M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Teung Chin, Ph.D USDA ARS, Office of Pest Management Policy National Plant Board National Meeting July 25 – 29, 2010 Report of the MBTOC-QPS on Quarantine and Pre-shipment uses of Methyl Bromide, Adapted

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva nts/oewg/30oewg/conf-presentations- sp.shtml Report of the MBTOC-QPS on Quarantine and Pre-shipment uses of Methyl Bromide, Adapted

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Latest (2008) consumption data Global consumption declines A5 increases Non-A5 decreases Methyl bromide QPS consumption Ozone Secretariat Data Centre May 2010

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva USA MB-QPS consumption reduces significantly to a level comparable with other Parties MB-QPS consumption in Non-A5 Parties Ozone Secretariat Data Centre May 2010

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva China MB-QPS consumption variable, trending upwards and significantly larger than other A5 Parties MB-QPS consumption in A5 Parties Ozone Secretariat Data Centre May 2010

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Asian region increasing significantly MB-QPS use in A5 Party regions...

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva The availability, market penetration, regulatory requirements and drivers for technically and economically feasible alternatives for the largest MB-consuming categories: 1.Sawn timber and wood packaging material (ISPM-15) 2.Grains and similar foodstuffs 3.Pre-plant soils uses 4.Logs Estimates of the amount of methyl bromide that could be replaced for these uses (update of Table 9.1 in 2009 QPSTF Report) Draft methodology that TEAP would use, if requested by the Parties, to assess the impact of any future restriction on the QPS use of methyl bromide Decision XXI/6: TEAP Report (Chapter 8)

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Technical feasibility Controls pests to an appropriate level of protection Logistically acceptable Does not reduce the marketability of the commodity Economic feasibility Net returns using the alternative are acceptable No significant market disruption Other factors Authorised by relevant protection agency Registered, when necessary and operating to the required level of protection Alternatives for MB-QPS

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Examples for sawn timber and wood packaging material (ISPM-15) QPS category Principle alternative technology Market Penetration Economic feasibility WPM (ISPM-15) HeatMany Parties including A5 Acceptable WPM (ISPM-15) Non-wood pallets Some PartiesAcceptable in some countries WPM (ISPM-15) Alternative fumigants NoneNot known Sawn timber Kiln driedMost Parties including A5 Acceptable, but some countries prefer green timber e.g., low grade construction wood

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Examples of alternatives for grains and similar foodstuffs (pre-shipment) Principle alternative technology Market Penetration Economic feasibility PhosphineAcceptable in all PartiesAcceptable Controlled atmospheres Limited mainly to some non-A5 Parties Acceptable Sulfuryl fluorideLimited mainly to some non-A5 Parties Acceptable IrradiationPoorExpensive infrastructure compared to other alternatives

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Examples of alternatives for pre-plant soil treatment Principle alternative technology Market Penetration Economic feasibility Fumigants, sometimes with inspection Acceptable in many countries In the USA, the alternative must meet certification standards and be accepted by regulatory authorities Acceptable SubstratesAcceptable in some countries depending on the market Acceptable, depending on the market SteamAcceptable in some countries depending on the market Acceptability depends on source, application method and the market conditions

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Examples of alternatives for logs Principle alternative technology Market Penetration Economic feasibility Alternative fumigants Some Parties including A5Acceptable Sawn timber (lumber) Many Parties including A5Only where there is a price insensitive demand for higher value products without alternative sources of supply DebarkingSome PartiesAcceptable when a component of an alternative system HeatSome Parties including A5Only for high-grade logs

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Alternatives... an illustrative view of how they were assessed See TEAP Progress Report, Pages 96 to120 for actual examples

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Methyl bromide for QPS estimated to be replaceable globally with currently available technologies... Party2007 data WPM (ISPM- 15) Grains and similar foodstuffs SoilsLogs QuarantineQPSQuarantine A5Use (tonnes) ,371 A5MB replaceable> 60%<10%30-70%0%10-20% Non-A5Use (tonnes) , Non-A5MB replaceable60-80%<10%>80% *About 50% 10-20%

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Methyl bromide for QPS estimated to be replaceable globally with currently available technologies... Total consumption estimated of four* categories = 6,225 tonnes 2007 (tonnes) MinimumMaximum QPSQ A5 + Non A5 (tonnes) 1, , QPS Min-Max (tonnes) 1,9372,943 Percent of total consumption of four* categories 1,937 / 6,225 = 31%2,943 / 6,225 = 47% *1. Sawn timber and wood packaging material (ISPM-15); 2. Grains & similar foodstuffs; 3. Soils; 4. Logs

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Methyl bromide for QPS estimated to be replaceable globally with currently available technologies...

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Soil uses categorised by a Party as “QPS” One Party classifies pre-plant soil fumigation with MB as “QPS” The use is for propagation material shipped across a County, State or Country border and requires official certification for plant health The Party reported for some sectors almost 1,500 tonnes of MB in 2005 to certify a wide range of propagation material e.g. strawberry runners, ornamental nursery plants, forest nurseries A further review by MBTOC of official Party information suggested this could now be higher than 1,500 tonnes These pre-plant, soil uses of MB by the Party target endemic, non-quarantine pests, rather than quarantine pests

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Soil uses categorised by a Party as “QPS” (continued) Other Parties have replaced methyl bromide for propagation material with alternatives, through the CUN process Alternatives are available and registered in the Party for use in specific locations and under specific conditions. As a result, MBTOC estimated 50% of these uses were replaceable In consideration of a Minority Report on data in Table 8-5, MBTOC will update and re-analyse its estimate if further data are provided by the Party in time for the September TEAP- MBTOC Final Report on Critical Use Nominations Further details in TEAP Report Vol 2 on pages 103 – 109 and

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Draft methodology to assess the impact of a potential restriction on MB-QPS – General principles … Phytosanitary treatments facilitate trade while minimising risk of introducing unwanted pests that can cause significant economic loss and environmental damage MB-QPS is used on entry by relatively few Parties to facilitate trade with many other Parties Trade flows are important and not easily replaced once disrupted An available alternative for MB-QPS is one that is registered and operating to an appropriate level of protection Bilateral agreements between Parties are needed for some pests, and can take many years to agree The potential to replace MB-QPS depends on pest-commodity circumstances, regulations, economics, product marketability, and other important factors

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Differentiate between the amount of MB-QPS used on import and exports Initially focus analysis on Parties that consume most of the MB- QPS (12-15 A5 and 5-6 Non-A5 Parties) Obtain updated QPS use data from Parties / NOUs Consider regulations or measures that require the use of MB- QPS, and potential to change the regulation(s) Focus on MB-QPS used for Quarantine, as Pre-shipment is considered easier to replace Examine economic feasibility in terms of net returns of an alternative under the proposed conditions of use Examine methods in some countries that have been used to phase out MB-QPS (success and failure examples) Draft methodology to assess the impact of a potential restriction on MB-QPS – Specific steps …

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Past and future work on QPS… YearTEAP/MBTOCReport contained information for the Parties on... Parties further action 2009QPS Task Force Report in response to Decision XX/6 (2008) -Quantities of MB used per category -Alternatives; Recovery and recycling -Regulations that affect MB-QPS -Barriers to alternatives -Opportunities for reduction -Unusual uses of MB-QPS -Where more information is needed Decision XXI/10 (2009) 2010MBTOC-QPS Report in response to Decision XXI/10 (2009) -Technical and economical feasibility, availability and market penetration of alternatives in four major categories -R&D on alternatives -Estimate of MB replaceable globally for the 4 categories (by A5/non-A5; by Q/PS) -Methods that could be used to assess the impact of a restriction on MB-QPS Decision in 2010 ? 2011 ?-Topics to be decidedTBD

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Draft methodology to assess the impact of a potential restriction on MB-QPS – Guidance from the Parties Has TEAP’s proposed draft methodology for the assessment of a potential restriction on MB-QPS included all the elements that are considered important by the Parties? MBTOC continues to need information from MB-QPS users e.g., quantity by commodity, as urged in Decision XI/13 Other sources of information are important for TEAP e.g., UNEP regional meetings, annual reporting, other communications to OzSec MBTOC would be pleased to meet with Parties during the OEWG-30 to receive feedback and further guidance on the proposed draft methodology

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Summary In detail on Page 40 – 41 The EU asked if the Parties in November, 2010 would adopt the MBTOC findings/recommendations for the 31 st meeting of the Open-Ended Working Group (OEWG) in June/July MBTOC will work with the IPPC, using MBTOC methodology to find: - (1) The technical and feasible alternatives for sawn timber and wood packaging material, grains and similar foodstuffs and logs and alternatives to pre-plant soil uses qualifying as quarantine measures (2) “the impact of the implementation of the alternatives referred to in the preceding paragraph (3) The impact of restricting the quantity of MeBr production and consumption for all QPS uses. (4) to request all Parties to gather the best possible data about sectors in which QPS MeBr is used and provide to the Ozone Secretariat by Jan EU Proposal UNEP/OzL.Pro.WG.1/30/CRP.3 –TFChin’s Slide

30th OEWG, Geneva Critical Use Nomination: Interim Recommendations June 2010, Geneva Switzerland  Adapted from MBTOC by Teung Chin, USDA ARS OPMP  Documents/oewg/30oewg/conf- presentations-sp.shtml June 2010

Trends in Total Amount (t) of MB Approved or Newly Nominated for Critical Uses from Overall, CUNs continue to fall. The EC, New Zealand and Switzerland have phased out for controlled uses; Next year, Israel will phase out all uses and Japan all soil uses. tonnes

Adjustments to CUE Amounts - Consideration of Stocks (Dec IX/6 1,bii) MB stocks (t) reported at end of: Australia0 0 Canada EC Israel0Not Reported Japan New Zealand2.8 0 USA10,417.03,122.0 Total10,592.73, MBTOC CUE recommendations not adjusted to account for stocks -Stocks reported by USA are over twice the annual US CUNs.

Trends in Total MB (tonnes*) Exempted (Requested) Amounts by Party *Numbers rounded to nearest tonne

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva MBTOC Soils 30 th OEWG - Geneva

Preplant Soil CUNs in 2011 and 2012 Preplant Uses CUN 2011 CUN 2012 * Cucurbits, Melons, WatermelonsIsrael (x2)Japan (x3), USA Forest nurseriesUSA Ginger (open field, protected)Japan (x2) Nurseries (fruit, nut, flower)USA Orchard replantUSA Ornamentals (open field, protected)Israel (x2)USA Peppers and eggplantIsraelJapan, USA TomatoesIsraelUSA Sweet potato transplantsUSA Strawberry fruitIsrael (x2)USA Strawberry runnersIsrael (x2)Australia, Canada, USA Israel and Japan (16 CUNs) - will not nominate in future

Outcome of CUN 2010 interim assessment for soil use for 2011/2012 (tonnes) Total Quantity approved in CUN09 for New quantity nominated for 2011 Interim Recommendation Not Recommended Quantity nominated for 2012 Interim Recommendation Not Recommended (*Figures rounded to nearest tonne)

CUN10 Recommendations for Preplant Soil Use by Party (t) Country CUNInterim Recommendation Australia6306 Canada55 Israel* Japan*216 USA

In 2009, Parties reduced the Australian CUN by 5.95 t based on a 17.5 g/m 2 dose rate. In 2010, Australia reported this rate was ineffective for their conditions and renominated 5.95 t for MBTOC recommends approval ( note: Methyl Iodide has no buffers in Japan or Australia – TFChin, USDA ARS OPMP ) Australia Supplementary CUN 5.95 t for Strawberry Runners in 2011

MB Preplant Soil Use: Issues and Progress in CUN 2010 For 2012, Australia (29.790t) and Canada (5.261 t) nominated the same amount as for 2011 for strawberry runners. Future reductions in MB CUNs depend on registration of MI/Pic, Pic100 or plug plants in substrates. Israel and Japan reduced nominated amounts by 20% and 4% respectively. US made significant reductions in many sectors (48%). Further reductions in some sectors difficult if new alternatives not registered (e.g., MI/Pic, DMDS).

Significant US Progress in CUN 2010 Substantial reductions were made in several large sectors, including tomatoes and orchard replants

The US nominated t in January 2010 and subsequently revised the CUN to t after the April MBTOC meeting. At the April meeting, MBTOC recommended a reduced amount of t based on the CUN and a detailed database from the California Strawberry Commission. MBTOC based its reduction on further uptake of MB/Pic formulations, 1,3-D/Pic and Pic alone. A new alternative, methyl iodide/Pic, may be registered in late 2010, which could reduce future CUNs. MBTOC requests an action plan to address future reductions. US Strawberry Fruit: Issues

The US continues to reclassify some preplant soil uses from CUNs to the QPS exemption that other Parties consider subject to phaseout (e.g., forest nurseries, caladiums, roses).  The US previously nominated some of these uses for CUNs and the list of the pathogens reported were not quarantine pests.  TEAP/MBTOC is concerned that these uses are not for quarantine pests and therefore may not qualify for the QPS exemption MBTOC urges Parties to decide under which circumstances preplant soil use for propagative material qualifies for QPS. Question Concerning QPS Soil Uses

MBTOC Structures and Commodities 30th OEWG - Geneva

2010 CUN Structures (4 CUNs) Food processing -- bakeries, pasta, cheese in storages, pet food facilities (Canada and US) Flour mills and cereal processing (Canada and US) Commodities (4 CUNs) Chestnuts (Japan) Dry cure pork in storages (US) Dried fruit, walnuts and dates (US) Rice (Australia)

2010 SC CUN Summary Australia rice 2012; Nominated t. Recommended t Registered alternatives are available for immediate adoption. Canada flour mills 2012; Nominated t. Recommended t. Reduction of 22% in 2011 and 50% since Will fumigate ~ 8 mills. SF still not registered for food contact. Canada pasta 2011; Nominated t, Recommended t Request for three facilities - one annual fumigation each. MB use in one facility not recommended - not gas tight. Heat treatment and SF are only alternatives for part of facilities.

2010 SC CUN Summary cont’d Japan chestnuts 2012; Nominated t. Recommended t MI registered. Farmer training and adoption could begin in 2011 US dried fruit, walnuts and dates 2012; Nominated t. Recommended t. - US reports that this sector has reached maximum adoption of alternatives, and that export walnuts that formerly used SF are now using QPS MB. - MBTOC identified registered alternatives for some uses. - Research hopes to resolve lack of efficacy with SF for dates. US food processing (NPMA) 2012 ; Nominated t. Not recommended. - The nomination failed to substantiate appropriate effort. Applicable studies or reports were not provided. The CUN claimed that trials had been conducted, but that reports would not be submitted.

2010 SC CUN cont’d US mills and processors 2012; Nominated t, Reduced to t 50% decrease in flour and rice milling. Only one flour mill study was submitted - no studies in rice mills or pet food establishments. No heat treatment trials were included. US cured pork 2012; Nominated 3.73 t, Recommended 3.73 t. No alternative registered for this use. A multi-state, multi-university research program is ongoing.

Problems Identified Progress has stalled for the majority of postharvest CUNs Further reductions in MB use for post harvest require; Regulatory approvals of alternatives Commitment to requiring the use of the alternatives that are available, Concerns about costs and the high GWP of SF are cited as barriers to adoption. The limited registration of SF for food contact prevents full adoption in mills and food processing facilities. In applications where heat treatment could be effective, delay in the registration of SF for food contact is used as a reason to continue the use of MB.

Problems continued In two CUNs, regulatory interpretation is cited as preventing the adoption of alternatives - sulfuryl fluoride for rice in Australia and sulfuryl fluoride use for dates in US. MBTOC believes the label covers these uses. Despite the return to normal profitability, there has been no adoption of alternatives for rice in Australia. Inadequate substantiation that identified alternatives are ineffective in replacing MB in the food processing facility sector.

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Two workers sickened in Long Beach after opening containers in cold storage PPQ is working with the registrant and EPA on monitoring studies Permissible reentry level may be reduced from 5 ppm to 1 ppm Capture technology will be on 2012 labels though not required EPA Concerns/ Issues

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Two fumigant operations in Virginia did not have state permits under the Clean Air Act. 25,000 lb threshold for MeBr Please check with your state for information on state permits. PPQ, OPMP and will work with NPMA and EPA. EPA Concerns/ Issues

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva The US delegation requests that NPB regularly participate in support of QPS uses including sending a representative to future meetings at the Dept. of State on QPS issues. (Next one in early-mid August).  Can NPB also provide additional data on state and local regulations for QPS uses and MeBr usage? (PCIT data only has federal data.) State and local use is estimated to be 85% of all QPS use. EPA will be contacting various fumigators for data. CUE and QPS Next Steps

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva APHIS PPQ has agreed to work with the IPPC for the MBTOC 2010 report APHIS PPQ is preparing a report on commodity treatment requirements by country and commodities. Benefits of MeBr and alternatives assessed. CUE and QPS Next Steps

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva 2013 Critical Use Exemption Application Forms (Due September 15, 2010) MBTOC Bi-Laterals on the interim decisions for CUN 2012 with California Strawberry Commission, Dried Fruits and Nuts, and Millers in early September, Monterey, CA (Per the TEAP Progress May 2010 Report Volume 2 EAP_Reports/teap-2010-progress-report-volume2-May2010.pdf New data are needed by early/mid-August for EPA to process for any Bi-Laterals. EAP_Reports/teap-2010-progress-report-volume2-May2010.pdf Let EPA know if other parties wish to hold bilaterals since the State Department must send a request letter. CUE and QPS Next Steps

M o n t r e a l P r o t o c o l O E W G - 30, J u ne 2010, Geneva Oct/Nov 2010 FR Notice - Will issue the proposed rule for 2011 CUEs - Will seek comments on whether CUE applications should continue after 2013  Next Meeting of the Parties in November 2010 to decide on the June OEWG proposals. Uganda or elsewhere. Stakeholder participation encouraged.  2011 MeBr labels will have all CUE crops listed.  EPA is considering to place all post-harvest commodities on 2012 labels. CUE and QPS Next Steps