alternatives to methyl bromide: selected case...

Alternatives to Methyl Bromide:Selected Case Studies

2001: Canadian Leadership in the Developmentof Methyl Bromide Alternatives

Agriculture andAgri-Food Canada

Agriculture etAgroalimentaire Canada

Alternatives to Methyl Bromide: Selected Case Studies2001: Canadian Leadership in the Development of Methyl Bromide Alternatives

AAFC No.: 2106/EAugust 2001

Prepared byChris LindbergEnvironmental AnalystEnvironment BureauStrategic Policy BranchAgriculture and Agri-Food Canada

This publication is available from the Environment Bureau, Strategic PolicyBranch Agriculture and Agri-Food Canada, 930 Carling Avenue, Ottawa, Ontario,K1A 0C5

It is also available on the World Wide Web at:http://www.agr.ca/policy/environment/eb/public_html/ebe/ozone.html

Photo creditsAnderson Sod Farm, Pillsbury Canada Ltd., Rogers Foods Ltd., Cereal ResearchCentre, Agriculture and Agri-Food Canada.

Front cover photosTop: Pre-planting treatment of field with washed sand using a big A spreader.Bottom: Roll floor in flour mill.

Members of the Industry/Government working group who made comments to themanuscript: Lubna Bokhari, Alex Cavadias, Linda Dunn, Paul Fields, GeorgeLazarovits, Dorothy Laidlaw, Michelle Marcotte, Dale McKeague, John D Smithand Robin Tremblay.

EditorsThe Gordon Writing Group901-141 Laurier Avenue West,Ottawa, Ontario, K1P 5J3

Graphic Design and Page LayoutEric Boyer, Studio Eclipse, Pontiac, QC

PrintingBonanza printing & Copying Centre Inc., Ottawa, ON

Alternatives to Methyl Bromide: Selected Case Studies 3

4 Alternatives to Methyl Bromide: Selected Case Studies

Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Results of Methyl Bromide Allowance Holder Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Analysis of Results of Methyl Bromide Allowance Holders Survey . . . . . . . . . . . . . . . . . . . . . . 18

Next Steps – Growers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

• Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

• Case Study 1: Alternatives for Sod Production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

• Case Study 2: Alternatives for Strawberry Nurseries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Next Steps – Space Users . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

• Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

• Elements of an Effective Integrated Pest Management Strategy . . . . . . . . . . . . . . . . . . . . . 31

• Case Study 1: Pillsbury Canada Ltd. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

• Case Study 2: Rogers Foods Ltd. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

• Case Study 3: Pest Management Professionals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Appendix A: Product and Chemical Names . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Appendix B: Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40


Table of Contents


The Montreal Protocol on Substances that Deplete the Ozone Layer is a global agreement aimed atprotecting the ozone layer by reducing the production and consumption of ozone-depleting substances.Under the Montreal Protocol, participating nations have agreed to a complete phase-out of the non-quarantine use of methyl bromide. For developed nations (including Canada and the United States) thephase-out date is 2005 (this includes Canada and the United States) and for developing nations 2015.

Reduction in the use of methyl bromide has resulted in an urgent need to develop alternatives methodsof pest and weed management.

This report provides an assessment of the current agricultural use of methyl bromide and alternativesin Canada, and outlines Agriculture and Agri-Food Canada’s (AAFC) strategy regarding its phase-out.It also presents the results of the June 2000 survey and case studies of selected users who have successfully implemented methyl bromide alternatives.

To maximize research collaboration and the development of alternatives, two working groups were setup in the mid-1990s: a Canadian government/industry working group, and a Canada/U.S. workinggroup, the latter comprised of Agriculture and Agri-Food Canada and the United States Departmentof Agriculture (USDA). Since 1996, these two groups have collaborated on laboratory experimentsand other research projects, many of which have been documented in written reports. These reportsare listed at the end of this paper.

Through government research programs and commercial development of alternative technologiesand products we have made excellent progress. This work will continue to ensure good control ofpests and plant diseases in agriculture and food processing.

On behalf of Agriculture and Agri-Food Canada, I would like to extend our appreciation to thecompanies and farmers presented in the case studies for generously giving their time and expertise.I would also like to thank the Canadian Joint Industry-Government Working Group on MethylBromide Alternatives for their contribution.

Yaprak BaltaciogluAssistant Deputy MinisterStrategic Policy BranchAgriculture and Agri-Food Canada

Foreword


• The Montreal Protocol on Substances that Deplete the Ozone Layer is an internationalagreement that responds to the thinning of the stratospheric ozone layer. In 1992, parties to theMontreal Protocol recognized methyl bromide as an ozone depleting substance responsiblefor up to 10% of the depletion of the ozone layer. In 1997, developed nations that were partiesto the Montreal Protocol agreed to a phase-out schedule requiring methyl bromide reductionsof 25%, 50%, 70% and 100% by January 1, 1999, 2001, 2003, and 2005, respectively.

• In response to methyl bromide’s classification as an ozone depleting substance, theGovernment of Canada conducted broad consultations with industry, research organizationsand environmental experts in Canada and in the U.S. The objective of these consultations wasto develop a solution that would protect the environment, while minimizing the economicimpact that eliminating methyl bromide would have on the agriculture and agri-food sector.

• In 1995, the government established the Canadian Joint Industry–Government WorkingGroup on Methyl Bromide Alternatives to identify obstacles, propose solutions and disseminate information.

• Marcotte Consulting Inc., on behalf of Agriculture and Agri-Food Canada carried out asurvey to identify and interview allowance holders who had successfully implementedalternatives to methyl bromide.

• The survey showed that 72% of allowance holders were growers and 38% were space users.

• The survey also revealed that all the space users and 83% of the growers were aware of theimpending phase-out of methyl bromide, although a few allowance holders still misunderstandthe impact of methyl bromide on the environment and the mechanism by which it harmsthe ozone layer.

• A number of growers with large allowances indicated that they were transferring theirquota to other users. As a result, much of the transferred quota left the farm and was usedfor space fumigation.

• Recent changes to the Canadian Environmental Protection Act (CEPA) have assisted in the transfer mechanism by establishing a Web site (http://www.ec.gc.ca/CEPARegistry/Permits/ozone.cfm) listing allowance holders and their quotas.

• In all, 73% of growers responded to the survey. According to the survey results, 23% oflarge allowance holders are still using their quota, compared to 40% and 37% for mediumand small holders, respectively. Growers’ motivating reasons for finding alternatives tomethyl bromide were: an increased cost of methyl bromide, negative environmentalimpacts, regulatory prohibitions and lack of availability of applicators. Of those growers who still used methyl bromide, the majority stated that there were no adequatecompetitive alternatives.

Executive Summary


• For greenhouses, alternatives used were soil-less mediums, commercially sterilized soil,bleaching/shade cloth/hand-weeding, hand-weeding and steam or heat.

• Since the 1990s, greenhouse users have been moving towards soil-less mixes or pre-purchasedsterile soil using a variety of integrated pest management measures, biological control agentsand sanitation measures.

• The field growers’ alternatives to methyl bromide were: 11,3-dichloropropene, metam sodium,1,3-dichloropropene, post-emergence herbicides, insecticide/plastic culture/hand-weeding.

• Many field growers have found adequate control using chemicals, primarily 11,3-dichloropropeneor 11,3-dichloropropene-metam sodium mix.

• This report presents three case studies of growers who have adopted pest management systems that minimize or eliminate the use of methyl bromide.

• Potential drawbacks of using alternative chemical fumigants include the fact that they are restricted in their application and that they may only provide limited long-term disease control.

• 69% of space users were still using methyl bromide.

• The space users’ suggested alternatives to methyl bromide were: Integrated Pest Management(IPM), phosphine, sanitation, heat, carbon dioxide, CO2/phosphine/heat combination,diatomaceous earth (DE), pyrethrins, IPM/pheromones/UV light/sanitation and ethylene oxide.

• Changes to traditional pest management practices in the flour-milling sector were necessarybecause of the imminent phase-out of methyl bromide and new regulations on pesticide use.

• This has resulted in the development of an Integrated Pest Management Strategy, whichtakes a holistic approach using biological, cultural, physical, mechanical and chemical methodsto manage pest problems in a more environmentally sound and cost-effective manner.

• This report presents three case studies of space users. Two case studies present companiesthat have developed an integrated pest management strategy in-house. One study presents apest management professional whose clients include a mix producer and a flourmill.

• Some growers and space users find that the alternatives to methyl bromide now availabledo not meet their needs and that they require more information about other existing alternatives.In response to their need, the Department of Agriculture and Agri-Food Canada (AAFC)prepared this report, and is creating an interactive Web site and information clearinghousefor methyl bromide users.

ObjectiveThe purpose of this document is to provide anassessment of the current status and use ofmethyl bromide, and its alternatives, in Canada.The document also outlines the FederalGovernment’s strategy regarding its plan tophase-out the use of methyl bromide. It presentsthe results of a June 2000 survey of allowanceholders, and case studies of various users whohave successfully implemented methyl bromidealternatives. This document is a tribute to thesuccessful collaboration and cooperationbetween the stakeholders and government, andillustrates the need for continued work together.

BackgroundMethyl bromide is a broad-spectrum gas usedpredominantly as an agricultural fumigant tocontrol pests in soils, structures, and commodities.Methyl bromide can be injected into the soil,sterilizing it and providing effective control of awide variety of insects, weeds and diseases.Structures and commodities have been routinelyfumigated to control and eliminate pest infestations,and meet the phytosanitary requirements ofimporting countries. Although the quantitiesused in Canada are small, they represent significanteconomic activity.

The Montreal ProtocolCreated in 1987, the Montreal Protocol onSubstances that Deplete the Ozone Layer is aninternational agreement that responds to thethinning of the stratospheric ozone layer. In1992, parties to the Montreal Protocol recognized

methyl bromide as an ozone depleting substanceresponsible for up to 10% of the depletion ofthe ozone layer. In 1997, developed nationsthat were parties to the Montreal Protocolagreed to a phase-out schedule requiring methylbromide reductions of 25%, 50%, 70% and100% by January 1; 1999, 2001, 2003, and2005, respectively. Developing nations haveagreed to cap consumption at 2002 levels, witha complete phase-out by 2015. The parties tothe Montreal Protocol have agreed on someexemptions to these phase-out schedules. Theexemptions include: quarantine and pre-shipmentuses, and critical and emergency uses. Financialassistance for projects that test or adopt alternatives to methyl bromide is available todeveloping countries that are signatory to theMontreal Protocol through the Multi-LateralFund (MLF).

Management of Methyl Bromide in CanadaIn response to methyl bromide’s classificationas an ozone depleting substance, the Governmentof Canada conducted broad consultations withindustry, research organizations, and environmentalexperts in Canada and in the U.S. The objectiveof these consultations was to develop a solutionthat would protect the environment while minimizingthe economic impact that eliminating methylbromide would have on the agriculture andagri-food sector.

In 1995, the government established theCanadian Joint Industry-Government WorkingGroup on Methyl Bromide Alternatives.


Introduction

Category Global Use Canadian Use

Soil 75% 45%

Commodities 22% 5%

Structural Fumigation 3% 50%

Total Consumption 71 400 tonnes 200 tonnes (<1%)

Table 1: Methyl Bromide Use and Consumption (1997)

Co-chaired by Environment Canada andAgriculture and Agri-Food Canada, the workinggroup meets three times a year. Membersinclude industry stakeholders, environmentalgroups, and government representatives fromAgriculture and Agri-Food Canada, EnvironmentCanada, Industry Canada, the Pest ManagementRegulatory Agency (Health Canada) and theCanadian Food Inspection Agency (CFIA).This collaborative approach to working withindustry and the public has proven to be extremelyeffective in identifying obstacles, proposingsolutions, and disseminating information.Members have been extremely pro-active in theirapproach; organizing conferences, workshopsand demonstration projects. The FederalGovernment, and Agriculture and Agri-FoodCanada in particular, has played a key facilitativerole; identifying research needs and fundingopportunities, organizing demonstration andpilot projects, developing effective regulations,and negotiating Canada’s position at internationalmeetings. Agriculture and Agri-Food Canadaalso co-chairs a Canada-U.S. Joint IndustryGovernment Working Group that meets twotimes per year.

Regulation in Canada – Allowance HoldersEnvironment Canada has established a systemof tradable allowances for methyl bromide use,based on 1993 consumption. Under the OzoneDepleting Substances Regulations (and theiramendments) each allowance holder is given apercentage of Canada’s total allowance.Allowance holders may choose to relinquish ortrade their allowance if they no longer requiremethyl bromide. When the system was establishedin 1995, there were about 160 allowance holders.Changes in technology and the efforts of government and industry have reduced thatnumber to 68, in 2001.

Quarantine and Pre-shipment (QPS)Exemption When control measures were considered in1992, parties agreed that the alternatives tomethyl bromide available at the time could not

meet the phytosanitary and sanitary requirementsof exporting and importing countries. Therefore,under the Montreal Protocol, quarantine andpre-shipment applications of methyl bromidewere exempted from all controls (for example,reduction in consumption, freeze or phase-out).However, many parties have begun to expressconcern over the amount of methyl bromideused for QPS purposes. In 1998, approximately20% of the global consumption of methyl bromide(16000 tons) was under QPS, and this figure isbelieved to have increased substantially overthe last three years. Furthermore, methyl bromideused for QPS purposes is vented directly intothe atmosphere at the end of the treatment.Limited technologies have been developed forthe recapture, recycling and destruction ofmethyl bromide used in a variety of QPS andstructural applications. Canada is continuing adialogue with industry to examine the viabilityof using methyl bromide alternatives for QPSpurposes, and the long-term implications of theQPS exemption.

Critical and Emergency Use ExemptionAfter 2005, parties to the Montreal Protocolwill be able to request methyl bromide foremergency or critical uses. Stringent criteriahave been developed for critical uses, includingdemonstrating that all technically and economicallyfeasible alternatives have been tried and foundto be inadequate. Emergency uses will be limitedto 20 tons, and evaluated by the same criteria.The use of methyl bromide under these exemptionswill be evaluated by the Secretariat of theMontreal Protocol, and non-compliant nationswill be penalized. In Canada, the MethylBromide Industry–Government working grouphas developed a critical and emergency use criteria document entitled Process and Criteriafor the Evaluation of Exemptions for Criticaland Emergency Uses of Methyl Bromide. The document describes the criteria, process andschedule that the Canadian regulatory body(Environment Canada) could use to determinewhether or not to grant an exemption for criticalor emergency use of methyl bromide, after the


2005 phase-out date. This document will act asa guide for Environment Canada’s decisionsand is available on the Environment CanadaWeb site at http://www.ec.gc.ca/ozone/e/subsec/mbr/workgroup.

Government’s Roles and ObjectivesThe Federal Government is committed to eliminating methyl bromide use while ensuringthe protection of the environment and minimizingthe economic impact of the phase-out on theagriculture and agri-food sector. Continuousconsultation and collaboration with stakeholders,largely through working groups, is a key componentof this strategy. The government also recognizesthat the industry may need assistance in theresearch, development, and application of alternatives to methyl bromide. In addition, the government understands that it needs tocontribute to international efforts to eliminatethe use of methyl bromide, particularly indeveloping nations.

The Federal Government’s Responsibility withregard to these issues is shared among severalof its departments and agencies:

Environment Canada: Environment Canada’sprimary role is to develop control measures for,and track the usage of methyl bromide andother Ozone Depleting Substances (ODS).Environment Canada consults stakeholders in thedevelopment of control instruments (includingregulations). Environment Canada is also thelead in developing Canada’s negotiating positionfor all ODS-related international meetings.

Agriculture and Agri-Food Canada:Agriculture and Agri-Food Canada plays largelya facilitative and supportive role, helping industryand other government departments in identifyingresearch needs and funding opportunities; partnering with industry to develop technologies;organizing demonstration and pilot projects;examining regulations and collaborating in thedevelopment of Canada’s negotiating positionon methyl bromide, for international meetings.

Canadian Food Inspection Agency: TheCanadian Food Inspection Agency (CFIA)oversees quarantine and pre-shipment activities.Among the Agency’s responsibilities is beingthe official sanitary and phytosanitary certificationbody for Canada. The Agency protects Canadaand its trading partners from the distribution ofalien or destructive pests and diseases in productsthat we import or export. As part of this role,the Agency manages quarantine programs incollaboration with other government departments,industry sectors and other national governments.The Agency is continuing to work with manysectors to update and introduce systematicapproaches to production and pest managementand to adapt existing alternatives so that theymeet the phytosanitary requirements of bothdomestic and importing countries. This is especially important in helping the industrymaintain desired market access.

Industry Canada: One of Industry Canada’smandates is to promote, develop and expandthe environmental technologies industry.Consequently, Industry Canada has an interest inassisting Canadian companies that have developedmethyl bromide alternatives and expertise inexporting their products internationally.

Pest Management Regulatory Agency (HealthCanada): The Pest Management RegulatoryAgency is responsible for the federal regulationof pest control products, including pre-marketassessment of the products’ health and environmental safety, and establishing the meritand value of products submitted for registration.Submission of applications to register alternativesto methyl bromide is encouraged throughoutthe Joint Review Program (a collaboration withthe U.S. Environmental Protection Agency),and through minor use registration.

AAFC Case Studies – BackgroundAgriculture and Agri-Food Canada has preparedcase studies in response to the allowance holders’need for more information on viable alternativesto methyl bromide. The objective of these case


studies is to provide concrete, Canadian examplesof the successful implementation of methyl bromide alternatives. These case studies usedthe survey responses to identify and interviewthose allowance holders who had successfullyimplemented alternatives to methyl bromide.Agriculture and Agri-Food Canada also invitedmembers of the Joint Industry– GovernmentWorking Group on Methyl Bromide Alternatives

to participate at the January 30 meeting. AAFCasked Working Group members to circulate the invitation to their various professionalorganizations. Agriculture and Agri-Food Canadacontacted individuals and companies from Januaryto March 2001. Those who agreed to participatein the case studies were interviewed over thephone for 30 to 90 minutes, and later participatedin editing and reviewing of the written study.



In May to June 2000, on behalf of Agricultureand Agri-Food Canada, Marcotte ConsultingInc. carried out a telephone survey of methylbromide allowance holders in Canada. Theobjective of the survey was to determinewhether allowance holders were informed ofthe phase-out schedule; find out if they werestill using methyl bromide and for what purpose;and, establish the participants’ readiness toadopt methyl bromide alternatives. The surveyalso examined the methyl bromide users’ needfor more alternatives.

Marcotte Consulting divided allowance holdersinto two main categories: growers and spaceusers; and divided these two categories intothree sub-groups: small (<1 kg–100 kg), medium(101 kg–500 kg) and large (501 kg–40000 kg).The grower category encompassed all soilusers, greenhouse and field producers, and pest management companies that dealt with soilapplications. The space category encompassedboth structural and commodity users, andincluded both pest management and quarantineand pre-shipment applications. The actualallowances of each allowance holder remainedconfidential; the contractor was given a list ofgrowers and space users with small, mediumand large allowances. The contractor attemptedto contact all 106 holders of methyl bromideallowance. In all, 84 quota holders responded tothe survey for a success rate of 79%. The resultsof the survey are presented in this section andanalyzed in the next section.

Awareness of Phase-outThe survey revealed that all of the space usersand 83% of the growers were aware of theimpending phase-out of methyl bromide use. Thegrowers who were not aware of the phase-outall came from the same region in Quebec, andmany of them had not been using methyl bromidefor several years.

Over the years, Environment Canada has distributed various information packages on theenvironmental impacts of methyl bromide andthe rationale for the phase-out. Despite this, afew allowance holders still misunderstand theimpact of methyl bromide on the environment,and the mechanism by which it harms theozone layer. Two individuals felt that usingmethyl bromide in contained spaces minimizedpollution problems and that bromide releasefrom the oceans outweighed the amounts resultingfrom industrial use. Several individuals believedthat methyl bromide would not be phased out inthe U.S. or in Canada. Their opinion was basedprimarily on their contact with the U.S. industryand lobby groups.

Awareness of the existence of The Working GroupAwareness of the existence of The WorkingGroup was much greater for the structural users(72%) as compared to the growers (31%). Inboth groups, large allowance holders (ratherthan small or medium allowance holders) weremore likely to be aware of The Working Group.This is understandable because the phase-outwill have a greater influence on the largeallowance holders’ businesses.

Transfer of Allowance QuotasA number of growers with large allowancesindicated that they were transferring their quotato other users of methyl bromide. This wasmentioned by the structural users only twice. Thesurvey indicates that much of the transferred quotais leaving the farm to be used for space fumigation.

Respondents commented that the costs of methylbromide and allowance transfers are rising rapidly.Some respondents were concerned that peopleselling their quota are making unfair profits. Onerespondent indicated that they have insufficientmethyl bromide to meet their current demands,but cannot find anyone selling their quotabecause the list of quota holders is not a public

Results of Methyl Bromide Allowance Holders Survey

document. They felt that the current quota systemshould be revamped so that those who reallyneed methyl bromide can get it.

GrowersOf the 106 methyl bromide quota holders inCanada, 66 (62%) are classified as growers.This group’s response rate to the survey was73%. Of the 48 respondents, 16 (33%) werestill using their quota and 32 (66%) hadstopped using their quota for various reasons.Only 3 (23%) of the large allowance holdersindicated that they are still using their quota, ascompared to 40% and 37% for medium andsmall holders, respectively. Many growers werehaving fairly good success with several currentlyregistered soil fumigants (other than methylbromide), but identified some problems. Thosestill using methyl bromide include greenhouseand field producers of berries, bedding plants,strawberry plants, fruits, vegetables, flowers,cuttings and nursery stock (trees), and one pestmanagement contractor who services growers.Those that have found alternatives include theproducers of sod, strawberry seedlings, cran-berries, raspberries, vegetables and flowers.This list is not complete because growers whono longer use methyl bromide did not alwaysindicate their type of farming operation.

Individuals who have stopped using methylbromide gave various reasons for having done so:

1. The increasing cost of methyl bromide;2. The negative environmental impact of using

methyl bromide and the dangers inherent inapplying it;

3. They had sold their farm or had changed thecrops they were growing or the way theywere growing them;

4. They were unable to obtain methyl bromide(despite having an allowance) because itwas being “blocked at the border”, orbecause the regulations were prohibitivelycomplicated. Some respondents were unableto find an applicator willing to travel totheir farm to apply it.

Growers still using methyl bromideOf the sixteen growers who reported still usingmethyl bromide in their operation, less thanhalf had tried using alternatives. All stated thatavailable alternatives were too expensive (heat,steam, soil-less mix, commercially sterilizedsoil, metam sodium), less effective (metamsodium, 11,3-dichloropropene, 1,3-dichloro-propene), or required a prohibitively long treatmentperiod (metam sodium, 11,3-dichloropropene).Two growers were unable to find a companythat would deliver commercially sterilized soilbecause their production was too small. Themajority stated that there were no adequatealternatives and that it will be impossible to remaincompetitive without using methyl bromide.

Growers using alternatives to methyl bromideRespondents identified and critiqued the following alternatives:

Note: These critiques represent the opinionsexpressed in the survey, and are not necessarilya definitive, scientific evaluation of any of thealternatives.

1. Greenhouse – soil-less mediums: Growersfound hydroponic systems or alternate substrates (such as rockwool and peat) to be significantly more expensive but highlyeffective. The majority of greenhouse growersreported having adopted this alternative.

2. Greenhouse – commercially sterilized soil:Growers found commercially sterilized soilto be more expensive but very convenient.

3. Greenhouse – bleaching/shade cloth/hand-weeding: Growers found this method effectivebut probably more expensive because it istime consuming.

4. Greenhouse – hand-weeding: Growers foundthis method effective but labour-intensiveand time-consuming.

5. Greenhouse – steam and/or heat: Two growersidentified this alternative as effective butprohibitively expensive.

6. Field – 11,3-dichloropropene: Growersreported varying levels of success with


11,3-dichloropropene. 11,3-dichloropropene,a mixture of 78% 1,3-dichloropropene plus17% chloropicrin, was more expensive thanmethyl bromide but provided “reasonable”(95% to 98%) control. Growers reportedhaving to do some hand-weeding in additionto using it. 11,3-dichloropropene was sometimes used in combination with otherchemicals (for example, 1,3-dichloropropeneor metam sodium). One grower compared11,3-dichloropropene, metam sodium and1,3-dichloropropene, and found that 11,3-dichloropropene was as effective as methylbromide and the least expensive of the three.Several growers expressed a desire to try aproduct with higher chloropicrin content foradditional disease control.

7. Field – Metam sodium: Growers who triedit, did not consider metam sodium alone tobe a viable alternative to methyl bromide.It was less expensive but not nearly aseffective. Growers reported some diseasecontrol but no weed kill.

8. Field – 1,3-dichloropropene: Growers foundthat 1,3-dichloropropene did not provideadequate control.

9. Field – Post-emergence insecticides/plasticculture/hand-weeding: The grower who wasusing this technique found it less effectiveand more time consuming, but less expensivethan methyl bromide.

10. Field – Hand-weeding: Growers with mediumand small quotas were more likely to mentionmanual weed control. This method is labour-intensive, time consuming and costly. Growersagreed that it was not a very effective alternativeto methyl bromide, but some growers wereusing it on a regular basis.

Many growers indicated a desire for moreinformation, particularly about effective andeconomically feasible methods of sterilizing thesoil, including non-chemical means.

Many growers expressed an interest in productswith a higher level of chloropicrin or a 1,3-dichloropropene/chloropicrin mix. Specific

products that were mentioned included: 35%chloropicrin, Ethofumesate, 3,5-dimethyl-1,3,5-thiadiazinane-2-thione (a granular product mixedwith the soil in the fall), a new 11,3-dichloro-propene formulation (with better soil bindingcapability so that less of it leaches through to theground water) and methyl iodide. Several smallgrowers were interested in steam and electricalsterilization, but indicated that the equipment wastoo costly for them to purchase on their own.

Space UsersOf the 106 methyl bromide quota holders inCanada, 40 (38%) fell into the category ofstructural or commodity users (Table 2). All butfour holders were successfully surveyed, a successrate of 90%. Of the 36 respondents to this survey,25 (69%) were still using methyl bromide,including all of the large quota holders. All butone of the medium quota holders and 54% ofthe small quota holders were using methyl bromide. The 11 small allowance holders who were no longer using their quota did notnecessarily find alternatives because they wereno longer doing fumigation work. They alsopointed out that the quota was too small to beuseful. Government, universities and collegeswere the majority of small allowance holdersthat were still using their quota, and this wasfor research and teaching purposes. Oneresearcher was investigating the possible damage to the ozone caused by the release ofmethyl bromide into the atmosphere.

Space users still using methyl bromideOf the small allowance holders that were stillusing their quota of methyl bromide, most usedit for structural and commodity fumigation.They could be divided into four categories:

• pest management professionals (22)• food processors (8)• government (2)• universities or colleges (4)

With one exception, large holders of methylbromide were all pest control operators.


Space users using alternativesto methyl bromideThere was a strong dichotomy in the respondents’outlook on the future use of methyl bromide.Some allowance holders saw the need for thephase-out and were confident that the industrycould adapt. Others felt that the future of theirbusiness was at stake.

Most of the space users knew of or had triedalternatives. Respondents identified and critiquedthe following alternatives:

Note: These critiques represent the opinionsexpressed in the survey, and are not necessarilya definitive, scientific evaluation of any of thealternatives.

1. Integrated Pest Management (IPM) – IPMis a holistic approach to pest control thatuses biological, cultural, physical, mechanicaland chemical methods to manage, controland eliminate pest populations. Respondentsfound that applying IPM principles enabledthem to effectively manage pest populationsusing the available alternatives to methylbromide (at a comparable cost), and identifiedIPM as a long term, low-cost alternative.

2. Phosphine – Phosphine is the most widelyused chemical alternative. Those currently registered in Canada are Degesch magnesiumand aluminum phosphides. Respondentsidentified four major drawbacks of phosphine:effectiveness, cost, treatment time and corrosiveness to metals. The corrosivenesswas particularly problematic for some commodities (i.e. brass door handles).While the purchase price of phosphine isgenerally lower than methyl bromide, thelonger treatment time required (three to fourdays as opposed to 24 hours) resulted ingreater costs due to longer plant shutdowns. Effectively, this made phosphinemore expensive to use at its current prices.Some respondents also complained thatphosphine was temperature sensitive (andtherefore could not be used in the winter),and that it was highly flammable whenexposed to moisture. Respondents identifiedAluminum phosphide as an effective alternativefor commodity fumigation.

3. Sanitation – Several respondents indicatedthat they were able to significantly reducethe frequency of pesticide and fumigantapplications because of improvements incleaning, maintenance and general sanitation,


Category Size ofallowance

Number ofallowanceholders

Number ofresponses(% response)

Usingmethylbromide

Aware ofphase out?

Grower Large 16 13 (81%) 3 10 12 0 1

Awareof workinggroup?

9 2 2

Medium 8 5 (63%) 2 3 4 0 1 1 2 2

Small 42 30 (71%) 11 19 21 8 1 5 23 2

Total 66 48 (72%) 16 32 37 8 3 15 27 6

Space Large 7 6 (86%) 6 0 6 0 0 6 0 0

Combined 106 84 (79%) 40 44 73 8 3 43 34 9

Medium 6 6 (100%) 5 1 6 0 0 6 0 0

Small 27 24 (89%) 13 11 24 0 0 14 7 3

Total 40 36 (90%) 24 12 36 0 0 26 7 3

Yes No Yes No n.a. Yes No n.a.

Table 2: Number of Survey Respondents Using Allowance, Awareness of Phase out and Working Group(n.a. = not answered)

but said that sanitation alone did not providesufficient pest control.

4. Heat – This method was generally consideredto be costly and time consuming in terms ofpreparation and treatment. Users stated thatits effectiveness depended on buildings havinggood seals and that it was inadequate for usein bins. One user had found it effective andinexpensive for use in small-scale applications,but inappropriate at larger scales.

5. Carbon dioxide – Users found that it wasdifficult, if not impossible, to obtain the targetcarbon dioxide concentrations requiredbecause structures were simply not air tightenough. Carbon dioxide also required alonger treatment time than other alternatives.

6. Carbon dioxide /phosphine/heat combination –One respondent indicated that this combinationwas less effective than methyl bromide andmore time consuming. Phosphine and heatmix was found to be effective, although moreexpensive in terms of time and equipmentrequirements.

7. Diatomaceous earth (DE) – Several respon-dents found DE an effective and inexpensiveresidual insecticide. One respondent indicatedthat using heat and DE was only 50% aseffective as methyl bromide, and requiredmonthly applications as opposed to annual.

8. Pyrethrins – Good for spot fumigationsbetween annual treatments.

9. IPM/pheromones/UV light/sanitation – Onerespondent identified this as an alternativethat was more labour-intensive (and thereforemore costly) than methyl bromide.

10. Ethylene oxide – One user found this methodeffective for vault fumigation.

Virtually all pest control companies surveyedindicated some level of dissatisfaction with thealternatives available, or noted that no suitablealternative was available for some or most circumstances. Many of the allowance holdersindicated that they were using their quota forquarantine or pre-shipment use; indicatingsome misinformation with regards to quarantineand pre-shipment exemptions.

Several respondents identified carbon dioxidemixed with phosphine and sulfuryl fluoride asproducts that should be investigated and fasttracked for registration in Canada. Other productsthat the respondents identified were the phosphineproducts, magnesium phosphide, and the Horngenerator. Since the time of the survey, magnesiumphosphide (for use in the phosphine generator)has been registered. Several individuals requestedmore data on the efficacy of non-chemicalalternatives such as heat and cold treatments.

Other CommentsOne respondent indicated that he would shift tousing aluminum phosphide, but that the importingcountries would have to be willing to acceptgoods fumigated with this product, rather thanwith methyl bromide, as currently stipulated.Consumers will need to be educated about thephase-out and be willing to accept higher levels ofinsect infestation as a trade-off for environmentalsustainability. Other respondents questioned theneed for the phase-out, particularly in Canadawhere the use of methyl bromide constitutes asmall percentage of its worldwide use. Theserespondents felt that there were other chemicalsreleased into the environment that were just asdetrimental as methyl bromide. One respondentmentioned that the monthly inspections by theCanadian Food Inspection Agency (CFIA) werea strong incentive to keep up with sanitationprocedures in their facility.

Large quota holders expressed general dissatisfactionwith the phase-out. They did not see any viablealternatives to methyl bromide.

Several respondents indicated that product registration takes too long and chemicals availablein the U.S. are not registered for use in Canada.They suggested that Canada re-evaluate someof the older fumigants to be brought back intousage. Respondents said that all countries—Canada, the U.S. and Mexico in particular—need to be on an equal basis in terms of methylbromide use.


This section takes the conclusions and observationsof the survey and places them in the context ofother information. It outlines actions alreadytaken to address problems identified by the survey, and identifies the next steps industryand government must take to ensure a smoothtransition from using methyl bromide to usingits alternatives.

Several features of the survey (and the allowancesystem itself) make an in-depth analysis of thesurvey results difficult. Not all end-users ofmethyl bromide are allowance holders (forinstance, the food processing industry contractspest management professionals to apply methylbromide). As a result, an analysis of the usepatterns of allowance holders may not accuratelyreflect the use patterns of all end-users. In addition,the specific quantities of each allowance wasclassified information under the CanadianEnvironmental Protection Act (CEPA), makingit difficult for Marcotte Consulting Inc. to conductany quantitative analyses of the amount ofallowances being transferred, used or lapsed.Subsequent to this study, CEPA has been modifiedand that information has become unclassified.

Communications IssuesThe survey identified communications issuesthat needed to be resolved for both growers andspace users. In the case of growers, many usersstated that they were no longer using methylbromide and that they would like to have theirquota removed so that they would not have todeal with the paperwork. Officers ofEnvironment Canada contacted all of theseindividuals in person, and some have chosen togive up their allowance.

The survey also identified some confusion concerning the way allowances are calculatedand re-distributed, and what constitutes quarantineand pre-shipment use. Environment Canadaresponded with a presentation to the JointIndustry Government Work Group on Methyl

Bromide Alternatives. General informationabout this presentation and other topics aboutmethyl bromide are available on the Internet athttp://www.ec.gc.ca/ozone/. Additional informationis available through Environment Canada,Chemicals Control Division, telephone (819) 953-1665, fax (819) 994-0007.

Research NeedsThe survey identified that there is a small numberof researchers who are using methyl bromide tostudy its impact on the ozone layer, and for otherresearch-related purposes. Some researcherssurveyed suggested that research needs shouldbe exempted from the allowance system.Unfortunately, there are no provisions in theMontreal Protocol to make such an exceptionuntil 2005, at which time the researchers couldapply for an exemption under the Critical Usescriteria. Until that time, researchers can purchaseor request the transfer of any additional quotafrom other allowance holders. This should not be difficult or prohibitive given the smallquantities involved.

Allowance System and TransfersSeveral allowance holders mentioned that theprice of methyl bromide and methyl bromidetransfers was rapidly increasing, and that therewere no adequate alternatives in place. Thisconcern came predominantly from the spaceusers, who felt that growers were profitingunfairly from the system.

There are several responses to this criticism:

1. Environment Canada’s analysis of methylbromide use indicates that in 1999allowance holders imported only 83% ofthe allowance they were authorized toimport. Growers failed to import 22% oftheir allowance, while the space users failedto import 13%. Evidently, both sectors donot use all of the methyl bromide available.


Analysis of Results of Methyl Bromide Allowance Holders Survey

2. Environment Canada data show that transfersare occurring from growers to space users,between space users, and from allowanceholders to non-allowance holders, but notfrom space users to growers. After thosetransfers are taken into account, it is evidentthat the space users sector actually increasedthe amount of methyl bromide it used from1997 to 1998, despite their knowledge ofthe impending phase-out. This suggests thatby failing to control and reduce its consumption,the space users sector might have contributedto the price increase by increasing demandunder conditions of limited supply.

Several allowance holders mentioned that theywere unable to identify other allowance holdersin order to purchase additional allowance underthe transfer system. Given recent changes toCEPA, Environment Canada has been able torespond to this critique by establishing a Website (http://www.ec.gc.ca/CEPARegistry/Permits/ozone.cfm) that lists allowance holdersand their quota.

AlternativesBoth growers and structural users of methylbromide were concerned that the phase-outwould occur before alternatives were in place.They emphasized the need for a level playingfield among all countries so that Canada wouldremain competitive in the global economy.Some growers and space users are finding that

the alternatives now available do not meet theirneeds. They require more information about theexisting alternatives that they have not yet heardabout. Other allowance holders have been verysuccessful in finding and refining alternativesfor their particular uses.

In response to this need, the Department ofAgriculture and Agri-Food Canada have preparedthis report, including the case studies. In addition,AAFC is creating a Web site and informationclearinghouse for methyl bromide users, andcontinuing an ongoing collaborative work withthe industry and the Working Group.

Canada continues to communicate and collaboratewith the international community through theCanada–U.S. Working Group on MethylBromide Alternatives, the Methyl BromideTechnical Options Committee (MBTOC), andthe Meetings of the Parties of the MontrealProtocol.

Several allowance holders mentioned concernsthat the U.S. was not going to eliminate methylbromide, or was going to provide an exemptionfor space fumigation. Canada maintains regularcommunication with the United StatesDepartment of Agriculture and the UnitedStates Environmental Protection Agency. Theseorganizations have reiterated their commitmentto phasing-out methyl bromide use by 2005.


INTRODUCTIONBoth field and greenhouse producers havefound alternatives to methyl bromide. Theymay have been motivated by cost, availability,safety or a change in their farming situation. Ingeneral, for every crop currently or historicallygrown using methyl bromide, it is possible tofind growers growing the same crops usingalternatives to methyl bromide.

Since the 1990s, greenhouse users have beenmoving toward soil-less mixes or pre-purchasedsterile soil, which eliminate the need for on-sitesoil fumigation. This supports the results of a1997 survey of growers, which found that othermarket factors might be driving the change tosoil-less systems (see box). Successful soil-lesssystems employ a variety of integrated pestmanagement measures, biological controlagents, and sanitation measures to control pestsand manage diseases. Some smaller operations,however, have indicated that such systems aretoo expensive or not available to them.

Many field growers have found adequate controlusing chemicals, primarily 11,3-dichloropropeneor 11,3-dichloropropene metam sodium mixes.An extensive case study of strawberry productionin Nova Scotia is provided. Growers who havesuccessfully used these products indicate thatproper preparation is essential to obtain adequatecontrol levels.

There are two potential long-term drawbacks tousing the existing methyl bromide alternativesin fields:

1. These alternative chemical fumigants arerestricted in their application due to theirtoxicity to humans and the environment.

2. While most growers have found acceptablealternatives for pest and weed control, thereis a concern among the research communitythat available chemical fumigant alternativesprovide only limited long-term disease control.

In fact, methyl bromide has been so effectiveas a disease management tool in numerouscrop systems, that very little research exam-ining diseases of the soil agroecosystemhas been undertaken. Greenhouse growerswould also benefit from a more detailedunderstanding of the ecology of disease.


Next Steps – Growers

Methyl Bromide Use in SouthwesternOntarioIn 1997, AAFC conducted a survey of 39southwestern Ontario growers who usedmethyl bromide but were not allowanceholders. These growers—29 greenhouseoperations, seven combination of greenhouseand field operations and three field-onlyoperations—were clients of a pest management professional who had been providing fumigation service for a numberof years. At that time, all of the field growersand almost one-half (14) of the greenhousegrowers had switched to alternatives; 12 were using hydroponic/rockwool systems;one was using steam sterilization; and theremaining grower was using individual potsin combination with a chemical root drenchtreatment. Though many growers were concerned with the higher operating costs,the authors of the survey noted that manyhad stopped using methyl bromide withoutknowing about the impending phase-out andban. This implies that other reasons (such as labour costs, safety, environmental considerations or market demands) mayhave motivated the switch.

The survey concluded that “Changeover toan alternative technology is not simply atechnological problem for many growers —there are issues of information availability,personal situations and the need for vision,resources and ability to manage change andthe risks posed by change.”

New chemicals that could replace methyl bromide(such as methyl iodide) are being developed,but they may not be registered in Canada due torelatively minor demand. The Pest ManagementRegulatory Agency has developed a UserRequested Minor Use Registration programthat allows users to work with a registrant tosubmit registration requests for products, forminor uses.

Other alternatives to methyl bromide which arebeing investigated are organic amendments.Research has shown that certain soils andorganic amendments (such as swine manureand pulp and paper wastes) support microbialcommunities that actively suppress disease.Many of these are already in use in organicagriculture, but their mechanisms of action arenot well understood. Plant diseases in natureare relatively rare. The vast majority of cropsare produced without fumigants. The reason whysome soils become conducive to disease whileothers are disease suppressive, is not under-stood. It is possible that a commercial-scalesoil management system incorporating organ-ic amendments could be developed to provide dis-ease control, without the use of chemical fumi-gants. Such a system could be both economicaland environmentally beneficial. More researchis needed in this area.

CASE STUDY 1: ALTERNATIVES FORSOD PRODUCTION

BackgroundCanada supports a large sod industry that suppliesrolls of mature grass to a variety of clients foruse in landscaping parks, houses, sports facili-

ties, etc. The value of sod varies between $0.80and $4.50 per yard, and is dependent on thehardiness of the sod, the species of grass andthe absence of unwanted weeds. Kentuckybluegrass (Poa pratensis) is the predominantspecies for most uses, while other grasses, suchas bentgrass (Agrostis spp.), are used for spe-cialty markets, such as golf course puttinggreens. Many of these specialty markets require100% weed-free sod for aesthetic or practicalpurposes. Annual bluegrass (Poa annua) is theprimary weed species, particularly on theWest Coast, due to its rapid growth and frequentseed production. The hardiness of the sod dependson its age and health; sod growers typicallyguarantee the survival of their transplants, andtheir reputation and sales depend on the reliabili-ty of their product.

Methyl bromide has been used extensively bythe industry as a pre-plant fumigant to sterilizesoil in order to control disease, pests and weedspecies. However, due to the high cost, its usehas been primarily limited to high-value spe-cialty crops and markets. There is considerableregional variability in growing conditions aswell as market preferences and prices. SouthernBritish Columbia’s mild winters and favorablegrowing climate have fostered a highly competitiveindustry with a pervasive Poa annua problem.In general, consumers on the West Coast (as fardown as California), have a stronger preferencefor Poa annua-free product than those in the restof Canada. In contrast, while the harsh wintersin the rest of the country create additional challenges for crop production, they also serveto provide some control over Poa annua andother weeds.

A. ALTERNATIVES FOR BENTGRASSPRODUCTION(The company wishes to remain anonymous.)

BackgroundThe company produces Kentucky bluegrassand, more recently, bentgrass for golf courseputting greens.


Sod Farming or Soil Farming?Contrary to what one might expect, sodfarming actually contributes to topsoil production. When sod is harvested, only thetop quarter of an inch of soil is removed,leaving behind 10 to 12 inches of root mass,produced during the growing period.

Methyl Bromide UseThe company has never used methyl bromide,but many of their competitors in Canada andthe U.S. do.

Current Pest Management ProgramThere are basic procedures that apply to bothcrop species that the company produces. Priorto planting, fields are treated with glyphosateand tilled to a depth of five inches using aRotavator. Crops are seeded from late April orearly May until late August, depending on whenthe last crop is harvested. Crops are typicallyleft to grow for more than one season (to ensuretheir sod strength) and are harvested from Aprilto late November. Winter snow mould protectionis required (for bentgrass) to ensure that cropssurvive the winter. Late harvested fields are leftfallow over winter. The company selects fieldswith sandy loam soil that is well drained, formaximum productivity.

In terms of Kentucky bluegrass, the companycaters to a market that does not require theproduct to be 100% free of Poa annua, andsells the bluegrass for 10 to 16 cents per squarefoot. Poa annua does not survive the coldwinter climate. Consequently, the company hasfound that they are able to control pests withoutthe extensive use of pesticides. They have foundthat the occasional use of 2,4-D, mecoprop and3,6-dichloro-2-methoxybenzoic acid throughthe growing season is sufficient for pest control.

Bentgrass sod for golf courses must be 100%Poa annua free for both aesthetic and practicalreasons. The stringent requirements of this marketsupport prices of up to 50 cents per square foot. During the growing season, the fields arefrequently irrigated, and mowed daily, to main-tain an ideal length of five sixteenth of an inch;practices that promote Poa annua growth andreproduction. Due to harsh winters, golf greensthat become contaminated with Poa annuamust be repaired or replaced each spring. Thegrass weed species does not survive the cold,resulting in an unattractive and uneven green.

Because this company has never had an allowancefor methyl bromide, they have been forced todevelop cultural and chemical practices to controlPoa annua. Chemically, they apply metamsodium (at label rates, using a custom injectionapplicator) three weeks prior to planting, whichprovides about 80% control of Poa annua. Theyremove the remaining Poa annua by hand,picking it or burning it out with a propane torch.This is extremely labour-intensive becauseidentifying Poa annua is a difficult and tedioustask. If a field becomes too polluted, the companyturns the crop under, burns it down withglyphosate and leaves it to winter fallow untilthe following year. To avoid contamination of afield, the company employees constantly washor blow off equipment between fields, and useglyphosate to maintain a five-foot buffer ofbare ground on the edges of each field.

B. ALTERNATIVES FOR SPECIALTYMARKETS – ANDERSON SOD

BackgroundFounded 26 years ago by its owners Michael,Jerry, and Steve Anderson, the Anderson SodFarm cultivates 650 acres located near Dendrey,in the Lower Mainland of British Columbia.The Anderson Sod Farm has 20 employees and produces approximately one million yards ofturf every year; a value of almost two milliondollars. The company clients include contractors,homeowners, golf courses, school boards,municipalities and parks. The company producesa variety of species: bluegrass, rye grass, andfescues; and specializes in high-quality Poaannua-free sod for specialty markets and consumerswho prefer that product.

Methyl Bromide UseAnderson Sod began using methyl bromide tokill dormant seeds in the early 1990s. Theycontract a custom applicator who uses a trackmachine to inject the fumigant to a depth of 16 to 18 inches, seals the soil with a roller andcovers the field with a plastic tarp. Fumigationoccurs in the spring, prior to planting, and provides


100% control of Poa annua. Once a field isfumigated, it will remain free of weeds unless itis accidentally contaminated by: buying andseeding contaminated seed; weed seed transportedfrom equipment or employees; or, wind transportedseed from the edge of the field.

Anderson Sod still uses methyl bromide to periodically sterilize the majority of their fields,but they have adopted and developed a numberof cultural practices that reduce the frequencyof fumigations and that in the long run willreplace methyl bromide. Using the culturalmethods described below, Anderson Sod hasmanaged to maintain their soils free of Poaannua for up to 10 years between fumigations.

Current Pest Management ProgramAnderson Sod farms 500 acres of coarse, loamysand and sandy soils, which can be harvestedyear-round; and 150 acres of heavy clay soils,which are typically too wet to access fromNovember until the end of February. The loamysoils are the preferred soils for sod production,and are periodically fumigated with methyl bromide as a response to Poa annua infesta-tion; the clay soils are not fumigated. Soil pH ismaintained at 6.5 using composted grass clippingsand lime. Depending on the soil type, harvestingcan occur year round. Seeding, using certifiedPoa annua-free seeds, occurs from April firstuntil the end of September. When possible,fields are seeded immediately after harvest.Fields harvested in the fall are seeded with fallrye as a winter cover crop; those harvested inthe winter are left bare. Prior to seeding, fieldsare treated with glyphosate, and fumigated soilsare reworked to the depth of fumigation (14 to15 inches), using a Ripper.

Fields are mowed on a weekly basis, and wateredusing wheel lines and solid set irrigation.Glyphosate is used to maintain a buffer zonearound the edges of the fields. To reverse theeffects of soil compaction, fields are periodicallyworked to a depth of 18 inches using a Ripper.Anderson Sod began developing alternatives to

methyl bromide in the 1990s, in an effort toincrease productivity on marginal land, and inresponse to the imminent phase-out of methylbromide. They experimented briefly withmetam sodium, but unable to obtain better than80% control, chose to explore other options.They currently use four common methods ofcultural control: crop rotation, winter fallow,germination cycles and sanitation, and a noveltechnique involving washed sand. Combined,these practices provide 90% to 100% control.

Crop rotation: Fields are planted with fall rye,over winter, every three years from Septemberto October.

Fallow: Fields are left fallow for one to fourmonths, over winter, every three years fromDecember to February.

Germination Cycles: Workers harrow the soil toa depth of 1-inch every 7 to 10 days to germinateas many seeds as possible. This cycle is repeatedup to five times prior to planting the seed crop,depending on the degree of weed infestation inthe field.

Sanitation: Workers and equipment are carefullywashed before entering the field to avoid crosscontamination. The workers use custom builtmowers that vacuum and collect unwanted weedseed. Collected material is then composted (thecomposting process generates enough heat tokill any seeds). Finished compost is used to fertilize and pH-balance fields.

Washed sand: This technique involves spreadinga 1 ¼-inch layer of washed sand on top of thesoil and then planting the seed crop in that layer.The sand works as an alternative to fumigationbecause any seed below the layer will not receiveenough light to germinate. Big A spreaders areused to spread the sand.

This technique has been developed over theyears. Anderson Sod has experimented withdifferent sources of sand and tried spreading it


at different depths. Washed sand purchased fromgravel pits is ideally suited to this treatment asit contains no organic material or seed, and ismore or less sterilized. As quarter of an inch ofsand is removed with the sod during harvest,new sand must be added each year resulting ina gradual increase in topsoil. Anderson Sodexperimented with spreading 6 inches of sandand reusing it each year, but found there wastoo much compaction after two years.

Another complication that required some exper-imentation to resolve, was the length of timerequired to grow a hardy crop. It takes longerfor grass to grow a root system in sand substrate;and a stronger root system than normal is requiredto support grass when it is harvested and rolledup. Dirt products are stronger and hardier. Whileat first 20 months was required to produce a crop,subtle refinements and experience have reducedthat time to as short as eight to 10 months.

Comparison of Methyl Bromide withAlternativesWhile products produced on methyl bromide-fumigated fields still fetch the highest marketprice (see box), the washed sand products andcultural methods continue to improve each yearand present a viable alternative to methyl bromide.The main additional cost associated with thecultural methods was the capital cost of the custombuilt mower with vacuum unit. However, this isused on both fumigated and non-fumigatedfields. The disadvantages of the washed sandmethod are the extra cost of equipment andmaterials (dump trucks, spreaders, loaders,sand), the labour to apply the sand each yearand the fact that there is less flexibility in termsof the time it takes to grow the crop.

CASE STUDY 2: ALTERNATIVES FORSTRAWBERRY NURSERIES

Strawberry production in Nova Scotia consistsof both berry and nursery stock transplantcrops. In 1999, strawberry nurseries produced39 million transplants, valued at approximately$3.7 million; berry nurseries produced 3.9 millionquarts, valued at approximately $5.8 million.Due to the strict phytosanitary requirements of theexport market and the Nova Scotia certificationprogram, strawberry nursery fields are routinelyfumigated to sterilize the soil prior to planting.Methyl bromide has been the fumigant of choiceto control a broad spectrum of weeds, nematodesand diseases.

BackgroundC.O. Keddy Nursery Ltd. is located in Lakeville,in the Annapolis Valley west of Kentville, NS,Canada. Charles and Doris Keddy purchasedthe farm in 1979, and have been cultivatingstrawberry plants for the transplant market eversince. The farm has 500 acres (250 cleared, 250wooded), and an additional 175 acres are rented(100 of which are intensely cropped). KeddyNursery employs an average of 10 to 15 peoplefor eight to 10 months of the year, as few asseven in the winter and as many as 90 duringthe two to three-month fall harvest. They produceexclusively nursery stock: strawberries, raspberries, rhubarb, asparagus crowns, highand low bush blueberries; for export all acrossNorth America. They sell direct, retail andwholesale, and do not use brokers. KeddyNursery produces 10 to 12 million strawberryplants per year, 200000 raspberry canes andlower numbers of the other crops.

Physical location and climateThe nursery has coarse, loamy sand and sandysoils. These soils have developed from glacialtill, have low organic matter (less than threepercent), and tend to be droughty. All fieldshave solid, set irrigation; water is collected inartificial ponds on the property. The nearby Bayof Fundy has a moderated climate. It averages


Market Price Comparison for Top GradeProducts (price per yard)$2.25 ...................... Fumigated, washed sand$1.62 ...................................... Fumigated soil$1.10 ............... Non-fumigated, washed sand$0.50–0.70...................... Non-fumigated soil

1177 mm of precipitation per year (897 mm ofwhich is rain), and has late cold springs andshort winters. It has an average of 138 frost-freedays and more than 2400 Corn Heat Units (CHU)per year. The growing season averages 203 daysin length. Planting begins as early as April 10,and harvest may run as late as December 20.The year-round average temperature is 6.8°C,with lows of –31°C in winter and highs of 37°Cin summer.

Strawberry productionKeddy Nursery caters to two distinct markets:

Southern markets – Florida, Alabama, GeorgiaKeddy Nursery grows five varieties of strawberryplant for this market, accounting for approximatelytwo thirds of their production. They purchasethe mother plants from California in late April,and plant in early May. They aim to produce atleast 25 daughter plants from each mother.Daughter plants are typically harvested from mid-September until the end of October, and shippedas a green top (living) plant to their southernclients, where they are immediately put intoberry production.

Northern markets – Canada, Northern statesKeddy Nursery grows 17 varieties of strawberriesfor this market, accounting for approximatelyone third of their production. Many of these

varieties were developed at the AAFC Kentvilleresearch station. These are planted in early May,harvested when dormant (late November tomid-December), put into storage over the winter,and then shipped out in spring. Some plantsmay be left to winter in the fields and are dugup in April. These plants will not produce fruituntil the following season.

Methyl Bromide UseKeddy Nursery used both 11,3-dichloropropeneand 1,3-dichloropropene CP until the mid-1980s.Keddy started using methyl bromide becausethey had heard that it was a superior productand very forgiving (for example, the timing ofapplication not as crucial as with 11,3-dichloro-propene). In addition to being competitivelypriced, it was what their customers in Floridawere using.

ApplicationSoils are only fumigated once every three yearsdue to the Keddy’s crop rotation program(described below). Keddy contracted a PestControl Operator (PCO) (Hendrix and Dail)from North Carolina, U.S. Soils were fumigatedfrom late August to September. The contractorsapplied 400 pounds of a 67% methyl bromide/33% chloropicrin mixture per acre,which was injected eight to 10 inches into thesoil using PCO’s custom applicator. A 0.5 mmplastic tarp was used to cover the soil andincrease methyl bromide retention. The fieldswere then left undisturbed for a minimum offive to seven days, before planting a wintercereal crop (rye or wheat).

Preparatory work prior to fumigationThe preparatory work prior to fumigation was thesame as for 11,3-dichloropropene, described below.

EfficacyMethyl bromide provided excellent, consistentcontrol (90% to 95%) of nematodes, weeds andsoil-borne diseases.


Nova Scotia Strawberry CertificationAgriculture and Agri-Food Canada and theNova Scotia Department of Agriculture andMarketing have developed a policy, in aneffort to increase the productivity of NovaScotia’s strawberry fields and meet phytosani-tary requirements for the export of nurseryplants.

The plan has been carefully developed toreduce viral diseases, mycoplasmic diseases,fungal diseases, bacterial diseases, andinsect and mite infestations.

Rationale for phasing-out methyl bromideKeddy stopped using methyl bromide in early1994–95 because: Canada had decided toimplement a quota system to gradually phase-outthe use of methyl bromide; with the reductionof Keddy Nursery’s quota, they were limited asto how much acreage they could fumigate withmethyl bromide, and needed alternatives for theremainder; the cost of methyl bromide wasincreasing due to the poor Canadian–U.S. dollarexchange rate; they were concerned aboutincreasing landfill costs to dispose of the plastictarp; and they had always continued to use11,3-dichloropropene on parts of their fieldsand felt confident that it would be an effectivereplacement.

Current Pest Management SystemThere were not many alternatives to methylbromide available at the time Keddy Nurserystarted its operation. They resumed the use of11,3-dichloropropene at 38 gallons per acre.The Keddys also tried using a combination of 25 gallons per acre 11,3-dichloropropene and 25 gallons per acre metam sodium. Thiscombination was comparable in cost to using11,3-dichloropropene alone, and providedslightly (5% to 10%) better control. However,they were more labour-intensive to co-apply,and required renting a more expensive Rumptstad-brand applicator to inject the metam sodiuminto the top four inches of soil. As a result, theydecided to purchase a conventional s-tinebroadcast applicator (from Agrispray) andreturned to using 11,3-dichloropropene alone.

In Keddy Nursery’s current system, crops arerotated on a three-year cycle (nursery crop,rotation crop, green manure crop) to controldisease, improve soil-health, and reduce theaccumulation of weed seed stock in the soil.Consequently, only 85 acres (24%) are used forthe nursery each year, of which 70 acres (20%)are used for strawberry transplant production.

Nursery stock is planted in the spring of yearone; strawberry nursery stock arrives in late

April and daughter plants are started as soon aspossible, typically May 1. Mechanical cultivationis undertaken every seven to 10 days throughoutthe growing season. Herbicides are not used;any remaining weeds are removed by handwhen picking flowers or setting runners. Plants are harvested from mid-September untilmid-December. Plants exported to the southernmarket are harvested by mid-October, and thenthe fields are planted with a winter cereal crop(rye or wheat). This serves both to protect thesoil during the winter months and to reduce theworkload in the spring. Plants destined for theNorthern market are either harvested Novemberto December and placed in storage, or coveredwith straw and left in the ground until earlyApril. These fields are then planted with aspring grain crop (barley or oats).


Pests of issueWeeds include shepherd’s purse (Capsellabursa-pastoris), common chickweed(Stellaria media), St. John’s wort (Hypericumperforatum), mouse-eared chickweed(Cerastium fontanum), sand spurry(Spergularia rubra), lamb’s quarters(Chenopodium alba), redroot pigweed(Amaranthus retroflexus), white clover(Trifolium repens), low cudweed (Gnaphaliumuliginosum), fireweed/willow herb (Epilobiumspp.), pineapple weed/scentless chamomile(Matricaria spp.), common purslane(Portulaca orleracea), sheep sorrel (Rumexacetosella), plantains (Plantago spp.), annualgrasses (Digitaria spp., Echinochloa crus-gali), Bluegrasses and bentgrass (Poa andAgrostis spp.), sedges (Carex spp.) and rush-es (Juncus spp.).

Other pests include Root Lesion and RootKnot nematodes (Pratylenchus penetrans,Meloidogyne hapla), Verticillium wilt(Verticillium albo-atrum, Verticilium dahliae),Black Root Rot (caused by Fusarium,Cylindrocarpon, Rhizoctonia) andRhizoctonia Root Rot (Rhizoctonia solani).

The winter cereal and spring grain crops are leftto grow throughout the spring and summer ofyear two. Herbicides are rarely used on thesecrops. They combine the fields in late August;sell the grain; and keep the straw for mulching.The fields are then harrowed and planted with awinter cereal crop (rye or wheat).

Keddy Nursery workers leave the winter cropto grow until mid-June of year three and thenplow it into the fields as green manure. Theythen summer fallow the fields to get them intoseed bed condition. The workers try to harrowthe fields every seven to 10 days to germinateas many weed seeds as possible and break downany clumps of organic matter. They fumigatethe fields in late August or September, dependingon the soil moisture (Also see example in boxon the right).

Keddy applies 11,3-dichloropropene at a sterilantrate of 38 gallons per acre, as indicated on thelabel. The applicator’s tines are eight inchesapart, and inject the fumigant eight to 10 inchesinto the soil. A power roller seals the furrowand packs the surface to increase fumigantretention. Soil moisture is crucial to ensure

adequate fumigant retention. Charles Keddyassesses soil moisture by grabbing a handfulof soil from a depth of six to seven inches, andthen balling the soil in his hand. If it staysclumped together, there is sufficient moisture toproceed with fumigation.

Two to three weeks after treatment, KeddyNursery direct-drills a winter cover crop (rye orwheat). In the springtime they apply glyphosateto kill the cover crop, then harrow the fieldsand plant nursery stock again.


Strawberry Tyme Farms, of Simcoe, Ontariouses a similar system of pest managementwith their strawberry and nursery stock.John Cooper follows a crop rotation programjointly administered by the University ofGuelph, the Ontario Berry Growers Associationand Agriculture and Agri-Food Canada. He uses a pre-plant herbicide (trifluralin) in the top two inches of the soil, hand-weeds asnecessary, and fumigates fields with 11,3-dichloropropene or metam sodium, dependingon the disease history of the field. In hisexperience, metam sodium is less expensivethan 11,3-dichloropropene, but provides inferiordisease control. Both fumigants’ efficiency is increased with good soil moisture, but significantly decreased if it rains within threedays of application.

Non-chemical alternatives to methyl bromideused at C.O. Keddy Nursery Ltd.• Crop rotation – Cultivation of successive

crops that are non-hosts, less suitable hosts,or antagonistic crops for the target pests.

• Fallow – Temporarily taking land out ofproduction to reduce soil pest populationsby denying them hosts or substrate fortheir development and exposing them toadverse environmental conditions.

• Soil amendments and compost – Addinggreen manure and other organic amendmentsto control certain soil-borne pests in variouscrops, and to add nutrients to the soil.

• Mulching and cover crops – Mulches(soil covers), cover crops and greenmanures can be used to control a widerange of soil pathogens and insects.

• Sanitation – Sanitation is the avoidanceor elimination of pathogen inoculum orpest sources (such as infected plant residues)before planting. Seedbed sanitation incommercial production permits bettermanagement of disease problems in horticultural and other crops.

• Germination cycles – Germination cyclesare used for additional weed control. Duringsummer fallow the soil is harrowedevery seven to 10 days with the objectiveof germinating any seeds that are presentin the soil, so that the planted crop doesnot compete with other crop species.

Comparison of Methyl Bromide withAlternativesKeddy finds that they have excellent (90% to95%), consistent control of nematodes, weedsand soil-borne diseases with 11,3-dichloro-propene. According to Keddy, the key factorsare properly preparing your soil so that it is inseed bed shape at the time of fumigation; ensuringthat there is adequate soil moisture before fumigating; and allowing adequate time (two to three weeks) for the treatment to take effect.

When Keddy made the switch to 11,3-dichloro-propene in 1995, he found the cost to be thesame as using methyl bromide. Today, giventhe limited supply of methyl bromide under thequota system, and the strength of the U.S. dollar,11,3-dichloropropene is much less expensive.Methyl bromide’s advantages are that it is moreforgiving if you have not adequately preparedyour soil, and that it acts faster–five days, ascompared to up to 21 days for 11,3-dichloro-propene. The disadvantage of methyl bromidewas the additional work to tarp the fields.

Keddy would like to use products with higherchloropicrin content for improved disease control. The Keddys recently participated infield trials of 35% chloropicrin, which has ahigher chloropicrin content and is not currentlyregistered for use in Canada. They found that it, at 25 gallons per acre, provided excellentcontrol, but the trials were not comprehensiveenough to draw other conclusions.


Farmers Teaching FarmersKeddy and Cooper believe the key to successis in knowing what you want to accomplish,and applying common sense to achieve yourgoals. They developed their techniquesthrough careful trial and error. They are opento sharing their experiences with other growersinterested in reducing their dependence onmethyl bromide. They can be reached at:

Charles Keddy, Keddy Nurseries982 North Bishop Road,Kentville, NSB4N 3V7Telephone: 902-678-4497Fax: 902-678-0067E-mail: [email protected]

John Cooper, Strawberry Tyme FarmsRR2,Simcoe, ONN3Y 4K1Telephone: 519-426-3099Fax: 519-426-2573E-mail: [email protected]

INTRODUCTIONThe food-processing sector is a major contributorto the Canadian economy. It contributes to economic growth by acting as a supplier offood and providing a market for agriculturalproduction. In terms of its relative size, Canada'sfood-processing sector, trade and processingintensity is similar to those in other large industrialcountries. In 1999, the sector produced shipmentsvalued at $49 billion and provided over200000 jobs. Most processing activity in thesector occurs in central Canada, but the sectoris relatively more important to the economiesof the Prairie and Atlantic provinces.

Food processing facilities in Canada, particularlyflourmills, usually run 24 hours a day, sevendays a week. Tremendous costs are associatedwith shutdowns. While this high and constantproduct flow maintains a relatively pest-freeproduct stream, the real challenges lie in managingthe buildings themselves. As food is processed,there are numerous opportunities for insectsand pests to access the system: bulk ingredientdelivery and storage, product spills and dustthat settles in inaccessible areas of buildingsand equipment, and blockages in the flow ofproduct between processing steps. The presenceof food, warm temperatures and the structure of the building make flour mills the perfectenvironment for insect growth. Regular equipmentcleaning and maintenance are therefore crucialto maintaining product flow and managing pestpopulations.

Pest Management in the Food ProcessingIndustryThe food-processing sector has been using methylbromide extensively to control pests in flourmills,warehouses, storage bins and production areas.The primary pests are rats, mice, red flour beetlesand confused flour beetles. Less common pestsare pigeons, rusty grain beetles, Indian mealmoth, dermestid beetles, sawtoothed grain beetles, and merchant grain beetles.

Several regulations control pest management inthe food processing industry. First, there is aspecified limit on the percentage content ofinsect parts in products. Because flour mills’product is food, there are strict Health Canadaregulations regarding what pest control productscan be used in a food processing facility, andunder what conditions. Some exporters arerequired to obtain a phytosanitary certificatefrom CFIA inspectors, to assure the exportingparty that their products are (quarantine) pest-free.

There are renewed discussions on whether thefacility-qualifying process should focus on pestmanagement in the product stream or on thebuilding itself. At this time, the focus is on both.Some representatives of the milling industry arearguing that because of Entoleters (a machinethat consists of rotating disks with pins thatpulverize any remaining insects – see box),their product is insect-free, regardless of whatinsect populations might exist in the rest of thebuilding. They complain that in the past theyhave been penalized by "one insect" rules. TheCFIA, in consultation with the millers, is in theprocess of examining and revising its inspectionprotocols and procedures.


Next Steps – Space Users

The Milling SectorThere are 40 mills in Canada, which produced$1.2 billion worth of product and employed2000 people in 1996. The basic process ofmilling involves several distinct steps: grainreceiving, grain blending, cleaning, temperingwith the addition of water, a resting periodof approximately 20 hours, milling into flour,then flour packaging or bulk flour delivery.At the end of the milling process and priorto packaging, all the white flour is passedthrough an impact mill or Entoleter, a machinethat consists of rotating disks with pins thatpulverize any remaining insects.

Pest management in mills and in the food processing industry has historically been, and in many instances still is, reactive instead ofproactive. Factories have generally contracted apest management contractor only in the eventof a noticeable infestation or emergency. In thepast, pest managers did not have to have in-depth knowledge of the biology of the pestsbecause of the chemicals at their disposal andthe industry’s desire for inexpensive treatment.At best, the role of pest managers has been toset traps, use trap counts to identify whetherpests are reaching hazardous levels, and theneliminate the pests through the application ofvarious chemicals (such as methyl bromide).Methyl bromide has long been the structuralfumigant of choice due to its cost, availability,rapid action, lack of residue, and broad-spectrumactivity. A factory’s idea of proactive controlhas been to schedule regular fumigations (i.e.once or twice a year), regardless of pest levels.The main shortcoming of this old approach isthat it fails to address the source of the problem,which is the fact that the facility and the processitself help the growth of pest populations.

The major pest management companies inCanada believe that the old approach is inefficientand does not effectively deal with the source ofmost infestations. New regulations concerningpesticides have also influenced attitudes. Manypest management experts argue that improvedsanitation and maintenance programs–combinedwith physical modifications to the structure andequipment itself–can reduce the habitat availableto pests populations, so that plant shutdownsfor full-scale fumigation are not necessary. Thecosts of fumigating with methyl bromide or analternative, are significant. The entire facilitymust be sealed to make it relatively airtight, thefumigant must be purchased and applied, andthe facility must be shut down for the durationof the treatment, resulting in lost productivity.There are also complications related to humanhealth and safety, particularly if the facility islocated in an urban setting.

Specialists in the area of insect infestation supportthe application of Integrated Pest Management(IPM) strategies that take a more holisticapproach, dealing with the root cause of theproblem and not just the symptoms. IPM isoften most effective when applied in conjunctionwith food safety and integrity systems, such asHazard Analysis of Critical Control Points(HACCP). IPM is a holistic approach to pestcontrol that uses biological, cultural, physical,mechanical, and chemical methods to monitorpest levels; identify and eliminate habitat; anddevelop systems of maintenance, sanitation andinspection that prevent or manage pest problems,in an environmentally sound and cost-effectivemanner. An important element of this programis to shift the perception of sanitation as a low-skill, low-value job, relegated to a few specificemployees, to the understanding that sanitationis every employee’s responsibility and is vitalto the smooth operation of the facility.

The case studies in the next section highlightsuccess stories of companies using a broadspectrum of IPM strategies; from fumigationswith alternatives (such as phospine) to sanitationsystems that have completely eliminated theneed for full-scale fumigation. These studiesshow that many facilities have been able toimplement effective, economical alternatives tomethyl bromide, while remaining competitive.Many of these alternatives have resulted in betterpest control than methyl bromide could offer.However, there remains an information gap.

Many mills and food processing facilities have beenreticent in accepting the imminent phase-out ofmethyl bromide. Others see the alternative fumigantsand “deep cleaning” techniques as prohibitivelyexpensive and ineffective, without ever havingexperimented with them in their facilities. Pestmanagement professionals must continue to educatethemselves and their clients on the advantages andlimitations of using methyl bromide alternatives,and must continue to refine these techniques.Clients must take a more pro-active and involvedapproach to pest management in their facilities.


ELEMENTS OF AN EFFECTIVEINTEGRATED PEST MANAGEMENT(IPM) STRATEGY

IPM is a holistic approach to pest control thatuses biological, cultural, physical, mechanicaland chemical methods to monitor pest levels.The approach also identifies and eliminates pesthabitat, and develops systems of maintenance,sanitation and inspection that prevent or man-age pest problems; all in an environmentallysound and cost-effective manner.

Gather informationEnlist the management – To facilitate and expeditethe process, it is necessary to consult with themanagers, who know the facility and canauthorize any changes or expenditures. A teamshould be assembled that includes managers ofmaintenance, sanitation, quality assurance, pestcontrol and production, as well as the plantmanager. The suppliers and the clients of thefacility should be contacted and asked abouttheir needs and pest management protocols.

Understand the facility – It is critical to examineevery square inch of the building to identifypotential pest habitat. This includes examiningthe structural layout of the building to locatedead spaces in the walls or under the floors thatcould be potential pest entry points. It is necessaryto learn how each piece of equipment works,how it is cleaned, how it comes apart, and whatpest control methods have been tried and arecurrently in use. The maintenance and sanitationschedules and routines should also be reviewed.

Understand the pests – Traps should be set outand pests correctly identified. It is necessary toresearch their lifecycle, nutrition, and habits toidentify potential habitat, points of entry, feedingand reproductive areas, in the facility.

Develop a pest management planKnowledge of the biology of the pests and thestructure of the facility should be applied to locateand eliminate infestations. A pest managementplan should then be developed to prevent re-infestation by eliminating food suppliesand habitat, disrupting reproduction, and block-ing entry points. Working with both employeesand a team of experts allows the development of innovative, cost-effective solutions. The system can later be optimized through continualmonitoring and evaluation.

A short-term pest management plan does notnecessarily involve fumigation or fogging;these methods often deal with the symptoms,and not the cause. For instance, Indian mealmoth eggs require 25 days to develop to theadult stage. In some cases, simply ensuring thatevery part of a facility is cleaned and inspectedevery 25 days can prevent the moth from reproducing; eliminating the source of theinfestation.

The long-term pest management plan mayinvolve major structural changes to the facilityand significant capital investment. By workingwith the management team, one can identifysolutions that combine pest-related changes withother benefits, such as reduced maintenance orcleaning time, improved air circulation, and otherbeneficial structural, maintenance or qualitycontrol changes.


Elements of a pest management plan• Good sanitation practices• Building maintenance• Exclusion practices• Inspections and monitoring• Pest identification• Physical and chemical controls• Building and materials design and

retrofitting

For further reading on this subject please referto: Integrated Pest Management in FoodProcessing: Working Without Methyl Bromide,and the accompanying brochure IntegratedPest Management in Food Processing:Adapting to the Phase Out of Methyl Bromide.Both are available on the PMRA’s Web site at:http://www.hc-sc.gc.ca/pmra-arla/english/pubs/spm-e.html.

CASE STUDY 1: PILLSBURY CANADALTD. (IPM)

BackgroundPillsbury Canada Ltd., located in Midland, Ontario,produces a line of flour-based refrigerateddough products and frozen pizza snacks. Theplant employs approximately 29 salaried and190 hourly employees. The Quality AssuranceManager, Jim Bales, has been with Pillsburysince 1972.

Pillsbury Canada Ltd. has been in their currentlocation since 1974. The plant consists of threeconnected structures: an office building, a threelevel concrete block building that houses two36000 kg (80000 lbs) flour bins, and the mainplant area. The main building is a Butler-stylebuilding that is metal clad on the outside; structural steel supports roof and cement blockwalls from the inside. The peak of the buildingis approximately 30 feet high, 25 feet on thesides. The total area occupied by the plant andoffices is approximately 80000 square feet.

A mixing area occupies one end of the building.The mezzanine above it, houses the dry batchingsystems. The rest of the building is divided intothe main production floor, a refrigerated/frozenfood storage area and a dry goods warehouse.Half of the production area is devoted to cookiesand refrigerated dough products, and half topizza products.

Methyl Bromide UsePillsbury Canada Ltd. is an example of a well-designed IPM system eliminating the need forfacility fumigation with methyl bromide, or analternative. Pillsbury has never used methylbromide, although many of their competitorshave, and still do. Pillsbury has used phosphineoccasionally, but not in the recent past. Theiroriginal pest management system required regularchemical use and involved regular cleaning. Italso included monthly inspections by an externalpest control operator, fumigations of the bulkflour bins with aluminum phosphide, and spotfumigations in response to localized infestations.They used ethylene dibromide as their spotfumigant, until its deregulation in the 1980s.

Current Pest Management ProgramPillsbury Canada Ltd. decided to implement IPMpractices in their plant in 1997. They contractedSteritech Group Inc., a food safety and environmental hygiene company based inMilton, ON, which has four affiliate companiesthroughout Canada. On the food safety side,Steritech performs food safety audits and developsmanagement systems using Hazard Analysis of Critical Control Points (HACCP). On theenvironmental hygiene side, Steritech providespest management services to their clients in thefood industry, as well as other large commercialstructures such as office towers and shoppingmalls. Steritech specializes in developingIntegrated Pest Management (IPM) systems.

Key Pest Control Issues and the IPMSolutions

BackgroundGiven Pillsbury’s large volume of production,flour dust in the air has always been an issue.At full production, as much as 36000 kg(80000 lbs) of flour is sifted, weighed and mixedevery 24 hours. This can create a substantialvolume of dust that will settle out on every surfaceof the building, including difficult to accessareas. Using IPM, Pillsbury re-evaluated itscleaning strategy and made a series of changes.


Step 1: Adopting a new approach to cleaningPillsbury staff was trained to be more aggressivein their approach to cleaning. They startedusing brushes and taking equipment apart, asopposed to just cleaning surfaces. Staff wastrained to be proactive and to identify and reportthe potential “hot spots” before infestationoccurs. At the outset, they conducted a thoroughcleaning of the entire factory, opening andcleaning every piece of equipment, includingitems such as square conduit runs and electricaljunction boxes; places they had never examinedclosely before. Empty spaces were then injectedwith diatomaceous earth (DE) to prevent infestationbetween cleanings.

For the Pillsbury staff, cleaning has become atool used for both the prevention and the treatmentof infestations. General cleaning occurs on adaily basis, and intensive “deep cleaning” is aregular part of their master sanitation schedule(weekly, monthly or quarterly). While in thepast infestations were treated by superficialcleaning, spot fumigation and the use of residualchemical pesticides, they are now able to controlinfestations by conducting a thorough cleaningof the area; identifying the root cause of theproblem and then adjusting their sanitation program to prevent re-infestation. The staff alsohas the option of using DE, a non-chemicalresidual pesticide.

Step 2: Upgrading equipment to reduce dustPillsbury installed a central vacuum system forcleaning the building and equipment. This helpedto minimize the use of compressed air blowers(40 psi safety nozzles), which had contributedto the dust accumulation in the plant. Pillsburyalso installed upgraded dust collectors. The disadvantage of vacuuming is that it can takelonger to clean an area.

Production methods were examined to identifysources of flour dust. For example, in the cookiedough-making process staff weighed out thedry ingredients for the product and poured theminto a hopper over the dry blender, creating a


Replacing fumigation with cleaningTraditionally, Pillsbury’s employees cleanedand fumigated the flour bins with aluminumphosphide, as required. They monitored tailings from the flour sifters for insects andscheduled additional fumigations in responseto infestations.

Pillsbury has managed to eliminate the needfor fumigations by contracting out the annualcleanings to professionals, who do a morethorough job. They have expanded thecleaning of the bins to include a completedisassembly of the filter sock units andexhaust ducts, on top of the bins. The staffmonitors tailings on a daily basis and keepsdetailed records. This allows them to trou-bleshoot potential problems.

When insects are found in the tailings, theyexamine the filters on top of the bins, andthen contact their supplier. Inspections ofincoming flour trucks are also a part of theoverall program. In the unlikely event of amajor infestation, the staff is prepared to useheat treatment in place of fumigation.

Conduit junctions were opened up, inspectedand DE blown in.

lot of dust. They solved the problem by installinga vacuum-conveying unit that delivered theingredients to a closed hopper, eliminating the dust.

Step3: Being proactive – Inspections andMonitoringThe tailings from the flour sifters have alwaysbeen inspected on a daily basis for the presenceof insects. Pillsbury keeps detailed records thathelp to troubleshoot a problem and better evaluatewhether the source of the infestation is internalor one of the suppliers.

With IPM, Pillsbury changed from monthly toweekly pest prevention inspections, and set upa logbook and a voicemail phone line (dial “bug”)for employees to record any insect sightings orpotential problem areas. Steritech has alsoimproved the quality of the monitoring by

conducting more thorough examinations; correctlyidentifying pest species; and reporting any relevantstructural and cleaning problems they encounter.Steritech established a routine of checking sticky-,mechanical-, and pheromone-traps located invarious areas inside and outside the Pillsbury plant.Whereas the original pest prevention operatorrelied heavily on the company’s inspections forinformation, Steritech is more proactive, conductingtheir own inspections and constantly pushing thecompany to follow up on any problems they find.

In general, adopting an IPM system has led to amore holistic approach to pest prevention. Easeof cleaning, maintenance and sanitation are keyconsiderations when purchasing new equipment,renovating and retrofitting. All capital projectshave approval sign-offs by the Quality Assuranceand the product safety people, who look at howthe projects will impact the ease of cleaning.Contractors are given strict instructions on howto carry out the repairs so that there are no safetyor infestation risks created.

Comparison of Methyl Bromide withAlternativesPillsbury Canada Ltd. has not conducted adetailed analysis of the costs and benefits ofimplementing IPM as compared to their traditionalpest prevention. However, Jim Bales feels confident that the benefits do indeed outweighthe costs, and Pillsbury had no difficultyremaining competitive.

In terms of cost, Steritech’s pest preventionservices are significantly (2 times) more expensivethan Pillsbury’s previous contractor, partly dueto added services. There have been additionalcosts over the years for equipment (central vacuumsystem, vacuum conveying system, dust collectors,etc.), and some initial increased labour costs forsanitation. However, it is Jim Bales’ experiencethat these costs can be greatly reduced by working“smarter” and more efficiently. This includesscheduling the detailed cleaning of known “hotspots”, and cleaning at intervals that break thelife cycle of the pest they are trying to control.


ProblemThe mezzanine wall was a frequent site ofinfestation of confused flour beetles. In thepast, each infestation was treated with spotfumigations and surface cleaning, which onlysolved the problem for a short period of time.Steritech determined that the root cause of theproblem was inside the blocks themselves.Over the years, various configurations ofequipment had been mounted to the wall andthen moved around. Poor practices hadresulted in a number of unsealed holes,through which flour had accumulated insidethe cement blocks. Replacing the blockswould have been prohibitively expensivedue to the structure of the wall.

SolutionDiatomaceous earth (DE) was blown insidethe blocks through one-centimeter (3/8 inch)diameter holes, drilled into the side of thewall. The wall was then completely sealed,including the areas where pipes and otherequipment penetrated the block. There havebeen virtually no sightings in that area in thetwo years since the treatment.

Savings result from having no fumigation andassociated plant shut-down costs ($7000 to$10000 per day), and knowing that with thecontrols Pillsbury has implemented, it is highlyunlikely that an infestation could develop to alevel that would seriously impede production or require plant shut down. There are also theenvironmental, human health and marketingbenefits of not using pesticides in the workplace.

CASE STUDY 2: ROGERS FOODS LTD.

BackgroundThe Rogers Foods Ltd. flourmill is located inArmstrong, B.C., just north of Kelowna. Itemploys 95 people and processes approximately220 tons of wheat, producing whole wheat andwhite flour products, as well as granola for groceries and bakeries. Rogers caters primarilyto the Canadian market, with limited export toPacific Rim countries. Rudy Bergen, VicePresident in charge of Quality Assurance, has beenoverseeing Rogers’ pest management systemsince 1981.

The mill (about 2000 m3 in size) is housed in afive-storey cement building, and there are threeadjacent warehouses constructed of cinder blocks.There are five floors of grain cleaning equipmentand five floors of milling equipment, arrangedto allow the product to be gravity-fed betweenfloors. The mill was built in 1979 around anolder, wooden building, constructed in 1950.This central wooden structure is slowly beingreplaced, but while it remains it presents uniquepest control issues.

Rogers mill is located in the Okanagan Valley,and is surrounded by farm fields of barley andwheat, which are ideal rodent habitat. The climatesupports a vibrant insect population. There is along summer season with extreme heat (up to40°C), and mild winters, with average temperaturesof zero to –2°C, thus ruling out cold treatments.The fall is extremely wet and the summerextremely dry.

Methyl Bromide UseRogers conducts a major fumigation once everysummer. In the 1980s, they experimented withmethyl bromide and phosphine, alternatingtreatments each year. They found that phosphineprovided better pest control for their mill. Theyalso found that they were unable to maintaintarget concentrations inside the building withmethyl bromide, but could with phosphine.

Current Pest Management ProgramBergen describes four key elements of their system:sanitation, monitoring, residual insecticides andfumigation.

SanitationIn terms of cleaning, each department has beenmade responsible for their own basic sanitation.In the past, a separate sanitation department,consisting of three employees, was responsible forthe entire plant. This, however, was ineffectiveas department workers tended to be carelessand rely on others to clean up for them. Now,every employee is trained to identify problemareas and report any and all insect finds.

MonitoringWhile Rogers’ staff are responsible for manyelements of the pest management system, theyalso contract a pest management expert whoconducts weekly inspections of the facility;operates and maintains rodent traps outside the building; and works with Bergen to identifymanufacturing issues which need to be addressed.

Residual InsecticidesThe facility is fogged with pyrethrins everymonth in the summer, and every second monthin the winter. Diatomaceous earth (DE) isblown into spaces in equipment and cracks inthe floor, to provide residual control of insects.

FumigationRogers conducts a major fumigation with phosphineonce every summer; in-house staff conducts thefumigation during the August long weekend.


A successful fumigation requires extensivepreparation. Maintenance crews begin workthree days before the fumigation and extra staffis hired for the day before. The entire buildingis sealed using plastic sheeting and duct tape,cracks are filled with silicone, and vents andchimneys are blocked. The phosphine itself isapplied using Aluminum phosphide (aluminumphosphide) pellets. Three-by-four- foot sheetsof paper are spread out in various locations onevery floor of the building.

On the day of the fumigation, five teams of twoenter the building and spend 15 minutes spreadingthe aluminum phosphide pellets on varioussheets of paper. Once exposed to air, the pelletsreact to produce phosphine gas. Phosphine levelsare monitored in parts per million (ppm) usingDräeger hand pumps. The objective is to maintainthe target application dose for at least 48 hours.This typically requires the building to be leftsealed for three days, and then opened up bystaff wearing protective clothing and SCBAequipment. Once open, the phosphine dissipatesfrom the building in approximately 18 hours.The time required for treatment is influencedby humidity and temperature. Consequently,pails of water are placed throughout the facility toincrease humidity, and the fumigation is conductedduring the hottest weekend of the summer tomaximize the rate of phosphine production andto increase the sensitivity of insects.

Comparison of Methyl Bromide withAlternativesThe major criticisms of phosphine are that it iscorrosive to metals and requires a longer treatmenttime than methyl bromide. In Bergen’s twentyyear experience and sixteen treatments withphosphine, he has had only minor corrosionproblems. His opinion is that its detractors havegreatly exaggerated this issue and attributed routineelectrical failure after shutdown to phosphinecorrosion. In terms of time, the experience andexpertise have allowed the entire procedure tobe conducted with only a four-day shutdown.Bergen’s long-term goal is to eliminate the need

for fumigation through better sanitation andother chemical and non-chemical controls. Thecompany is also experimenting with full-buildingspot heat treatment. They conducted a trial of enhanced diatomaceous earth (EDE) andsuperheated air in May 1997, and obtained100% control of the test insects in just over 24 hours. While this option was considerablymore expensive than phosphine, due to the costof renting heaters, Bergen is investigating theoption of purchasing equipment to implementthis method as a long-term solution.

CASE STUDY 3: PEST MANAGEMENTPROFESSIONALS

BackgroundTepeco Consultants Inc. was founded in 1973with the sole purpose of minimizing or eliminating pesticide use in food processingplants. Tepeco is highly selective in its choiceof clientele, developing pest prevention andproduct integrity (HACCP) programs for asmall number of medium and large facilitieswith management that is committed to Tepeco’sprinciples. Tepeco believes in going beyondpest management to pest avoidance and prevention,by applying three major principles: exclusion,harbourage removal, and structural and equipmentmodification. In their experience, the additionallabour and capital costs are offset, in the longterm, by increased efficiency and the elimina-tion of plant shutdowns, for fumigation.

Tepeco acknowledges the cooperation of individuals like Mr. Bruce Scott, and the management teams of such forward thinkingcompanies as ADM Milling Company and Lipton(a division of UL Canada), whose commitmentto food safety and product integrity is an essentialcomponent of Tepeco’s programs.

A MIX PRODUCERIn 1982, Tepeco began working with a three-storey50 000 sq. ft. facility that produced and packagedfood mixes (cake mix, doughnut mix, etc.) fortheir clients. The facility subsequently added a


single storey (20000 sq. ft.) warehouse for storageand loading. In this facility ingredients enter thesystem from the top floor, are mixed on the secondfloor, and are dispensed from packaging hop-pers on the bottom floor. An open area on thebottom floor is used for packaging the productinto two to 50 kg bags. Flour and sugar arestored in bulk storage bins. Other ingredients(spices, oils, flavourings, leavenings, etc.) arestored in bags. The facility is run in two shiftsand employs fewer than 65 people. The facilityuses some 350 raw materials to produce over300 different bakery mixes.

ProblemPest management prior to Tepeco’s involvementincluded weekly spraying with residual insecticides,weekly thermal fogging with pyrethrins throughoutthe summer; and one or more methyl bromidefumigations per year. Despite these efforts, thecompany complained of continual pest problems,commenting that the “bugs flew back in, theminute the door opened after a fumigation”.

SolutionsWith the support and co-operation of plantmanagement, Tepeco:

Eliminated harbourage by applying the principlethat structures and equipment must be 100%open or 100% closed. Tepeco went through theentire building and repaired cracks and crevicesin the walls and floors. They removed dropceilings that were collecting dust and foodresidue; “insect proofed” doors and entrypoints; replaced solid shelving with open meshshelving; replaced, encapsulated or removedinsulation; and ensured that all equipment wasinstalled flush to the floor. In collaboration withplant management, Tepeco also made extensivechanges to the electrical systems (over time),eliminating harbourage areas (such as replacementof splitter boxes, disconnect switches, etc.) byreplacing them with dust-proof units. Theworkers relocated electrical boxes away fromthe production and high-dust areas. They also

installed open grate mezzanines to provide accessto the sides and ledges around flour storage binsfor cleaning.

Modified equipment to ensure the smoothmovement of product without rough spots,ledges or pockets that accumulate product;installed proper sifters and a tailing monitoringsystem to ensure accessibility for maintenanceand cleaning; and installed dust-collection vacu-um systems over mixers. Implementation of aHACCP program and documentation, ensuredthat inspections of equipment were performedand that critical items in the system (sifterscreens, unloading screens, etc.) were in properoperating condition.

Developed regular cleaning and maintenanceschedules for the equipment and physical facility,and proper procedures for shut down. Tepecohelped establish and perform weekly managementinspections to ensure that facility cleaning wasperformed properly. The company helped withmaintenance schedules, putting a particularemphasis on items such as blower filters anddust-collection systems, because these present agreat risk as harbourage areas.

ResultsTepeco has eliminated weekly residual applicationsand summer weekly thermal foggings of thefacility. As a result, the facility has not requireda general fumigation since 1982. Chemicaltreatment is largely limited to occasional binfumigation with phosphine (in the event of thearrival of contaminated product) and occasionaluse of small quantities of methyl bromide, iflimited time is available.

A flour millIn 1976, Tepeco began working with a typicalmedium-sized Ontario flour mill. The facilityconsists of a 100-year-old, five-storey stone wallbuilding, a shipping and receiving warehouse, aloading building, a load-out building, andwheat storage silos.


ProblemPest management prior to Tepeco involvementPrior to Tepeco’s involvement, the mill wasoperating five days a week. Pest managementconsisted of annual facility-wide fumigationwith methyl bromide in the summer, a monthlyresidual spraying, with malathion, of the entireplant (during a closed-down weekend) alongwith spot fumigation, with methyl bromide, and spot treatment of equipment with ethylenedibromide.

SolutionsWith the involvement of the mill superintendent,using maintenance, regular cleaning and inspection,and equipment modification, Tepeco has reducedchoking events by over 95% and eliminated theneed for spot and general fumigation, and residualspraying. Chemical treatment, typically triggeredby infested wheat, is now limited to ULV foggingwith pyrethrins, as needed, during long weekends(up to four times per year). Since 1978, the millhas conducted a single methyl bromide fumigation,which was necessary because of a long periodwithout shut down which disrupted regularmaintenance and cleaning procedures.


Cost Comparison of Methyl Bromide with its Alternatives

Treatment Cost Down Time Damage

Aluminum

Phosphide

$ 8,600 Labour (in-house)

$ 800 Fan rental

$ 600 Draeger tubes, lock change, back hoe, filling air tanks

$ 6,000 Aluminum phosphide

$ 16,000 TOTAL

96 hours Minor, electrical

Methyl Bromide $ 8,600 Labour (in-house)

$ 15,500 Contractor

$ 900 Fan rental, lock change, air tanks

$ 5,000 Methyl bromide

$ 30,000 TOTAL

40 hours None

Heat $ 3,800 Labour (in house)

$ 29,800 Heater rental and technology

$ 5,800 Power consumption

$ 600 Fan rental

$ 40,000 TOTAL

45 hours Melted someplastic partsand fuses

Heat + DE $ 8,250 Labour (in-house)

$ 2,200 Heater rental

$ 1,200 Oil for heaters

$ 400 Fan rental

$ 150 Protect-it (DE)

$ 11,200 TOTAL

48 hours None

Recommendations for pesticide use in this publication are intended as guidelines only.Any application of a pesticide must followdirections printed on the product label of thatpesticide, as prescribed under the Pest ControlProducts Act. Reading and following directionsshould also be recommended by provincialauthorities. Because recommendations for use

may vary from province to province, agriculturalrepresentatives should be consulted for specificadvice.

Labels for these pesticides are available fromthe registrant or can be obtained from the Website of Health Canada’s Regulatory Agency:http://207.96.209.37/PMRA/Index-ang.asp.


Appendix A: Product and Chemical Names

Soil Pesticides

Product Name Pest ControlProducts ActRegistration No.

Registrant Active Ingredients

Space Pesticides

Product Name Pest ControlProducts ActRegistration No.

Registrant Active Ingredients

Dicamba 19290 BASF Canada 3,6-dichloro-2-methoxybenzoic acid

Nortranº Not registered in Canada Not registered in Canada ethofumesate

Roundup • • glyphosate

Telone® C17 16323 & 16324 Dow AgroSciences Canada Inc. 78% 11,3-dichloropropene17% chloropicrin

Telone® C35 Not registered in Canada Not registered in Canada 65% 1,3-dichloropropene35% chloropicrintrifluralin

Treflan • •

Vapam® 6453 Amvac Chemical Corp. 42% metam sodium

Vorlex Plus CP® 18354 AgrEvo Canada Inc. 34% 1,3-dichloropropene17% methyl15% chloropicrin

Basamid 15032 BASF Canada 3,5-dimethyl-1,3,5-thiadiazinane-2-thione

ECO2FUME® Not registered in Canada Not registered in Canada 2% phosphine98% carbon dioxide

Fumi-Cel®, Fumi-Strip® 26188 Degesch America Inc. 56% magnesium

Gastoxin® 17187 (tablets) and17188 (pellets)

Casa Bernardo Ltd. 57% aluminum

Magtoxin® 26523 (granules) and26524 (prepac spot fumigant)

Degesch America Inc. 66% magnesium

Phostoxin® 15736 Degesch America Inc. 55% aluminum

Pyrethrins 18348 Gardex Chemicals Ltd. Piperonyl

Vikane® / Profume® Not registered in Canada Dow AgroSciences LLC sulfuryl fluoride

• Roundup and Treflan have several formulations, due to space limitations, please refer to the Pest Management Regulatory Agency website for more information: http://www.hc-sc.gc.ca/pmra-arla/

º Nortran (Benzofuran family) site of action is unknown: http://www.weeds.iastate.edu/reference/siteofaction.htm

PublicationsMethyl Bromide Alternatives, Substitutes andRecovery Systems. Final Report. Prepared forAgriculture and Agri-Food Canada. December1993.

Heat, Phosphine and CO2 CollaborativeExperimental Structural Fumigation. CanadianLeadership in the Development of MethylBromide Alternatives. Prepared for theEnvironment Bureau, Agriculture and Agri-Food Canada. 1996.

Structural Pest Control: The Use of anEnhanced Diatomaceous Earth ProductCombined with Heat Treatment for the Controlof Insect Pests in Food Processing Facilities.Canadian Leadership in the Development ofMethyl Bromide Alternatives. Prepared for theEnvironment Bureau, Agriculture and Agri-Food Canada and the United StatesDepartment of Agriculture. June 1997.

Corrosive Effects of Phosphine, CarbonDioxide, Heat and Humidity on ElectronicEquipment. Canadian Leadership in theDevelopment of Methyl Bromide Alternatives.Prepared for the Environment Bureau, Agricultureand Agri-Food Canada. August 1998.

Improving Food and Agriculture Productivity –and the Environment. Canadian Leadership inthe development of Methyl Bromide Alternativesand Emission Control Technologies. Preparedfor the Environmental Protection Service,Environment Canada, Research Branch andEnvironment Bureau, Agriculture and Agri-FoodCanada, and Environmental Affairs Branch of theIndustry Sector, Industry Canada. December 1998.

Integrated Pest Management in FoodProcessing: Working Without Methyl Bromide.Sustainable Pest Management Series S98-01.Prepared by the Methyl Bromide IndustryGovernment Working Group for the PestManagement Regulatory Agency. 1998.

Corrosive Effects of Phosphine, CarbonDioxide, Heat and Humidity on ElectronicEquipment: Phase II. Canadian Leadership inthe Development of Methyl BromideAlternatives. Prepared for the EnvironmentBureau, Agriculture and Agri-Food Canada andthe United States Department of Agriculture.November 1999.

Alternatives to Methyl Bromide Fumigation ofEmpty Ship Holds. Canadian Leadership in theDevelopment of Methyl Bromide Alternatives.Prepared for the Environment Bureau,Agriculture and Agri-Food Canada. November1999.

Web sitesAAFC Environmnet Bureauhttp://www.agr.ca/policy/environment/eb/public_html/ebe/ozone.html

AAFC Stored Products Grouphttp://res2.agr.ca/winnipeg/stored.htm

Environment Canada ozone Web sitehttp://www.ec.gc.ca/ozone/e/subsec/mbr/workgroup

U.S. EPA Web site for methyl bromidehttp://www.epa.gov/docs/ozone/mbr/mbrqa.html

U.S.D.A. Web site for methyl bromidehttp://www.ars.usda.gov/is/mb/mebrweb.htm

The Ozone Secretariat (United NationsEnvironment Programme)http://www.unep.ch/ozone/montreal.shtml


Appendix B: Resources

alternatives to methyl bromide: selected case...

Documents