OMB Control # 2060-0482

Expires 10/31/2011

SECTOR _________________________

For EPA Use Only ID # ______________

2012 Application for Critical Use Exemption of Methyl Bromide 

for Post Harvest Use in the United States in 2014 and 2015

WHY IS THIS 

INFORMATION 

NEEDED? 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

Under the Clean Air Act and the international treaty to protect the ozone layer 

(the Montreal Protocol on Substances that Deplete the Ozone Layer), the 

production and import of methyl bromide was phased out in the United States 

on January 1, 2005. This application seeks information to support a U.S. 

request to produce and import methyl bromide for certain critical uses and 

circumstances beyond this 2005 phaseout date.

'The information in this application will be used to review whether your use of 

methyl bromide is "critical" because no technically and economically feasible 

alternatives are available. In order to estimate the loss as a result of not having 

EPA Form # 4900-137 Post Harvest

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or 

provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and 

utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete 

and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this 

collection of information is estimated to average 39 hours per response and assumes a large portion of applications will be 

submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a 

person is not required to respond to, a collection of information unless it displays a current OMB control number.

Click on the Instructions tab located at the bottom of the screen for additional information.

The information contained in this application is critical to process and assess the need for methyl 

bromide. Filling out this application in its entirety will bolster the U.S. government's ability to 

strengthen the nomination package for the international review boards. 

methyl bromide available, EPA needs to compare data (commodity prices, 

revenues, and costs) for your use of methyl bromide with uses of alternative 

pest control regimens. 
WHAT

INFORMATION IS 

REQUIRED?

HOW DO 

I APPLY?

WHEN IS THE 

INFORMATION 

NEEDED?

Mailing Address for applications being submitted 

by mail directly to the EPA:

Address for applications being sent by courier or non-U.S. 

Postal overnight express delivery to the EPA:

US Environmental Protection Agency US Environmental Protection Agency

Methyl Bromide Critical Use Exemption Methyl Bromide Critical Use Exemption 

Office of Air and Radiation Office of Air and Radiation

Stratospheric Protection Division (6205 J) Stratospheric Protection Division

1200 Pennsylvania Ave, NW 1310 L Street, NW, Suite 1047E

Washington, DC 20460 Washington DC 20005

OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest

Applicants submitting their application via e-mail assume responsibility for the confidentiality of the electronic message 

transmission.

This application must be postmarked to the EPA address below no later than August 15.

Electronic Address for applications: arling.jeremy@epa.gov

When submitting an application electronically, you should also sign Worksheet 1 and email or fax it to:

202-343-2338

Critical use exemptions are valid for only one year and do not renew automatically. Users desiring to obtain an exemption for 2015 

must apply to EPA. Because of the latest changes in registrations, costs, and economic aspects for producing critical use crops 

and commodities, all applicants will be required to fill out the application form completely. If these Worksheets are not submitted, 

EPA will not include the application in the U.S. nomination submitted for international consideration.

You may either complete an electronic (Microsoft Word or Excel) or a printed version of the application. Please fill out each section 

in the application as completely as possible. If you are completing the printed version and need extra space you may attach 

additional sheets as needed.

WHERE DO I 

SUBMIT THE 

APPLICATION?

If you have general questions about this application call the Stratospheric Ozone Hotline at:

1-800-296-1996

More information is also at http://www.epa.gov/ozone/mbr

The applicant may assert a business confidentiality claim covering part or all of the information in the application by placing on (or 

attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form of 

notice employing language such as trade secret, proprietary, or company confidential. 

Allegedly confidential portions of otherwise non-confidential documents should be clearly identified by the applicant, and may be 

submitted separately to facilitate identification and handling by EPA. If the applicant desires confidential treatment only until a 

certain date or until the occurrence of a certain event, the notice should so state. 

Information covered by a claim of confidentiality will be disclosed by EPA only to the extent, and by means of the procedures set 

forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no claim of confidentiality accompanies the 

information when it is received by EPA, it may be made available to the public by EPA without further notice to the applicant.

IS MY 

INFORMATION 

CONFIDENTIAL?

HOW CAN I 

RECEIVE 

ADDITIONAL 

INFORMATION?

INSTRUCTIONS

The information provided by you in this application will be used to evaluate the requested methyl bromide use. The U.S. and other countries that are 

parties to the Montreal Protocol On Substances That Deplete The Ozone Layer decided that: "a use of methyl bromide should qualify as "critical" only if 

the nominating Party determines that:

(i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a significant market disruption; and 

(ii) There are no technically and economically feasible alternatives available to the user that are acceptable from the standpoint of environment and 

health and are suitable to the crops and circumstances of the nomination ..." 

If you anticipate that you will need methyl bromide in 2015 because you believe there are no technically and economically feasible 

alternatives, then you should apply for the critical use exemption. This application may be submitted either by a consortium 

representing multiple users or by individual users. We encourage users with similar circumstances of use to submit a single 

application (for example, any number of post harvest users with similar commodity, pest, and structural conditions can submit a 

single application.)

If a consortium is applying for multiple methyl bromide users, the economic data should be for a representative or typical user 

within the consortium unless otherwise noted. If economic or technical factors (such as types of commodities) affecting the ability 

of this "representative user" to use alternatives are significantly different than other users in the consortium, more than one 

application should be submitted to reflect these differences.

Please contact your local, state, regional or national commodity association and/or state representative agency to find out if they 

plan on submitting an application on behalf of your commodity group.

WHO 

APPLIES?
SECTIONS OF 

WORKBOOK

OMB Control # 2060-0482, Expires 10/31/2011

4. Go to the blank worksheet where you want the copied information to be pasted.

5. Again, select the top left corner of the worksheet (left of column A and above row 1) to select the entire worksheet.

The two arrows on the bottom right of the screen allow you to move the worksheet that you are viewing to the right or to the left. 

This is useful if the viewable area of on the screen is smaller than the entire page that is in the worksheet.

Printing worksheets

6. Go to the menu line at the top of the worksheet and select “Edit” then “Paste”

7. Change the title row of the newly pasted worksheet from the old worksheet number to be consistent with the worksheet tab.

Note: This is the only way you can copy a worksheet and not lose portions of the text instructions. 

Viewing worksheets

If you would like to print all worksheets that are contained in this workbook, go to the menu bar at the top of the screen and 

select "File" and then "Print." Then in the section of the menu that appears called "Print what," select "Entire Workbook."

EPA Form # 4900-137 Post Harvest

Worksheets are best viewed in "Page Break Preview." To select the view of the worksheet, go to the menu bar and select 

"View" and then "Page Break Preview." Page break preview shows only the printable area of the worksheet, with the blue lines 

that surround the screen indicating the edges of each page.

To increase or decrease the size of the page that is viewable on the screen, go to the menu bar and select “View” and then 

“Zoom”. 

Navigating between worksheets

The set of four arrows on the bottom left of the screen will help you navigate between worksheets. This is necessary to access 

the remaining worksheet tabs in the workbook that are not viewable. The two arrows with vertical lines to either the left or right 

will take you to the first worksheet and to the last worksheet respectively in the workbook. The inner two arrows allow you move 

the worksheet tabs to the right or to the left incrementally.

EXCEL 

USER TIPS 

Inserting a blank worksheet:

1. To add additional blank worksheets in the Excel file, go to the menu line at the top of the worksheet and select “Insert” then 

“worksheet”

2. A tab with the name “Sheet 1” will appear at the bottom of the worksheet and will be highlighted in white. Take the cursor and 

double click the “new tab”

3. By double clicking in the tab you can now rename the worksheet to the appropriate number letter designation (e.g., 3-A(1), 3-

A(1)(a), etc.)

4. To move a newly inserted worksheet, simply drag the worksheet with your mouse to the desired location.

5. Once you add a new worksheet, Excel will automatically name each subsequently added worksheet as Sheet 2, Sheet 3, 

etc... Follow the instructions above to rename the new blank worksheets as appropriate.

2. Select the top left corner of the worksheet (this is the space to the left of column A and above row 1. You will know that the 

entire worksheet has been selected because the row and column marks as well as the worksheet itself will change to a different 

3. Go to the menu line at the top of the worksheet and select “Edit” then “Copy”.

Worksheet 3. Alternatives

Worksheet 3-A. Alternatives - Technical Feasibility of Alternatives to Methyl Bromide

Worksheet 3-B. Alternatives - Changes in Operating Costs

Copying and pasting an entire worksheet’s contents into a blank worksheet:

1. Select the worksheet to be copied by clicking on the worksheet tab at the bottom of the screen. The tab will turn white in 

color when it has been selected.

Worksheet 4. Emission Control

Worksheet 5. Future Research Plans

Definitions

Climate Zone Map

Worksheet 6. Application Summary

INSTRUCTIONS

Each worksheet number corresponds to the tab number in the electronic version of the application. 

Instructions specific to each worksheet are provided at the top of each sheet. A header row is included on 

each worksheet to include an application ID number that EPA will assign. 

Instructions

Worksheet 1. Contact and Methyl Bromide Request Information

Worksheet 2. Methyl Bromide 

Worksheet 2-A. Methyl Bromide - Pest and Processing Information

Worksheet 2-B. Methyl Bromide - Historical Use for 2007 - 2011

Worksheet 2-C. Methyl Bromide - Commodity Treated & Gross Profit for 2007 - 2011

Worksheet 2-D. Methyl Bromide - Operating Costs for 2011
Is this information Confidential Business Information (CBI)? Yes No

Applicant Name

Primary Contact

Contact Name Specialty

Address Agronomic

Economic

Daytime Phone Cell Phone

E-mail Address Fax

Alternate Contact

Contact Name Specialty

Address Agronomic

Economic

Daytime Phone Cell Phone

E-mail Address Fax

OMB Control # 2060-0482, Expires 10/31/2011

(Check One)

Worksheet 1. Contact & Methyl Bromide Request Information for 2015

The following information will be used to determine the amount of methyl bromide requested and the contact person for this request. It is important that we know 

whom to contact in case we need additional information during the review of the application. 

(Check One)

If yes, the applicant assumes responsibility for the secure transmission of electronic submissions.

I certify that all information contained in this document is factual to the best of my knowledge.

Signature Date

Title

Print Name

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal 

agency.

This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously 

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. 

Title

Signature Date

Information in this application may be aggregated with information from other applications and used by the United States government 

to justify claims in the national nomination package that a particular use of methyl bromide be considered "critical" and authorized for 

an exemption beyond the 2005 phaseout. Use of aggregate data will be crucial to making compelling arguments in favor of critical 

use exemptions. By signing below, you agree now to assert any claim of confidentiality that would affect the disclosure by EPA of 

aggregate information based in part on information contained in this application.

Print Name

EPA Form # 4900-137 Post Harvest

Public reporting burden for this collection of information is estimated to average 39 hours per response and assumes a large portion of applications will be submitted 

by consortia on behalf of many individual users of methyl bromide. 

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number.
1.

2.

3.

4.

Climate 

(Average Minimum 

Temperature) 

Zones: 

(check all that apply)

5. Yes Amount

No

6. Yes CUE #

No

7.

A.

Total Pounds Active 

Ingredient (a.i.) of 

Methyl Bromide

B. Total Actual Volume 

(1000 cu. ft.) Treated

C.

Formulation (Ratio of 

MB/Pic Mixture) to be 

Used for the CUE

D. Use Rate (lbs 

a.i./1000 cu. ft.)

8.

9.

10. Yes Lbs

No

11. Have you adjusted the request for the following issues?:

Regulatory Issues: Yes___ No___ Pest Pressure: Yes___ No___

Adoption of Alternatives: Yes___ No___ Other (Please Explain): Yes___ No___

2014 2015

EPA Form # 4900-137 Post Harvest

OMB Control # 2060-0482, Expires 10/31/2011

Have you previously applied for Critical Use Exemption of Methyl Bromide?

(Individual users should enter their climate zone designation by reviewing the U.S. climate zone map located at the end of this 

workbook or it can be reviewed online at http://planthardiness.ars.usda.gov/PHZMWeb. If a consortium is submitting this 

application, please indicate the estimated percentage of consortium users in each climate zone.) 

1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b____ 

7a____ 7b____ 8a____ 8b____ 9a____ 9b____ 10a____ 10b____ 11____

10,000 to 50,000 (1,000 cu ft)

If a consortium is submitting this application, the data should be the total for the consortium.

5,000 to 10,000 (1,000 cu ft)

What is the amount of methyl bromide being requested by this application? (Do NOT include QPS amounts)

Is this applicant eligible for Quarantine and Preshipment (QPS) uses of methyl 

bromide?

Please explain why there may be variations in the pounds or volume (1,000 cu ft) treated from year to year, especially if 

the request is higher this year than in previous years:

Please explain why methyl bromide is being requested.

Do you anticipate that you will have any methyl bromide in 

storage after January 1, 2013?

(Enter the name and physical address of the facility(ies) where the proposed critical use of methyl bromide will 

Location of Facility take place. Provide more details about the location if relevant to the feasibility of alternatives to methyl bromide.) (ies) 

If yes, please specify amount (in pounds).

Range of structure/facility size by processors included in this application?

Worksheet 1. Contact & Methyl Bromide Request Information for 2015

(Include all commodities that benefit from the application of methyl bromide in a fumigation cycle. See the 

Worksheet entitled "Fumigation Cycle" for definitions.)

Commodity

(Insert number or percentage of users in each category) 

0 to 1,000 (1,000 cu ft)

1,000 to 5,000 (1,000 cu ft)

over 100,000 (1,000 cu ft)

50,000 to 100,000 (1,000 cu ft)
Worksheet Title

2-A Methyl Bromide - Pest and Commodity Information

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

The purpose of this worksheet is to determine pest infestation and commodity information where methyl 

bromide is used. This forms the baseline for evaluating the impacts of using an alternative to replace methyl 

bromide.

2-B Methyl Bromide - Historical Use 2007 - 2011

If a consortium is submitting this application, all data should reflect the actual data for the consortium.

This worksheet provides data in actual usage for 2007 - 2011. 

2-C Methyl Bromide - Commodity Treated and Gross Profits for 2007 - 2011

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

This worksheet provides commodity treated and gross profits for 2007 through 2011.

The purpose of this worksheet is to determine past gross profits when methyl bromide is used. This forms the 

baseline for evaluating the revenue impacts of using an alternative to replace methyl bromide.

2-D Baseline - Operating Costs for 2011

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

This data is needed to estimate a baseline for operating costs in order to estimate changes in costs and the 

impact on operating profit and short-run economic viability as a result of not using methyl bromide.

The purpose of this worksheet is to determine operating expenses when methyl bromide is used. This forms 

the baseline for evaluating the cost impacts of using an alternative to replace methyl bromide. The data 

requested are designed to help you identify how your operation would change if methyl bromide were 

unavailable, which will be shown in Worksheet 3-B. 

EPA Form # 4900-137 Post Harvest

OMB Control # 2060-0482, Expires 10/31/2011

Worksheet 2. Methyl Bromide 

Purpose of Data: To establish a baseline estimate of commodity treated, gross profits, and costs using methyl bromide. 

Instructions specific to each worksheet are located at the top of each sheet.
1.

2.

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

3. Fumigation Timeline:

Beginning Fumigation Cycle

(please define time periods)

Facility Preparation

Sealing

Cleaning

Fumigation Timeline

Reception of Raw Materials

Processing

Storage

Raw Materials

Finished Product

Packing

Shipping

Retail Market Window

Other Pest Treatments

Other 

4.

4a.

OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest

Provide a narrative of market channel for each commodity, where it is fumigated, and how the fumigation effects 

market availability and commodity sale.

Time Interval ______________________ (e.g. WEEKS/MONTH/YEAR/SEASON)

Please provide a simplified schematic diagram which illustrates the basic steps of the commodity moving 

through the process from raw material to finished product.

Worksheet 2-A. Methyl Bromide - Pest & Processing Information

(Indicate when fumigation, major commodity and pest management practices typically

occur. If the fumigation cycle is longer than one year change the months to an appropriate 

interval.)

What month does your fumigation cycle start? (check only one)

Commodity or Consortium:
5. Target Pest(s) or Pest 

Problem(s):

Pest 1

Pest 2

Pest 3

6. Pest Economic Threshold:

Pest 1

Pest 2

Pest 3

7. Target Pest Infestation:

Pest 1 %

Pest 2 %

Pest 3 %

8.

9.

Structure / Facility

Commodity

Storage

All

Other

10.

11.

Worksheet 2-A. Methyl Bromide - Pest & Processing Information

OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest

Other

Please provide a brief description of any equipment fumigated in this operation.

(Please identify the top 3 target pests or pest problems. Provide at least common name and genus 

and species if possible. Additional pests or pest problems can be provided as an attachment.)

Common Name Genus

Indicate if common or 

minor pest

(If available, please provide the economic threshold information for each pest, units, and source of 

information.)

Economic 

Threshold

Units (e.g. 

pests/cu ft) Source

(Please estimate the percentage of this user's total structural/facility volume with a moderate to severe 

problem with these pests. Describe source of information such as a survey or expert estimate.)

Percentage of Total 

Structure/Facility Source

Alternative

Phosphine in Combination

Heat Treatment

Phase of Process

Representative User : (Please provide descriptive factors appropriate for your operation.)

% Replaced

What percentage of the operation have alternative(s) replaced methyl bromide in processing this commodity and 

if so, during what phase of the process?

Details

Phosphine (Alone)

Fumigation Chamber

Prior to Storage

In what part and phase of the operation does the methyl bromide fumigation take place? (check all that apply and indicate 

exposure time)

Sulfuryl Fluoride

Prior to Shipping

* Give gastightness estimates where possible according to the following scale: good - less than 25% gas loss within 24 hours or half loss time of pressure 

difference greater than 1 minute; medium - 25-50% gas loss within 24 hours or half loss time of pressure difference greater than 10 seconds; poor - 50-

90% gas loss within 24 hours or half loss time of pressure difference 1-10 second; very poor - more than 90% gas loss within 24 hours or a pressure half 

loss time of less than 1 second.

 b. Gastightness Estimate:*

 a. Number of Facilities:
2007 2008 2009 2010 2011

A.

B.

C.

D.

What is the frequency of methyl bromide applied per volume (1,000 cu ft)? (1x / year, 2x / year, 1x / 3 years, etc.)

Row A:

Row B:

Row C:

EPA Form # 4900-137 Post Harvest

Enter the formulation of methyl bromide used (e.g. MB 98:2; MB/Pic 70:30).

Use Rate (lbs a.i./1000 cu. ft.)

Enter the use rate in pounds a.i. of methyl bromide per area.

Use Rate (lbs a.i./1000 cu. ft.)

_________ times per ____________

OMB Control # 2060-0482, Expires 10/31/2011

Worksheet 2-B. Methyl Bromide - Historical Use 2007 - 2011

Total Actual Pounds a.i. of Methyl Bromide Applied 

Total Actual Volume (1,000 cu ft) Treated

Total Pounds Active 

Ingredient (a.i.) of Methyl 

Bromide

Row D:

If there is a variation (greater than 10%) in the quantity a.i., the volume (1,000 cu ft) treated or average 

application rate from year to year, please explain the reasons for the variation. 

Enter the total actual pounds active ingredient (ai) of methyl bromide applied. Note: This number should 

be the total pounds ai applied by the individual user or the entire consortium, for the year indicated. 

Include only the pounds active ingredient of methyl bromide. 

For the years shown specify:

Formulation (Ratio of MB/Pic 

Mixture) to be Used for the 

CUE

Total Actual Volume (1000 cu. 

ft.) Treated

Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE

Enter the total actual volume (1,000 cu ft) treated. Note: This number should be the total actual volume 

(1,000 cu ft) treated by the individual user or total actual volume (1,000 cu ft) treated for the entire 

consortium, for the year indicated. 

Comments:
A C D E F G H

Year Market Category

(grade, time, end use)

Unit of 

Commodity 

(e.g., pounds, 

tons)

Total 

Commodity 

Treated 

(per unit of 

commodity)

 Price

(per unit of 

commodity)

 Cost of 

Goods Sold

(per unit of 

commodity)

Gross Profit

(per unit of 

commodity)

 $ 0.00 

OMB Control # 2060-0482, Expires 10/31/2011

Comments:

EPA Form # 4900-137 Post Harvest

B

Commodity

Enter average prices received by the users for that commodity and category. For the total line, you do not have to enter a 

price. Average price over all categories can be calculated separately, if needed. If a commodity treated is never owned by

the facility, indicate the fees charged for all services.

Enter the total cost of goods sold (raw materials purchased) during the period. If this expense is not relevant to your postharvesting operation, please skip this column.

Column G: Cost of Goods Sold

Gross profit may be calculated using the data you entered as the Total Commodity Treated times Price minus the Cost of 

Goods Sold. If gross profit is not equal to total commodity sold times price subtracted by cost of goods sold ((Column E * 

Column F) - Column G), you may override the formula and enter a different revenue amount. Please explain why this gross 

profit amount is different in the comment section below.

Column H: Gross Profit

If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not 

have the quantitative data for the commodity treated in the same facility/structure, please indicate so in the comments 

section below.

Column F: Price

Enter the total units of commodity treated with methyl bromide and processed/sold per area.

Enter the unit of measurement for each commodity (lbs, tons, cwt). If not by weight, specify in the comments section the 

average weight of the measure. For the international review board, all measures will be converted to metric.

Column D: Unit of Commodity

Column E: Total Commodity Treated

Enter marketing categories that determine prices received, for example, grade (quality, taste, color) or timeliness (holiday

market season, early season, late season). Itemize or aggregate these factors to the extent appropriate if lack of methyl 

bromide would effect the price in each category. 

Column C: Market Categories

Column B: Commodity

Worksheet 2-C. Baseline - Methyl Bromide - Commodity Treated & 

Gross Profit for 2007 - 2011

Column A: 

Be sure to enter the year. Use as many rows as needed for each year for all the commodities in the fumigation cycles from 

2007 to 2011. If a fumigation cycle overlaps more than one calendar year, then the year of the fumigation cycle is the year 

methyl bromide was applied.

Year

Enter all commodities that benefit from methyl bromide in the fumigation cycle (interval between fumigations). See the 

Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle.
Column A:

Column B:

Column C: 

Column D:

Column E:

B C D E

Quantity Used per 

Volume (1,000 cu 

ft) or Weight (Tons 

(short))

Units 

(lbs, hours, etc.) Unit Cost ($)

Cost ($) per Volume (1,000 

cu ft) or Cost ($) per 

Weight (tons (short))

5. Other Operating Expenses

Operating Expense Items

c1) Product

c2) Application

d) Other Pest Management Costs

2. Repairs / Maintenance / Replacement

OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest

TOTAL OPERATING COSTS

3. Interest

Please fill in the unshaded areas. The shaded areas can be used if the information is known.

This field is required only for methyl bromide. However you may include specific amounts of other inputs or operations if you 

believe it helps to document the additional costs you would incur by using an alternative fumigant. 

Quantity Used per Volume (1,000 cu ft) or Weight (tons (short))

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

For all inputs and operations detailed in Column B, please specify the units of measurement.

4. Depreciation for Plant Assets

1. Pest Management Costs (a+b+c+d)

a) Sanitation 

b) Pest Control

c) Methyl Bromide Fumigation (c1+c2)

Units (lbs. hours, etc.)

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying methyl 

bromide, including any material costs (e.g. tarps). If custom applied and separate costs are unavailable, write 'custom' and 

enter total cost in Column E.

Worksheet 2-D. Methyl Bromide - Operating Costs for 2011

The purpose of this worksheet is to determine operating expenses when methyl bromide is used. This forms the baseline for 

evaluating the cost impacts of using an alternative to replace methyl bromide. The data requested are designed to help you 

identify how your operation would change if methyl bromide were unavailable, which will be shown in Worksheet 3-B.

A

Operating Expense Items

Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items 

listed here are not meant to be exhaustive or be representative of your specific operating system. Other operating expenses 

include, but are not limited to, wage/salary, advertising and selling, utilities, rent and lease, insurance, and supplies. Be as 

precise as necessary to explain how lack of methyl bromide would affect your operation, otherwise you may aggregate 

operating expenses. These are meant to provide suggestions and to help you identify how your operation would change if 

methyl bromide were unavailable. 

Enter all appropriate costs of operations per volume (1,000 cu ft) or weight (tons (short)). You may add or delete lines as 

necessary. 

Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (tons (short))
Worksheet

3-A

3-B

3-C

Enter all alternative pesticides and pest control methods (and associated profit and production practices) that would replace 

one treatment of methyl bromide throughout the fumigation cycle. See the Definition worksheet for a comprehensive 

definition on fumigation cycles.

Title

 Alternatives - Technical Feasibility of Alternatives to Methyl Bromide

You must complete one worksheet for each alternative. Please insert the name of the alternative in the area 

on top of the page. If you prefer, you may provide the information requested in this worksheet in a narrative 

review. However, you must fill in the information in Question #1 or we will assume no production or quality

loss.

OMB Control # 2060-0482, Expires 10/31/2011

Worksheet 3. Alternatives - Feasibility of Alternative Pest Control 

Regimens

Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs to compare data 

(commodity prices, gross profit, operating expenses, etc.) on the use of methyl bromide and alternative pest control 

regimens.

Complete Worksheet 3-A for each alternative pest control regimen. Each worksheet contains a place holder in the title for 

you to insert the name of the specific alternative pest control regimen addressed. You should add additional worksheets as 

required.

The purpose of this worksheet is to determine operating expenses when alternatives are used for evaluating 

the cost impacts of using an alternative to replace methyl bromide. The data requested are designed to help 

you identify how your operation would change if methyl bromide were unavailable. 

Alternatives - Economic Feasibility of Alternatives to Methyl Bromide

EPA Form # 4900-137 Post Harvest

Alternatives - Changes in Operating Costs

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

This data is needed to estimate a baseline for operating costs in order to estimate changes in costs and the 

impact on operating profit and short-run economic viability as a result of not using methyl bromide and to 

provide required information to the international review board.

Please fill out this worksheet for each alternative for which the economic evaluation would bolster 

the case that methyl bromide is needed.

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

Please include in this worksheet data for each alternative included in Worksheets 3-A and 3-B.
1.

Study # 

Relative % 

Pest 

Control 

1

2

3

4

5

2.

Study # Copy? EPA?

1

2

3

4

5

3. Yes No

(If yes, please continue with 3a, 3b, and 3c)

3a.

3b.

3c.

4.

5.

6.

 Pest Control When Comparing This Alternative to Methyl Bromide (Provide numerical estimates where possible.) 

Alternative: [ Insert Alternative ]

 - Label Restriction 

% of Structure/Facility/Volume Details

Restrictions/Limitations on Alternative Use

OMB Control # 2060-0482, Expires 10/31/2011

Worksheet 3-A. Alternatives - Technical Feasibility of Alternatives to 

Methyl Bromide

For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached 

and if it is on the EPA website.

Scale of Study

(e.g. pilot, plot)

Study Information

Pest Being Tested

Climate Restriction

Regulatory Restriction 

This information will be used to determine the amount of methyl bromide needed.

Please explain the details of going into downtime and why it is necessary with this alternative.

What is the cost of production delays or downtime per year? $ per year

What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or 

alternative treatments? (please explain)

Pest Resistant To Alternative

Structural Limitations

EPA Form # 4900-137 Post Harvest

Other Restrictions/Limitations (Describe)

Resulting Damages (please specify)

Facility Limitations

Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity?

Month/Year project started and 

finished (e.g. Nov '06 - Oct '09) Details

Please specify the number of days per year of downtime: days/year

Are there any production delays (downtime) associated with this alternative?
7.

8.

9.

1 2 3 4 5 6 7 8 9 10 11 12

Alternative: [ Insert Alternative ]

OMB Control # 2060-0482, Expires 10/31/2011

Worksheet 3-A. Alternatives - Technical Feasibility of Alternatives to 

Methyl Bromide

Use Rate of Chemical Alternative:

Volume (1,000 cu 

ft) Treated # of Applications per Year

Active Ingredient 

(a.i.) Name of Product and Formulation

Quantity per 

Volume 

(1,000 cu ft)

Units 

(gals, lbs., etc.)

 Sealing

EPA Form # 4900-137 Post Harvest

Other Pest Treatments

Other 

Fumigation Cycle

 Finished Product

Packing

 Raw Materials

Shipping

 Cleaning

Fumigation Timeline

Reception of Raw Materials

Processing

Retail Market Window

Non-Chemical Pest Control: (please describe)

(Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle 

is longer than one year change the months to an appropriate interval.)

Time Interval (e.g. WEEKS/MONTH/YEAR)

Fumigation 

Timeline:

Storage

Facility Preparation

Comments:
Column A: 

Column B:

Column C: 

Column D:

Column E:

B C D E

Quantity Used per 

Volume (1,000 cu 

ft) or Weight (tons 

(short))

Units (lbs, hours, 

etc.) Unit Cost ($)

Cost ($) per 

Volume (1,000 cu 

ft) or Cost ($) per 

Weight (tons 

Total Investment 

($)

Life of Investment 

(# of years) Salvage Value ($) Interest Rate (%)

OMB Control # 2060-0482, Expires 10/31/2011

1. Pest Management Costs (a+b+c+d)

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to 

heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and 

retrofitting other components to make them amenable to heat treatment. 

5. Other Operating Expenses

2. Repairs / Maintenance / Replacement

3. Interest

Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items

Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense 

items listed here are not meant to be exhaustive or be representative of your specific operating system. These are 

meant to provide suggestions and to help you identify how your operation would change if methyl bromide were 

unavailable. 

Operating Expense Items

Units (lbs. hours, etc.)

Quantity Used per Volume (1,000 cu ft) or Weight (tons (short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if 

you believe it helps to document the additional costs you would incur by using an alternative fumigant. 

For all inputs and operations detailed in Column B, please specify the units of measurement.

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying 

alternatives, including any material costs (e.g. tarps). If custom applied and separate costs are unavailable, write 

'custom' and enter total cost in Column E.

Worksheet 3-B. Alternative - Changes in Operating Expenses

Alternative: [ Insert Alternative ]

Comments:

 TOTAL OPERATING COST

What are the additional new investments (structures, facilities, equipment, fumigation chambers, etc.) needed to utilize 

this alternative?

 b) Pest Control

 c1) Product

EPA Form # 4900-137 Post Harvest

 a) Sanitation 

4. Depreciation for Plant Assets

Unit Cost ($)

 c2) Application

 c) Fumigation (c1+c2)

Type of Investment

 d) Other Pest Management Costs

Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (tons (short))

Enter all appropriate costs of operations per volume (1,000 cu ft) or weight (tons (short)). You may add or delete 

lines as necessary. 

A
1.

2007

_____ lbs/cubic ft

2012

_____ lbs/cubic ft

2011

_____ lbs/cubic ft

2016

_____ lbs/cubic ft

2007

____ times per____

2012

____ times per____

2011

____ times per____

2016

____ times per____

2007

_____% methyl bromide, _____% chloropicrin

2012

_____% methyl bromide, _____% chloropicrin

2011

_____% methyl bromide, _____% chloropicrin

2016

_____% methyl bromide, _____% chloropicrin

2007 2012

2011 2016

2007 2012

2011 2016

2007 2012

2011 2016

2007 2012

2011 2016

2007 2012

2011 2016

2007 2012

2011 2016

2007 2012

2011 2016

2.

EPA Form # 4900-137 Post-Harvest

Formulation Changes 

(please specify)

OMB Control # 2060-0482, Expires 10/31/2011

How do you currently minimize use and/or emissions of methyl bromide, and how do you plan to further reduce use and/or emissions in the 

future?

(For all use/emissions reduction technique that you use, please fill out the text, where provided, or state the adoption rate and/or describe changes.)

Other Measures 

(please specify)

Methyl Bromide 

Dosage Reduction

Worksheet 4. Emission Control

What use/emission reduction methods are presently

adopted? Please state the emission reduction amounts 

between each listed year.

What further use/emission reduction steps will be taken for the 

methyl bromide used for critical uses? Please project the 

reduction amounts for each year.

Cultural Practices 

(please specify)

Other Pesticides 

(please specify)

If methyl bromide emission reduction techniques are not being used, or are not planned for the future, state reasons:

Non-Chemical 

Methods (please 

specify)

Less Frequent 

Application

Reclamation

Sealing Buildings

Integrated Pest 

Mangement (IPM)
1.

1 4

2 5

3

2.

1 4

2 5

3

3.

1 4

2 5

3

4.

5.

6.

7.

8.

9.

10.

Year Amount ($)

11. $

Cost

12.

Provide a list of alternative chemicals or cultural practices that have been tested.

OMB Control # 2060-0482, Expires 10/31/2011

Worksheet 5. Future Research Plans

Please describe future plans to test alternatives to methyl bromide. You may use this worksheet to describe all future plans.

Identify the top 3 to 5 target pests for your research.

Prioritize the alternative chemicals or cultural practices to be tested.

What would be the best currently available alternative if methyl bromide were not available?

Grant requests made to USDA, EPA, state, or other funding group.

(Describe each investment and its associated costs. e.g. specialized machinery, new facilities, etc.)

Investment

What is the cumulative amount spent and the types of contributions this consortium has made to fund research 

to develop alternatives to methyl bromide since 1992? (e.g. consortium dues, direct research funding, etc.)

EPA Form # 4900-137 Post Harvest

Other total investments, if any, made to reduce your reliance on methyl bromide?

Are there any other potential alternatives under development which are being considered to replace methyl 

bromide?

Are there technologies being used to produce the crop which avoid the need for methyl bromide? Please 

explain whether such technologies could replace a proportion of proposed methyl bromide use.

Name of Organization / Research Institution

Please describe the management strategies that are in place or proposed to eliminate the use of methyl 

bromide for the nominated critical use, e.g., measures to avoid any increase in methyl bromide consumption, 

measure to encourage the use of alternatives, information on the market penetration of newly deployed 

alternatives and alternatives that may be used in the near future.

Will you include incidence reports where a commodity fails?

Please provide an overview/timeline of the plan to transition away from using methyl bromide.
1.

2.

3.

4. 2014 lbs. 2015 lbs.

5. 2014 (1,000 cu ft) 2015 (1,000 cu ft)

Not 

Technically

Feasible

Not 

Economically

Feasible

For EPA Use Only ID # _______________

SECTOR ___________________________

This worksheet will be posted on the web to notify the public of requests for critical use exemptions beyond the 2005 phaseout 

for methyl bromide. Therefore, this worksheet cannot be claimed as CBI. 

Place an "X" in the column(s) labeled "Not Technically Feasible" and/or "Not Economically Feasible" where appropriate. Use the 

"Reasons" column to describe why the potential alternative is not feasible.

Potential Alternative

Pounds of Methyl 

Bromide Requested

Volume Treated with 

Methyl Bromide

Crop:

OMB Control # 2060-0482, Expires 10/31/2011

Worksheet 6. Application Summary

Consortium Name:

Location:

Reasons

EPA Form # 4900-137 Post Harvest
Fumigation cycle: The period of time between methyl bromide fumigations.

Year: If a fumigation cycle overlaps more than one calendar year, "year" refers to the calendar year when 

methyl bromide is applied (or the beginning of the cycle).

Comparable data:

In order to compare revenues and costs with and without methyl bromide, data on alternatives for 

pest control, yields, revenues, and costs must be for the same time interval as the methyl bromide 

fumigation cycle. If, however, quantitative data, is not available for the entire fumigation cycle, then 

to be comparable, the quantitative data for the alternatives should cover the same portion of the 

fumigation cycle as the quantitative data for methyl bromide, and the rest of the cycle should be 

discussed in the comments sections.

2-year example:

If a methyl bromide fumigation is made every 2 years, then the 2003 fumigation cycle began in 

2003 and would end in 2005. The data should cover the methyl bromide costs and usage for the 

methyl bromide fumigation made in 2003, and all yields and revenues received and other costs 

incurred during the 2 year period. To be comparable, the data on alternatives should cover a 

similar 2 year period beginning at the same time of year when a methyl bromide fumigation would 

be made. The data should cover all methyl bromide alternatives used, and all yields and revenues 

received during that 2-year interval. Other pest control and other costs would only need to be 

provided for that interval if they would change from what they were with methyl bromide.

Other beneficiary 

example

If someone other than the applicant benefits from a methyl bromide fumigation, you should 

comment on these benefits if you do not have quantitative data for the entire fumigation cycle. For 

example, if a rotational crop in the second year benefits from a methyl bromide fumigation a year 

earlier, but there is quantitative data only on the first crop, then the data on the alternatives should 

cover only the first crop, and the benefits of methyl bromide and the additional pesticides that 

would have to be used on the rotational crop should be discussed in the comments sections.

Crop cycle change 

example:

If in a one year interval, methyl bromide is applied, tomatoes are grown and harvested followed by 

peppers, then the fumigation cycle would be one year including the tomatoes and peppers. If, 

however, without methyl bromide, it is not possible to follow tomatoes with peppers in the same one 

year interval, then the alternative data on pesticides, costs, yields, and revenues should just cover 

tomatoes. The loss of profit from not being able to grow peppers with the alternatives would be 

part of the loss from not having methyl bromide.

Crop Grouping

The applicant can group simliar crops together if: 

(i) Crops would experience similar yield and quality losses in the absence of methyl bromide; and 

(ii) Crops are grown on the same fumigation and cultivation cycle with similar operating costs.

For example, nursery crops including various flower or tree species can be aggregated, with 

average yields per acre and prices. However, if crops are distinctly different in revenues and 

operating costs, or the cycles, the applicant may want to present yield, price and operating costs 

for each crop separately and also indicate the proportion of land area allocated to each crop.

Definitions

OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest