Monday, November 23, 2009

2010 Methyl Bromide

The Environmental Protection Agency announced in today’s Federal Register their proposed allocations for the production and use of methyl bromide for 2010. The use and production of methyl bromide was supposed to have been completely phased out by 2005 under the Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol), as implemented by 40 CFR part 82, subpart A. Year-by-year extensions have been granted because of critical uses of methyl bromide as a fumigant/insecticide that have no reasonable substitute. This rule proposes to allocate the already approved amounts for use, production and import of methyl bromide for next year. While this is a serious issue strictly from an environmental point of view, it also has some implications for the chemical security community. Methyl bromide is an odorless, colorless, toxic gas. As such one would assume that it would be a DHS chemical of interest under CFATS, but one would be mistaken. It was removed from the list of proposed COI when the final version of Appendix A was published in November 2007 because methyl bromide and chloropicrin were being phased out under the Montreal Protocol. This current proposed rule would authorize (74 FR 61085) the use of 3,263 tons of methyl bromide in 2010 with production and or import of 759 tons being authorized. This, of course, implies that there is more than 2,500 tons of the material currently being stored in the United States. The rule also mentions authorizing continued usage of methyl bromide for 2011 is already being considered. As I have noted on previous occasions, it is probably time that DHS reconsiders its decision not to include methyl bromide and chloropicrin in their list of COI in Appendix A.

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