The process for the registration of pesticide alternatives to the use of methyl bromide is a lengthy and cumbersome process. Since methyl bromide was registered in the 1960's and did not have to undergo the more involved scrutiny involved in the present day pesticide registration process, the EPA decided to also re-register methyl bromide. They did this so that alternatives manufacturers would have an even playing field and issues related to registering an alternative would also apply to methyl bromide.
The EPA set up an "e docket" or electronic repository for commentary specifically for the methyl bromide re-registration issue. Over a hundred companies have submitted commentary on re-registration and these can be found at www.regulations.gov. The specific docket is EPA-HQ-OPP-2005-0123. These comments come from a broad spectrum of stakeholders, advocates and opponents of methyl bromide use.
Within this docket, the EPA published(1) an intermediary report on its findings under EPA-HQ-OPP-2005-0123-231. As part of that review, and because of the efforts of Value Recovery, scrubbers were listed as a risk mitigation option that would lower the risk to those who come into close contact (bystanders) to fumigation operations that use methyl bromide.
Specific excerpts from that report are shown below. Our comments are in brackets [ ]:
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pg 25-26: "The mitigation measures detailed below will require the applicator/fumigator to develop a fumigation management plan (FMP), or ensure one exists for each specific site that will be fumigated with methyl bromide.... the fumigator can opt to modify the fumigation parameters or alter the site conditions so that a smaller buffer zone can be used. Examples of alternative approaches include but are not limited to:
- Reducing application rates
- Extending treatment times
- Subdviding treatment areas
- Installing or modifying local exhaust ventilation systems
- Improving the tightness or retention capacity
- Empirically deriving retention or loss rates of the enclosure/chamber/structure ...
- Installing capture recovery or destructive systems (e.g. scrubbers)
[It is very interesting that scrubbers are shown last. Also, installing or modifying local exhaust ventilation systems (4th on the list) results in dilution with more air or exhausting at a higher stack height but does nothing to protect the ozone layer. We are amazed that this would be recommended by the EPA].
pg 31: "Air monitoring and modeling for methyl bromide destruction or capturing devices such as scrubbers may also be used to determine the use of smaller buffer zones than those listed in the Agency look-up tables. "....it is one of the few options that directly reduce the total methyl bromide released and potential ozone depletion."
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Thus scrubbers are listed as a risk mitigation option and are supported, in principal, by the EPA.
(1) "Report of Food Quality Protection Act (FQPA) Tolerance Reassessment and Risk Management Decision (TRED) for Methyl Bromide, and Reregistration Elegilibility Decision (RED) for Methyl Bromide's Commodity Uses. United States Environmental Protection Agency. Prevention, Pesticides and Toxic Substances (7508C) EPA 738-R-026. August 2006. Approved by Debra Edwards, Ph. D., Director, Special Review and Registration Division.
