Wednesday, July 1, 2015

EPA Requests Methyl Bromide CUE Applications for 2018

Today the EPA published a notice in the Federal Register (80 FR 37611-37615) requesting that persons who would need to use methyl bromide as a fumigant in 2018 submit information to support the designation of that need as a Critical Use Exemption (CUE) to the Montreal Protocol on Substances that Deplete the Ozone Layer. This is an annual exercise in the continued justification of limited uses of methyl bromide as a fumigant.


Since 1995 the signatories of the Montreal Protocol have been trying to eliminate the use of methyl bromide as they had concluded that the release of methyl bromide to the atmosphere was one of the contributing factors in the observed depletion of the ozone layer. The signatories realize, however, that methyl bromide is a very effective fumigant, and for a number of particular application (particularly protecting strawberry fields, see this C&EN article). With that in mind they authorize the use, and limited production to support that use, for applications where there is not currently an effective substitute.

Each year the EPA will request CUE applications, review those applications and prepare a nation CUE application for submission to the United Nations Environment Programme Ozone Secretariat. Last year the UNEPOS approved the following CUE’s for 2016 (in metric tons):

2016 CUE Approvals

In previous years the EPA and UNEPOS had considered the following uses for methyl bromide to be uses that would justify a critical use exemption:
Commodities such as dried fruit and nuts;
Dried cured pork;
Cucurbits, eggplant, pepper, and tomato;
Strawberry fruit;
Orchard replant;
Nurseries; and
Golf courses

On-going research programs have developed acceptable alternatives to methyl bromide for most of those applications. For the last couple of years the only CUEs approved have been for strawberries and cured pork. Last year the EPA did not submit a critical use nomination (CUN) for strawberry fields when they completed the submission process for 2017.

Application Process

Information that the EPA is requesting to support a CUE applications can be found in the Montreal Protocol's Technical and Economic Assessment Panel (TEAP) Handbook. Applications must be submitted by September 15th, 2015 so that the EPA can finalize their CUN application.


The C&EN article I reference earlier made a closing comment that “the exemptions will end completely after 2016”. This reflects the fact that the EPA did not submit a CUN last year (see page 10 Evaluation of 2015 Critical Use Nominations for Methyl Bromide - .DOC Download) for 2017 CUE’s. According to the notice it appears that the dried cured pork application is the only one for which the EPA is currently considering a CUN submission.

CUE applications are being accepted for the other methyl bromide applications, but it would appear that a much higher standard of need will be needed to overcome the EPA’s conclusion that viable alternatives for methyl bromide do exist.

I am not an agricultural chemist and I certainly do not have the information necessary to evaluate whether or not there are viable alternatives to methyl bromide for pre-planting fumigation of strawberry fields. My concern in this blog with methyl bromide has mainly been with its potential use (as a toxic inhalation hazard chemical) as terrorist weapon.

I have been lambasting DHS for their removing the methyl bromide from the proposed list of DHS chemicals of interest (COI) when the list was finalized in 2007. Based upon the continued use of methyl bromide as a fumigant I have obsessively recommended that DHS add the chemical to the COI list at the soonest opportunity.

With the small amount of methyl bromide that will be used on dried cured pork (3.2 metric tons approved for use in 2016), I think that my obsession should be allowed to die. I will continue to monitor methyl bromide use and abuse, but David Wulf, Director of ISCD, will no longer have to cringe when I write a blog post about the chemical.

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