method, target pests, application frequency, speed of control, costs , etc.). Of particular value is information regard ing use and importance ofmethyl bromide for post-harvest and QPS uses.
REFERENCES Cook, C. T.J. Wyatt. 2007. Summary ofAssessments ofthe Benefits of Soil Fumigation with Methyl Bromide in Crop P roduction. U.S. Environmental Protection Agency, Office of Pesticide Programs. EPA Proprietary Data, 1998-2011 EPA, 2 009. Amended Reregi stration Eli gibilit y Deci sion for M et h yl Bromide (soil and non-food structural uses). EPA. 20 12. Methyl Bromide (053201) Screening Level Usage Analys i s (SLUA),May 30,2012 U.S

. Environmental Protection Agency, Office of Pesticide Programs. US DA , 2006

- 20 10. NASS Crop Reporting Districts. http: //www.ers.usda.gov/briefmg/arms /resourceregions/resourceregions.htm#nass

. USDA , 2007. Cens u s of Agriculture. http: //www.agcensus.us d a .gov/Publications/2007 / index.asp

. USDA , 2006 and 2009. NASS Agricultural Chemical Usage Reports, Nursery & Flor iculture

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