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LIST OF QUESTIONS FOR PARTIES ON THE SOILS CUN’s: 2010 ROUND

Received from MBTOC March 2, 2010

UNITED STATES

General

1. MBTOC acknowledges the substantial reductions made in many sectors, however several 

sectors have MB quantities which may be classified as either QPS MB or CUN MB 

depending on the use of the material grown in fumigated soil. Despite questions in previous 

years, MBTOC is still unclear of the technical (or regulatory) difference for this 

classification and how it affects the current requests for CUNs. 

Is it possible to provide a list of sectors where preplant soil use for CUNs has been 

reclassified as QPS use and how the technical or regulatory reason differs for the portion 

treated under CUN and QPS?

USG Response

The classification of quarantine versus critical use is considered when the U.S. prepares the 

nomination package. The U.S. asks applicants for information on their CUE and QPS uses for 

their relevant areas. Based on this information the amount needed for critical uses is calculated 

and forwarded to the Parties. 

The only sector where the U.S. has information on a shift from CUE uses to QPS uses of MeBr 

is forest seedling nurseries. As part of the U.S. nomination preparation process the U.S. has 

reduced the Southern Forest Nursery nomination based on the transition to alternatives and a 

transition of CUE uses to QPS uses in Alabama and Mississippi, which have added methyl 

bromide to their list of approved quarantine treatments. The U.S. does not have any additional 

information about other sectors that have transitioned from CUE uses to QPS uses. 

2. Specifically, has any of the methyl bromide sought under the CUN requests last year for 2011 

been reclassified to QPS MB under this year’s requests? If so, in which sectors and what is

the reason? 

USG Response

The U.S. does not know of any other applicants that between 2011 and 2012 have reclassified 

their uses to QPS. 

3. Could you please show the historic change in relevant sectors since 2003 of MB applied for 

under the CUN process and that now considered QPS MB?

USG Response

The U.S. does not track information on changes from CUE uses to QPS uses. It appears from the 

question that MBTOC has evidence to show that some uses are transitioning from CUE to QPS 

uses. Without a clear indication from MBTOC on the specific sectors involved and the source of 

the information it is very difficult to provide additional information.
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US Peppers 

1. According to table 5 and 6, the yields obtained with the 3 ways system (except for fall 

application in Georgia) and with Iodomethane are equivalent to MB. Therefore, the two 

alternatives can be used in all the nominated region except in Georgia. How important is the 

fall application in this region compared to the spring application?

USG Response

Information provided to the USG indicates that 35% of the pepper areas are fumigated and 

planted in the fall. 

US Eggplant

4. Until 1999, the chemical formulation primarily used was 98:2. Since then, growers have 

shifted to formulations with lower concentrations of methyl bromide and higher amounts of 

chloropicrin due to the phase-out schedule of methyl bromide. At present, the standard 

formulation is 50:50 in Florida. What MB formulation is used in Georgia?

USG Response

The 50:50 MeBr formulation is used in Georgia.

5. When Iodomethane is expected to be registered on eggplant?

USG Response

The manufacturer of iodomethane has not submitted a request to add eggplant to its registered

uses and the EPA has no additional information when that might happen. 

USA Forest Nursery

1. The Party states that the Midas label states use for conifers, but appears to be silent on 

deciduous forest nursery trees. Is it likely that the label will be expanded to include 

deciduous trees by 2012? If not, could the Party indicate what portion of the nomination is 

for deciduous forest nursery trees? 

USG Response

The iodomethane manufacturer has not submitted a request to add deciduous forest nursery trees 

to its labelled uses and the EPA has no additional information when that might occur. 

2. The Party states that the forest nursery industry has not been able to contract with 

commercial fumigant applicators for fumigation with iodomethane. Is there any information 

from the registrant or the fumigation companies that would indicate this will change by 

2012?

USG Response
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The U.S. has contacted the registrant of iodomethane and representatives of the forest nursery 

industry. Industry comments (see below) indicate that soil fumigation with iodomethane is 

unlikely for at least the near future for forest seedling nurseries. A representative of Arysta 

LifeScience Corp. said they fumigated “large scale demonstration blocks” in forest nurseries “as 

recently as 2009 and as far back as 2004.” However, Dr. Ronald Overton of the U.S. Forest 

Service, who represents the Northeast Forest Conservation Nursery Association (with member 

nurseries in 10 states) and Dr. Scott Enebak of Auburn University, who represents the Southern 

Forest Nursery Management Cooperative (with member nurseries in 13 states) had different 

impressions.

Dr. Overton responded:

No Midas trials have been conducted in nurseries in the Northeast Forest and Conservation 

Nursery Association consortium. Also, to my knowledge, there are no certified contract 

applicators of Midas in the Northeast for the broadcast tarped applications used in forest 

nurseries. As a consequence, the lack of availability of IM to Northeast nurseries, the lack of 

information on application rates, efficacy, effect on beneficial soil microorganisms, and crop 

phytotoxicity, as well as the other issues has not changed in the Northeast US.

[Ronald P. Overton, Area Regeneration Specialist, Northeastern Area, State & Private Forestry, USDA 

Forest Service; 4 March 2010]

Dr. Enebak responded:

1) Try as we might we cannot get Arysta Life Science to do tests in forest tree nurseries. This is 

not "free" stuff we are asking for. Nurseries will pay for the materials as part of their normal 

fumigation costs, but we can't seem to get a response from their reps. 

2) As far as wide-scale testing in the broadcast system, we (Nursery Cooperative) had a small (0.5 

acre) study in 2005 in GA tested straight iodomethane (prior to Midas' registration) and just this 

past spring (April 2009) we had 1.2 acres of Midas (2 rates, 4 replications) applied in a nursery in 

Alabama. We are currently processing the first year’s seedling data from those trials and will 

have a report in April 2010. 

We have two more cropping/growing seasons on those plots, so MI's effectiveness as a MBr 

replacement will start to show this year. I would not consider these wide-scale studies. 

I would agree with Ron Overton's assessment, "The lack of availability of Midas in southern US 

nurseries, the lack of information on application rates, efficacy, effect on beneficial soil 

microorganisms, and crop phytotoxicity, has not changed in the Southern US". 

[Scott Enebak, Professor & Director, Forest Health Dynamics Laboratory, Southern Forest Nursery 

Management Cooperative, Auburn University; 4 March 2010]

USA Strawberry fruit 

1. The CUN states that the lowest formulation of methyl bromide that is likely to be allowed in 

California is 57:43 (methyl bromide:chloropicrin) due to severe restrictions on the use of 

chloropicrin. High rates of chloropicrin (greater than 225 kg/ha) are restricted by 

regulation and lower rates may not be optimally effective against plant pathogens. 
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Which strawberry hectareage of the main strawberry producing districts (Oxnard, 

Watsonville/Salinas, Santa Maria) will in 2012 be constrained in terms of regulatory 

caps on rates of chloropicrin?

What is the lowest possible rate of chloropicrin application considered effective under 

barrier films?

USG Response

See Appendix NN.10 Summary of VIF and rate research by Ajwa and Browne 2010 CUE 

regarding the effect of reduced rates of fumigants and VIF on control of soil borne diseases. See 

Appendix JJ.12 Regulatory barriers that limit the use of alternatives CUE 2010 for fumigants by 

California strawberry fruit growers.

2. The CUN states that in Florida, rates that are 25-50% lower than historical methyl bromide 

rates are being used as the use of VIF-type films has increased. 

Looking at successful adoption of VIF in Florida and its favourable impact on dosage 

rates, will California policymakers review the regulation that bans use of VIF in MB 

application?

USG Response

The EPA believes that high barrier films can reduce emissions and improve bystander safety

when used according to label directions. But the EPA has no information regarding a decision 

by Cal DPR to allow the use of these films. See Appendix NN.10 Summary of VIF and rate 

research by Ajwa and Browne 2010 CUE for a summary of research regarding the effect of 

reduced rates of fumigants and VIF on control of soil borne diseases.

3. The CUN states that in California, township caps currently restrict the use of 1,3-D on 

approximately 40-62% of total strawberry land (California Strawberry Commission, 2008). 

Which strawberry hectareage of the main strawberry producing districts (Oxnard, 

Watsonville/Salinas, Santa Maria) will in 2012 be constrained in terms of township caps 

on 1,3-D?

USG Response

See Appendix JJ.12 Regulatory barriers that limit the use of alternative fumigants by California 

strawberry fruit growers.

4. The CUN states that the California Strawberry Commission has funded Farming Without 

Fumigants Initiative whose goal is to develop strawberry fruit production methods that can 

avoid the complexities of highly regulated fumigants. 

o Please provide a summary of research results to date?

USG Response

See Wang et al 2009. MBAO. Strawberry Production in soilless Substrate Troughs – Water 

Management
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5. Tables 3, 4 and 5 provide economic impacts of MB alternatives, but do not state over which 

years, on what hectareage (how many farms) or over which seasons these data have been 

collected.

Please provide more in-depth background information on the economic data provided in 

the CUN, and/or please provide a more up-to-date analysis?

USG Response

The economic data provided in the report is from the 2008 assessment year. See Appendix U.07 

Economic impacts of alternatives. 

USA Sweet Potato Transplants

1. MBTOC acknowledges that the nominated area of sweet potato is reduced to 58ha from 81ha 

between CUN08 to CUN11. What alternatives are being used in the areas that have phased 

out MB.? What is the reason that those alternatives could not be used in the area of 58ha in 

CUN for 2012.

USG Response

Scott Stoddard responded:

Increased organic production. The number of producers has doubled since 2007, and 

much of the acreage growth can be attributed to increased organic acres. 

Alternatives: more metam sodium is being used (sprinkler applied).

It is very likely that alternatives like metam and Telone + Pic will show as viable 

alternatives by 2012. Currently, we are beginning the 3rd year of a 3 year project to 

document this. In 2011, verification of the results from the replicated trial will be done in 

6 to 8 locations. One of the big impediments to metam use is that it requires a change in 

production practices to utilizing a "cold bed", where the organic matter "layering" that is 

currently the standard method is eliminated in order to preserve the integrity of the 

metam in the soil and therefore the weed control. (the cold bed system is also required 

for solarization to work) Growers are hesitant to switch to a cold bed system for several 

reasons, including the belief that it reduces plant production. 

[C. Scott Stoddard, Assoc. Farm Advisor, Merced & Madera Counties, University of California; 11 March 

2010]

2. Pic is found very effective to treat nematodes. Devrinol and Valor in the tank mix were found 

to be effective for weed control. What is the reason that those alternatives could not be 

replaced methyl bromide in 2012?

USG Response

Scott Stoddard responded:

Research is showing that weeds are the main pest in the hotbed area, not nematodes or 

disease. If verified, as is planned in 2011, there would be little need for tarped 

applications of this fumigant (pic). Valor application rates still need to be determined 
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that will provide weed control with improved crop safety. Devrinol should be used more

than it is for sweetpotatoes. Regardless, I believe that there is good potential for 

herbicides to help alleviate the impact from fumigant loss. I will wait until after the third 

year of the trial and the verification trials in 2011 before stating that herbicides can be 

used as effective alternatives to fumigation.

[C. Scott Stoddard, Assoc. Farm Advisor, Merced & Madera Counties, University of California; 11 March 

2010]

3. According to the table 7, Pic. gave yield increases of 11% with a gain of $1,410/hectare 

although it is in the list of the substances that are a VOC. What restrictions does this place 

on Pic used in sweet potato production? 

USG Response

Scott Stoddard responded

In 2008 the best yielding fumigation treatment was Telone + Vapam, in 2009 it was Pic 

Chlor 60. Basically this tells me there is no consistent and significant impact of the 

hotbed fumigation treatments on root yield. But I tend to think of yield for the hotbeds as 

yield of plants. In either year Pic did not really have an advantage over the other 

treatments, so again, I'm unclear what this is referencing. I do not consider Pic only to be 

an alternative to pursue beyond 2010: It is mostly a disease control product and disease 

is not an issue, it is expensive to apply, it doesn't give weed control, and it has VOC 

issues.

[C. Scott Stoddard, Assoc. Farm Advisor, Merced & Madera Counties, University of California; 11 March 

2010]

USA Tomatoes – FIELD

1. The nomination is for methyl bromide use in the production of tomatoes in Florida, Georgia, 

the Mid-Atlantic (Maryland, and Virginia), and the Southeast. Table 15 reports only 3 

regions: SE, Georgia, and Florida. Maryland and Virginia are missing. Is this correct?

USG Response

MBTOC is correct the list of sites should include Maryland and Virginia. We have inserted the 

corrected Table 15 below. 

2. The University of Georgia reported that the price of iodomethane went up so dramatically 

that they did not advise growers to use the product. Please give a reference to this statement?

USG Response

This information was provided by Dr. Stanley Culpepper, University of Georgia. 

3. Is the quantity required for 2011 or 2012? Please update the nomination (Table 15)

USG Response

MBTOC is correct that the numbers should be for 2012 (see corrected table below). 
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 Maryland 

Tomatoes Virginia Tomato Southeast Tomato Total Georgia Tomato Florida Tomato Total Sector Total / Average 

Quantity Requested for 2011: Amount (kgs) 365 14,145 44,781 21,578 255,322 336,191

Quantity Recommended by 

MBTOC/TEAP for 2011 : Amount (kgs) 365 12,914 40,821 19,411 219,240 292,751

Amount (kgs) 365 12,914 40,821 19,411 219,240 292,751

Area (ha) 2 86 272 129 1,461 1,951

Rate 150 150 150 150 150 150

Transition from 2011 

Baseline Adjusted Value

Percentage (%) -80% -95% -80% -80% -81% -81%

Amount (kgs) 73 646 8,164 3,882 41,657 54,423

Area (ha) 1 5 65 31 333 435

Rate 125 125 125 125 125 125

SECTOR

2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

Quantity Required for 

2012 Nomination:

TOMATOES

Transition Use Reduction Description Spreadsheet

Quantity Approved by Parties 

for 2011:

LIST OF ATTACHED FILES

Appendix JJ.12 Regulatory barriers that limit the use of alternatives CUE .

Appendix NN.10 Summary of VIF and rate research by Ajwa and Browne 2010 CUE. 

Wang et al 2009. MBAO. Strawberry Production in soilless Substrate Troughs – Water 

Management

Appendix U.07 Economic impacts of alternatives.