9.11 Methyl Bromide

The harmonization of the Clean Air Act with the Montreal Protocol requires that both the production and use of methyl bromide for non-critical or non-exempted uses be gradually phased out in the United States by 2005. The current regimen will require a 50 percent reduction in non-critical/non-exempt methyl bromide use by the end of calendar year 2000 with a complete phase-out by 2005. Developing countries such as Mexico and China will have until 2015 to complete phase-out. The Montreal Protocol also provides for a process for exemption from phase-out for agricultural quarantine and pre-shipment uses of methyl bromide.

Methyl bromide provides highly effective control for a broad spectrum of economically important pests on a wide range of food and non-food commodities. It provides rapid and complete control of pests, mostly within twenty-four hours of exposure, for fumigation of large and small quantities of material. When applied properly, it does not leave residues of any toxicological significance. The compound is widely used in agriculture as a soil fumigant, for post-harvest applications (including quarantine and stored agricultural commodities and durable products, such as, cotton timber and artifacts) and structural fumigation. It is active against a diverse variety of organisms at low concentration, including rodents, insects, mites, nematodes, fungi, weeds, bacteria, and viruses. Methyl bromide is often the preplant treatment of choice given its easy application and wide variety of uses.

The greatest use of methyl bromide is for soil fumigation during intensive production of high value crops, such as strawberries, tomatoes, cucumbers, peppers, melons, and eggplant. Methyl bromide is particularly important in quarantine treatments. It is effective against a large variety of indigenous and non-indigenous pests. Methyl bromide can easily and economically be applied to both small and large shipments; U.S. regulations require that a wide array of imported food and non-food commodities be fumigated with methyl bromide as a condition of entry. A number of commodities exported by the United States must be fumigated with methyl bromide in order to comply with the quarantine requirements of recipient countries. In addition, methyl bromide plays a critical role in the United States as the only practical emergency treatment to move commodities out of areas quarantined for outbreaks of exotic pest insects, such as, the Mediterranean fruit f fly.

Structural fumigation of food production and storage facilities, non-food facilities, transport vehicles are very reliant on methyl bromide for control of a large number of pests. It is used either on an entire structure or a significant portion of a structure. Fumigation is utilized whenever the infestation is so widespread that localized treatments may result in re-infestation or when the infestation is within the walls or other inaccessible areas

Failure to find an alternative to methyl bromide will cost billions of dollars in lost exports and increased cost of production in the United States. We must ensure that American farmers can continue to raise and market their crops. Adequate funding is needed for a research program to find and develop alternatives for methyl bromide. In addition, Congress must ensure that the EPA gives expedited treatment to a methyl bromide alternative during the registration process.

NASDA urges the U.S. EPA to work closely with USDA and the U.S. Congress to allow the continued use of critical use exemptions for agriculture. Many economically important uses of methyl bromide, such as quarantine and pre-shipment uses of methyl bromide do not have viable alternatives for use. It is in the best interest of all states and segments of the agricultural industry to find safe and environmentally sound alternatives to methyl bromide, but until those alternatives are available for use, critical use exemptions must be continued. Domestic policy issues and international consensus on environmental protection must be resolved so as not to put U.S. agriculture and trade at a competitive disadvantage.

As alternative fumigants are registered and existing fumigants go through reregistration, label amendments associated with calculating buffer zones, monitoring access to buffer zones by unprotected persons and other use restrictions though important must be functional and enforceable. Proposals to require written management plans may not be the best alternative for documenting compliance. Also, required "certification" programs administered by the registrant and approved by EPA will cause a variety of enforcement problems for states and therefore should undergo state review for accountability and enforceability.