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) 

FROM: Wtlham Chism, Seruor B10log1st ; 

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, 2014 

Page 1 of12 
INTRODUCTION 

The purpose of this document is to convey usage information and a broad overview of the pest 

management roles of pesticides that are beginning to undergo registration review. The 

anticipated audience consists of the team of EPA staff currently evaluating the registration status 

of methyl bromide (bromomethane), and stakeholders including users ofthe chemical, registrants 

of the chemical, and the general public. This document builds upon the data BEAD provides 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 restrictions 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 controlled 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 (production plus imports minus exports) approximately 1.2 million lbs. for critical uses. 

For critical exemption use in 2015 the U.S. government only nominated strawberry fruit in 

California, fresh dates, and country ham for approximately 830,000 lbs. The U.S. consumes 

approximately 4 million lbs. of methyl 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 of the mitigation measures to improve worker 

and bystander safety and the increasing cost of methyl bromide BEAD anticipates that use will 

continue to decline from current levels. 

HISTORY OF BEAD ASSESSMENTS FOR METHYL BROMIDE 

BEAD has evaluated methyl bromide extensively, both as part of the reregistration and tolerance 

assessment processes for the fumigants, and as an input for the Critical Use Exemption process, 

where information about the value of methyl bromide and the availability of alternatives for pest 

control are important issues. 

Page 2 of12 
Methyl bromide, in combination with chloropicrin, has been 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 the 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 of crops, representing those with the highest fumigant usage in terms 

of share 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, 2012) shows several additional uses 

(pepper, strawberry, and tomato) from 2003 to 2010 where the percent crop treated is over 25% 

of the crop suggesting 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 because 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 uses such as timber, 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 of the following uses: (1) soils 

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 

courses and athletic/recreational fields for resurfacing/replanting of turf (use allowed until 

December 31, 2013), and (3) caneberries and tobacco seedling trays (use allowed until December 

31, 2014). 

Alternatives 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 leaves growers with fewer 

alternatives. In the fall of 2010 dimethyl disulfide (Paladin TM) another soil fumigant was 

registered by the EPA. 

Page 3 of12 
Past evaluations of methyl bromide have shown high value to growers relative to the alternatives. 

The high cost and dwindling availability of methyl bromide, along with experience 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 FORMULATIONS 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 (methyl 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 nonfood commodity fumigation treatments using cylinders and fumigation chambers, as well as 

structural/space fumigation of commercial shipping containers, storage and warehouse premises, 

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 cane berries (raspberries, blackberries, 

boysenberries), golf courses and athletic/recreational fields for resurfacing/replanting of turf, and 

tobacco seedling trays even though they do not have a CUE. 

USDA-APHIS Quarantine and Preshipment COPS) Uses: 

Page 4 of12 
Methyl 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 of the 

importing country. 

Other Quarantine Uses (not USDA-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 following: 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, flower 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 

of enclosed spaces and structures used to process, transport, store, or handle food such as flour 

mills, feed mills, spice 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 of12 
Figure 1: Methyl bromide: Pounds A.I. Applied to the soil, 1998-2011 

"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 of12 
Agricultural 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 of pounds 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 

of total area treated were the same; however, the percentage of the area of strawberries was 

lower than the percentage of pounds a.i. applied, implying higher than average a.i. rates of 

application. Conversely, the percentages of the total area of peppers and tomatoes treated were 

higher than the percentage of pounds 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 method of application. Many of the vegetable crops such as peppers and tomato apply 

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. applied during this period were Florida (47%), California (41 %) and North Carolina 

(6%) as shown in Figure 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, squash, tobacco, walnuts, and watermelons. See SLUA for more details (EPA, 2012). 

Table 1. Me t h l 1yJ b rom1 "d e u se on T op C rops: A verage A .. I R ae, t 2007 -20 11 

Crop Avg. AI Rate (lbs a.i./acre) 

Strawberries 160 

Tomatoes 100 

Peppers 81 

Source: EPA Propnetary Data, 2007-2011 

Page 7 of12 
The top states in terms of pounds a.i. applied during this period were Florida ( 4 7% ), California 

(41 %), and North 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 

of the 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 et 1y 1 B 'd U . N romt e sem ursery & Fl one . ul ture 

A vg. A.I. Rate 

Year Lbs A.I. Applied (lb/acre) 

2006 363,600 161 

2009 943,700 230 

Source: USDA NASS, Agncultural Chemtcal Usage Reports, 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 

Note: 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 intensity in the U.S., which is relatively greater in California and Florida, 

reflecting the concentration of use on strawberries and vegetables. 

Figure 5. Methyl Bromide Use Intensity by Crop Reporting District (2007- 2011) 

Average Pounds Per 

1,000 Acres of Farmland 

- <16 

- 16-40 

C) 41- 137 

- 138-278 

- 279-800 

This is a map of agricultural pesticide usage at the Crop Reporting District (CRD) level prepared by 

BEAD for use in the Environmental Fate and Effects Division documents. These maps are used to 

help visualize where the pesticide being considered is most likely to be used and can be helpful in 

scenario selection and placing the exposure assessment in context. CRDs are boundaries created by 

USDA NASS which are aggregates of counties. Pesticide usage is displayed as average pounds 

(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 from USDA (2007). Farmland or "land 

in farms" is defined as follows: 

The acreage designated as "land in farms" consists primarily of 

agricultural land used for crops, pasture, or grazing. It also includes 

woodland and wasteland not actually under cultivation or used for 

pasture or grazing, provided it was part of the farm operator's total 

operation. Large acreages of woodland or wasteland held for 

nonagricultural purposes were deleted from individual reports during the 

Page 9 ofl2 
edit process. Land in farms includes CRP, WRP, FWP, and CREP1 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 

farms" provided it was part of a farm or ranch. Land under the exclusive 

use of a grazing association was reported by the grazing association and 

included as land in farms. All land in American Indian reservations used 

for growing crops, grazing livestock, or the potential of grazing livestock 

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 of the 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 individual 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 Crop Reporting District may have 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. 

USDA, 2007. Census of Agriculture. Online: http://www.agcensus.usda.gov/Publications/2007/index.asp. 

Quarantine and Preshipment Use 

The Montreal Protocol on Substances that Deplete the Ozone Layer (Protocol) and the Clean 

Air Act (CAA) do not control the use of methyl bromide for quarantine and preshipment uses. 

1 CRP: Conservation Reserve Program; WRP: Wetland Reserve Program; FWP: Farmable Wetlands Program; 

CREP: Conservation Reserve Enhancement Program 

Page 10 of12 
Another measure of usage is consumption [(U.S. production + imports) minus exports] of methyl 

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 

0 

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 20 10 2011 

Year 

Source: 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 within 21 days of shipment. Fumigations with methyl bromide 

under USDA/APHIS supervision include: grape, asparagus, pineapple, cut flowers and greenery, 

yams, kiwi, lemon, plant propagative materials, logs, 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 

soil 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 fumigation has 

led to an increase in the acres treated 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-agricultural (post-harvest) use of methyl bromide is to control pests in structures, on 

stored commodities (dried fruits and nuts), and on imported food and non-food items. As use of 

methyl bromide for post-harvest fumigations is decreasing the use of sulfuryl fluoride and 

phosphine are increasing. 

Page 11 of 12 
CONCLUSION/ROLE OF METHYL BROMIDE IN PEST CONTROL 

The use of methyl bromide has significantly decreased over time due to its potential 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 planting strawberry fruit and post-harvest use on fresh dates and ham. 

In addition, its use at current levels for quarantine and preshipment is expected to continue into 

the future. 

INFORMATION THAT MAY BE USEFUL FOR BEAD'S FUTURE WORK ON 

METHYL BROMIDE 

Additional information on typical postharvest, quarantine, and non-agricultural uses of methyl 

bromide would improve future BEAD assessments ofthe importance of methyl bromide and 

may be required as part of the registration review for this pesticide. Useful data would include, 

but not limited to, usage data (application timing, application rate, application method, target 

pests, application frequency, speed of control, costs, etc.). Of particular value is information 

regarding use and importance of methyl bromide for post-harvest and QPS uses. 

REFERENCES 

Cook, C. T.J. Wyatt. 2007. Summary of Assessments of the Benefits of Soil Fumigation with 

Methyl Bromide in Crop Production. U.S. Environmental Protection Agency, Office of 

Pesticide Programs. 

EPA Proprietary Data, 1998-2011 

EPA, 2009. Amended Reregistration Eligibility Decision for Methyl Bromide (soil and non-food 

structural uses). 

EPA. 2012. Methyl Bromide (053201) Screening Level Usage Analysis (SLUA),May 30,2012 

U.S. Environmental Protection Agency, Office of Pesticide Programs. 

USDA, 2006-2010. NASS Crop Reporting Districts. 

http://www.ers.usda.gov/briefmg/arms/resourceregions/resourceregions.htm#nass. 

USDA, 2007. Census of Agriculture. 

http://www .agcensus. usda. gov/Publications/2007 /index.asp. 

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

Page 12 of12