Methyl bromide and the Montreal Protocol: An update on the critical use exemption and quarantine pre-shipment process

Abstract

Over the past 50 years, methyl bromide (MBr) has proven to be a consistently reliable pesticide that enhances seedling production and suppresses soilborne pests. It is the industry standard and an essential component of virtually every pest management program in southern forest tree nurseries. Due to the listing of MBr as a ozone depleting substance, the U.S. Environmental Protection Agency (EPA) ordered production frozen at 1991 levels and a complete ban on the production of MBr after 1 January 2005. Provisions within the Montreal Protocol (MP) allow for economic and scientific uncertainty and provide growers with the critical use exemption (CUE) and quarantine pre-shipment allowances (QPS). In the CUE process, the U.S. government nominates uses for “approval” on behalf of U.S. interests and must defend the nominations and effectively persuade the international community that there is, in fact, a critical need. Since the inception of the CUE process in 2005, the amount requested by US growers has ranged from 33 to 35 million lb (15 to 16 million kg) MBr per year. However, the amount approved by the International group that oversees the Montreal Protocol has decreased from 21.0 million lb (9.5 million kg) in 2005 to14.8 million lb (6.7 million kg) in 2007, which is less than half of the amount U.S. growers requested. Another provision within the MP is that QPS uses of MBr are exempt from the 2005 phase-out, which eliminated all MBr uses except for CUEs. MBr used for QPS is to ensure that only pest-free products and materials are moved across political boundaries. An amendment to the Plant Protection Act requires the Secretary of Agriculture to determine whether a MBr treatment or application required by state authorities to prevent the spread of plant pests should be authorized as an official control or official requirement using QPS MBr. Eventually, the CUE is slowly going to be phased-out by both the EPA and the Parties of the MP. If MBr fumigation is to remain an important treatment in the production of forest tree seedlings, its acceptance as a legitimate QPS use in the United States is the most prudent way to continue.

Citation

Enebak, Scott. 2007. Methyl bromide and the Montreal Protocol: An update on the critical use exemption and quarantine pre-shipment process. In: Riley, L.E.; Dumroese, R.K.; Landis, T.D. National Proceedings: Forest and Conservation Nursery Associations - 2006. Proceedings RMRS-P-50. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. p. 135-141