METHYL BROMIDE CRITICAL USE NOMINATION FOR POST HARVEST USE BY NPMA FOR FACILITIES AND COMMODITIES FOR ADMINISTRATIVE PURPOSES ONLY: DATE RECEIVED BY OZONE SECRETARIAT:

YEAR: CUN:

NOMINATING PARTY: The United States of America BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Post Harvest Use by NPMA for Facilities and Commodities ( Prepared in 2005)

NOMINATING PARTY CONTACT DETAILS Contact Person: John E. Thompson, Ph. D. Title: International Affairs Officer Address: Office of Environmental Policy U. S. Department of State 2201 C Street N. W. Room 4325 Washington, DC 20520 U. S. A. Telephone: ( 202) 647 9799 Fax: ( 202) 647 5947 E mail: ThompsonJE2@ state. gov Following the requirements of Decision IX/ 6 paragraph ( a)( 1), the United States of America has determined that the specific use detailed in this Critical use Nomination is critical because the lack of availability of methyl bromide for this use would result in a significant market disruption.

Yes

No Signature Name Date Title: U. S. Post Harvest NPMA ii CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Steve Knizner Title: Acting Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U. S. Environmental Protection Agency Mail Code 7503C Washington, DC 20460 U. S. A. Telephone: ( 703) 305 6903 Fax: ( 703) 308 8090 E mail: knizner. steve@ epa. gov LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE LIST ALL PAPER AND ELECTRONIC DOCUMENTS SUBMITTED BY THE NOMINATING PARTY TO THE OZONE SECRETARIAT 1. PAPER DOCUMENTS: Title of Paper Documents and Appendices Number of Pages Date Sent to Ozone Secretariat 2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: Title of Electronic Files Size of File ( kb) Date Sent to Ozone Secretariat U. S. Post Harvest NPMA iii TABLE OF CONTENTS PART A: SUMMARY................................................................................................................... 6 1. Nominating Party.............................................................................................................. 6 2. Descriptive Title of Nomination........................................................................................ 6 3. Situation of Nominated Methyl Bromide Use .................................................................. 6 4. Methyl Bromide Nominated For Post Harvest Use ( Commodities and Facilities) Not Included in Other Chapters.................................................................................................. 6 5. Brief Summary of the Need for Methyl Bromide as a Critical Use................................. 6 6. Methyl Bromide Consumption for Past 5 Years and Amount Requested in the Year( s) Nominated For Post Harvest Use ( commodities and facilities) not included in other chapters.. 8 7. Location of the Facility or Facilities Where the Proposed Critical Use of Methyl Bromide Will Take Place....................................................................................................................... 9 PART B: SITUATION CHARACTERISTICS AND METHYL BROMIDE USE................... 10 8. Key Pests for which Methyl Bromide is Requested ........................................................... 10 9 Summary of the Circumstances in which the Methyl Bromide is Currently being Used ............................................................................................................................................. 12 10. List Alternative Techniques that are being Used to Control Key Target Pest Species in this Sector........................................................................................................................ 12 PART C: TECHNICAL VALIDATION................................................................................... 14 11. Summarize the Alternative( s) Tested, Starting with the Most Promising Alternative( s)....................................................................................................................... 14 12. Summarize Technical Reasons, if any, for each Alternative not being Feasible or Available for your Circumstances: ........................................................................................................ 16 PART D: EMISSION CONTROL ........................................................................................... 17 13. How has this Sector Reduced the Use and Emissions of Methyl Bromide in the Situation of the Nomination?.............................................................................................. 17 PART E: ECONOMIC ASSESSMENT................................................................................... 18 14. Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period ................. 18 15. Summarize Economic Reasons, if any, for each Alternative not being Feasible or Available for your Circumstances ...................................................................................... 18 Measures of Economic Impacts of Methyl Bromide Alternatives..................................... 20 PART F: FUTURE PLANS..................................................................................................... 20 16. Provide a Detailed Plan Describing how the Use and Emissions of Methyl Bromide will be Minimized in the Future for the Nominated Use.................................................................... 20 17. Provide a Detailed Plan Describing what Actions will be Undertaken to Rapidly Develop and Deploy Alternatives for this Use.................................................................... 20 17.1. Research...................................................................................................................... 20 17.2. Registration ............................................................................................................... 22 18. Additional Comments ................................................................................................... 22 19. Citations......................................................................................................................... 23 Bibliography........................................................................................................................ 24 APPENDIX A PUBLISHED PERFORMANCE DATA.......................................................... 26 U. S. Post Harvest NPMA iv APPENDIX B. 2007 METHYL BROMIDE USAGE NUMERICAL INDEX ( BUNI)............ 28 APPENDIX C. 2006 METHYL BROMIDE RECONSIDERATION FOR DRY COMMODITIES: COCOA BEANS. ....................................................................................... 32 APPENDIX D. 2006 METHYL BROMIDE RECONSIDERATION FOR DRY COMMODITIES: HERBS, SPICES, DRIED MILK, CHEESE PROCESSING.................... 34 U. S. Post Harvest NPMA v List of Tables PART A: SUMMARY................................................................................................................... 6 Table 4.1: Methyl Bromide Nominated For Post Harvest Use ( Commodities and Facilities) Not Included in Other Chapters.................................................................................................. 6 Table A. 1: Executive Summary................................................................................................... 8 Table 6.1: Methyl Bromide Consumption for the Past 5 Years and the Amount Requested in the Year( s) Nominated For Post Harvest Use ( Commodities and Facilities) Not Included In Other Chapters .................................................................................................................... 8 PART B: SITUATION CHARACTERISTICS AND METHYL BROMIDE USE........................... 10 Table 8.1: Key Pests for Methyl Bromide Request: Facilties ...................................................... 10 Table 8.2: Key Pests for Methyl Bromide Request: Commodities ............................................. 10 Table B. 1: Characteristic of Sector  Facilities .......................................................................... 11 Table B. 2: Characteristic of Sector: Commodities ..................................................................... 11 Table 9.1: ( a) Food Processing Plants........................................................................................ 12 Table 9.1: ( b) Fixed Facilities ................................................................................................... 12 PART C: TECHNICAL VALIDATION....................................................................................... 14 Table 11.1: Summary of the Alternatives Tested....................................................................... 14 Table 11.2: Summary of Review or Position Papers concerning Alternatives for Stored Product Pests.................................................................................................................................. 15 Table 12.1: Summary of Technical Reason for each Alternative not being Feasible or Available .......................................................................................................................................... 16 Table 12.2: Comparison of Alternatives to Methyl Bromide Fumigation................................... 17 PART D: EMISSION CONTROL .............................................................................................. 17 PART E: ECONOMIC ASSESSMENT....................................................................................... 18 Table 15.1: Summary of Economic Reasons for each Alternative not being Feasible or Available .......................................................................................................................................... 18 PART F: FUTURE PLANS ....................................................................................................... 20 APPENDIX A PUBLISHED PERFORMANCE DATA............................................................... 26 Appendix A  Table 1: Effect of temperature on concentration and time thresholds for some pests of stored products. ( From: Bell, C. H. 2000)...................................................................... 26 Appendix A  Table 2: Concentration Time Product recommendations by National Pest Management Association .................................................................................................. 27 APPENDIX A. 2007 Methyl Bromide Usage Numerical Index ( BUNI). .................................. 28 Page 6 PART A: SUMMARY 1. NOMINATING PARTY The United States of America ( U. S.)

2. DESCRIPTIVE TITLE OF NOMINATION Methyl Bromide Critical Use Nomination For Post Harvest Use By NPMA For Facilities and Commodities ( Prepared in 2005)

3. SITUATION OF NOMINATED METHYL BROMIDE USE This sector includes commodities and food processing plants treated by National Pest Management Association ( NPMA) members. Commodities included in this application are; processed foods ( such as chips, crackers, cookies and pasta), spices and herbs, cocoa, dried milk, tea pellets, coffee beans, tomato and bell peppers, citrus and cassava. Methyl bromide is typically utilized in processed food and feed facilities as a space fumigant for treating the facility 1 to 3 times per year. As the need arises, methyl bromide is also used for trailer fumigations of product or packaging material. These facilities are under intense pressure from many insect pests as well as rodents.

4. METHYL BROMIDE NOMINATED FOR POST HARVEST USE ( COMMODITIES AND FACILITIES) NOT INCLUDED IN OTHER CHAPTERS TABLE 4.1: METHYL BROMIDE NOMINATED FOR POST HARVEST USE ( COMMODITIES AND FACILITIES) NOT INCLUDED IN OTHER CHAPTERS YEAR NOMINATION AMOUNT ( KG) NOMINATION VOLUME ( 1000 M 3)

2007 147,320 7,358 5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE The U. S. CUE nomination in this sector includes a request for methyl bromide use only where use of alternatives is limited for the reasons described below: 1. pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide in some areas, making these alternatives technically and/ or economically infeasible 2. technical difficulties in adopting alternatives, for example heat may not be suitable for wood frame buildings or commodities with high oil content ( development of rancidity) 3. regulatory concerns, such as the adoption of a new fumigant, such as sulfuryl fluoride, that may not be registered for all sites or in all states Page 7 COMMODITIES: Methyl bromide fumigation for commodities occurs to ensure pest free food and meet the strict requirements of the Food Sanitation Regulations. The uses listed in this chapter, processed foods ( chips, cookies, crackers, pasta, etc.), spices and herbs, cocoa, dried milk, cheese, tea pellets, coffee beans, have no technically feasible alternative that can be used without incurring significant economic losses. Phosphine, alone or combined with carbon dioxide, is the only chemical alternative currently available for use on these commodities. Phosphine fumigations, however, take much longer than methyl bromide fumigations and are not a feasible alternative when rapid fumigations are needed. Harvest of commodities occurs in autumn, when temperatures are falling, making temperature dependent phosphine fumigation less likely. These sectors are already using phosphine alone or in combination to the extent that their processing systems and marketing needs allow it. Any additional shifting from methyl bromide to the slower phosphine fumigation would result in disruption of commodity processing during peak production times, lost market windows, and substantial economic losses. In addition, adoption of not in kind alternatives, such as controlled atmospheres, cold, and carbon dioxide under pressure, would require major investments for appropriate treatment units and / or retrofitting of existing warehouses.

FACILITIES: Food processing facilities in the United States have reduced the number of methyl bromide fumigations by incorporating many of the alternatives identified by MBTOC. Most important have been implementing IPM strategies, especially sanitation, in all areas of a facility. Plants are now being monitored for pest populations, using visual inspections, pheromone traps, light traps and electrocution traps. When insect pests are found, plants will attempt to contain the infestation with treatments of low volatility pesticides applied to both surfaces and cracks and crevices. These techniques do not disinfest a facility but are critical in monitoring and managing pests.

Facilities in the United States also are using both phosphine and heat treatments to disinfest at least portions of their plants. Phosphine, both alone and in combination with carbon dioxide, is often used to treat incoming grains and some finished products. Unfortunately, phosphine is corrosive to copper, silver, gold and their alloys. These metals are critical components of both the computers that run the machines as well as some of the machines in the plants. Therefore, phosphine is not feasible in all areas of food processing facilities. Additionally, phosphine requires more time to kill insect pests than does methyl bromide, so plants need to be shut down longer to achieve maximum insect mortality, with associated economic losses from this downtime. There are also reports of stored product insects becoming resistant to phosphine.

There are a number of limitations associated with the use of heat in this industry. Not all areas of a plant can be efficiently fumigated with heat. Some food substances, for instance cheeses, will go rancid with heat treatments. Not all finished food products can be heated for the length of time heat is required for efficient kill of pests. In addition, geography of the United States plays a crucial role in the use of heat treatment. Food processing plants in the northern United States will experience winters with several weeks of sustaining temperatures of  32 ° to  35 ° C ( 30 ° to  25 ° F). In these areas some plants have heaters and the power plants have the capability to supply excess power as needed. However, the southern zones and parts of the western zones of the United States are geographically quite different from the northern areas. Winter temperatures in the south and west seldom reach   1.2 ° C ( 30 ° F) and if temperatures fall that low, it is Page 8 typically for only a few hours one night. Frequently winters in these warmer areas of the U. S. do not freeze at all. Subsequently, these facilities do not have heaters, nor do the power plants have sufficient power to allow them to heat such large areas and sustain the temperatures necessary for a kill. Additionally, escaping insects can survive these outdoor temperatures and re enter the facility after treatment, even when low volatility pesticides are used to treat the surfaces in the plant and its perimeter. Still, many southern and western facilities use heat treatments as a spot treatment whereas some northern facilities use heat treatments for all or parts of their plants.

By utilizing all these options, facilities in the U. S. have been able to reduce the number of methyl bromide fumigations from an average of 6 times a year to an average of 2 times in the south and west and once every 3 to 5 years in the north. The U. S. CUE nomination in this sector only includes a request for methyl bromide use where use of alternatives is limited for the reasons described above. There are many food processing facilities in the U. S. for which we are not requesting methyl bromide use because they have been able to successfully implement alternatives. This U. S. CUE nomination in this sector includes a request for methyl bromide only where use of alternatives is limited for the reasons described above.

TABLE A. 1: EXECUTIVE SUMMARY* Processed Foods ( chips, cookies, crackers, Pasta, etc) Spices and Herbs Cocoa Cheese processing Plants Other Commodity1 AMOUNT OF REQUEST ( KG) 2007 93,319 10,800 79,950 3,856 1,126 NOMINATED AMOUNT ( KG) 2007 74,884 4,891 64,082 2,996 467 * See Appendix B for complete description of how the nominated amount was calculated. 1Includes tea on pallets, coffee beans, tomatoes, bell peppers, citrus and cassava.

6. METHYL BROMIDE CONSUMPTION FOR PAST 5 YEARS AND AMOUNT REQUESTED IN THE YEAR( S) NOMINATED FOR POST HARVEST USE ( COMMODITIES AND FACILITIES) NOT INCLUDED IN OTHER CHAPTERS TABLE 6.1: METHYL BROMIDE CONSUMPTION FOR THE PAST 5 YEARS AND THE AMOUNT REQUESTED IN THE YEAR( S) NOMINATED FOR POST HARVEST USE ( COMMODITES AND FACILITIES) NOT INCLUDED IN OTHER CHAPTERS*

HISTORICAL USE* REQUESTED USE For each year specify: 1998** 1999 2000 2001 2002 2003** 2007 Amount of MB ( kg) 220,300 219,616 193,149 217,636 189,050 Volume Treated ( 1000 m ³ ) 7,020 8,037 6,791 8,293 7,868 Formulation of MB The applicant did not provide any information on formulation Unknown Dosage Rate ( kg/ 1000 m ³ ) 24.03 24.03 24.03 24.03 24.03 Actual ( A) Estimate ( E) Unknown Unknown * Based on most current information. ** No data from NPMA for 1998 & 2003. Page 9 7. LOCATION OF THE FACILITY OR FACILITIES WHERE THE PROPOSED CRITICAL USE OF METHYL BROMIDE WILL TAKE PLACE This nomination package represents a wide variety of food processing and commodity facilities. The location of each facility where methyl bromide fumigations may take place was not requested by the U. S. Government in the forms filled out by the applicants. Therefore, we currently do not have a complete listing of the actual addresses for each facility.

The location of each facility where methyl bromide fumigations may take place was not requested by the U. S. Government in the forms filled out by the applicants. Therefore, we currently do not have a complete listing of the actual addresses for each facility. However, we have sent out an additional survey requesting this information, after receipt, compilation, analysis, and fact checking, this information will be sent to MBTOC.

In addition, a full list of all processing plants that apply any registered pesticide in the U. S. is available from the U. S. Department of Labor, Occupational Safety and Health Administration website located at http:// www. osha. gov/ pls/ imis/ sicsearch. html. EPA's Facility Registry System is publicly available and is located at http:// www. epa. gov/ enviro/ html/ fii/ ez. html. This information was previously submitted in August of 2004. Page 10 PART B: SITUATION CHARACTERISTICS AND METHYL BROMIDE USE 8. KEY PESTS FOR WHICH METHYL BROMIDE IS REQUESTED:

TABLE 8.1: KEY PESTS FOR METHYL BROMIDE REQUEST: FACILITIES GENUS AND SPECIES OF MAJOR PESTS FOR WHICH THE USE OF METHYL BROMIDE IS CRITICAL COMMON NAME SPECIFIC REASON WHY METHYL BROMIDE IS NEEDED Tribolium confusum Confused flour beetle Tribolium castaneum Red flour beetle Pest status is due to health hazard: allergens; plus body parts, exuviae, and excretia violate FDA regulations1. Methyl bromide is needed because these insects can occur in areas with electronic equipment and materials that cannot tolerate high temperatures ( i. e. cooking) so phosphine and heat are not completely adequate.

Trogoderma variable Warehouse beetle Health hazard: choking and allergens; plus body parts, exuviae, and excretia violate FDA regulations. Methyl bromide is needed because these insects can occur in areas with electronic equipment and materials that cannot tolerate high temperatures ( i. e. cooking) so phosphine and heat are not completely adequate.

Lasioderma serricorne Cigarette beetle Sitophilus oryzae Rice weevil Plodia interpunctella Indianmeal moth Oryzaephilus mercator Merchant grain beetle Cryptolestes pusillus Flat grain beetle Food contamination violates FDA regulations. Methyl bromide is needed because these insects can occur in areas with electronic equipment and materials that cannot tolerate high temperatures ( i. e. cooking of some products; oils and butter go rancid with heat) so phosphine and heat are not completely adequate.

1 FDA regulations can be found at: http:// www. cfsan. fda. gov/~ dms/ dalbook. html and http:// www. fda. gov/ opacom/ laws/ fdcact/ fdcact4. htm.

TABLE 8.2: KEY PESTS FOR METHYL BROMIDE REQUEST: COMMODITIES GENUS AND SPECIES FOR WHICH THE USE OF METHYL BROMIDE IS CRITICAL COMMON NAME SPECIFIC REASON WHY METHYL BROMIDE IS NEEDED Cydia pomonella Codling moth Amyelois transitella Navel orangeworm Plodia interpunctella Indianmeal moth Tribolium castaneum Red Flour Beetle Cadra figulilella Raisin Moth Carpophilus sp. Dried Fruit Beetle Ectomyelois ceratoniae Carob pod moth Carpophilus spp., Haptoncus spp. Nitidulid beetles MB is used mainly where rapid fumigations are needed to meet customer timelines during critical market windows and peak production periods. During peak production months, phosphine fumigation takes three times longer than conventional MB fumigation and 17 times longer than vacuum MB fumigation. The required duration of phosphine fumigation increases as commodity temperature decreases, making its use impractical during the cold winter months. No technically or economically feasible alternatives exist at present during these critical periods. Page 11 TABLE B. 1: CHARACTERISTIC OF SECTOR  FACILITIES JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Harvest or Raw Material In X X X X X X X X X X X X Fumigation Schedule ( MB)* X X Retail Target Market Window N/ A * Plants in the southern United States may fumigate twice a year; plants in the northern United States may fumigate once every 3 years. However, fumigations may occur whenever a population explosion occurs.

TABLE B. 2: CHARACTERISTIC OF SECTOR: COMMODITIES Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Fumigation Schedule ( MB): All Commodities X X X X X X X X X X X X Retail Target Market Window: All Commodities X X X X Although fumigations may occur whenever a pest population explosion occurs, ideally foodprocessing plants will be fumigated with methyl bromide on 3 day holiday weekends just prior to the summer and at summer's end. This maximizes efficiency since the facilities are usually closed and workers are not present; and prior to very warm temperatures that increases insect pressure. Page 12 9. SUMMARY OF THE CIRCUMSTANCES IN WHICH THE METHYL BROMIDE IS CURRENTLY BEING USED TABLE 9.1: ( a) FOOD PROCESSING PLANTS CUE MB DOSAGE ( kg/ 1000m ³ ) EXPOSURE TIME ( hours) TEMP ( º C) NUMBER OF FUMIGATIONS PER YEAR PROPORTION OF FACILITY TREATED AT THIS DOSE FIXED ( F) MOBILE ( M) STACK ( S) National Pest Management Association Ave. 24 48 24 hrs 1 3 60 100% F, M TABLE 9.1: ( b) FIXED FACILITIES CUE TYPE OF CONSTRUCTION AND APPROXIMATE AGE IN YEARS VOLUME ( 1,000m ³ ) OR RANGE NUMBER OF FACILITIES GASTIGHTNESS ESTIMATE National Pest Management Association 5 10% 1 15 yrs old typically newer structures are tilt up concrete construction.

80% 15 75 yrs old, combination of metal, wood, brick and concrete.

5 10% 75+ years old, combination of construction materials and methods. Not available Not available Tilt up concrete   good to medium Metal, wood, brick construction   medium to poor.

Trailers/ containers   good to poor, must be inspected prior to treatment.

10. LIST ALTERNATIVE TECHNIQUES THAT ARE BEING USED TO CONTROL KEY TARGET PEST SPECIES IN THIS SECTOR :

Many of the MBTOC not in kind alternatives to methyl bromide are critical to monitoring pest populations and managing those populations, but they do not render a facility free of pests. . The most critical of these are: sanitation and IPM strategies. Sanitation is important and constantly addressed in management programs ( Arthur and Phillips 2003). Cleaning and hygiene practices alone do not reduce pest populations, but reportedly improve the efficacy of insecticides or diatomaceous earth ( Arthur and Phillips 2003). The principles of IPM are to utilize all available chemical, cultural, biological, and mechanical pest control practices. These include pheromone traps, electrocution traps, and light traps to monitor pest populations. If pests are found in traps, then contact insecticides and low volatility pesticides are applied in spot treatments for surfaces, cracks and crevices, or anywhere the pests may be hiding. These applications are intended to restrict pests from spreading throughout the facility to try to avoid a plant fumigation ( Arthur and Phillips 2003). However, IPM is not designed to completely eliminate pests from any given facility or to ensure that a facility remains free from infestation. In addition a major problem is the infestation of equipment and bins where there are no legal pesticides for those use sites other than the fumigants. Although FDA allows minimal contamination of food products, there is a zero tolerance for insects imposed by market demands, therefore, neither sanitation nor IPM is acceptable as an alternative to methyl bromide fumigation; but these strategies are used to manage pest populations and extend the time between methyl bromide fumigations. Page 13 In addition to sanitation and IPM, most food processing manufacturers in the United States currently use both phosphine, alone and in combination with carbon dioxide, and heat to fumigate their facilities. Many of the facilities treat incoming grains and their storage facilities with phosphine, but the corrosive nature of phosphine limits its use throughout the entire plant, especially in areas with electronic components. Phosphine is problematic in that some stored product pests are already becoming resistant to this chemical ( Bell 2000). Some facilities, probably due to construction, are unable to use phosphine and/ or heat. Facilities in the southern and western parts of the United States do not have heat sources on the premises thereby making heat fumigations impractical. Additionally, heat is a problem causing rancidity in butters and oils and denaturing proteins that may be used in the facility. Yet, there are plants in the U. S. that have incorporated both fumigation techniques and still need to fumigate with methyl bromide although they have been able to lengthen times between methyl bromide applications, thereby reducing the amount of methyl bromide used. Page 14 PART C: TECHNICAL VALIDATION 11. SUMMARIZE THE ALTERNATIVE( S) TESTED, STARTING WITH THE MOST PROMISING ALTERNATIVE( S)

Table 11.1: Summary of the Alternatives Tested PEST STUDY TYPE RESULTS CITATION T. castaneum Pilot feed and flour mills; Insects contained in plastic boxes. Non uniform heat. Number of hours to reach 50 ° C varied between the mills and within mills. 100% mortality at most locations of 50 60 ° C for 52 hrs. Old instars and pupae more heat tolerant Mahroof, et al. 2003 T. castaneum Lab Mortality of each life stage increased with increase in temperature and exposure time. Young larvae most heat tolerant and required 7.2 hr at > 50 ° C. Mahroof, et al. 2003 T. castaneum & T. confusum Lab Mortality increased as temperature increased and decreased as humidity increased. Mortality at one week was greater than initial mortality probably due to delayed effects of DE. T. confusum mortality lower than T. castaneum. Arthur 2000 Rhyzopertha dominica; P. interpunctella; & T. castaneum Lab Initial investigation of volatiles from mountain sagebrush demonstrated some activity in against these insects in bioassays. No indication of whether this is really a potential alternative Dunkel & Sears 1998 T. confusum 2nd & 3rd floors of a Pilot flour mill Adult insects in open rings placed in mill. 100% mortality of beetles in 25 hr on the north end of the 3rd floor, but south end of 2nd floor had only 75% mortality with full DE and 50% mortality with partial DE after 64 hr. Dowdy & Fields 2002 Ephestia kuehniella Lab Efficacy was influenced by age of the medium with DE when investigated under driest conditions ( 58% rh). But this is not a pest of concern in the U. S. Nielsen 1998 T. castaneum & T. confusum Lab Field collected flour beetles demonstrated varying degrees of resistance to several pesticides: malathion, chlorpyrifos, dichlorvos, phosphine, but not to resmethrin. T. castaneum more resistant than confusum. Zettler 1991 T. castaneum & T. confusum Lab Malathion resistant flour beetles were susceptible to cyfluthrin treated steel panels. Longer residuals on unpainted panels than on painted panels Arthur 1992 Page 15 TABLE 11.2: SUMMARY OF REVIEW OR POSITION PAPERS CONCERNING ALTERNATIVES FOR STORED PRODUCT PESTS SYNOPSIS OF REVIEW OR POSITION PAPERS CITATION Review of methyl bromide alternatives for stored product insects: Heat: gradients in buildings, insect refugia, rate can be problematic due to structures, some equipment heat sensitive, plastics warp, dust explosions, sugar, oils, butter & adhesives removed, not all food products can be heated; phosphine: activity slow, flammability above concentrations of 1.8% by volume, corrosion of copper, silver, and gold, no data for in combination with CO2 and heat; modified atmospheres: activity slow, requires air tight structures; sulfuryl fluoride1: no food tolerances in the U. S., no registration for this use. Fields & White 2002 Cites studies on: the development of resistance to phosphine in stored product pests; interaction of time, temperature and concentration of performance of phosphine; sulfuryl fluoride's difficulty in killing egg stage; Tables comparing phosphine to methyl bromide ( Table 1, Appendix A) Bell 2000 Theoretical paper based on a few lab studies and small field crop trials indicating that traps currently used for monitoring pest populations could be used to reduce those populations. No studies on a commercial scale or food processing/ storage facility were present. Cox 2004 Mostly lab studies on assorted stored product pests indicate that IGRs, especially methoprene and diflubenzuron, may play a role in controlling these insects Oberlander, et al. 1997 A simulation model in Denmark suggests that increase temperatures inside mills drives moth outbreaks and if mills were cooled to outdoor temperatures, moth outbreaks would be less frequent. Skovgard, et al. 1999 Investigations into chemical control strategies should include a thorough examination of physical, biological and environmental factors that can affect pesticide toxicity. These include: application rate, formulation, timing, surface substrate, and target pest. WP formulation of cyfluthrin applied to concrete lasted longer than the EC formulation. T. confusum was more susceptible than T. castaneum to WP. Zettler & Arthur 2000 1At the time of this review, sulfuryl fluoride had not been registered in the United States for any food uses. The new registration does not include the commodities within this sector. Page 16 12. SUMMARIZE TECHNICAL REASONS, IF ANY, FOR EACH ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE FOR YOUR CIRCUMSTANCES: ( For economic constraints, see Question 15):

TABLE 12.1: SUMMARY OF TECHNICAL REASON FOR EACH ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IN KIND ALTERNATIVES TECHNICAL FEASIBILITY COMMENTS Carbon Dioxide ( high pressure) No Controlled & Modified Atmospheres No Facilities in the United States are not airtight enough for modified atmospheres or carbon dioxide to be effective primarily because most are more than 25 years old and are not subsidized by the federal government. Downtime required for CO2 alone is much longer, at 6 12 days. Ethyl/ Methyl Formate No Not registered in United States ( last product cancelled in Oct. 1989) Hydrogen Cyanide No Not registered in United States ( last product cancelled in Feb. 1988) Phosphine, alone No Phosphine, in combination No Although does kill insects, it is corrosive to metals, especially copper and its alloys, bronze and brass. These metals are important components of the electronics that run the manufacturing equipment. In addition some of the equipment itself ( for example: motors, mixers, etc.) also have metal parts that contain copper. In addition it requires longer application time and is temperature sensitive. This alternative is already being used in the areas without electronics and where temperatures are not a factor. Resistance to this fumigant has also been reported for several stored product pests. Sulfuryl fluoride No United States recent registration does not include these uses NOT IN KIND ALTERNATIVE TECHNICAL FEASIBILITY COMMENTS Heat Treatment No Sufficiently high temperature will kill insects given enough time; but heat sources are not readily available in all areas of United States ( such as those in the south where hot weather is the norm and no heaters are available); and heat requires longer time of exposure. In areas that can use heat, it is being used. It is not feasible in remaining plants or areas of a plant. Cold Treatment No Contact Insecticides No Cultural Practices No Electrocution No Inert Dust No Pest Exclusion/ Physical Removal No Pesticides of Low Volatility No Pheromones No Physical Removal/ Cleaning / Sanitation No Rodenticide No Does not completely disinfest facility, however, all facilities are using pheromone traps for monitoring, electrocution traps near entrances, sanitation and cleaning, contact and low volatility insecticides for spot treatments and to prevent pest outbreaks. All facilities use rodenticides in traps for rodents. Page 17 Table 12.2: Comparison of Alternatives to Methyl Bromide Fumigation FUMIGANT PREPARATION TIME ( HR) FUMIGATION TIME ( HRS) DISSIPATION TIME ( HRS) MINIMUM NUMBER OF APPLICATIONS TO ONE MB APPLICATION Methyl Bromide 24 24 24  Phosphine, alone 24 48 72 24 0 2 Phosphine + CO2 24 48 72 24 3 4 Heat 36 48 52 24 3 4 PART D: EMISSION CONTROL 13. HOW HAS THIS SECTOR REDUCED THE USE AND EMISSIONS OF METHYL BROMIDE IN THE SITUATION OF THE NOMINATION?

Using sanitation, IPM, i. e. the " not in kind" alternatives the industry has been able to reduce methyl bromide use by extending the time between fumigations. Plants in the southern United States used to fumigate with methyl bromide as much as 4 6 times a year. The use of IPM strategies and more stringent sanitation methods have allowed these facilities to reduce the number of methyl bromide fumigations to twice a year. These fumigations are typically at the beginning of the summer and at the end of the summer.

In the northern regions of the United States, IPM strategies and sanitation methods have enabled some of these facilities to fumigate with methyl bromide once every 3 years, and a few facilities have gone without a methyl bromide fumigation for almost 5 years. The facilities in the northern United States have been able to exploit heat treatments more extensively than their southern counterparts, as well as opening up facilities during extremely cold weather for extensive cleaning with low volatility pesticides ( organophosphates, pyrethroids, insect growth regulators, botanicals) at the perimeters to kill pests within the facilities.

The use of methyl bromide in food processing plants in the U. S. is minimized in several ways. In preparation for the loss of methyl bromide, the food processing industry has been active in finding ways to reduce pests in the plants ( these techniques were described in Table 12.1). Page 18 PART E: ECONOMIC ASSESSMENT 14. COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD No data are available.

15. SUMMARIZE ECONOMIC REASONS, IF ANY, FOR EACH ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE FOR YOUR CIRCUMSTANCES TABLE 15.1. SUMMARY OF ECONOMIC REASONS FOR EACH ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE NO. METHYL BROMIDE ALTERNATIVE ECONOMIC REASON ( IF ANY) FOR THE ALTERNATIVE NOT BEING AVAILABLE ESTIMATED MONTH/ YEAR WHEN THE ECONOMIC CONSTRAINT COULD BE SOLVED 1 Heat Treatment Under laboratory conditions, brief exposure of commodities to high temperatures may eliminate insects without adversely affecting product quality. Sufficiently high temperature will kill insects given enough time; but heat sources are not readily available in all areas of United States ( such as those in the south where hot weather is the norm and no heaters are available); and heat requires longer time of exposure. In areas that can use heat, it is being used. It is not feasible in remaining plants or areas of a plant. Also, this approach is not feasible for treating commercial scale commodity volumes. Most insects do not survive more than 12 hours when exposed to 45oC or more than 5 minutes when exposed to 50oC ( Fields, 1992). However, the effectiveness of this approach has not been tested with large volumes of commodities. Substitution of heat treatments where high temperatures are not already used for other applications would require extensive retrofitting of existing facilities, as well as heat delivery systems capable of rapidly and uniformly heating large volumes of commodities in order to achieve total insect control. Furthermore, cheese quality may be adversely affected by exposure to heat. No indication was given by the applicant as to a timetable to solve identified problems.

2 Phosphine alone or in combination Although does kill insects, it is corrosive to metals, especially copper and its alloys, bronze and brass. These metals are important components of the electronics that run the manufacturing equipment. In addition some of the equipment itself ( for example: motors, mixers, etc.) also have metal parts that contain copper. In addition it requires longer application time. This alternative is already being used in the areas without electronics and where temperatures are not a factor. Resistance to this fumigant has also been reported for several stored product pests. Also, not suitable to replace methyl bromide when rapid fumigations are needed to meet No indication was given by the applicant as to a timetable to solve identified problems. Page 19 NO. METHYL BROMIDE ALTERNATIVE ECONOMIC REASON ( IF ANY) FOR THE ALTERNATIVE NOT BEING AVAILABLE ESTIMATED MONTH/ YEAR WHEN THE ECONOMIC CONSTRAINT COULD BE SOLVED customer timelines. Furthermore, cheese makers claim that phosphine causes damage to the cheese, " melting of the cheese" and may cause acid residue, acrid off odors and affect flavor.

Phosphine fumigation takes 3 10 days, depending on temperature, compared to 1 day for MB ( Hartsell et al., 1991, Zettler, 2002, Soderstrom et al., 1984, phosphine labels). An additional 2 days are needed for outgassing phosphine. Phosphine fumigation is least feasible during the colder winter months when, according to label directions, the minimum exposure periods increases to 8 10 days ( plus two days for aeration) when commodity temperature decreases to 5oC  12 oC. Phosphine is not used when commodity temperature drops below 5oC ( Phosphine and Eco2fume ® labels).

3 Irradiation Although rapid and effective, irradiation may result in living insect left in the treated product. Treated insects are sterilized and stop feeding, but are not immediately killed. The high dosages necessary to cause immediate mortality in target insects may reduce product quality. Irradiation requires major capital expenditures and irradiated food are not widely accepted by consumers. No indication was given by the applicant as to a timetable to solve identified problems.

4 Carbon Dioxide ( high pressure) Facilities in the United States are not airtight enough for modified atmospheres or carbon dioxide to be effective primarily because most are more than 25 years old. No indication was given by the applicant as to a timetable to solve identified problems.

Commodities and facilities listed in this chapter were requested by the National Pest Management Association which represents members that provide fumigation services to food processing and storage facilities. The economic impacts on the facility from using the next best alternative could not be assessed since the applicant is not the end user. However, the uses included in this chapter are those with no technically and economically feasible alternative. In general, economic impacts to the commodity and food processing sector can be characterized as arising from three contributing factors. First, the direct pest control costs increased in most cases because phosphine is more expensive due to increased labor time required for longer treatment time and increased number of treatments. Second, capital expenditures may be required to adopt phosphine for accelerated replacement of plant and equipment due to corrosive nature of phosphine. Finally, additional production downtimes for the use of alternatives are unavoidable. Many facilities operate at or near full production capacity and alternatives that take longer than methyl bromide or require more frequent application can result in manufacturing slowdowns, shutdowns, and shipping delays. Slowing down production would result in additional costs to the methyl bromide users.

The industries that use methyl bromide for commodity and facility fumigation are, in general, subject to limited pricing power, changing market conditions, and government regulations. Companies within these industries operate in a highly competitive global marketplace Page 20 characterized by high sales volume, low profit margins, and rapid turnover of inventories. In addition, producers' associations generally manage companies of this type, and, therefore, making new capital investment is often difficult.

MEASURES OF ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES No information available.

PART F: FUTURE PLANS 16. PROVIDE A DETAILED PLAN DESCRIBING HOW THE USE AND EMISSIONS OF METHYL BROMIDE WILL BE MINIMIZED IN THE FUTURE FOR THE NOMINATED USE.

The industry is committed to studying how to improve insect control with IPM strategies and sanitation and to further reduce the number of methyl bromide fumigations. They are also continuing to pursue research of heat treatments to maximize efficiency. The United States government is supporting research in this sector ( see Section 17.1) and the United States Environmental Protection Agency ( EPA or Agency) has made registering methyl bromide alternatives a priority ( see Section 17.2). EPA registered sulfuryl fluoride for some commodities and some mills on January 23, 2004 ( see Section 17.2.1).

17. PROVIDE A DETAILED PLAN DESCRIBING WHAT ACTIONS WILL BE UNDERTAKEN TO RAPIDLY DEVELOP AND DEPLOY ALTERNATIVES FOR THIS USE:

17.1. Research The number of available insecticides that can be used in and around food plants, processing mills, and food warehouses in the U. S. has declined in recent years. The research and development of chemical alternatives to be used by this sector is a critical need in the U. S. The post harvest food processing sector has invested substantial time and funding into research and development of technically and economically feasible alternatives to methyl bromide. Past and current research focuses on the biology and ecology of the pests, primarily insect pests. To implement non chemical controls and reduce methyl bromide use requires a thorough understanding of the pests in order to exploit their weaknesses. Some of these investigations have studied the effects of temperature and humidity on the fecundity, development, and longevity of a specific species. Other studies have been to determine the structural preferences and microhabitat requirements of a species. Studies of factors affecting population growth ( interactions within and among species) have been conducted. However, there is still much research that needs to be done.

IPM and sanitation methods are also under investigation. Studies have focused on food plant design, engineering modifications for pest exclusion, and insect resistant packaging. New research is demonstrating a potential to incorporate chemical repellents into packaging materials ( Arthur and Phillips 2003). Further studies with pheromones and trapping strategies are helping to improve IPM in food processing plants. Page 21 The USDA is continuing to fund research projects for post harvest/ food processing plants. Such activities include:

Biology and Management of Food Pests ( Oct 2002 Sep 2007) to: examine the reproductive biology and behavior of storage weevils, Indianmeal moth, and red and confused flour beetles; determine the influence of temperature on the population growth, mating and development of storage pests, specifically storage weevils, Indianmeal moth, and red and confused flour beetles; examine the use of CO2 concentrations within a grain mass to predict storage weevils and flour beetle population growth; and examine the use of alternative fumigants on insect mortality ( ozone, sagebrush, Profume ® ) .

Chemically Based Alternatives to Methyl Bromide for Post harvest and Quarantine Pests ( Jul 2000  Dec 2004) to: develop quarantine/ post harvest control strategies using chemicals to reduce arthropod pests in durable and perishable commodities; develop new fumigants and/ or strategies to reduce methyl bromide use; develop technology and equipment to reduce methyl bromide emissions to the atmosphere; develop system approaches for control using chemicals combined with nonchemical methodologies which will yield integrated pest control management programs; and develop methods to detect insect infestations.

The rice milling industry has spent over US$ 500,000 on research to develop alternatives since 1992, and plans to use additional pesticides, such as carbonyl sulfide, carbon dioxide, phosphine, magnesium phosphide ( magtoxin), and dichlorvos ( vapona) over the next few years. Nonchemical methods used by this sub sector, to reduce methyl bromide use, include heat and cold treatments, and many individual companies are involved in further research and testing of alternatives. Industry experts also recommend further studies on sulfuryl fluoride tolerances and combination treatments of heat/ carbon dioxide/ phosphine.

The bakery sector is implementing heat as an alternative at those facilities where heat is technically feasible. Currently, heat is being implemented at several facilities nationwide, but further trials are needed to determine the effects of heat on a long term basis. However, older facilities with hardwood floors and plant electrical wiring systems are unsuitable for heat treatments. Other methods being used to reduce reliance on methyl bromide are: exclusion, cleaning, early detection, improved design of equipment, trapping, and other integrated pest management ( IPM) approaches. Phosphine continues to be tested.

The flour milling industry is committed to IPM techniques in order to minimize reliance on any one tool. Many plants have reduced the amount of annual fumigations from 4 5 per year to 2 3 per year. Some of these facilities combine methyl bromide with carbon dioxide. Further, these applicants have authored three manuals on fumigation best practices, which are widely utilized throughout the industry. The industry continues to test high heat, phosphine, alone and in combination; and the combination of heat, phosphine, and carbon dioxide. Page 22 17.2. Registration Since 1997, the United States EPA has made the registration of alternatives to methyl bromide a high registration priority. Because the EPA currently has more applications pending in its registration review queue than the resources to evaluate them, EPA prioritizes the applications. By virtue of being a top registration priority, methyl bromide alternatives enter the science review process as soon as U. S. EPA receives the application and supporting data rather than waiting in turn for the EPA to initiate its review.

As one incentive for the pesticide industry to develop alternatives to methyl bromide, the Agency has worked to reduce the burdens on data generation, to the extent feasible while still ensuring that the Agency's registration decisions meet the Federal statutory safety standards. Where appropriate from a scientific standpoint, the Agency has refined the data requirements for a given pesticide application, allowing a shortening of the research and development process for the methyl bromide alternative. Furthermore, Agency scientists routinely meet with prospective methyl bromide alternative applicants, counseling them through the preregistration process to increase the probability that the data is done right the first time and rework delays are minimized The U. S. EPA has also co chaired the USDA/ EPA Methyl Bromide Alternatives Work Group since 1993 to help coordinate research, development and the registration of viable alternatives. This coordination has resulted in key registration issues ( such as worker and bystander exposure through volatilization, township caps and drinking water concerns) being directly addressed through USDA's Agricultural Research Service's US$ 15 million per year research program conducted at more than 20 field evaluation facilities across the country. Also EPA's participation in the evaluation of research grant proposals each year for USDA's US$ 2.5 million per year methyl bromide alternatives research has further ensured close coordination between the U. S. government and the research community.

Since 1997, the U. S. EPA has registered the following chemical/ use combinations as part of its commitment to expedite the review of methyl bromide alternatives:

  2000: Phosphine in combination to control stored product insect pests   2001: Indianmeal Moth Granulosis Virus to control Indianmeal moth in stored grains   2004: Sulfuryl fluoride registered as a post harvest fumigant for grains and flour mills, but not for the commodities included in this chapter.

18. ADDITIONAL COMMENTS Page 23 19. CITATIONS Arthur, F. H. 2000. Toxicity of diatomaceous earth to red flour beetles and confused flour beetles ( Coleoptera: Tenebrionidae): Effects of temperature and relative humidity. J. Econ. Entomol. 93( 2): 526 532.

Arthur, F. H. 1992. Cyfluthrin WP and EC formulations to control malathion resistant red flour beetles and confused flour beetles ( Coleoptera: Tenebrionidae): Effects of paint on residual activity. J. Entomol. Sci. 27( 4): 436 444.

Arthur, F. and T. W. Phillips. 2003. Stored product insect pest management an d control, In: Food Plant Sanitation eds: Y. H. Hui, B. L. Bruinsma, J. R. Gorham, W. Nip, P. S. Tong, and P. Ventresca. Marcel Dekker, Inc., New York, pp. 341 358.

Bell, C. H. 2000. Fumigation in the 21st century. Crop Protection 19: 563 569.

Cox, P. D. 2004. Potential for using semiochemicals to protect stored products from insect infestation. J Stored Prod. Res. 40: 1 25.

Dowdy, A K.& P. G. Fields. 2002. Heat combined with diatomaceous earth to control the confused flour beetle ( Coleoptera: Tenebrionidae) in a flour mill. J Stored Prod. Res. 38: 11 22.

Dunkel, F. V. and L. J. Sears. 1998. Fumigant properties of physical preparations from Mountain big sagebrush, Artemisia tridentate Nutt. ssp. vaseyana ( Rydb.) Beetle for stored grain insects. J. Stored Prod. Res. 34( 4): 307 321.

Fields, P. and N. D. G. White. 2002. Alternatives to methyl bromide treatments for storedproduct and quarantine insects. Annual Review of Entomology 47: 331 59.

Hou, X., P. Fields, and W. Taylor. 2004. The effect of repellents on penetration into packaging by stored product insects. J Stored Prod. Res. 40: 47 54.

Mahroof, R., Subramanyam, B. and Eustace, D. 2003. Temperature and relative humidity profiles during heat treatment of mills and its efficacy against Tribolium castaneum ( Herbst) life stages. J. Stored Prod. Res. 39: 555 569.

Mahroof, R., B. Subramanyam, J. E. Throne, and A. Menon. 2003. Time mortality relationships for Tribolium castaneum ( Coleoptera: Tenebrionidae) life stages exposed to elevated temperatures. J. Econ. Entomol. 96( 4): 1345 1351.

Nielsen, P. S. 1998. The effect of a diatomaceous earth formulation on the larvae of Ephestia kuehniella Zeller. J Stored Prod. Res 34: 113 121. Page 24 Oberlander, H., D. L. Silhacek, E. Shaaya, and I. Ishaaya. 1997. Current status and future perspectives of the use of insect growth regulators for the control of stored product insects. J Stored Prod. Res. 33: 1 6.

Skovgard, H., N. Holst, and P. S. Nielsen. 1999. Simulation model of the Mediterranean flour moth ( Lepidoptera: Pyralidae) in Danish flour mills. Environ. Entomol. 28( 6): 1060 1066.

Zettler, J. L. 1991. Pesticide resistance in Tribolium castaneum and T. confusum ( Coleoptera: Tenebrionidae) form flour mills in the United States. J. Econ. Entomol. 84( 3): 763 767.

Zettler, J. L. and F. H. Arthur. 2000. Chemical control of stored product insects with fumigants and residual treatments. Crop Protection 19: 577 582.

BIBLIOGRAPHY Arthur, F. H. 2000. Toxicity of diatomaceous earth to red flour beetles and confused flour beetles ( Coleoptera: Tenebrionidae): Effects of temperature and relative humidity. J. Econ. Entomol. 93( 2): 526 532.

Arthur, F. H. 1992. Cyfluthrin WP and EC formulations to control malathion resistant red flour beetles and confused flour beetles ( Coleoptera: Tenebrionidae): Effects of paint on residual activity. J. Entomol. Sci. 27( 4): 436 444.

Bell, C. H. 2000. Fumigation in the 21st century. Crop Protection 19: 563 569.

Cox, P. D. 2004. Potential for using semiochemicals to protect stored products from insect infestation. J Stored Prod. Res. 40: 1 25.

Dowdy, A K.& P. G. Fields. 2002. Heat combined with diatomaceous earth to control the confused flour beetle ( Coleoptera: Tenebrionidae) in a flour mill. J Stored Prod. Res. 38: 11 22.

Dunkel, F. V. and L. J. Sears. 1998. Fumigant properties of physical preparations from Mountain big sagebrush, Artemisia tridentate Nutt. ssp. vaseyana ( Rydb.) Beetle for stored grain insects. J. Stored Prod. Res. 34( 4): 307 321.

Fields, P. and N. D. G. White. 2002. Alternatives to methyl bromide treatments for storedproduct and quarantine insects. Annual Review of Entomology 47: 331 59.

Hou, X., P. Fields, and W. Taylor. 2004. The effect of repellents on penetration into packaging by stored product insects. J Stored Prod. Res. 40: 47 54.

Mahroof, R., Subramanyam, B. and Eustace, D. 2003. Temperature and relative humidity profiles during heat treatment of mills and its efficacy against Tribolium castaneum ( Herbst) life stages. J. Stored Prod. Res. 39: 555 569. Page 25 Mahroof, R., B. Subramanyam, J. E. Throne, and A. Menon. 2003. Time mortality relationships for Tribolium castaneum ( Coleoptera: Tenebrionidae) life stages exposed to elevated temperatures. J. Econ. Entomol. 96( 4): 1345 1351.

Mueller, D. K. 1998. Stored product protection  a period of transition. Insects Limited, Inc., Indianapolis, IN. 337 pp.

Nielsen, P. S. 1998. The effect of a diatomaceous earth formulation on the larvae of Ephestia kuehniella Zeller. J Stored Prod. Res 34: 113 121.

Oberlander, H., D. L. Silhacek, E. Shaaya, and I. Ishaaya. 1997. Current status and future perspectives of the use of insect growth regulators for the control of stored product insects. J Stored Prod. Res. 33: 1 6.

Skovgard, H., N. Holst, and P. S. Nielsen. 1999. Simulation model of the Mediterranean flour moth ( Lepidoptera: Pyralidae) in Danish flour mills. Environ. Entomol. 28( 6): 1060 1066.

UNEP. 1998. 1998 Assessment of alternatives to methyl bromide. United Nations Publication.

UNEP. 2001. Sourcebook of Technologies for protecting the ozone layer: alternatives to methyl bromide. United Nations Publication Zettler, J. L. 1991. Pesticide resistance in Tribolium castaneum and T. confusum ( Coleoptera: Tenebrionidae) form flour mills in the United States. J. Econ. Entomol. 84( 3): 763 767.

Zettler, J. L. and F. H. Arthur. 2000. Chemical control of stored product insects with fumigants and residual treatments. Crop Protection 19: 577 582. Page 26 APPENDIX A PUBLISHED PERFORMANCE DATA APPENDIX A  TABLE 1: EFFECT OF TEMPERATURE ON CONCENTRATION AND TIME THRESHOLDS FOR SOME PESTS OF STORED PRODUCTS. ( FROM: BELL, C. H. 2000) TEMPERATURE ( º C) SPECIES FUMIGANT THRESHOLD ( º C OR TIME) 15 25 Sitophilus oryzae Methyl Bromide º C ( mg/ l) 0.6 0.9 1.3 2.0 Tribolium confusum Methyl Bromide º C ( mg/ l) 1.3 2.0 2.5 3.0 Tribolium castaneum Methyl Bromide º C ( mg/ l) 1.3 2.0 3.0 3.5 Tribolium castaneum Phosphine º C ( mg/ l) 0.005 0.0011 Tribolium castaneum Phosphine Time ( h) 0.5 1.5 For phosphine relatively long exposure times are required for kill of all stages & time threshold is more important than the concentration for efficient fumigant action. Page 27 APPENDIX A  TABLE 2: CONCENTRATION TIME PRODUCT RECOMMENDATIONS BY NATIONAL PEST MANAGEMENT ASSOCIATION OUNCE HOURS MG/ L SPECIES STAGE TEMP ( ° C) PHOSPHINE 72 HR PHOSPHINE 144 HR METHYL BROMIDE SULFURYL FLUORIDE eggs 4.4 146.4 eggs 10 8.5 49.5 91.2 eggs 15.6 61.8 37.9 48 eggs 21.1 0.64 0.86 43.2 eggs 26.5 711.7 larvae 4.4 6.9 1.2 379.2 larvae 10 3.7 0.86 206.4 larvae 15.6 0.94 0.72 132 larvae 21.1 0.5 0.43 120 larvae 26.5 55.9 pupae 4.4 5.6 7.4 1046 pupae 10 5.6 4.6 324 pupae 15.6 5.2 1.3 124.8 pupae 21.1 0.58 0.3 108 adult 4.4 2.2 1.9 230.4 adult 10 1.8 1.1 105.6 adult 15.6 1 0.5 64.8 adult 21.1 0.36 0.3 57.6 Lasioderma serricorne adult 26.5 34.9 Sitophilus oryzae adult 21 0.36 30 eggs 26.7 1124.8 adult 4.4 209.3 178.2 adult 15.6 92.8 97.6 adult 25 0.48 64 55 Tribolium confusum adult 26.7 74.2 76.5 Tribolium castaneum adult 24 11.5 62 eggs 15 53 eggs 20 29 eggs 25 22 eggs 30 21 larvae 15 34 larvae 20 31 larvae 25 24 larvae 30 25 pupae 15 64 pupae 20 50 pupae 25 43 Plodia interpunctella pupae 30 35 Page 28 APPENDIX B. 2007 Methyl Bromide Usage Numerical Index ( BUNI). Date: Sector:

Kilograms ( kgs) Volume ( 1000m 3) Use Rate ( kg/ 1000m 3) Kilograms ( kgs) Volume ( 1000m 3) Use Rate ( kg/ 1000m 3) 2001 & 2002 Average % of Volume 93,319 3,884 24 89,861 3,740 24 0%

10,800 449 24 5,869 244 24 0%

79,950 3,327 24 76,899 3,200 24 0%

3,856 160 24 3,596 150 24 0%

1,126 47 24 560 23 24 0%

189,050 7,868 24 176,784 7,358 24 2007 Request () Double Counting () Growth () Use Rate Adjustment () QPS HIGH LOW Amount ( kgs) Volume ( 1000m 3) Use Rate ( kg/

1000m 3)

93,319  3,459 14,977  74,884 74,884 74,884 3,740 20 10,800  4,931 978  4,891 4,891 4,891 244 20 79,950  3,051 12,816  64,082 64,082 64,082 3,200 20 3,856  260 599  2,996 2,996 2,996 150 20 1,126  566 93  467 467 467 23 20 189,050 189,050 185,173 171,664 171,664 147,320 147,320 147,320 7,358 20 0% 0% 2% 9% 9% 22% 22% 22% 6% 17%

Low EPA High Low High Low HIGH LOW 24 20 100% 100% 0% 0% 100% 100%

24 20 100% 100% 0% 0% 100% 100%

24 20 100% 100% 0% 0% 100% 100%

24 20 100% 100% 0% 0% 100% 100%

24 20 100% 100% 0% 0% 100% 100%

Currently Use Alternatives? Research /

Transition Plans Pest free Market Requirement Change from Prior CUE Request (+/) Verified Historic MeBr Use /

State Frequency of Treatment of Product Loss per 1000 m 3 ( US$/ 1000m) Loss per Kg of MeBr ( US$/ kg) Loss as a % of Gross Revenue Loss as a %

of Net Revenue Yes Yes Yes 0 No 1 Yes Yes Yes 0 No 1 Yes Yes Yes 0 No 1 Yes Yes Yes 0 No 1 Yes Yes Yes 0 No 1 Conversion Units: 1 Pound = 0.453592 Kilograms 1,000 cu ft = 0.028316847 1,000 cubic meters High 24% Low 77%

Adopt new fumigants  Sulfuryl fluoride Percent of Market adoption depends on Registration Date, Cost, % of Structures that are suitable,

SF efficacy still unknown. SF might also require registration on all the additives typically found in a mill or food processing plant EPA estimates are for an eventual 20 to 40% market share after complete registration. 0 Most Likely Impact Value: Marginal Strategy (%) Combined Impacts Time, Quality,

or Product Loss % Reduction from Initial Request Processed Foods Cheese Processing Plants FOOD FACILITY TYPE Cocoa Methyl Bromide Critical Use Exemption Process 2007 Bromide Usage Numerical Index ( BUNI) POST HARVEST USE ( NPMA)

1/ 28/ 2005 Quarantine and Pre Shipment Regional Volume (%) Key Pest Distribution (%) Adopt New Fumigants Subtractions from Requested Amounts ( kgs)

Other Considerations Other Commodity Spices and Herbs Cocoa Cheese Processing Plants Economic Analysis Not provided by applicant.

Cheese Processing Plants Other Commodity Dichotomous Variables ( Y/ N)

Cocoa FOOD FACILITY TYPE Spices and Herbs Other Issues Processed Foods Heat & Phosphine Other Commodity FOOD FACILITY TYPE Processed Foods Unknown Use Rate ( kg/ 1000m3) % of Average Volume Requested:

Average Volume in the US:

Adjustments to Requested Amounts 2007 Nomination Options Spices and Herbs FOOD FACILITY TYPE Processed Foods Cheese Processing Plants Other Commodity 2001 & 2002 Average Use not available MOST LIKELY IMPACT VALUE Combined Impacts Adjustment ( kgs)

Nomination Amount TOTAL OR AVERAGE Spices and Herbs Cocoa 2007 Amount of Request not available Research Amount ( kgs) Page 29 Footnotes for Appendix B:

Values may not sum exactly due to rounding. 1. Average Volume in the U. S.   Average Volume in the U. S. is the average of 2001 and 2002 total volume fumigated with methyl bromide in the U. S. in this sector ( when available). 2. % of Average Volume Requested  Percent (%) of Average Volume Requested is the total volume in the sector's request divided by the Average Volume in the U. S. ( when available). 3. 2007 Amount of Request   The 2007 amount of request is the actual amount requested by applicants given in total pounds active ingredient of methyl bromide, total volume of methyl bromide use, and application rate in pounds active ingredient of methyl bromide per thousand cubic feet. U. S. units of measure were used to describe the initial request and then were converted to metric units to calculate the amount of the U. S. nomination. 4. 2001 & 2002 Average Use   The 2001 & 2002 Average Use is the average of the 2001 and 2002 historical usage figures provided by the applicants given in kilograms active ingredient of methyl bromide, total volume of methyl bromide use, and application rate in kilograms active ingredient of methyl bromide per thousand cubic meters. Adjustments are made when necessary due in part to unavailable 2002 estimates in which case only the 2001 average use figure is used. 5. Quarantine and Pre Shipment   Quarantine and pre shipment ( QPS) is the percentage (%) of the applicant's requested amount subject to QPS treatments. 6. Regional Volume, 2001 & 2002 Average Volume   Regional Volume, 2001 & 2002 Average Volume is the 2001 and 2002 average estimate of volume of methyl bromide used within the defined region ( when available). 7. Regional Volume, Requested Volume %  Regional Volume, Requested Volume % is the volume in the applicant's request divided by the total volume fumigated with methyl bromide in the sector in the region covered by the request. 8. 2007 Nomination Options   2007 Nomination Options are the options of the inclusion of various factors used to adjust the initial applicant request into the nomination figure. 9. Subtractions from Requested Amounts   Subtractions from Requested Amounts are the elements that were subtracted from the initial request amount. 10. Subtractions from Requested Amounts, 2007 Request   Subtractions from Requested Amounts, 2007 Request is the starting point for all calculations. This is the amount of the applicant request in kilograms. 11. Subtractions from Requested Amounts, Double Counting  Subtractions from Requested Amounts, Double Counting is the estimate measured in kilograms in situations where an applicant has made a request for a CUE with an individual application while a consortium has also made a request for a CUE on their behalf in the consortium application. In these cases the double counting is removed from the consortium application and the individual application takes precedence. 12. Subtractions from Requested Amounts, Growth or 2002 CUE Comparison  Subtractions from Requested Amounts, Growth or 2002 CUE Comparison is the greatest reduction of the estimate measured in kilograms of either the difference in the amount of methyl bromide requested by the applicant that is greater than that historically used or treated at a higher use rate or the difference in the 2007 request from an applicant's 2002 CUE application compared with the 2007 request from the applicant's 2003 CUE application. 13. Subtractions from Requested Amounts, QPS  Subtractions from Requested Amounts, QPS is the estimate measured in kilograms of the request subject to QPS treatments. This subtraction estimate is calculated as the 2007 Request minus Double Counting, minus Growth or 2002 CUE Comparison then multiplied by the percentage subject to QPS treatments. Subtraction from Requested Amounts, QPS = ( 2007 Request   Double Counting   Growth)*( QPS %) 14. Subtraction from Requested Amounts, Use Rate Difference   Subtractions from requested amounts, use rate difference is the estimate measured in kilograms of the lower of the historic use rate or the requested use rate. The subtraction estimate is calculated as the 2007 Request minus Double Counting, minus Growth or 2002 CUE Comparison, minus the QPS amount, if applicable, minus the difference between the requested use rate and the lowest use rate applied to the remaining hectares. 15. Adjustments to Requested Amounts   Adjustments to requested amounts were factors that reduced to total amount of methyl bromide requested by factoring in the specific situations were the applicant could use alternatives to methyl bromide. These are calculated as proportions of the total request. We have tried Page 30 to make the adjustment to the requested amounts in the most appropriate category when the adjustment could fall into more than one category. 16. Use Rate kg/ 1000 m3 2007   Use rate in pounds per thousand cubic feet, 2007, is the use rate requested by the applicant as derived from the total volume to be fumigated divided by the total amount ( in pounds) of methyl bromide requested. 17. Use Rate kg/ 1000 m3 low   Use rate in pounds per thousand cubic feet, low, is the lowest historic use rate reported by the applicant. The use rate selected for determining the amount to nominate is the lower of this rate or the 2007 use rate ( above). 18. (%) Key Pest Impacts  Percent (%) of the requested area with moderate to severe pest problems. Key pests are those that are not adequately controlled by MB alternatives. For structures/ food facilities and commodities, key pests are assumed to infest 100% of the volume for the specific uses requested in that 100% of the problem must be eradicated. 19. Adopt New Fumigants (%)   Adopt new fumigants (%) is the percent (%) of the requested volume where we expect alternatives could be adopted to replace methyl bromide during the year of the CUE request. 20. Combined Impacts (%)  Total combined impacts are the percent (%) of the requested area where alternatives cannot be used due to key pest, regulatory, and new fumigants. In each case the total area impacted is the conjoined area that is impacted by any individual impact. The effects were assumed to be independently distributed unless contrary evidence was available ( e. g., affects are known to be mutually exclusive). 21. Qualifying Volume  Qualifying volume ( 1000 cubic meters) is calculated by multiplying the adjusted volume by the combined impacts. 22. CUE Nominated amount  CUE nominated amount is calculated by multiplying the qualifying volume by the use rate. 23. Percent Reduction  Percent reduction from initial request is the percentage of the initial request that did not qualify for the CUE nomination. 24. Sum of CUE Nominations in Sector  Self explanatory. 25. Total U. S. Sector Nomination  Total U. S. sector nomination is the most likely estimate of the amount needed in that sector. 26. Dichotomous Variables   dichotomous variables are those which take one of two values, for example, 0 or 1, yes or no. These variables were used to categorize the uses during the preparation of the nomination. 27. Currently Use Alternatives   Currently use alternatives is ` yes' if the applicant uses alternatives for some portion of pesticide use on the crop for which an application to use methyl bromide is made. 28. Research/ Transition Plans   Research/ Transition Plans is ` yes' when the applicant has indicated that there is research underway to test alternatives or if applicant has a plan to transition to alternatives. 29. Pest free Market. Required  This variable is a ` yes' when the product must be pest free in order to be sold either because of U. S. sanitary requirements or because of consumer acceptance. 30. Other Issues. Other issues is a short reminder of other elements of an application that were checked 31. Change from Prior CUE Request This variable takes a `+' if the current request is larger than the previous request, a ` 0' if the current request is equal to the previous request, and a `` if the current request is smaller that the previous request. If the applicant has not previously applied the word ` new' appears in this column. 32. Verified Historic Use/ State This item indicates whether the amounts requested by administrative area have been compared to records of historic use in that area. 33. Frequency of Treatment   This indicates how often methyl bromide is applied in the sector. Frequency varies from multiple times per year to once in several decades. 34. Economic Analysis   provides summary economic information for the applications. 35. Loss per 1000 m3   This measures the total loss per 1000 m3 of fumigation when a specific alternative is used in place of methyl bromide. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative, such as longer time spent in the fumigation chamber. It is measured in current U. S. dollars. 36. Loss per Kilogram of Methyl Bromide   This measures the total loss per kilogram of methyl bromide when it is replaced with an alternative. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current U. S. dollars. Page 31 37. Loss as a % of Gross revenue   This measures the loss as a proportion of gross ( total) revenue. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current U. S. dollars. 38. Loss as a % of Net Operating Revenue  This measures loss as a proportion of total revenue minus operating costs. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current U. S. dollars. This item is also called net cash returns. 39. Quality/ Time/ Market Window/ Yield Loss (%)   When this measure is available it measures the sum of losses including quality losses, non productive time, missed market windows and other yield losses when using the marginal strategy. 40. Marginal Strategy  This is the strategy that a particular methyl bromide user would use if not permitted to use methyl bromide. Page 32 APPENDIX C. 2006 Methyl Bromide Reconsideration for Dry Commodities: Cocoa Beans.

Overview of the U. S. Nomination The U. S. requested 61.519 metric tons of methyl bromide for use on cocoa beans in the U. S. for both 2005 and 2006. This is a request at the national level to treat cocoa beans.

The U. S. nomination is only for those food commodities, such as cocoa, where the use of alternatives is not suitable. In the U. S. there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  Pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide, making these alternatives technically and/ or economically infeasible.  Constraints of the alternatives: some types of commodities ( e. g., those containing high levels of fats and oils) prevent the use of heat as an alternative because of its effect on the final product ( e. g., rancidity) or because it changes the nature of the final product ( e. g. cooking it).  Transition to newly available alternatives: Sulfuryl fluoride recently received a Federal registration for use on small grains ( flour, rice, oats, etc.) but not for other foods. State registrations for small grains have not yet been issued in all states. Further, it will take some time for applicators to be trained in the use of this chemical and for its incorporation into a pest control program. A registration decision concerning the establishment of sulfuryl fluoride tolerances on other processed food ingredients in a treated facility is still pending.  Time to complete fumigation: e. g., the use of some methyl bromide alternatives can add a delay to production by requiring additional time to complete the fumigation process. Production delays can result in significant economic impacts to the processors. Capacity of fumigation chambers can become an issue. If, for example, fumigation capacity for cocoa beans is fully utilized, moving to an alternative that requires a longer in chamber time would require construction of additional fumigation capacity incurring large capital costs.

MBTOC recommended a 25% cut to a level of 46.139 metric tons for 20061. The basis for this suggested reduction was " for phasein of alternatives".

MBTOC further stated " Frequent fumigations indicate that there are poor or no measures to prevent re infestation, resulting in additional and perhaps unnecessary use of MB."

To clarify the U. S. request, shipments of cocoa beans are fumigated once each and then distributed throughout the U. S. for further processing into finished products such as cocoa powder, chocolates, etc, and we therefore disagree that cuts to our request based on the frequency of fumigation are appropriate. Although phosphine ( aluminium phosphide) is labeled 1 The original recommendation for 2005 was for a cut of 10% to a level of 55.367 metric tons. The cut was rejected by the Parties at the November MOP and the full request was granted. It is now not clear if the recommended amount for 2006 remains at 46.139, a 25% cut from the requested amount, or, whether the amount will be adjusted to reflect a 15% reduction for a recommended quantity of 52.291. Page 33 for use on cocoa beans in the US, the time required to complete a fumigation is more than 96 hours compared with 24 hours for a methyl bromide fumigation. This extra time imposes a cost on the manufacturers of finished cocoa products. According to the International Cocoa Organization ( www. icco. org) " Some countries also use plastic strips containing Dichlorovos for continuous chemical control, though these are banned in some countries and the U. S. is withdrawing permission to use it."

Methyl bromide is the cost effective fumigant to use on cocoa beans. The short time required allows rapid turn over of existing fumigation capacity.

Technical and Economic Assessment of MBTOC/ TEAP Report. No technical assessment of the performance of alternatives, or economic assessment of the impact of converting to alternatives was provided by MBTOC. No economic data were provided to support a 25% reduction schedule as suggested by MBTOC.

To support the MBTOC's recommended change in the U. S. request citations of the research references and economic assessments that led to the MBTOC conclusions are needed so we can understand the justification. The technical references should describe the species tested, pest numbers, concentrations, times, and commodity volumes. Economic references should describe the costs of converting from methyl bromide to alternatives, the impact of longer treatment times, and the economic feasibility of a four year transition time.

U. S. 2006 nomination The U. S. has considered the issues raised by MBTOC, but continues to support our request for 61.519 metric tons of methyl bromide for use on cocoa beans for 2006 which is an increase of 15.380 metric tons over the MBTOC recommended amount of 46.139 metric tons. Page 34 APPENDIX D. 2006 Methyl Bromide Reconsideration for Dry Commodities: Herbs, Spices, Dried Milk, Cheese Processing.

Overview of the U. S. Nomination The U. S. requested 83.344 metric tons of methyl bromide for use on processed foods ( 71.889 metric tons), herbs and spices ( 4.695 metric tons), dried milk ( 0.402 metric tons), cheese processing facilities ( 2.876 metric tons), and other commodities ( 3.482 metric tons) for 2006. This is a request at the national level.

The U. S. nomination is only for those facilities where the use of alternatives is not suitable. In U. S. food processing plants there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  Pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide, making these alternatives technically and/ or economically infeasible.  Geographic distribution of the facilities: some facilities are situated in areas where key pests may occur at low levels, such as those located in the northern part of the U. S. In such cases, the U. S. is only nominating a CUE for facilities where the key pest pressure is moderate to high.  Age and type of facility: older food processing facilities, especially those constructed of wood, experience more frequent and severe pest infestations that must be controlled by fumigation.  Constraints of the alternatives: some types of commodities ( e. g., those containing high levels of fats and oils) prevent the use of heat as an alternative because of its effect on the final product ( e. g., rancidity). Further, the corrosive nature of phosphine on certain metals prevents its use in mechanical and electrical areas of the facilities.  Transition to newly available alternatives: Sulfuryl fluoride recently received a Federal registration for use on small grains ( flour, rice, oats, etc.) but not for other foods. State registrations for small grains have not yet been issued in all states. Further, it will take some time for applicators to be trained in the use of this chemical and for its incorporation into a pest control program. A registration decision concerning the establishment of sulfuryl fluoride tolerances on other processed food ingredients in a treated facility is still pending.  Delay in plant operations: e. g., the use of some methyl bromide alternatives can add a delay to production by requiring additional time to complete the fumigation process. Production delays can result in significant economic impacts to the processors.

MBTOC recommended 47.925 metric tons for processed dry foods2, 3.13 metric tons for herbs and spices, nothing for dried milk, 2.876 metric tons for cheese processing facilities ( the full amount requested) and 2.321 metric tons for other commodities. The total recommendation was for 56.253 metric tons of methyl bromide for these uses in 2006.

2 As is the case for cocoa ( above) because the cut for 2005 was rejected by the Parties at the November MOP, it is not clear whether the amounts recommended by MBTOC for 2006 will remain as recommended ( a cut of approximately 20% in addition to a lower use rate) or will be changed to a 10% cut again, in addition to the lower use rate) in recognition of the higher 2005 amount. Page 35 USG agrees that in general, a use rate of 20g/ m3 should allow for adequate control of pests in mills and processing facilities but reserves the right to re visit this issue should we become aware of data demonstrating that this level is not adequate to control pests in the specific circumstances of the nomination when appropriate practices ( eg careful sealing of the building/ container and other ` best practices') are followed.

USG also agrees that there are alternatives for controlling pests in dried milk and therefore withdraws the requested amount of 0.402 metric tons for this purpose.

USG does not agree that it is appropriate to cut 10% ( or 20%) from the requested use for transition to alternatives and for improved sealing.

To take the simpler issue first, there is no evidence that facilities for which this request for methyl bromide is being made are failing to seal the facilities properly. As far as the phase in of alternatives is concerned, the Montreal Protocol calls for a critical use nomination being granted when there are no alternatives that are both technically and economically feasible.

Over the last decade, food processing facilities in the United States have reduced the number of methyl bromide fumigations by incorporating many of the alternatives to methyl bromide use identified by MBTOC. The most critical alternative implemented is IPM strategies, especially sanitation, in all areas of a facility. Plants are now being monitored for pest populations, using visual inspections, pheromone traps, light traps and electrocution traps. When insect pests are found, plants will attempt to contain the infestation with treatments of low volatility pesticides applied to both surfaces and cracks and crevices. These techniques do not disinfest a facility but are critical in monitoring and managing pests. However, when all these methods fail to control a pest problem, facilities will resort to phosphine, heat, and if all else fails, to methyl bromide.

Many facilities in the United States also are using both phosphine and heat treatments to disinfest at least portions of their plants. Phosphine, alone and in combination with carbon dioxide, is often used to treat both incoming grains and finished products. Unfortunately, phosphine is corrosive to copper, silver, gold and their alloys. These metals are critical components of both the computers that run the machines as well as some of the machines themselves. Therefore, phosphine is not feasible in all areas of food processing facilities. Additionally, phosphine requires more time to kill insect pests than does methyl bromide, so plants need to be shut down longer to achieve mortality, resulting in economic losses. There are also reports of stored product pests becoming resist to phosphine ( Taylor, 1989; Bell, 2000; Mueller, 2002).

Heat treatments have a number of problems in this industry. Not all areas of a plant can be efficiently treated with heat. Some food substances, for instance oils and butters will become rancid with heat treatments. Not all finished food products can be heated for the length of time heat is required for efficient kill of pests. In addition, geography of the United States plays a crucial role in the use of heat treatments. Food processing plants in the northern United States will experience winters with several weeks of sustaining temperatures of  32 ° to  35 ° C ( 30 ° to  25 ° F). In these areas plants have heaters and the power plants have the capacity to supply excess power as needed. However, the southern and parts of the western zones of the United Page 36 States are geographically quite different. Winter temperatures there seldom reach   1.2 ° C ( 30 ° F) and when temperatures should fall that low, it is typically for only a few hours one night. For many winters, these areas of the U. S. don't freeze at all. Subsequently, these facilities do not have heaters, nor do the power plants have enough power to allow them to heat such large areas and sustain the temperatures necessary for an effective kill of pest populations. Additionally, escaping insects can survive these outdoor temperatures and re enter the facility after treatment, even when low volatility pesticides are used to treat the surfaces exiting the plant. Still, many southern and western facilities use heat treatments as a spot treatment whereas the northern facilities can use heat treatments more extensively.

In addition, there are economic costs incurred when alternatives are used that are over and above costs when using methyl bromide to control pests. Economic costs in the post harvest uses of the food processing sector can be characterized as arising from three contributing factors. First, the direct pest control costs are increased in most cases because heat treatment is more expensive, and labor is increased because of longer treatment time and increased number of treatments. For food processing facilities that are not already using heat, capital expenditure is also required to retrofit them suitable for heat treatment. Moreover, additional production downtimes for the use of alternatives are unavoidable. Many facilities operate at or near full production capacity and alternatives that take longer than methyl bromide or require more frequent application can result in manufacturing slowdowns, shutdowns, and shipping delays. Slowing down production would result in additional costs relative to the costs incurred by methyl bromide users.

The potential economic losses associated with the use of heat treatment mainly originate from the cost of capital investment. Although economic costs were not calculated for these specific types of food processing facilities, they were calculated for milling facilities. In the milling facilities the estimated economic loss per 1000 m3 ranges from $ 2,023 to $ 12,439, depending on the product being milled. The estimated economic losses as a percentage of gross revenue ranges from 3% to 18% and the estimated economic loss as a percentage of net revenue are over 45% for all the CUE applicants in the food processing ( milling) sector. We expect losses of a similar scale in this segment of the food processing sector as well.

The industries that use methyl bromide for commodity fumigation are, in general, subject to limited pricing power, changing market conditions, and government regulations. Companies within these industries operate in a highly competitive global marketplace characterized by high sales volume, low profit margins, and rapid turnover of inventories. The results suggest that heat treatment is not economically viable as an alternative for methyl bromide in existing facilities that still use methyl bromide.

Sulfuryl Fluoride is not registered for use on herbs and spices. Heat is not an appropriate treatment, as it will degrade the quality of the spice/ herb. Although phosphine ( aluminium phosphide) is labeled for use on spices and herbs in the U. S., the time required to complete a fumigation is more than 96 hours compared with 24 hours for a methyl bromide fumigation. This extra time imposes a cost on the manufacturers of these products. Because the market is a highly competitive and globalized one, characterized by high sales volume, low profit margins, and rapid turnover of inventories, phosphine may not be an economically feasible alternative for methyl bromide in this use. Page 37 Technical and Economic Assessment of MBTOC/ TEAP Report. We have not been provided by MBTOC with information on the technical assessment of the performance of alternatives, the economic assessment on the impact of converting to alternatives, and in particular the economic data used to support a 10% reduction.

To support the MBTOC's recommended change in the U. S. request citations of the research references and economic assessments that led to the MBTOC conclusions are needed so we can understand the justification. The technical references should describe the species tested, pest numbers, concentrations, times, and commodity volumes. Economic references should describe the costs of converting from methyl bromide to alternatives, the impact of longer treatment times, and the economic feasibility of a 10% reduction.

U. S. 2006 nomination Therefore the U. S. is requesting that and additional amount ( over the MBTOC recommended amount of 56.253 metric tons) of 12.865 metric tons by granted brining the sector total to 69.118 metric tons of methyl bromide.

Citations Arthur, F. H. 2000. Toxicity of diatomaceous earth to red flour beetles and confused flour beetles ( Coleoptera: Tenebrionidae): Effects of temperature and relative humidity. J. Econ. Entomol. 93( 2): 526 532.

Arthur, F. H. 1992. Cyfluthrin WP and EC formulations to control malathion resistant red flour beetles and confused flour beetles ( Coleoptera: Tenebrionidae): Effects of paint on residual activity. J. Entomol. Sci. 27( 4): 436 444.

Arthur, F. and T. W. Phillips. 2003. Stored product insect pest management an d control, In: Food Plant Sanitation eds: Y. H. Hui, B. L. Bruinsma, J. R. Gorham, W. Nip, P. S. Tong, and P. Ventresca. Marcel Dekker, Inc., New York, pp. 341 358.

Bell, C. H. 2000. Fumigation in the 21st century. Crop Protection 19: 563 569.

Cox, P. D. 2004. Potential for using semiochemicals to protect stored products from insect infestation. J Stored Prod. Res. 40: 1 25.

Dowdy, A K.& P. G. Fields. 2002. Heat combined with diatomaceous earth to control the confused flour beetle ( Coleoptera: Tenebrionidae) in a flour mill. J Stored Prod. Res. 38: 11 22.

Dunkel, F. V. and L. J. Sears. 1998. Fumigant properties of physical preparations from Mountain big sagebrush, Artemisia tridentate Nutt. ssp. vaseyana ( Rydb.) Beetle for stored grain insects. J. Stored Prod. Res. 34( 4): 307 321. Page 38 Fields, P. and N. D. G. White. 2002. Alternatives to methyl bromide treatments for storedproduct and quarantine insects. Annual Review of Entomology 47: 331 59.

Hou, X., P. Fields, and W. Taylor. 2004. The effect of repellents on penetration into packaging by stored product insects. J Stored Prod. Res. 40: 47 54.

Mahroof, R., Subramanyam, B. and Eustace, D. 2003. Temperature and relative humidity profiles during heat treatment of mills and its efficacy against Tribolium castaneum ( Herbst) life stages. J. Stored Prod. Res. 39: 555 569.

Mahroof, R., B. Subramanyam, J. E. Throne, and A. Menon. 2003. Time mortality relationships for Tribolium castaneum ( Coleoptera: Tenebrionidae) life stages exposed to elevated temperatures. J. Econ. Entomol. 96( 4): 1345 1351.

Mueller, D. K. 1998. Stored product protection  a period of transition. Insects Limited, Inc., Indianapolis, IN. 337 pp.

Nielsen, P. S. 1998. The effect of a diatomaceous earth formulation on the larvae of Ephestia kuehniella Zeller. J Stored Prod. Res 34: 113 121.

Oberlander, H., D. L. Silhacek, E. Shaaya, and I. Ishaaya. 1997. Current status and future perspectives of the use of insect growth regulators for the control of stored product insects. J Stored Prod. Res. 33: 1 6.

Skovgard, H., N. Holst, and P. S. Nielsen. 1999. Simulation model of the Mediterranean flour moth ( Lepidoptera: Pyralidae) in Danish flour mills. Environ. Entomol. 28( 6): 1060 1066.

UNEP. 1998. 1998 Assessment of alternatives to methyl bromide. United Nations Publication.

UNEP. 2001. Sourcebook of Technologies for protecting the ozone layer: alternatives to methyl bromide. United Nations Publication Zettler, J. L. 1991. Pesticide resistance in Tribolium castaneum and T. confusum ( Coleoptera: Tenebrionidae) form flour mills in the United States. J. Econ. Entomol. 84( 3): 763 767.

Zettler, J. L. and F. H. Arthur. 2000. Chemical control of stored product insects with fumigants and residual treatments. Crop Protection 19: 577 582.


[Federal Register Volume 86, Number 223 (Tuesday, November 23, 2021)]
[Notices]
[Page 66615]
[FR Doc No: 2021-25541]

-----------------------------------------------------------------------

DEPARTMENT OF TRANSPORTATION

Federal Aviation Administration

Notice of Availability, Notice of Public Comment Period, Notice
of Public Meeting, and Request for Comment on the Draft Environmental
Assessment for the Huntsville International Airport Reentry Site
Operator License and Sierra Space Corporation Vehicle Operator License

AGENCY: Federal Aviation Administration (FAA), Department of
Transportation (DOT).

ACTION: Notice of availability, notice of public comment period, notice
of public meeting, and request for comment.

-----------------------------------------------------------------------

SUMMARY: In accordance with the National Environmental Policy Act of
1969, as amended (NEPA), Council on Environmental Quality NEPA
implementing regulations, and FAA Order 1050.1F, Environmental Impacts:
Policies and Procedures, the FAA is announcing the availability of and
requesting comment on the Draft Environmental Assessment for the
Huntsville International Airport Reentry Site Operator License and
Sierra Space Corporation Vehicle Operator License (Draft EA).

DATES: Comments must be received on or before December 22, 2021. The
FAA will hold a public meeting on December 9, 2021 at 5 p.m. central to
solicit comments from the public concerning the scope and content of
the Draft EA. Information for the meeting will be available at https://www.faa.gov/space/stakeholder_engagement/huntsville_reentry/.

ADDRESSES: Comments should be mailed to Ms. Stacey Zee, Huntsville
Reentry, c/o ICF, 9300 Lee Highway, Fairfax, VA 22031. Comments may
also be submitted by email to [email protected].

FOR FURTHER INFORMATION CONTACT: Stacey Zee, Environmental Protection
Specialist, Federal Aviation Administration, 800 Independence Avenue
SW, Suite 325, Washington, DC 20591; phone<PHONE_NUMBER> (Stacey);
email [email protected]

SUPPLEMENTARY INFORMATION: The FAA is the lead agency. The National
Aeronautics and Space Administration (NASA) and United States Coast
Guard (USGC) are cooperating agencies for the Draft Environmental
Assessment for the Huntsville International Airport Reentry Site
Operator License and Sierra Space Corporation Vehicle Operator License
due to their special expertise and jurisdictions. The FAA is evaluating
(1) Huntsville-Madison County Airport Authority's (Authority) proposal
to operate a commercial reentry site at Huntsville International
Airport, which would require the FAA to issue a Reentry Site Operator
License, and (2) Sierra Space Corporation's (Sierra Space) proposal to
land the Dream Chaser at Huntsville International Airport, which would
require the FAA to issue a Vehicle Operator License. Issuing a Reentry
Site Operator License and Vehicle Operator License are considered
Federal actions subject to environmental review under NEPA. Under the
Proposed Action, the FAA would issue a Reentry Site Operator License to
the Authority to operate a commercial reentry site at Huntsville
International Airport; the Reentry Site Operator License would allow
the Authority to offer Huntsville International Airport to Sierra Space
to conduct reentries of Dream Chaser vehicles in compliance with 14 CFR
part 433. Also under the Proposed Action, the FAA would issue a Vehicle
Operator License to Sierra Space to land the Dream Chaser at Huntsville
International Airport; the Vehicle Operator License would allow Sierra
Space to land Dream Chaser at Huntsville International Airport in
compliance with 14 CFR part 450.
    Alternatives under consideration include the Proposed Action and
the No Action Alternative. Under the No Action Alternative, the FAA
would not issue a Reentry Site Operator License to the Authority for
commercial reentries, nor would the FAA issue a Vehicle Operator
License to Sierra Space for landing the Dream Chaser at Huntsville
International Airport. Sierra Space's Dream Chaser reentry operations
would not occur and Huntsville International Airport would continue to
operate and serve forecast activity.
    The FAA has posted the Draft EA on the FAA Office of Commercial
Space Transportation website: https://www.faa.gov/space/stakeholder_engagement/huntsville_reentry/.
    The FAA encourages all interested parties to provide comments
concerning the scope and content of the Draft EA. Before including your
address, phone number, email address, or other personal identifying
information in your comment, be advised that your entire comment--
including your personal identifying information--may be made publicly
available at any time. While you can ask the FAA in your comment to
withhold from public review your personal identifying information, the
FAA cannot guarantee that we will be able to do so.

    Issued in Washington, DC, on November 19, 2021.
James R. Repcheck,
Manager, Safety Authorization Division.
[FR Doc. 2021-25541 Filed 11-22-21; 8:45 am]
BILLING CODE 4910-13-P