Form 5900-137 Application for Critical Use Exemption of Methyl Bromide

OMB Control #2060-0170
Expiration Date: 4/16/2023

For EPA Use Only ID # _______
SECTOR ___________________

UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Application for Critical Use Exemption of Methyl Bromide
for Post Harvest Use in the United States

WHY IS THIS
INFORMATION
NEEDED?

Under the Clean Air Act and the international treaty to protect
the ozone layer (the Montreal Protocol on Substances that
Deplete the Ozone Layer), the production and import of methyl
bromide was phased out in the United States on January 1,
2005. This application seeks information to support a U.S.
request to produce and import methyl bromide for certain critical
uses and circumstances beyond this 2005 phaseout date.
The information in this application will be used to review
whether your use of methyl bromide is "critical" because no
technically and economically feasible alternatives are available.
In order to estimate the loss as a result of not having methyl
bromide available, EPA needs to compare data (commodity
prices, revenues, and costs) for your use of methyl bromide with
uses of alternative pest control regimens.

The information contained in this application is critical to process and assess the need for
methyl bromide. Filling out this application in its entirety will bolster the U.S. government's
ability to strengthen the nomination package for the international review boards.
This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB
Control No. 2060-0170). Responses to this collection of information are mandatory (40 CFR 82.13). An agency may not
conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid
OMB control number. The number and expiration date are displayed in the upper right corner of the form. The public
reporting and recordkeeping burden for this collection of information is estimated to be 38 hours per response. Send
comments on the Agency’s need this formation, the accuracy of the provided burden estimates and any suggested methods
for minimizing respondent burden including through the use of automated collection techniques to the Director, Regulatory
Support Division, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.
Include the OMB control number in any correspondence. Do not send the completed form to this address.

EPA Form # 5900-137

Post-harvest

INSTRUCTIONS
The information provided by you in this application will be used to evaluate the requested methyl bromide use. The
U.S. and other countries that are parties to the Montreal Protocol On Substances That Deplete The Ozone Layer
decided that: "a use of methyl bromide should qualify as "critical" only if the nominating Party determines that:
(i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a
significant market disruption; and
(ii) There are no technically and economically feasible alternatives available to the user that are acceptable from
the standpoint of environment and health and are suitable to the crops and circumstances of the nomination …"

WHO
APPLIES?

If you anticipate that you will need methyl bromide because you believe there are no
technically and economically feasible alternatives, then you should apply for the critical use
exemption. This application may be submitted either by a consortium representing multiple
users or by individual users. We encourage users with similar circumstances of use to
submit a single application (for example, any number of post harvest users with similar
commodity, pest, and structural conditions can submit a single application.)
If a consortium is applying for multiple methyl bromide users, the economic data should be for
a representative or typical user within the consortium unless otherwise noted. If economic or
technical factors (such as types of commodities) affecting the ability of this "representative
user" to use alternatives are significantly different than other users in the consortium, more
than one application should be submitted to reflect these differences.
Please contact your local, state, regional, or national commodity association and/or state
representative agency to find out if they plan on submitting an application on behalf of your
commodity group.

WHAT
INFORMATION IS
REQUIRED?

Critical use exemptions are valid for only one year and do not renew automatically. Users
desiring to obtain an exemption must apply annually to EPA. Because of the latest changes
in registrations, costs, and economic aspects for producing critical use crops and
commodities, all applicants will be required to fill out the application form completely.
If these Worksheets are not submitted, EPA will not include the application in the U.S.
nomination submitted for international consideration.

HOW DO
I APPLY?

You may either complete an electronic (Microsoft Word or Excel) or a printed version of the
application. Please fill out each section in the application as completely as possible. If you are
completing the printed version and need extra space you may attach additional sheets as
needed.

IS MY
INFORMATION
CONFIDENTIAL?

The applicant may assert a business confidentiality claim covering part or all of the
information in the application by placing on (or attaching to) the information, at the time it is
submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form of notice
employing language such as trade secret, proprietary, or company confidential. Allegedly
confidential portions of otherwise non-confidential documents should be clearly identified by
the applicant, and may be submitted separately to facilitate identification and handling by
EPA. If the applicant desires confidential treatment only until a certain date or until the
occurrence of a certain event, the notice should so state. Information covered by a claim of
confidentiality will be disclosed by EPA only to the extent, and by means of the procedures
set forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no
claim of confidentiality accompanies the information when it is received by EPA, it may be
made available to the public by EPA without further notice to the applicant.
Applicants submitting their application via e-mail assume responsibility for the confidentiality
of the electronic message transmission.

WHEN IS THE
INFORMATION
NEEDED?

EPA Form # 5900-137

This application must be postmarked to the EPA address below no later than September 15.

Post-harvest

Electronic address for applications: [email protected]
When submitting an application electronically, you should also sign Worksheet 1
and email or fax it to 202-343-2338

WHERE DO I
SUBMIT THE
APPLICATION?

HOW CAN I
RECEIVE
ADDITIONAL
INFORMATION?

EPA Form # 5900-137

Mailing address for applications
being submitted by mail directly to
the EPA:

Address for applications being sent by
courier or non-U.S. Postal overnight
express delivery to the EPA:

US Environmental Protection Agency
Methyl Bromide Critical Use Exemption
Office of Air and Radiation
Stratospheric Protection Division
(6205T)
1200 Pennsylvania Ave, NW
Washington, DC 20460

US Environmental Protection Agency
Methyl Bromide Critical Use Exemption
Office of Air and Radiation
Stratospheric Protection Division
1201 Constitution Ave, NW
Room 4355TT
Washington, DC 20004

For general questions about this application:
Stratospheric Ozone Information Inbox at [email protected]
More information is also at http://www.epa.gov/ozone/mbr

Post-harvest

WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST
INFORMATION
The following information will be used to determine the amount of methyl bromide requested and the
contact person for this request. It is important that we know whom to contact in case we need additional
information during the review of the application.
Is this information Confidential Business Information:
Yes ___
No ___
If yes, the applicant assumes responsibility for the secure transmission of electronic submissions.
Applicant Name:
Primary Contact:
Contact Name:
Address:
Daytime Phone:
Cell:
Fax:
Email Address:
Specialty: (check one) Agronomic ___
Alternate Contact:
Contact Name:
Address:
Daytime Phone:
Cell:
Fax:
Email Address:
Specialty: (check one) Agronomic ___

Economic ___

Economic ___

I certify that all information contained in this document is factual to the best of my knowledge.
Signature: ______________________________________________

Date: _______

Print Name: _____________________________________________

Title: _______

Information in this application may be aggregated with information from other applications and used by
the United States government to justify claims in the national nomination package that a particular use of
methyl bromide be considered "critical" and authorized for an exemption beyond the 2005 phaseout. By
signing below, you agree now to assert any claim of confidentiality that would affect the disclosure by
EPA of aggregate information based in part on information contained in this application.
Signature: ______________________________________________

Date: _______

Print Name: _____________________________________________

Title: _______

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or
disclose or provide information to or for a Federal agency. This includes the time needed to review instructions;
develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and providing information; adjust the existing
ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond
to a collection of information; search data sources; complete and review the collection of information; and transmit or
otherwise disclose the information. Public reporting burden for this collection of information is estimated to average
38 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many
individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond
to, a collection of information unless it displays a current OMB control number.

EPA Form # 5900-137

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WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST
INFORMATION (continued)
1. Location of Facility(ies): Enter the name and physical address of the facility(ies) where the proposed
critical use of methyl bromide will take place. Provide more details about the location if relevant to the
feasibility of alternatives to methyl bromide.

2. Commodity: Include all commodities that benefit from the application of methyl bromide in a
fumigation cycle.

3. Range of structure/facility size by processors included in this application: Insert number or
percentage of users in each category.
0 to 1,000 (1,000 cu ft)
10,000 to 50,000 (1,000 cu ft)
1,000 to 5,000 (1,000 cu ft)
50,000 to 100,000 (1,000 cu ft)
5,000 to 10,000 (1,000 cu ft)
over 100,000 (1,000 cu ft)
4. Climate Average Minimum Temperature: Individual users should enter their climate zone designation
by reviewing the U.S. climate zone map located at the end of this workbook or it can be reviewed online
at http://planthardiness.ars.usda.gov/PHZMWeb. If a consortium is submitting this application, please
indicate the estimated percentage of consortium users in each climate zone. Please check all that apply.
1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b____ 7a____
7b____ 8a____ 8b____ 9a____ 9b ____ 10a____ 10b____ 11a____ 11b____
5. Is this applicant eligible for Quarantine and Preshipment (QPS) uses of methyl bromide:
Yes ___
No ___
If yes, indicate amount: ____ lbs
6. Has this applicant previously applied for Critical Use Exemption of methyl bromide:
Yes ___
No ___
If yes, indicate CUE #: ________
7. What is the amount of methyl bromide being requested by this application: (Do NOT include
QPS amounts) If a consortium is submitting this application, the data should be the total for the
consortium.
Year:______
Year:______
Total Pounds Active Ingredient (a.i.) of Methyl
A.
Bromide
B.

Total Actual Volume (1000 cu. ft.) Treated

C.

Formulation (Ratio of MB/Pic) to be Used for
the CUE

D.

Use Rate (lbs a.i./1000 cu. ft.)

8. Please explain why there may be variations in the pounds or volume (1,000 cu ft) treated from
year to year, especially if the request is higher this year than in previous years:

9. Please explain why methyl bromide is being requested:

EPA Form # 5900-137

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10. Do you anticipate that you will have any methyl bromide in storage?
Yes ___
No ___
If yes, please specify amount: _______ lbs
11. Have you adjusted the request for the following issues:
Regulatory Issues:
Yes ___No ___
Pest Pressure:
Yes ___No ___
Adoption of Alternatives: Yes ___No ___
Other (Please Explain): Yes ___No ___
_______________________________________________________________________

EPA Form # 5900-137

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WORKSHEET 2: METHYL BROMIDE
Purpose of Data: To establish a baseline estimate of commodity treated, gross profits, and costs using
methyl bromide.
Instructions specific to each worksheet are located at the top of each sheet.
Worksheet
2-A

Title
Methyl Bromide - Pest and Commodity Information
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
The purpose of this worksheet is to determine pest infestation and commodity
information where methyl bromide is used. This forms the baseline for evaluating the
impacts of using an alternative to replace methyl bromide.

2-B

Methyl Bromide - Historical Use
If a consortium is submitting this application, all data should reflect the actual data for
the consortium.
This worksheet provides data in actual usage for the last five years.

2-C

Methyl Bromide - Commodity Treated and Gross Profits
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
This worksheet provides commodity treated and gross profits for the last five years.
The purpose of this worksheet is to determine past gross profits when methyl bromide is
used. This forms the baseline for evaluating the revenue impacts of using an alternative
to replace methyl bromide.

2-D

Baseline - Operating Costs
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
This data is needed to estimate a baseline for operating costs in order to estimate
changes in costs and the impact on operating profit and short-run economic viability as
a result of not using methyl bromide.
The purpose of this worksheet is to determine operating expenses when methyl bromide
is used. This forms the baseline for evaluating the cost impacts of using an alternative to
replace methyl bromide. The data requested are designed to help you identify how your
operation would change if methyl bromide were unavailable, which will be shown in
Worksheet 3-B.

EPA Form # 5900-137

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WORKSHEET 2-A: METHYL BROMIDE – PEST & PROCESSING
INFORMATION
1. Commodity or Consortium:

2. What month does your fumigation cycle start: Please check only one.
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sept

Oct

Nov

Dec

3. Fumigation Timeline: Indicate when fumigation, major commodity and pest management practices
typically occur. If the fumigation cycle is longer than one year, change the months to an appropriate
interval.
Time Interval ______________________
Beginning Fumigation Cycle
(e.g. WEEKS/MONTH/YEAR/SEASON)
(please define time periods)
Facility Preparation
Sealing
Cleaning
Fumigation Timeline
Reception of Raw Materials
Processing
Storage
Raw Materials
Finished Product
Packing
Shipping
Retail Market Window
Other Pest Treatments
Other

4. Please provide a simplified schematic diagram which illustrates the basic steps of the
commodity moving through the process from raw material to finished product:

4a. Provide a narrative of market channel for each commodity, where it is fumigated, and how the
fumigation effects market availability and commodity sale:

EPA Form # 5900-137

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5. Target Pest(s) or Pest Problem(s): Please identify the key target pests or pest problems for which
methyl bromide is requested. Provide at least common name and genus and species if possible.
Additional pests or pest problems can be provided as an attachment. Please also explain the specific
reasons why methyl bromide is being requested for each pest [e.g., effective herbicide is available, but
not registered for this crop; mandatory requirement to meet certification for disease tolerance].
Common Name

Genus

Specific Reasons Why Methyl Bromide Is Needed

Pest 1
Pest 2
Pest 3
Pest 4
Pest 5
6. Pest Economic Threshold: Please provide the economic threshold information for each pest.
Describe year and source of information such as survey or expert estimate.
Units (e.g.
Threshold
Year
Source
pests/sq ft)
Pest 1
Pest 2
Pest 3
Pest 4
Pest 5
7. Target Pest Infestation: Please estimate the percentage of this user's total structural/facility volume
with a moderate to severe problem with these pests. Describe source of information such as a survey or
expert estimate.
Percentage of Total
Source
Structure/Facility
Pest 1
Pest 2
Pest 3

%
%
%

8. Representative User: Please provide descriptive factors appropriate for your operation.
a. Number of Facilities: _____
b. Gastightness Estimate (if available):* _________
* Give gastightness estimates where possible according to the following scale: good - less than 25% gas loss within 24 hours or half
loss time of pressure difference greater than 1 minute; medium - 25-50% gas loss within 24 hours or half loss time of pressure
difference greater than 10 seconds; poor - 50-90% gas loss within 24 hours or half loss time of pressure difference 1-10 second;
very poor - more than 90% gas loss within 24 hours or a pressure half loss time of less than 1 second.

9. In what part and phase of the operation does the methyl bromide fumigation take place: Please
check all that apply and indicate exposure time.
Structure / Facility: _________
Fumigation Chamber: _________
Commodity: _________
Prior to Storage: _________
Storage: _________
Prior to Shipping: _________
All: _________
Other: _________

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10. For what percentage of the operation have alternative(s) replaced methyl bromide in
processing this commodity and if so, during what phase of the process:
Alternative

% Replaced

Phase of
Process

Details

Phosphine (Alone)
Heat Treatment
Phosphine in Combination
Sulfuryl Fluoride
Other
11. Please provide a brief description of any equipment fumigated in this operation:

EPA Form # 5900-137

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WORKSHEET 2-B: METHYL BROMIDE – HISTORICAL USE
Row A:

Year

Row B:

Enter dates for the last five years. For example, for applications filled out in 2015, provide data
from 2010-2014.
Total Actual Pounds a.i. of Methyl Bromide Applied

Row C:

Enter the total actual pounds active ingredient (a.i.) of methyl bromide applied. Note: This
number should be the total pounds a.i. applied by the individual user or the entire consortium,
for the year indicated. Include only the pounds active ingredient of methyl bromide.
Total Actual Volume (1,000 cu ft) Treated

Row D:

Enter the total actual volume (1,000 cu ft) treated. Note: This number should be the total actual
volume (1,000 cu ft) treated by the individual user or total actual volume (1,000 cu ft) treated
for the entire consortium, for the year indicated.
Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE
Enter the formulation of methyl bromide used (e.g. MB 98:2; MB/Pic 70:30).

Row: E

Use Rate (lbs a.i./1000 cu. ft.)
Enter the use rate in pounds a.i. of methyl bromide per area.

A.
B.
C.

Year
Total Actual Pounds a.i. of Methyl
Bromide Applied
Total Actual Volume (1,000 cu ft)
Treated

D.

Formulation (Ratio of MB/Pic
Mixture) to be Used for the CUE

E.

Use Rate (lbs a.i./1000 cu. ft.)

What is the frequency of methyl bromide applied per volume (1,000 cu ft): (1x / year, 2x / year, 1x / 3
years, etc.)
_______ times per _______
If there is a variation (greater than 10%) in the quantity a.i., the acres treated or average
application rate from year to year, please explain the reasons for the variation:

Comments:

EPA Form # 5900-137

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WORKSHEET 2-C: BASELINE – METHYL BROMIDE – COMMODITY
TREATED & GROSS PROFIT
Column A:

Year
Be sure to enter the year. Use as many rows as needed for each year for all the commodities in the
fumigation cycles for the last five years. If a fumigation cycle overlaps more than one calendar year, then
the year of the fumigation cycle is the year methyl bromide was applied.

Column B:

Commodity
Enter all commodities that benefit from methyl bromide in the fumigation cycle (interval between
fumigations). See the Definitions page for a comprehensive definition of the fumigation cycle.
If someone other than the applicant benefits from the application of methyl bromide in the fumigation
cycle and you do not have the quantitative data for the commodity treated in the same facility/structure,
please indicate so in the comments section below.

Column C:

Market Categories
Enter marketing categories that determine prices received, for example, grade (quality, taste, color) or
timeliness (holiday market season, early season, late season). Itemize or aggregate these factors to the
extent appropriate if lack of methyl bromide would affect the price in each category.

Column D:

Column E:
Column F:

Unit of Commodity
Enter the unit of measurement for each commodity (lbs, tons, cwt). If not by weight, specify in the
comments section the average weight of the measure. For the international review board, all measures
will be converted to metric.
Total Commodity Treated
Enter the total units of commodity treated with methyl bromide and processed/sold per area.
Price
Enter average prices received by the users for that commodity and category. For the total line, you do not
have to enter a price. Average price over all categories can be calculated separately, if needed. If a
commodity treated is never owned by the facility, indicate the fees charged for all services.

Column G:

Cost of Goods Sold
Enter the total cost of goods sold (raw materials purchased) during the period. If this expense is not
relevant to your post-harvesting operation, please skip this column.

Column H:

A

Year

Gross Profit
Gross profit may be calculated using the data you entered as the Total Commodity Treated times Price
minus the Cost of Goods Sold. If gross profit is not equal to total commodity sold times price subtracted
by cost of goods sold ((Column E * Column F) - Column G), you may override the formula and enter a
different revenue amount. Please explain why this gross profit amount is different in the comment section
below.

B

C

D

E

F

G

H

Commodity

Market
Category
(grade,
time, end
use)

Unit of
Commodity
(e.g., lbs,
tons)

Total
Commodity
Treated
(per unit of
commodity)

Price
(per unit of
commodity)

Cost of
Goods Sold
(per unit of
commodity)

Gross
Profit
(per unit of
commodity)

Comments:

EPA Form # 5900-137

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WORKSHEET 2-D: METHYL BROMIDE – OPERATING COSTS
The purpose of this section is to determine operating expenses when methyl bromide is used. This forms
the baseline for evaluating the cost impacts of using an alternative to replace methyl bromide. The data
requested are designed to help you identify how your operation would change if methyl bromide were
unavailable, which will be shown in Worksheet 3-B. Please fill in the unshaded areas. The shaded
areas can be used if the information is known.
Column A:

Operating Expense Items

Column B:

Identify the operations to which the costs apply. You may add or delete lines as necessary. The
operating expense items listed here are not meant to be exhaustive or be representative of your
specific operating system. Other operating expenses include, but are not limited to, wage/salary,
advertising and selling, utilities, rent and lease, insurance, and supplies. Be as precise as necessary
to explain how lack of methyl bromide would affect your operation, otherwise you may aggregate
operating expenses. These are meant to provide suggestions and to help you identify how your
operation would change if methyl bromide were unavailable.
Quantity Used per Volume (1,000 cu ft) or Weight (short tons)
This field is required only for methyl bromide. However you may include specific amounts of other
inputs or operations if you believe it helps to document the additional costs you would incur by using
an alternative fumigant.

Column C:

Units (lbs. hours, etc.)
For all inputs and operations detailed in Column B, please specify the units of measurement.

Column D:

Unit Cost ($)
For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all
costs of applying methyl bromide, including any material costs (e.g. tarps). If custom applied and
separate costs are unavailable, write 'custom' and enter total cost in Column E.

Column E:

Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (short tons)
Enter all appropriate costs of operations per volume (1,000 cu ft) or weight (short tons). You may add
or delete lines as necessary.
If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A

B

C

D

E

Operating Expense Items

Quantity Used per
Volume (1,000 cu.
ft.) or Weight (short
tons)

Units
(lbs.,
hours,
etc.)

Unit
Cost
($)

Cost ($) per Volume
(1,000 cu. ft.) or Cost
($) per Weight (short
tons)

1. Pest Management Costs (a+b+c+d)
a) Sanitation
b) Pest Control
c) Methyl Bromide Fumigation (c1+c2)
c1) Product
c2) Application
d) Other Pest Management Costs
2. Repairs / Maintenance / Replacement
3. Interest
4. Depreciation for Plant Assets
5. Other Operating Expenses

TOTAL OPERATING COST

EPA Form # 5900-137

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WORKSHEET 3: ALTERNATIVES – FEASIBILITY OF ALTERNATIVE
PEST CONTROL REGIMENS
Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs to
compare data (commodity prices, gross profit, operating expenses, etc.) on the use of methyl bromide
and alternative pest control regimens.
Complete Worksheet 3-A for each alternative pest control regimen. Please indicate the name of the
specific alternative pest control regimen addressed and add additional pages as required.
Enter all alternative pesticides and pest control methods (and associated cost and yield data) that would
replace one treatment of methyl bromide throughout the fumigation cycle. See the Definitions page for a
comprehensive definition on fumigation cycles.
Worksheet
3-A

Title
Alternatives - Technical Feasibility of Alternatives to Methyl Bromide
You must complete one worksheet for each alternative. Please insert the name of the
alternative in the area on top of the page. If you prefer, you may provide the information
requested in this worksheet in a narrative review. However, you must fill in the information in
Question #1 or we will assume no production or quality loss.

3-B

Alternatives - Changes in Operating Costs
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
This data is needed to estimate a baseline for operating costs in order to estimate changes
in costs and the impact on operating profit and short-run economic viability as a result of
not using methyl bromide and to provide required information to the international review
board.
Please fill out this worksheet for each alternative for which the economic evaluation
would bolster the case that methyl bromide is needed.
The purpose of this worksheet is to determine operating expenses when alternatives are
used for evaluating the cost impacts of using an alternative to replace methyl bromide. The
data requested are designed to help you identify how your operation would change if methyl
bromide were unavailable.

3-C

Alternatives - Economic Feasibility of Alternatives to Methyl Bromide
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
Please include in this worksheet data for each alternative included in worksheets 3-A
and 3-B.

EPA Form # 5900-137

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WORKSHEET 3-A: ALTERNATIVES – FEASIBILITY OF ALTERNATIVE PEST CONTROL
REGIMENS
Name of Alternative:
1. Pest Control When Comparing This Alternative to Methyl Bromide: Provide numerical estimates where possible.
Study #

Pest Being Tested

Relative % Pest
Control

Scale of Study (e.g.
pilot, plot)

Resulting Damages (please
specify)

1
2
3
4
5
2. Study Information: For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is
attached and if it is on the EPA website.
Month/Year project started and
Study #
Copy?
EPA?
finished (e.g. Nov '09 - Oct '12)
Details
1
2
3
4
5
3. Are there any production delays (downtime) associated with this alternative?
Yes ___
No ___
If yes, please continue with 3a, 3b, 3c.
3a. Please specify the number of days per year of downtime: _________ days/year
3b. What is the cost of production delays or downtime per year? $ _________ per year
3c. Please explain the details of going into downtime and why it is necessary with this alternative:

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4. What is the estimated probability of the commodity not meeting consumer quality standards
with and without methyl bromide or alternative treatments: Please explain.

5. Restrictions/Limitations on Alternative Use: This information will be used to determine the amount
of methyl bromide needed.
% of
Structure/Facility/Volume

Details

Regulatory Restriction
- Label Restriction
Climate Restriction
Pest Resistant To Alternative
Structural Limitations
Facility Limitations
Other Restrictions/Limitations (Describe)

6. Why is this alternative not suitable to replace 100% of methyl bromide use in processing this
commodity:

7. Use Rate of Chemical Alternative:
Active Ingredient
(a.i.)

Name of Product and
Formulation

Quantity per
Volume
(1,000 cu ft)

Units
(gals, lbs,
etc.)

Volume
(1,000 cu ft)
Treated

# of
Applications
per Year

8. Non-Chemical Pest Control: Please describe.

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9. Fumigation Timeline: Indicate when fumigation, major commodity and pest management practices
typically occur. If the fumigation cycle is longer than one year, change the months to an appropriate
interval.
Fumigation Cycle
Time Interval (e.g. WEEKS/MONTH/YEAR)
1
2
3
4
5
6
7
8
9
10
11
Facility Preparation
Sealing
Cleaning
Fumigation Timeline
Reception of Raw Materials
Processing
Storage
Raw Materials
Finished Product
Packing
Shipping
Retail Market Window
Other Pest Treatments
Other

Comments:

EPA Form # 5900-137

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12

WORKSHEET 3-B: ALTERNATIVE – CHANGES IN OPERATING
EXPENSES
Name of Alternative:
Column A:

Column B:

Operating Expense Items
Identify the operations to which the costs apply. You may add or delete lines as necessary. The
operating expense items listed here are not meant to be exhaustive or be representative of your
specific operating system. These are meant to provide suggestions and to help you identify how your
operation would change if methyl bromide were unavailable.
Quantity Used per Volume (1,000 cu ft) or Weight (short tons)
This field is required only for alternatives. However you may include specific amounts of other inputs or
operations if you believe it helps to document the additional costs you would incur by using an
alternative fumigant.

Column C:

Units (lbs. hours, etc.)
For all inputs and operations detailed in Column B, please specify the units of measurement.

Column D:

Unit Cost ($)
For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs
of applying alternatives, including any material costs (e.g. tarps). If custom applied and separate costs
are unavailable, write 'custom' and enter total cost in Column E.

Column E:

Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (short tons)
Enter all appropriate costs of operations per volume (1,000 cu ft) or weight (short tons). You may add or
delete lines as necessary.
If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A
Operating Expense Items

B

C

Quantity Used per
Volume (1,000 cu
ft) or Weight
(short tons)

Units (lbs.,
hours, etc.)

D

E

Unit Cost
($)

Cost ($) per
Volume (1,000 cu.
ft.) or Cost ($) per
Weight (short
tons)

1. Pest Management Costs (a+b+c+d)
a) Sanitation
b) Pest Control
c) Fumigation (c1+c2)
c1) Product
c2) Application
d) Other Pest Management Costs
2. Repairs / Maintenance / Replacement
3. Interest
4. Depreciation for Plant Assets
5. Other Operating Expenses

TOTAL OPERATING COST

EPA Form # 5900-137

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4. What are the additional new investments (structures, facilities, equipment, fumigation
chambers, etc.) needed to utilize this alternative: Establish necessary capital expenditures required
for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include
installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting
other components to make them amenable to heat treatment.
Total
Life of Investment
Salvage
Interest
Type of Investment
Investment ($)
(# of years)
Value ($)
Rate (%)

Comments:

EPA Form # 5900-137

Post-harvest

WORKSHEET 4: EMISSION CONTROL
1. How do you currently minimize use and/or emissions of methyl bromide, and how do you plan
to further reduce use and/or emissions in the future: For all use/emissions reduction technique that
you use, please fill out the text, where provided, or state the adoption rate and/or describe changes.
What use/emission reduction
What further use/emission reduction
methods are you currently using?
methods will be used for critical uses?
Please state the emission
Please project the reduction amounts for
reduction amounts.
the year being requested.
Methyl Bromide
Dosage
_____________ lbs/1,000 cu ft
_____________ lbs/1,000 cu ft
Reduction
_____________ lbs/1,000 cu ft
_____________ lbs/1,000 cu ft
Less Frequent
____ times per____
____ times per____
Application
____ times per____
____ times per____
Formulation
_________% MeBr, _________% Pic
_________% MeBr, ________% Pic
Changes
(please specify)
_________% MeBr, _________% Pic
_________% MeBr, ________% Pic
Reclamation

Sealing
Buildings
Integrated Pest
Management
(IPM)
Cultural
Practices
(please specify)
Other Pesticides
(please specify)
Non-Chemical
Methods (please
specify)
Other Measures
(please specify)

2. If methyl bromide emission reduction techniques are not being used, or are not planned for the
future, state reasons:

EPA Form # 5900-137

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WORKSHEET 5: FUTURE RESEARCH PLANS
1. Identify the top 3 to 5 target pests for your research:
1.
2.
3.
4.
5.
2. Provide a list of alternative chemicals or cultural practices that have been tested:
1.
2.
3.
4.
5.
3. Prioritize the alternative chemicals or cultural practices to be tested:
1.
2.
3.
4.
5.
4. What would be the best currently available alternative if methyl bromide were not available:

5. Are there any other potential alternatives under development which are being considered to
replace methyl bromide:

6. Are there technologies being used to produce the crop which avoid the need for methyl
bromide? Please explain whether such technologies could replace a proportion of proposed
methyl bromide use:

7. Please provide an overview/timeline of the plan to transition away from using methyl bromide:

8. Will you include incidence reports where a commodity fails:

EPA Form # 5900-137

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9. Please describe the management strategies that are in place or proposed to eliminate the use of
methyl bromide for the nominated critical use, e.g., measures to avoid any increase in methyl
bromide consumption, measure to encourage the use of alternatives, information on the market
penetration of newly deployed alternatives and alternatives that may be used in the near future:

10. What is the cumulative amount spent and the types of contributions this consortium has made
to fund research to develop alternatives to methyl bromide since 1992, e.g. consortium dues,
direct research funding, etc.: Please add additional rows if necessary.
Years
Name of Organization / Research Institution
Amount ($)

11. Other total investments, if any, made to reduce your reliance on methyl bromide: $ ________
Describe each investment and its associated costs (e.g. specialized machinery, etc.). Please add
additional rows if necessary.
Investment
Cost

13. Grant requests made to USDA, EPA, state, or other funding group:

EPA Form # 5900-137

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For EPA Use Only ID # _________
SECTOR _____________________

WORKSHEET 6: SUMMARY
This section may be posted on the web to notify the public of requests for critical use exemptions
beyond the 2005 phaseout for methyl bromide. Therefore, this section cannot be claimed as CBI.
1. Consortium Name:

2. Location:

3. Crop:

4: Year:

4. Pounds of Methyl Bromide Requested:

5. Volume Treated with Methyl Bromide:

______ (1,000 cu. ft.)

6. Summary of Alternatives Not Feasible: Place an "X" in the column(s) labeled "Not Technically
Feasible" and/or "Not Economically Feasible" where appropriate. Use the "Reasons" column to describe
why the potential alternative is not feasible. Please add additional rows if necessary.
Potential
Alternative

EPA Form # 5900-137

Not
Technically
Feasible

Not
Economically
Feasible

Reasons

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Definitions:
Fumigation cycle:
Year:

Comparable data:

2-year example:

Other beneficiary example

The period of time between methyl bromide fumigations.
If a fumigation cycle overlaps more than one calendar year, "year" refers
to the calendar year when methyl bromide is applied (or the beginning of
the cycle).
In order to compare revenues and costs with and without methyl
bromide, data on alternatives for pest control, yields, revenues, and
costs must be for the same time interval as the methyl bromide
fumigation cycle. If, however, quantitative data, is not available for the
entire fumigation cycle, then to be comparable, the quantitative data for
the alternatives should cover the same portion of the fumigation cycle as
the quantitative data for methyl bromide, and the rest of the cycle should
be discussed in the comments sections.
If a methyl bromide fumigation is made every 2 years, then the 2003
fumigation cycle began in 2003 and would end in 2005. The data should
cover the methyl bromide costs and usage for the methyl bromide
fumigation made in 2003, and all yields and revenues received and other
costs incurred during the 2 year period. To be comparable, the data on
alternatives should cover a similar 2 year period beginning at the same
time of year when a methyl bromide fumigation would be made. The
data should cover all methyl bromide alternatives used, and all yields
and revenues received during that 2-year interval. Other pest control
and other costs would only need to be provided for that interval if they
would change from what they were with methyl bromide.
If someone other than the applicant benefits from a methyl bromide
fumigation, you should comment on these benefits if you do not have
quantitative data for the entire fumigation cycle. For example, if a
rotational crop in the second year benefits from a methyl bromide
fumigation a year earlier, but there is quantitative data only on the first
crop, then the data on the alternatives should cover only the first crop,
and the benefits of methyl bromide and the additional pesticides that
would have to be used on the rotational crop should be discussed in the
comments sections.

Crop cycle change example:

If in a one year interval, methyl bromide is applied, tomatoes are grown
and harvested followed by peppers, then the fumigation cycle would be
one year including the tomatoes and peppers. If, however, without
methyl bromide, it is not possible to follow tomatoes with peppers in the
same one year interval, then the alternative data on pesticides, costs,
yields, and revenues should just cover tomatoes. The loss of profit from
not being able to grow peppers with the alternatives would be part of the
loss from not having methyl bromide.

Crop Grouping

The applicant can group similar crops together if:
(i) Crops would experience similar yield and quality losses in the
absence of methyl bromide; and
(ii) Crops are grown on the same fumigation and cultivation cycle with
similar operating costs.
For example, nursery crops including various flower or tree species can
be aggregated, with average yields per acre and prices. However, if
crops are distinctly different in revenues and operating costs, or the
cycles, the applicant may want to present yield, price and operating
costs for each crop separately and also indicate the proportion of land
area allocated to each crop.

EPA Form # 5900-137

Post-harvest

EPA Form # 5900-137

Post-harvest