Pesticides: The Phaseout of Methyl Bromide in the United States (Letter
Report, 12/15/95, GAO/RCED-96-16).

GAO provided information on the phaseout of methyl bromide in the United
States, focusing on the: (1) scientific evidence that emissions of
methyl bromide are depleting the ozone layer; (2) availability of
economical and effective alternatives to the pesticide; (3) effects of
banning the pesticide on U.S. trade in agricultural commodities; and (4)
Environmental Protection Agency's (EPA) authority under the Clean Air
Act to exempt essential uses of methyl bromide from the phaseout.

GAO found that: (1) world scientists participating in the United
Nation's Environment Programme believe that emissions of methyl bromide
contribute significantly to ozone depletion; (2) although several
chemical and nonchemical pest-control alternatives to methyl bromide are
available, none are as economical and effective as methyl bromide; (3)
if other countries continue to use methyl bromide after it is phased out
in the United States, they will have an unfair advantage in
international markets for the various agricultural commodities produced
with the substance; and (4) the Clean Air Act does not authorize EPA to
grant exemptions on producing and importing methyl bromide except for
use in medical devices and for export to developing countries that have
signed the Montreal Protocol.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-96-16
     TITLE:  Pesticides: The Phaseout of Methyl Bromide in the United 
             States
      DATE:  12/15/95
   SUBJECT:  Hazardous substances
             Pesticide regulation
             Health hazards
             Environmental monitoring
             Unfair competition
             Agricultural research
             Agricultural chemicals
             International trade

             
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Cover
================================================================ COVER


Report to the Ranking Minority Member, Committee on Commerce, House
of Representatives

December 1995

PESTICIDES - THE PHASEOUT OF
METHYL BROMIDE IN THE UNITED
STATES

GAO/RCED-96-16

Phaseout of Methyl Bromide

(160301)


Abbreviations
=============================================================== ABBREV

  APHIS - Animal and Plant Health Inspection Service
  CFC - chlorofluorocarbon
  EPA - Environmental Protection Agency
  ODP - ozone depletion potential
  UNEP - United Nations Environment Programme
  USDA - U.S.  Department of Agriculture

Letter
=============================================================== LETTER


B-261602

December 15, 1995

The Honorable John D.  Dingell
Ranking Minority Member
Committee on Commerce
House of Representatives

Dear Mr.  Dingell: 

Emissions of various chemicals are depleting the stratospheric ozone
layer, which shields the earth from the sun's harmful ultraviolet
rays.\1 According to the Environmental Protection Agency (EPA),
increased ultraviolet radiation reaching the earth's surface can,
over time, raise the incidence of skin cancer and cataracts and
weaken the immune system in humans, as well as damage the
environment. 

To protect the ozone layer, 24 nations, including the United States,
signed the Montreal Protocol in September 1987, agreeing to place
controls on and perform further assessments of major ozone-depleting
substances.  In 1990, the Congress amended the Clean Air Act to,
among other things, require EPA to identify ozone-depleting
substances and phase out their production.  In December 1993, EPA
issued regulations under these provisions to phase out methyl
bromide, a widely used agricultural pesticide identified by
scientists as an ozone-depleting substance.  EPA's regulations freeze
the production and importation of methyl bromide at 1991 levels until
January 1, 2001; after this date, the pesticide can no longer be
produced or imported into the United States for domestic use.  The
Montreal Protocol--now signed by over 150 countries--freezes methyl
bromide's production at 1991 levels but does not require a phaseout. 

Methyl bromide has been used in agriculture since the 1930s,
principally as a fumigant to control pests in the soil before
planting various crops, to protect stored agricultural commodities,
and to treat commodities being shipped in international trade.\2 In
response to your questions about the consequences of banning methyl
bromide for these purposes, we agreed to provide you with information
on (1) the scientific evidence that emissions from human uses of
methyl bromide are depleting the ozone layer, (2) the availability of
economical and effective alternatives to the pesticide's agricultural
uses, (3) the effects of banning the pesticide on U.S.  trade in
agricultural commodities, and (4) EPA's authority under the Clean Air
Act to exempt essential uses from the phaseout. 


--------------------
\1 There are three types of ultraviolet radiation classified
according to their wavelength.  UV-C, the most harmful, does not
reach the earth's surface.  UV-B, which is somewhat less harmful, is
partially absorbed by stratospheric ozone.  UV-A, the least harmful,
reaches the earth with little obstruction. 

\2 Similarly, methyl bromide is used to fumigate certain commodities
shipped between states such as California and Florida. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

World scientists participating in the United Nations Environment
Programme's assessment of ozone-depleting substances have concluded
that emissions from human uses of methyl bromide contribute
significantly to ozone depletion and should be controlled.  Although
some complex atmospheric processes are not fully understood,
scientists know from laboratory measurements that bromine, a major
component of methyl bromide, is very efficient in destroying ozone. 

Various chemical and nonchemical pest-control alternatives are
available, but none is as economical and effective as methyl bromide
for its many uses.  Hence, a combination of these alternatives will
likely have to replace methyl bromide.  The agricultural community is
concerned that federal research to identify the most cost-effective
alternatives or combination of alternatives is not adequately funded
or coordinated.  For some uses, such as treating certain commodities
in trade and destroying certain organisms in the soil that can cause
plant diseases, alternatives have not yet been identified. 

If other countries continue to use methyl bromide after it is phased
out in the United States, they may have an unfair advantage in
international markets for the various agricultural commodities
produced with the substance.  At the next meeting of the parties to
the Montreal Protocol in November 1995, U.S.  officials plan to
propose a worldwide phaseout similar to the U.S.  one.  The officials
believe that the parties are likely to agree on some additional
controls but not to a phaseout.  In addition, a U.S.  phaseout could
mean that some commodities, which must now be fumigated with methyl
bromide to kill pests that might damage U.S.  crops, could no longer
be imported into this country.  Other countries have similar
requirements that might affect U.S.  exports. 

The Clean Air Act does not authorize EPA to grant exemptions from the
ban on producing and importing methyl bromide except for use in
medical devices and for export to developing countries that have
signed the Montreal Protocol.  The Clean Air Act would have to be
amended before EPA could grant exemptions from the January 1, 2001,
ban for other uses. 


   BACKGROUND
------------------------------------------------------------ Letter :2

During the past decade, both international and national efforts have
been made to control ozone-depleting chemicals.  Shortly after the
United Nations Environment Programme (UNEP) developed the Montreal
Protocol on Substances that Deplete the Ozone Layer (Protocol), the
Congress added title VI to the Clean Air Act to supplement the
Protocol's terms and conditions.  Amendments to the Protocol and
regulations implementing title VI have since expanded the
restrictions on individual ozone-depleting chemicals. 

An ozone depletion potential (ODP) index is used under the Protocol
and the Clean Air Act to gauge a substance's relative potential to
deplete stratospheric ozone.  This index primarily reflects the
substance's (1) likely lifetime in the atmosphere and (2) efficiency
in destroying ozone compared with chlorofluorocarbon-11 (CFC-11), a
widely used refrigerant and major ozone depleter that is being phased
out under the Protocol and the Clean Air Act.  On the basis of
scientific assessments performed in December 1991 and updated in June
1992, UNEP calculated that methyl bromide has an ODP of 0.7, or 70
percent of CFC-11's ozone-depleting potential. 

The Protocol originally placed controls on eight major ozone
depleters--five chlorofluorocarbons (CFC) and three halons--and
provided for technical and scientific assessments of potential
ozone-depleting substances to be undertaken at least every 4 years.\3
In November 1992, following the update of UNEP's 1991 assessment, the
parties to the Protocol first imposed controls on methyl bromide. 
They agreed to accept UNEP's calculation of methyl bromide's ODP as
0.7, and they amended the Protocol to freeze production of the
substance at 1991 levels, beginning in January 1995.\4 They did,
however, create an exemption for the substance's preshipment and
quarantine uses.\5 The parties also agreed to decide by January 1,
1996, how the freeze would affect the consumption of methyl bromide
in developing countries.  (The Protocol allows methyl bromide
producers to produce 10 percent above 1991 levels for export to
developing countries.) The parties further agreed to consider
imposing additional controls on methyl bromide at their November 1995
meeting, after they had reviewed the results of UNEP's next round of
scientific and technical assessments.  These assessments were
completed in late 1994. 

Title VI of the Clean Air Act identifies many substances that EPA is
to list as ozone depleting and requires the agency to list any others
that have an ODP of 0.2 or that it finds may reasonably be
anticipated to cause harm to the ozone layer.  These substances are
to be listed as either class I or class II, depending primarily on
their ODP.  The title authorizes EPA to add substances to either list
and requires the agency to update both periodically.  Substances that
have an ODP of 0.2 or greater are to be listed as class I, and EPA is
to take action to phase out their production no later than 7 years
after they are listed.  The schedule for phasing out the less
threatening class II substances is less stringent. 

In December 1991, three environmental groups petitioned EPA under the
Clean Air Act to list methyl bromide as a class I substance.  EPA
concluded, in large part on the basis of UNEP's calculation, that
methyl bromide has an ODP of 0.7, well above the act's 0.2 threshold
for listing as a class I substance.  In December 1993, EPA issued a
rule first freezing and then banning the production and importation
of methyl bromide.  The freeze, which is at 1991 levels, took effect
on January 1, 1994.  No further reduction from 1991 levels is
required until January 1, 2001, when the ban is mandated to begin. 
EPA imposed no further reductions during this 7-year period because
it recognized that the loss of methyl bromide would be costly and it
wanted to allow as much time as possible for the development of
alternatives.  (In promulgating the rule, EPA estimated both the
costs and benefits of phasing out methyl bromide.  The U.S. 
Department of Agriculture (USDA) and the University of California at
Berkeley and the University of Florida have also estimated the costs
of banning methyl bromide's agricultural uses.  App.  I summarizes
these studies.)

Table 1 compares the controls placed on methyl bromide by the
Montreal Protocol and by EPA's regulation. 



                                     Table 1
                     
                     Comparison of Controls Placed on Methyl
                                     Bromide

Provision            Montreal Protocol              U.S. regulation
-------------------  -----------------------------  ----------------------------
Freeze on            Production and importation     Production and importation
production and       were frozen at 1991 levels,    were frozen at 1991 levels,
importation          effective January 1, 1995.     effective January 1, 1994.

Exemptions to the    Preshipment and quarantine     No exemptions have been
freeze               uses were exempted.            granted yet, but EPA has the
                                                    authority to grant
                     Methyl bromide producers can   exemptions for use in
                     generally exceed their 1991    medical devices and for
                     levels by 10 percent for       export to developing
                     export to developing           countries.
                     countries. The Protocol
                     parties are to decide by
                     January 1, 1996, how the
                     freeze will affect developing
                     countries.

Ban on production    No ban has been approved.      A ban on production and
and importation                                     importation becomes
                                                    effective January 1, 2001.
--------------------------------------------------------------------------------
Methyl bromide is a highly effective fumigant used to control a broad
spectrum of pests--insects, nematodes (parasitic worms), weeds,
pathogens (bacteria, fungi, and viruses), and rodents.  The
agricultural community today uses it for over 100 crops.  U.S. 
production in 1993 was over 60 million pounds.\6 About 80 percent is
used to fumigate the soil before planting crops.\7 Another 19 percent
is used to fumigate harvested agricultural commodities during
storage--including those being exported from and imported into the
United States--and to fumigate structures such as food processing
plants, warehouses, mills, and grain elevators.  A small amount is
used in the production of other chemicals. 

According to EPA, methyl bromide is a very toxic substance whose
effects on human health depend on the concentration and duration of
the exposure.  Exposure to the pesticide can damage the lungs, eyes,
and skin and, in severe cases, cause the central nervous and
respiratory systems to fail.  Gross permanent disabilities or death
may result.  Agricultural field workers and structural fumigators
have developed respiratory, gastrointestinal, and neurological
problems, including inflammation of nerves and organs and
degeneration of the eyes.  EPA officials told us that exposures to
high concentrations have resulted in deaths. 


--------------------
\3 Halons have been used primarily as fire extinguishers in ships,
planes, and military vehicles, as well as in computer facilities,
telephone switching centers, and other places where materials would
be damaged by the use of water or foam fire extinguishers. 

\4 The agreement technically froze member countries' "consumption"
levels of methyl bromide, that is, the amounts produced plus the
amounts imported minus the amounts exported. 

\5 Preshipment use generally refers to the treatment with methyl
bromide of commodities being exported to meet the phytosanitary and
sanitary (plant and animal health) requirements of the importing
country.  Quarantine use refers to the treatment performed or
authorized by a national plant, animal, environmental protection, or
health authority to prevent the introduction, establishment, or
spread of harmful pests that are (1) not yet present or (2) present
but not widely distributed and being officially controlled. 

\6 Chemical Marketing Reporter, Vol.  245, No.  1 (Jan.  3, 1994). 

\7 According to a 1994 USDA report, five crops--tomatoes,
strawberries, peppers, ornamentals, and tobacco--account for over 80
percent of the methyl bromide used for soil fumigation. 


   SCIENTIFIC EVIDENCE OF METHYL
   BROMIDE'S ROLE IN OZONE
   DEPLETION
------------------------------------------------------------ Letter :3

UNEP's scientific assessments of ozone-depleting substances have
concluded that methyl bromide is a significant ozone depleter.\8
Although some uncertainties are involved in these assessments, the
participating scientists are confident that methyl bromide's ODP will
not drop below the 0.2 level that triggers the phaseout of the
pesticide as a class I substance under the Clean Air Act. 

The atmosphere is made up of distinct layers, each of which has its
own composition of gases and natural processes.  The troposphere
extends from the earth's surface up to about 6 miles, and the
stratosphere extends from the troposphere to about 30 miles above the
surface.  Although ozone can be harmful in the troposphere--it is a
primary constituent of smog--in the stratosphere it helps protect
life on earth from the sun's ultraviolet radiation.  (See fig.  1.)

   Figure 1:  Ozone in the Earth's
   Atmosphere

   (See figure in printed
   edition.)

Ozone is continuously being produced naturally in the stratosphere by
a photochemical reaction caused by the sun's rays.  It is also
continuously being removed by other chemical reactions.  According to
scientists involved in the UNEP assessment, the production and
destruction of ozone are normally in balance.  However, as emissions
from human uses of ozone-depleting chemicals reach the stratosphere,
more ozone is lost than is created, and the ozone layer is thinned. 
Similarly, methyl bromide is continuously being produced and removed
from the atmosphere by natural processes--scientists estimate that up
to 60 percent or more of the methyl bromide in the atmosphere may be
released from the oceans.  Again, the UNEP scientists believe that
the amounts produced and removed by natural processes tend to be in
balance.  Therefore, their concern about methyl bromide as an ozone
depleter is focused on emissions from human uses. 

The scientific basis for the Montreal Protocol's freeze and EPA's
phaseout was principally a 1992 assessment completed under the
auspices of UNEP.  This assessment, which scientists from around the
world performed for the parties to the Montreal Protocol, concluded
that the best estimate of methyl bromide's ODP was 0.7.  The 1994
UNEP scientific assessment found that the pesticide's ODP is 0.6. 

Producers of methyl bromide and members of the agricultural community
have expressed concern about UNEP's estimate of the substance's ODP. 
More specifically, they have questioned UNEP's calculation of methyl
bromide's "lifetime" in the atmosphere, which the 1994 UNEP
assessment calculated to be about 1 year.\9 This calculation is
important because the less time the substance is in the atmosphere,
the less chance it has of reaching the stratosphere and depleting the
ozone layer.  UNEP's calculation of the pesticide's lifetime assumes
that significant amounts of methyl bromide are being removed from the
atmosphere through chemical reactions in the troposphere and through
interaction with the oceans.  However, some in industry and the
agricultural community have suggested that soil and vegetation may
also remove significant amounts of methyl bromide from the
atmosphere.  Scientists who participated in the UNEP assessment
believe that the range of uncertainty factored into their estimates
of methyl bromide's lifetime is sufficient to allow for the
possibility that the substance may be removed by soil and vegetation. 

The other major part of the ODP measurement is the relative
efficiency of methyl bromide in destroying ozone.  On the basis of
laboratory measurements, the scientists who participated in the UNEP
assessment estimate that bromine, a major component of methyl
bromide, is about 50 times more efficient in destroying ozone than
the chlorine in chlorofluorocarbons. 

Additional research is addressing the scientific uncertainties
currently involved in calculating methyl bromide's ODP.  At this
point, the scientists associated with the UNEP assessment anticipate
only a further refinement of the ODP calculation.  They are confident
that the research results will not bring the ODP below 0.3. 


--------------------
\8 According to the Montreal Protocol's 1992 assessment update
report, modeling results suggest that emissions of methyl bromide
from human activities could have accounted for about 5 to 10 percent
of the current observed stratospheric ozone loss.  The modeling
results further suggest that this amount could grow to about 17
percent by the year 2000 if emissions continue to increase at the
present rate of 5 to 6 percent per year. 

\9 Various physical and chemical processes tend to break down and
remove chemicals in the atmosphere.  Atmospheric lifetime is a
measure of how long a gas stays in the atmosphere before it is
removed by these processes.  Atmospheric lifetimes are commonly
modeled as e-folding lifetimes, which means that the concentration of
a gas is assumed to decay exponentially. 


   AVAILABILITY OF ECONOMICAL AND
   EFFECTIVE ALTERNATIVES
------------------------------------------------------------ Letter :4

EPA, USDA, and industry representatives generally agree that chemical
substitutes and other alternatives are available today to manage many
of the pests currently controlled with methyl bromide.  They further
agree that no one substitute or alternative is available for methyl
bromide's many uses and that research is needed to identify the
alternatives or combinations of alternatives that can economically
and effectively replace the pesticide's individual uses.  USDA and
the agricultural community, however, are less optimistic than EPA
that economical and effective alternatives will be identified by the
time the ban on methyl bromide goes into effect in 2001.  EPA, USDA,
and industry are sponsoring or conducting research on alternatives,
but it is not clear at this point what this research will be able to
achieve over the next 5 years. 


      EFFECTIVENESS OF EFFORTS TO
      IDENTIFY REPLACEMENTS IS
      UNCLEAR
---------------------------------------------------------- Letter :4.1

According to EPA, there are many chemical and nonchemical
alternatives to methyl bromide.  These include fumigants that can
kill a range of pests similar to those killed by methyl bromide. 
Other chemicals--for example, insecticides, fungicides, and
herbicides--with a more limited range are also available. 
Nonchemical alternatives include techniques such as rotating crops to
avoid a buildup of pests, using plants that are more pest-resistant,
and using organisms like parasitic bacteria to control weeds and
nematodes. 

These alternatives, according to EPA, are technically capable of
controlling many of the pests currently controlled by methyl bromide. 
(In its 1994 report, UNEP's Methyl Bromide Technical Options
Committee said that it had identified a technically feasible
alternative, either currently available or at an advanced stage of
development, for over 90 percent of the uses being made of methyl
bromide in 1991.\10 According to the report, alternatives were not
identified for controlling some soilborne viruses and other pathogens
and for some quarantine procedures.) The key question--assuming that
the alternatives do not pose any unmanageable health and
environmental risks--is which alternative or combination of
alternatives is most effective and economical in a given situation. 

According to USDA officials, alternatives are not currently available
for some important uses, such as treating certain quarantined
commodities and responding to certain incidents or emergencies.  The
officials noted, for example, that ships carrying infested
commodities may dock at U.S.  ports, military equipment contaminated
with soilborne pests may be brought back to the United States, or a
destructive pest, such as the Mediterranean fruit fly, may be found
in an area of California or another state.  In these circumstances,
they said, fumigation with methyl bromide is the only effective way
to deal with the pests. 

USDA officials also pointed out that numerous scientific, economic,
and environmental variables have to be considered in evaluating
potential replacements.  Selecting a replacement can be further
complicated because a use can be quite specific.  For example,
alternatives for preplant soil fumigation (a technique for killing
pests in the soil before planting) will need to be selected on the
basis of such factors as the crop grown, the pests present in the
soil, the climate, and the geographical location.  Government and
industry researchers believe that considerable research and field
testing are needed to define the alternatives' efficacy,
applicability, and cost-effectiveness in given situations. 

To fund research on alternatives to methyl bromide, EPA and USDA
spent about $13.3 million in fiscal year 1995 and, according to
agency officials, a similar amount has been requested for fiscal year
1996.  However, the Crop Protection Coalition\11 estimates that about
$60 million is needed annually for this research.  According to the
Coalition, the public sector has not mobilized sufficient resources
and funds to achieve meaningful results before 2001 in either
preplant or postharvest applications.  The Coalition also believes
that this research needs to be more effectively coordinated. 

The Coalition, with USDA's and EPA's cooperation, is attempting to
consolidate federal and private research activities into a single
agenda reflecting a consensus on priorities.  In July 1995, the
Coalition issued a report on the status of research activities to (1)
help prioritize projects for funding, (2) identify gaps in current
research, and (3) improve the transfer of technology to users of
methyl bromide.\12 According to a USDA official, the Coalition's
report and research agenda will be discussed at an international
research conference on alternatives and methods for reducing methyl
bromide emissions that the Department is cosponsoring in November
1995 with the Coalition and EPA. 


--------------------
\10 The Methyl Bromide Technical Options Committee is one of the
technical committees operating under the Technology and Economic
Assessment Panel, which was established under the Montreal Protocol
to perform the technical and economic assessments needed for the
parties to consider controls on ozone-depleting substances. 

\11 A national organization of about 30 fresh fruit and vegetable
producers, associations, cooperatives and related industries.  During
action on USDA's fiscal year 1995 appropriation, the Senate
Appropriations Committee expressed its expectation that the
Department would work with the Coalition on directing funds for
methyl bromide research (Senate Report 103-290, June 23, 1994, p. 
23). 

\12 Status of Methyl Bromide Alternatives Research Activities, Crop
Protection Coalition (July 1995). 


      NEW CHEMICAL SUBSTITUTES
      APPEAR UNLIKELY
---------------------------------------------------------- Letter :4.2

USDA, the Methyl Bromide Working Group--which represents methyl
bromide producers and distributors--and the Crop Protection Coalition
believe that very few new chemical alternatives will be available
when the ban on methyl bromide goes into effect.  They said that
substantial development costs, research requiring multiple planting
cycles, and federal/state regulatory reviews are involved in putting
a new chemical on the market.  They noted that moving a new pesticide
from development to commercialization can take up to 10 years and
cost a manufacturer from $50 million to $70 million.  As part of this
process, the manufacturer must develop the health and safety data
that EPA requires to register a pesticide for use. 

Under the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA), EPA decides whether to register a pesticide after assessing,
among other things, the potential effects on human health and the
environment of using a pesticide product according to the directions
on the label.  A separate registration is required for each new
chemical, and an existing registration has to be amended for a new or
different use.  The registration process can take many years,
depending on the type of substance, the complexity of the testing
needed, the gaps in the data, and the nature of EPA's findings from
the health and safety data submitted for the agency's review. 
However, EPA recently established an expedited system for reviewing
alternatives to methyl bromide.\13 According to EPA, to date, no new
chemicals and only a few new uses of existing chemicals have been
submitted to EPA as potential alternatives to methyl bromide. 

Under 1988 amendments to FIFRA, all pesticides registered before
November 1984 must be reviewed for reregistration and the data
supporting their registrations must be brought up to current
scientific standards.  Methyl bromide and a number of pesticides that
have been approved for use on pests now controlled by methyl bromide
are included in this group of chemicals.  USDA has identified six of
these chemicals as potential alternatives to methyl bromide.\14

For each of the alternatives identified by USDA, EPA has found
potentially serious environmental and/or health and safety concerns. 
According to USDA officials, regulatory actions by EPA to ban or
limit the use of these or other pesticides because of health and
environmental concerns could exacerbate the economic effects of the
methyl bromide phaseout by eliminating potentially effective
alternatives.  However, EPA officials told us that, under FIFRA, the
agency balances risks and benefits, and if the benefits of using a
pesticide outweigh the potential risks to people and the environment,
then EPA may register or reregister the pesticide.  The officials
said that EPA is likely to reregister many of the chemical
alternatives to methyl bromide after adopting appropriate risk
mitigation measures, such as label changes.  (App.  II lists these
and other potential alternatives to methyl bromide's agricultural
uses and describes various concerns raised by EPA and others.  The
appendix also lists recent studies and reports by EPA, USDA,
industry, and environmental groups that provide additional details on
alternatives.)


--------------------
\13 In a July 13, 1995, pesticide regulation notice (No.  95-4), EPA
explained the expedited review process and invited the submission of
potential alternatives.  In this notice, EPA said that if all
necessary data have been submitted, the agency will work to ensure
that decisions are made within 6 months on petitions for new food
uses for registered pesticides, within 8 months on applications to
register biological pesticides, and within 12 months on applications
to register new active ingredients as reduced-risk pesticides. 

\14 These chemicals are 1,3-dichloropropene, dazomet, metam-sodium,
chloropicrin, phosphine, and dichlorvos. 


      REDUCING EMISSIONS AND
      RECYCLING ARE NOT
      ALTERNATIVES UNDER THE CLEAN
      AIR ACT
---------------------------------------------------------- Letter :4.3

Some technically proven methods for reducing methyl bromide
emissions, such as better sealing of fumigation enclosures, are
available.  In addition, industry is working to develop technology
that can recapture and recycle a very high percentage of the methyl
bromide used to fumigate commodities and structures.  According to
UNEP's Methyl Bromide Technical Options Committee, a few pieces of
methyl bromide recovery equipment are already in use, and prototype
systems capable of recycling recaptured gas for some uses will be
evaluated by the end of 1995.  Although using these technologies
could substantially reduce emissions, the Clean Air Act does not
exempt production for use in such systems from the ban.  However,
using recovery and recycling technology would extend the existing
supply of methyl bromide when the ban on production and importation
becomes effective. 


      EXEMPTIONS FOR ESSENTIAL
      USES MAY BE NECESSARY
---------------------------------------------------------- Letter :4.4

In August 1995, EPA's Assistant Administrator for Air and Radiation
said that the agency is aware of and understands the agricultural
community's concern that it does not currently have satisfactory
substitutes for all uses of methyl bromide.\15 The Assistant
Administrator said that alternatives are available to effectively
control many of the pests on which methyl bromide is used and that
research on additional alternatives is taking place.  According to
the Assistant Administrator, the critical issue is whether adequate
alternatives will be available by the time the phaseout deadline
arrives and, if they are not available, the agency will seek an
appropriate solution.  According to EPA, alternatives do not need to
be identical to methyl bromide but they must be environmentally
acceptable and must effectively and economically manage those pests
that are now being controlled by the pesticide.  (As discussed later,
the Clean Air Act would have to be amended to give EPA the authority
to grant exemptions from the ban.)


--------------------
\15 Statement of the Assistant Administrator for Air and Radiation,
EPA, before the Subcommittee on Oversight and Investigations, House
Committee on Commerce (Aug.  1, 1995). 


   POTENTIAL IMPACT OF BANNING
   METHYL BROMIDE ON U.S.  TRADE
------------------------------------------------------------ Letter :5

Because methyl bromide is an important pesticide worldwide, a ban
that took effect in the United States before similar actions were
implemented in other countries could create an "uneven playing field"
in international trade for U.S.  producers of various agricultural
commodities.  The need to use more costly and/or less effective
alternatives could increase the costs and reduce the yields for
growers of U.S crops.  In addition, some countries require certain
U.S.  commodities to be treated with methyl bromide as a condition of
entry.  These exports would likely be lost unless acceptable
alternatives could be agreed upon with the importing countries. 
Likewise, the United States requires treatment with methyl bromide as
a condition of entry for certain imports.  The impact of the U.S. 
ban on agricultural trade, however, will depend on the controls other
countries have placed on methyl bromide and on the cost-effectiveness
of the alternatives available when the U.S.  ban goes into effect in
2001. 


      USE MAY CONTINUE IN MANY
      COUNTRIES
---------------------------------------------------------- Letter :5.1

Although the parties to the Montreal Protocol are to consider placing
additional controls on methyl bromide at their November 1995 meeting,
they may not agree to ban the pesticide.  According to U.S. 
officials, the United States will propose a ban, but contacts with
representatives of other countries indicate that a wide range of
proposals will be made at the meeting.  For example, the technical
assessment report prepared for the parties by UNEP's Methyl Bromide
Technical Options Committee states that individual committee members
estimated feasible reductions in methyl bromide emissions ranging
from 50 percent by 1998 to only a few percent by 2001. 

Even if the parties agree to a ban, they may give developing
countries special consideration.  The parties have recognized that
these countries may not have the technical or financial resources to
switch to alternatives or that a change may have a greater economic
impact on them than on more developed countries.  For example, in
addition to financial and technical assistance, the Protocol gave
these countries a 10-year grace period to implement the controls on
CFCs and halons.  The Methyl Bromide Technical Options Committee is
presenting several options for the parties to consider if additional
controls are placed on methyl bromide.  One proposal would establish
a 9-year grace period for developing countries, with reviews every 3
years to determine whether the grace period should be adjusted. 
Another option would cap or freeze the quantities used by developing
countries and grant exemptions for preshipment and quarantine uses. 

A few countries have acted independently to control their methyl
bromide emissions.  According to EPA, the Netherlands phased out its
use of methyl bromide for soil fumigation in 1992 because of concerns
that the pesticide contaminates groundwater.  Germany and Switzerland
have also prohibited its use on soil.  Denmark and Sweden plan to
phase out the pesticide's uses by 1998, as does Italy by 2000,
although Italy plans to retain essential uses.  The European Union
plans a 25-percent reduction in use by 1998, and Canada has drafted
controls calling for a 25-percent reduction by 1998. 


      LOSS FOR SOIL FUMIGATION
      COULD HURT U.S. 
      COMPETITIVENESS
---------------------------------------------------------- Letter :5.2

In response to a 1994 survey by the Methyl Bromide Technical Options
Committee, 39 countries reported information on their use of methyl
bromide for preplant soil fumigation.  The committee also obtained
estimates from industry for nine additional countries.  Although the
use of methyl bromide in many of these countries is small (developing
countries account for about 18 percent of its use), the crops
produced with it are primarily high-value cash crops, usually for
export.  Because these crops--for example, strawberries, tomatoes,
peppers, cucumbers, and various other produce--are similar to those
grown in the United States with methyl bromide, producers in these
countries potentially compete with U.S.  growers for both domestic
and international markets for these commodities. 

Studies done by USDA and for California and Florida, the two states
that are the largest users of methyl bromide for soil fumigation,
have concluded that alternatives to the substance are less effective
in controlling soil pests and often cost more (see app.  I). 
According to USDA officials, the higher costs and reduced yields
would put U.S.  growers at a disadvantage if growers in other
countries could continue to use methyl bromide.  For example, the
Florida study stated that the use of methyl bromide is critical
because of the state's environment.  According to the study,
producers faced with substantially reduced revenues would reduce
their acreage for fresh fruit, vegetable, and fresh citrus crops. 
The study concluded that the primary beneficiary would be Mexico,
which, the study assumed, would be given longer, as a developing
country, to use methyl bromide under any future agreement reached
under the Montreal Protocol.  If Mexico or other developing countries
expand their use of methyl bromide, the environmental benefits gained
by phasing out the pesticide's use in the United States would be at
least partially offset. 

EPA's Methyl Bromide Program Director told us that the U.S. 
agricultural community's concerns about the uneven playing field may
be valid.  He said that Mexico may increase its production of such
fruits and vegetables as tomatoes and strawberries, which are major
crops for California and Florida.  He added, however, that additional
study would be needed to determine whether Mexico could realistically
market increased amounts of these commodities in the United States. 
For example, could strawberries be shipped to market in time to
maintain the necessary freshness?  And would these fruits and
vegetables be grown in Mexico at the same time of year as in the
United States? 

According to USDA officials, the Florida study and two recent USDA
studies document the competition that the United States faces from
developing countries, especially Mexico, in markets for crops whose
production relies heavily on the use of methyl bromide.\16 The
officials said, for example, that such competition occurs in the
cucumber market in March and April, in the bell pepper market from
January through March, and in the tomato market from January through
April.  The officials also said that Mexico has supplied nearly all
of the strawberries imported into the United States over the last 5
years. 


--------------------
\16 The two USDA studies, issued by the Economic Research Service,
are Competition in the U.S.  Winter Fresh Vegetable Industry,
Agricultural Economic Report No.  691 (July 1994), and The U.S. 
Strawberry Industry Statistical Bulletin No.  914 (Jan.  1995). 


      TREATMENT WITH METHYL
      BROMIDE IS REQUIRED FOR
      CERTAIN EXPORTS AND IMPORTS
---------------------------------------------------------- Letter :5.3

Although less than 1 percent of the methyl bromide produced in the
United States is used to treat quarantined commodities, this use is
important because it permits trade in these commodities.  During
quarantine treatments, which are usually done at international
borders, the commodities are fumigated to kill pests that could cross
geographical barriers and infect susceptible crops or commodities. 
Quarantine requirements are negotiated between the importing and
exporting countries for individual commodities, and the treatments
are governed by strict regulations that require very high efficacy
levels.  For example, USDA's Animal and Plant Health Inspection
Service (APHIS) requires efficacy levels of 99.9968 percent for most
treatments.  To meet these efficacy levels, APHIS requires that
certain imports be treated with methyl bromide because of its
effectiveness, and some other countries, notably Japan, likewise
require this treatment for certain imports from the United States. 

APHIS currently requires fumigation with methyl bromide or an
alternative treatment as a condition of entry into the United States
for 19 fruits, 14 vegetables, and 7 nuts, seeds, and miscellaneous
foods coming from certain countries (see app.  III).\17 (APHIS also
requires these treatments for various nonfood imports, including
unprocessed seeds and nuts, hays and straw, cotton products, gums,
bagging, and brassware.) About 90 percent of some U.S.  imports,
including apricots, nectarines, grapes, peaches, plums, and yams, are
affected by these requirements.  According to APHIS officials,
acceptable alternatives are generally not available and the loss of
methyl bromide will lead APHIS to ban imports of many economically
important commodities.\18

An April 1993 USDA study of nine imported fruits found that the loss
of imports would reduce supplies and increase prices.\19 According to
the study, the higher prices would increase the revenues to U.S. 
producers by $3.0 billion to $3.3 billion over 5 years.  However, the
losses to U.S.  consumers from paying the higher prices would range
from $4.7 billion to $5.0 billion over 5 years.  The study further
found that many of the imported items fill an important niche in U.S. 
supplies.  For example, the study said that apricots, grapes,
nectarines, peaches, and plums from Chile enter the United States
during the winter when none or nearly none of these items are
produced domestically. 

In addition, U.S.  exports worth over $400 million were fumigated
with methyl bromide in 1994 (see app.  IV).  If the United States
bans methyl bromide, an acceptable alternative treatment must be
negotiated with the receiving countries.  According to USDA
officials, these negotiations can take several years and may not be
successful, especially if other producers can continue to use methyl
bromide and meet the quarantine requirements.  EPA officials told us
that they are more optimistic than USDA officials that acceptable
alternatives will be available for imports and can be agreed upon for
exports. 


--------------------
\17 According to APHIS officials, the agency will approve
alternatives to methyl bromide if the exporting country can document
that the alternatives will meet the required efficacy levels. 

\18 According to USDA officials, import and export requirements may
change from year to year. 

\19 The Biologic and Economic Assessment of Methyl Bromide, National
Agricultural Pesticide Impact Assessment Program, USDA (Apr.  1993). 


   EPA'S AUTHORITY TO GRANT
   ESSENTIAL USE EXEMPTIONS
------------------------------------------------------------ Letter :6

On the basis of our review, we have concluded that the Clean Air Act
does not currently authorize EPA to grant exemptions from the ban on
methyl bromide for domestic agricultural uses, including preshipment
and quarantine treatments.  Supplies of methyl bromide available when
the ban goes into effect on January 1, 2001, can be used, but no
additional amounts can be produced or imported for domestic uses. 

The Congress, in section 604 of the act, specified the conditions
under which EPA may grant exemptions from the production phaseout of
class I ozone-depleting substances, including methyl bromide.  This
section details six categories of substances for which exemptions may
be granted.  For four of the six categories, the exemptions are
restricted to specific chemicals named in the relevant provisions,
none of which is methyl bromide.  For the remaining two
categories--chemicals used in medical devices and exports to
developing countries--EPA is authorized to promulgate exemptions for
any class I substance after giving notice and an opportunity for
public comment.  Neither section 604 nor any other provision of title
VI grants EPA general authority to issue essential use exemptions. 

We identified no current uses of methyl bromide in medical devices,
and it appears that an exemption for this purpose would not be
applicable.  However, methyl bromide could qualify for an exemption
under the export provision of section 604(e).  That provision imposes
only three limits on the availability of the exemption:  (1) it
authorizes the production of only "limited quantities" (not defined
in the provision), (2) the substance may be exported only to
developing countries that are parties to the Montreal Protocol, and
(3) the export may be only for the purpose of "satisfying the basic
domestic needs of such countries."


   CONCLUSIONS
------------------------------------------------------------ Letter :7

UNEP's scientific assessments indicate that emissions from human uses
of methyl bromide cause significant ozone depletion and should be
controlled.  However, a phaseout of the substance could adversely
affect some parts of U.S.  agriculture and trade unless
adequate--that is, environmentally acceptable, effective, and
economical--alternatives are identified before the ban takes effect
in 5 years.  More progress in identifying alternatives is being made
for some uses of methyl bromide than for others.  If adequate
alternatives are not available by the time the ban takes effect,
exemptions from the ban may be needed for some domestic uses until
alternatives can be developed.  However, EPA does not currently have
the authority to grant exemptions for the continued production and/or
importation of methyl bromide for domestic uses. 


   RECOMMENDATION
------------------------------------------------------------ Letter :8

To provide for an orderly phaseout of methyl bromide, we recommend
that the Administrator, EPA, seek changes to the Clean Air Act to
authorize the agency to grant exemptions from the ban for essential
uses.  This authority should provide for EPA to grant exemptions
after determining that adequate alternatives for a particular use are
not available and that the adverse impact of not having methyl
bromide for that use outweighs the negative effects on human health
and the environment of further production and importation. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :9

We provided copies of a draft of this report to EPA and USDA for
their review and comment.  On November 3, 1995, we met with USDA
officials, including the Chairman of the USDA Ad Hoc Committee for
Alternatives to Methyl Bromide and the Deputy Director of the
National Agricultural Pesticide Impact Assessment Program.  The USDA
officials generally agreed with the report's findings.  The officials
said that overall the report is balanced and presents the important
issues and viewpoints associated with the use of methyl bromide.  The
officials again stressed their positions that practical or
cost-effective alternatives are not available for many of methyl
bromide's uses and that a unilateral ban on the pesticide is likely
to hurt U.S.  competitiveness in world agricultural markets. 

On November 7, 1995, we met with EPA officials, including the Methyl
Bromide Program Director in the Office of Air and Radiation and the
Deputy Director of the Policy and Special Projects Staff in the
Office of Pesticide Programs.  The officials described the report's
summarization of available information on the agricultural, economic,
environmental, and health effects of the planned phaseout of methyl
bromide as generally accurate.  However, they expressed concern that
the report leaves the impression that the outlook for finding
alternatives to methyl bromide is more dire than warranted.  In their
view, the fact that no single chemical or other alternative is
expected to replace methyl bromide for all of its uses does not mean
that viable, economical alternatives will not be available for most
uses by 2001.  Furthermore, they added, even though viable,
economical alternatives may not be found for some uses by 2001,
current projections of large losses resulting from the phaseout
cannot be relied on by any means. 

EPA officials indicated that the agency would look at the need for
exemptions and determine whether EPA has the authority to grant them
as the deadline for the ban approaches.  The officials stated that
the focus now should be on identifying alternatives. 

We believe that our report accurately depicts the availability of
alternatives to methyl bromide at this time.  We have made no
judgment as to whether the alternatives will prove to be inadequate
for many uses, as USDA officials have suggested, or for only a few,
as EPA officials have suggested.  In either case, we believe that EPA
will need authority to grant exemptions.  Although EPA could wait to
seek such authority until the deadline approaches, it will need some
lead time to propose changes to the Clean Air Act, have them
approved, and issue implementing regulations. 

EPA and USDA also provided some technical comments on our draft
report.  We have revised our report as appropriate in response to
these comments. 


---------------------------------------------------------- Letter :9.1

We conducted our work from November 1994 through November 1995 in
accordance with generally accepted government auditing standards.  We
interviewed officials from EPA, USDA, the Executive Office of the
President, and the United Nations Environment Programme.  We also
interviewed representatives of the Methyl Bromide Working Group
(producers and distributors) and the Crop Protection Coalition (a
broad spectrum of methyl bromide users).  In addition, we reviewed
available studies on methyl bromide's contribution to the depletion
of the ozone layer and economic and technical assessments of a
phaseout.  We also reviewed applicable laws and regulations and
public comments during the proposal stage of EPA's phaseout
regulation.  Moreover, we attended conferences on alternatives to
methyl bromide and on the status of scientific knowledge concerning
methyl bromide's role in ozone depletion.  Appendix V more fully
discusses our scope and methodology. 

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 7 days after the date of this letter.  At that time, we will
send copies to the Secretary of Agriculture, the Administrator of
EPA, and other interested parties.  We will make copies available to
others upon request. 

Please call me at (202) 512-6112 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
VI. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
 Protection Issues


STUDIES OF THE ECONOMIC IMPACT OF
PHASING OUT METHYL BROMIDE FOR
AGRICULTURAL USES
=========================================================== Appendix I

Methyl bromide is used primarily for agricultural purposes,
principally for fumigating (1) the soil before planting (preplant
soil fumigation) and (2) commodities after harvesting (commodity
fumigation).  The costs and benefits of a ban on these uses were
analyzed by the Environmental Protection Agency (EPA) during the
promulgation of its phaseout rule.  We also identified three other
studies of the potential economic impact of a phaseout on
agricultural users.  The U.S.  Department of Agriculture's (USDA)
National Agricultural Pesticide Impact Assessment Program studied the
effects of a phaseout on 21 crops in six states, and the University
of California at Berkeley and the University of Florida examined the
impact of a phaseout in their states.  Each of these studies compared
the projected costs and crop yields for likely replacements with
those for methyl bromide and found that growers would incur
significant losses because of a ban on agricultural uses of methyl
bromide.  The USDA study also found that consumers would suffer a
loss because supplies would be reduced and prices would be higher. 
Each study based its economic estimates on alternatives available at
the time the study was conducted.  The economic impact could change
if more effective or less costly alternatives are identified in the
future. 

The studies by EPA and USDA arrived at substantially different
estimates of the impact of a ban on methyl bromide.  However, these
estimates could not be easily compared because the studies made
different assumptions, differed in their scope, and used different
methodologies and cost data.  The California and Florida studies were
more limited in their scope than either the EPA or USDA studies.  We
did not independently evaluate these studies. 


   EPA'S ANALYSIS OF COSTS AND
   BENEFITS
--------------------------------------------------------- Appendix I:1

In 1993, EPA reviewed the costs and benefits of its regulatory action
to phase out the production and importation of methyl bromide.\1 This
study included information on the costs and effectiveness of
potential new alternatives by the year 2001 and on the costs and
benefits of improving the use of existing alternatives.  On the basis
of this study, EPA estimated that the total costs of a phaseout of
methyl bromide between 1994 and 2010 would be $1.7 billion to $2.3
billion.\2 EPA's cost analysis examined the likely range of costs for
the alternatives and coupled these assumptions with a monte carlo
analysis, presenting a set of costs (median, mean, minimum, and
maximum) that could be expected with a methyl bromide phaseout in
2001.  The $1.7 billion figure represented the estimated median cost,
and the $2.3 billion figure represented the mean cost.  The minimum
and maximum costs were estimated at approximately $7 million and
roughly $16 billion, respectively.  According to EPA, some available
alternatives, if used after 2001, may indeed prove to be more
expensive than methyl bromide, and their users may receive lower
profits if the increases cannot be passed on to consumers.  However,
EPA said that it has found that the effects of regulatory actions
that remove pesticides from the market are mitigated over time as new
pest control technologies are introduced and adjustments are made to
compensate for the loss of the pesticide through alternative pest
control practices. 

EPA estimated that the benefits of the phaseout would be between $244
billion and $952 billion.  This estimate was based primarily on
avoided cases of nonmelanoma cancers.  According to the study, in the
longer term (until 2160), a total of 2,800 skin cancer fatalities in
the United States would be avoided because of the phaseout.  The
benefits for the period from 1994 through 2010 were estimated to be
between $14 billion and $56 billion.  The analysis reflected key
assumptions about emissions of methyl bromide from human activities,
the impact of bromine on ozone, and the likely growth in use of
methyl bromide without regulations.  The range in values for benefits
results from different estimates of the value of a human life. 

EPA recognized but did not calculate the benefits of avoiding other
health and environmental problems caused by increased ultraviolet
radiation, such as damage to plants and animals.  EPA also did not
consider the possible adverse effects on humans, plants, and animals
of contact with methyl bromide during its application. 


--------------------
\1 The Cost and Cost-Effectiveness of the Proposed Phaseout of Methyl
Bromide, EPA (1993). 

\2 The year 2010 was chosen as the end point in estimating the costs
because the study team believed that forecasting the course of
technological innovation and identifying alternatives to methyl
bromide would be difficult beyond this date. 


   USDA'S NATIONAL AGRICULTURAL
   PESTICIDE IMPACT ASSESSMENT
   PROGRAM STUDY
--------------------------------------------------------- Appendix I:2

In 1993, USDA published a study of the effects on U.S.  agriculture
of banning methyl bromide, under the National Agricultural Pesticide
Impact Assessment Program.\4 The study showed that actions to ban or
restrict methyl bromide's use in the United States would be costly
because currently available alternative control practices are less
effective or more expensive than using methyl bromide.  The study
estimated that the annual economic loss to producers and consumers
from banning the agricultural uses of methyl bromide included in this
study would be about $1.3 billion to $1.5 billion.  Of this amount,
$800 million to $900 million would be attributed to the loss of
methyl bromide for soil fumigation and $450 million to its loss for
the fumigation of quarantine imports.  An additional economic loss of
about $200 million would occur if Vorlex--the alternative identified
as having the most potential for succeeding methyl bromide--were no
longer available.  (The manufacturer had indicated to EPA that it
planned to stop producing Vorlex because of high reregistration
costs.)

According to the study, a phaseout, rather than an immediate ban, of
methyl bromide would postpone annual losses and provide time for
potential alternatives to be developed and for consumers and
producers to adjust.  The study concluded, however, that the
likelihood of developing new, effective fumigant alternatives appears
very remote. 

The results of USDA's study were presented to EPA as part of the
Department's comments on the agency's proposed phaseout rule. 
According to EPA, the study would be a useful analysis if methyl
bromide were being banned immediately, but it does not consider
alternatives that may be developed before the ban goes into effect. 
EPA also said that the study considers only alternatives that
duplicate methyl bromide's ability to kill a wide range of pests and
that other alternatives could be used in combination to achieve
similar results.  USDA officials believe that no alternatives are
available for many uses. 


--------------------
\4 The Biologic and Economic Assessment of Methyl Bromide, National
Agricultural Pesticide Impact Assessment Program (Apr.  1993). 


   STUDY BY THE UNIVERSITY OF
   CALIFORNIA AT BERKELEY
--------------------------------------------------------- Appendix I:3

A 1993 study by the University of California at Berkeley for the
California Department of Food and Agriculture examined the role of
methyl bromide in the state's agriculture and the impact on growers
of regulatory action to further restrict or ban its use.\5

The University examined background information on the patterns and
intensity of methyl bromide's uses for preplant soil and postharvest
fumigation and then used a model to measure the financial impact on
California growers of canceling agricultural uses of methyl bromide. 

According to the University's report on the study, in the short term,
the loss of methyl bromide for preplant soil fumigation would reduce
net farm income in California by more than $233.8 million annually. 
The most significantly affected crops would be strawberries, nursery
products (cut flowers and rose, fruit, vine, nut, and strawberry
plants), and grapes, and estimated net annual farm income losses
would be $105.8 million, $71.7 million, and 31.3 million,
respectively.  Net income losses reflect differences in production
costs from using alternative treatments, which are more costly for
some crops, and lower revenues from reduced yields. 

The report also found that the cancellation of methyl bromide for
postharvest applications would have a significant impact on the
profitability of California's fresh fruit and dried nut crops in the
short run because fumigation by another method would cost more and
take longer.  For example, producers of cherries sell their
highest-quality fruit on the export market and receive a premium
price.  If the cancellation of methyl bromide diverts all of the
cherries previously sold on the export market to the domestic market,
growers will lose $7.3 million annually.  Likewise, walnut producers
will have to ship more products to the domestic market instead of the
holiday markets abroad because alternative techniques could not be
used to fumigate the walnuts quickly enough to meet the holiday
markets' needs.  As a result, walnut producers would lose about $36.8
million annually.  However, according to the study, trade
negotiations could, in the long term, remove the requirements for
quarantine treatments for cherries or approve alternative techniques. 
For walnuts, the expansion of holiday markets or earlier harvesting
could help meet producers' needs. 


--------------------
\5 Economic Impacts of Methyl Bromide Cancellation, Department of
Agricultural and Resource Economics, University of California at
Berkeley (Feb.  1993). 


   STUDY BY THE UNIVERSITY OF
   FLORIDA
--------------------------------------------------------- Appendix I:4

A University of Florida study of the economic impact of losing methyl
bromide on Florida's agriculture concluded that the environment that
prevails in the state makes the use of methyl bromide critical to the
competitiveness of the state's fruit and vegetable crops in U.S.  and
international markets.\6 The University surveyed extension
specialists in the production areas and reviewed previous work on
methyl bromide to identify existing production systems and possible
alternatives to the use of methyl bromide.  To analyze the economic
impact of the ban, the University developed mathematical models of
the North American winter fresh vegetable market and the world market
for Florida grapefruit. 

According to the study, the loss of methyl bromide would have a
devastating effect on Florida's winter fresh vegetable producers. 
Because no viable alternatives can be effectively substituted for
methyl bromide, Florida is estimated to lose over $620 million in the
value of fresh fruit, vegetables, and fresh citrus (measured at the
time of shipping) worth over $1 billion in total sales and more than
13,000 jobs.  The study concludes that producers in the state would
reduce the acreage allocated to these crops by 43 percent, from about
126,000 acres to 71,500 acres.  Tomato production would decline by
more than 60 percent, pepper production by 63 percent, and cucumber
production by 46 percent without methyl bromide.  The study also
predicted that Mexico, in particular, would expand its production of
vegetables, increasing its tomato production by 80 percent and its
pepper production by 54 percent because, as a developing country, it
was expected to have longer to use methyl bromide in producing and
marketing its crops. 


--------------------
\6 The Use of Methyl Bromide and the Economic Impact of Its Proposed
Ban in the Florida Fresh Fruit and Vegetable Industry, Institute of
Food and Agricultural Sciences Bulletin No.  898, University of
Florida at Gainesville (Nov.  1995). 


POTENTIAL ALTERNATIVES TO METHYL
BROMIDE FOR AGRICULTURAL USES
========================================================== Appendix II

Research is currently being conducted by governmental and academic
institutions, as well as by the private sector, to ensure that
alternative materials and methods will be proven viable and available
to the agricultural community before methyl bromide is phased out. 
Tables II.1 and II.2, together with the accompanying descriptions,
briefly profile various alternatives to methyl bromide being
evaluated by USDA and other researchers for methyl bromide's preplant
and postharvest end uses and note various concerns that need to be
resolved during the 5 years before the ban goes into effect. 



                               Table II.1
                
                   Potential Alternatives for Methyl
                      Bromide's Preplant End Uses


                                Small fruit                 Orchards
                                and vegetable               and
Alternatives                    farms           Nurseries   vineyards
------------------------------  --------------  ----------  ----------
Chemical

1,3-Dichloropropene             x               x           x

Dazomet                         x               x           x

Metam-sodium                    x               x           x

Sodium tetrathiocarbonate       x                           x

Formalin/formaldehyde           x               x           x

Chloropicrin                    x               x           x

Nonfumigant narrow-spectrum     x               x           x
pesticides

Future and preliminary          x               x           x
research alternatives

Nonchemical

Steam                           x               x

Solar heating                   x               x           x

Hydroponics                     x               x

Organic matter                  x               x           x

Plant modification              x               x           x

Crop rotation                   x

Future and preliminary          x               x           x
research alternatives

Integrated pest                 x               x           x
management
----------------------------------------------------------------------
Source:  EPA and USDA studies, conference proceedings, and
discussions between GAO and representatives of government and
industry organizations. 


   DESCRIPTIONS OF POTENTIAL
   ALTERNATIVES FOR METHYL
   BROMIDE'S PREPLANT END USES
-------------------------------------------------------- Appendix II:1

1,3-Dichloropropene.  A broad-spectrum liquid fumigant comparable to
methyl bromide for controlling most soil pests but less effective for
controlling weeds.  A potential groundwater contaminant.  Classified
by EPA as a probable human carcinogen.  Under special review by EPA
because of concerns about cancer for workers and residents in and
around treated fields.  Use permits previously suspended by
California because of health and safety concerns but currently
allowed for limited use. 

Dazomet.  A broad-spectrum granular fumigant comparable to methyl
bromide for controlling most soil pests but can be less effective for
controlling nematodes (parasitic worms).  Currently registered for
some food crops, but approval may not be sought for all uses of
methyl bromide (e.g., crops with low production acreage).  Small
fruit and orchard uses restricted to the propagation or outplanting
of nonbearing berry, vine, fruit and nut crops and similar nonbearing
plants, according to EPA.  Concerns about potential genotoxicity
raised by EPA.  Releases methyl isothiocyanate (MITC), a potential
groundwater contaminant.  Concerns expressed by United Nations
Environment Programme (UNEP) about contamination of groundwater. 

Metam-sodium.  A broad-spectrum liquid fumigant comparable to methyl
bromide for controlling most soil pests but may be less effective as
a nematicide.  Identified by EPA as a known teratogen (i.e., cause of
developmental malformations).  Classified by EPA as a probable human
carcinogen.  Efficacy dependent on the availability of water
(irrigation) to ensure even distribution in the soil.  Releases
methyl isothiocyanate (MITC), a potential groundwater contaminant. 
Concerns about contamination of groundwater expressed by EPA and
UNEP. 

Sodium tetrathiocarbonate.  A broad-spectrum liquid fumigant found
effective for many soilborne pests but not for weeds.  Is considered
less effective than methyl bromide for controlling nematodes. 
Currently registered for use on grapes and citrus and registration
being sought for almonds, prunes, and peaches.  Efficacy dependent on
the availability of water (irrigation) to ensure even distribution in
the soil.  Concerns about groundwater contamination expressed by
UNEP.  Groundwater concerns addressed by EPA through label
restrictions. 

Formalin/formaldehyde.  A broad-spectrum granular (paraformaldehyde)
or liquid (formalin) fumigant comparable to methyl bromide for
controlling fungi but less effective for controlling nematodes and
weeds.  Registration voluntarily canceled because of health, safety,
and environmental concerns.  Efficacy dependent on the availability
of water (irrigation) to ensure even distribution in the soil and
prevent toxicity to plants. 

Chloropicrin.  A broad-spectrum liquid fumigant principally used as a
fungicide.  Comparable to methyl bromide for controlling many soil
pests but less effective for controlling nematodes and weeds.  Also
used for tear gas, has a pungent/noxious odor, and can be very
unpleasant or even hazardous to handle.  Concerns about toxicity and
effects of exposure on humans raised by EPA. 

Nonfumigant narrow-spectrum pesticides.  Include granular or liquid
nonfumigant nematicides, herbicides, and fungicides spread or sprayed
on the soil before or after planting to control specific pests
(nematodes, weeds, insects, fungi, or bacteria).  Less effective than
methyl bromide.  Registered uses specific to crops and locations,
varying from state to state.  Some reregistration concerns raised
(e.g., registered nematicides such as aldicarb, carbofuran, and
oxamyl are potential groundwater contaminants). 

Future and preliminary chemical research alternatives.  Include new
and modified pesticides (e.g., bromonitromethane and carbonyl
sulfide) being researched.  Will require registration and are in
varying stages of research.  Will take time to completely develop
products and assess their suitability as replacements. 

Steam.  Technically feasible for soil applications and can be as
effective as methyl bromide, depending on methods of application and
soil conditions/temperatures.  Concerns about viability raised by
USDA.  May be impractical for large-scale (more than 2-acre)
applications because it is labor-, equipment-, and energy-intensive
and current estimated costs per acre are about two to five times
higher than for methyl bromide.  Related equipment and services may
not be readily available.  Feasibility dependent in some areas on
availability of energy resources and fuel costs, according to EPA. 

Solar heating.  Technically feasible for soil applications, depending
on geographic location and climate.  Can be as effective as methyl
bromide, depending on application methods and soil
conditions/temperatures.  Requires long treatment periods and may
therefore be impractical for sterilizing soil in areas with short
growing seasons (e.g., northern United States).  Is likely, for the
most part, to be used in combination with other alternatives (e.g.,
soil fumigants) rather than by itself. 

Hydroponics.  Relatively new plant production systems that eliminate
soilborne pests by eliminating soil as the growing medium.  Instead,
technology uses water-retaining substrates to deliver nutrients. 
Cannot be used for root crops (e.g., carrots), can have high start-up
costs, requires significant support services, and, in the long run,
could take many years to become widely accepted and economical. 

Organic matter.  Incorporates soil amendments, such as compost, green
waste, straw, sawdust, and animal manure, into the soil to build soil
health and control some soilborne pests (e.g., nematodes and weeds). 
Information on efficacy generally lacking.  Some amendments as or
more effective than some nonfumigant pesticide alternatives used to
control nematodes and possibly viable for use in combined treatments. 

Plant modification.  Includes techniques such as crossbreeding
plants, grafting orchard and vineyard rootstocks, and changing
plants' genetic makeup to obtain high resistance to pests and
desirable production characteristics.  Extensive research required to
determine potential of some techniques as alternatives.  Considered
an important source of viable alternatives by USDA and as having an
already demonstrated potential in breeding plants for pest
resistance. 

Crop rotation.  Can be effective in suppressing damage by soilborne
pests.  Effectiveness can be improved by including plants that
produce fungicidal and nematicidal substances.  Limitations include
land availability and required knowledge of pest dynamics, general
ecology, and appropriate rotational crops in specific production
areas.  Research under way to address these concerns. 

Future and preliminary nonchemical research alternatives.  Include
biocontrol methods (e.g., egg-destroying fungi) and genetic
engineering (e.g., altering organisms to control plant pathogens). 
Registration and further research required for most.  Time needed to
complete development and assess suitability as replacements. 

Integrated pest management.  Prevents pest populations from reaching
damaging levels through the use of chemical and/or nonchemical
treatments and management practices, as appropriate.  Requires strict
monitoring of pest populations and knowledge of soil ecosystem/crop
production interactions.  For effective implementation, requires
intensive research, training for growers, and use of some chemical
control methods that require regulatory approval and may involve
health, safety, and environmental concerns.  Research needed to
determine effective combinations.  Choices potentially limited by
concerns about registering or reregistering chemicals. 



                               Table II.2
                
                   Potential Alternatives for Methyl
                     Bromide's Postharvest End Uses


                          Perishable  Nonperishabl
                          commoditie  e             Quaranti  Structur
Alternatives              s           commodities   ne        es
------------------------  ----------  ------------  --------  --------
Chemical

Phosphine                             x             x         x

Sulfuryl fluoride                                   x         x

Dichlorvos                            x

Previously used/                                    x
limited-use alternatives

Nonchemical

Irradiation               x           x             x

Controlled/modified       x           x             x         x
atmosphere

Thermotherapy             x           x             x         x

Combination treatments    x           x             x         x
----------------------------------------------------------------------
Source:  EPA and USDA studies, conference proceedings, and
discussions between GAO and representatives of government and
industry organizations. 


   DESCRIPTIONS OF POTENTIAL
   ALTERNATIVES FOR METHYL
   BROMIDE'S POSTHARVEST END USES
-------------------------------------------------------- Appendix II:2

Phosphine.  A gas produced when aluminum or magnesium phosphide is
exposed to moisture.  Primarily used to fumigate grains but can be
used to control numerous pests on a wide variety of commodities and
in some structures.  Commodities include raw agricultural foods
(e.g., grains and almonds), processed foods (e.g., cereal flours),
animal feeds, and nonfood commodities (e.g., tobacco).  Structural
uses include disinfesting grain storage facilities, such as silos and
grain bins, and other structures that are not sensitive to
phosphine's highly corrosive properties, which can damage switches or
electronic equipment.  Also used as a quarantine treatment for
nonfood commodities, such as tobacco exports and cotton products. 
Effectiveness comparable to methyl bromide's for allowed treatments. 
Not suitable for some agricultural commodities (e.g., toxic to fresh
fruits and vegetables and can decrease efficiencies when longer
treatment times are required, according to USDA).  Poses concerns for
EPA about effects of exposure on workers, mutagenicity, and
neurotoxicity.  Risk of corrosion can be reduced and penetration and
toxicity can be enhanced by combining low doses with heat and carbon
dioxide, according to EPA. 

Sulfuryl fluoride.  Applied as a liquid that converts to a gas and
can be used for some nonfood quarantine treatments and for
disinfesting some structures empty of food and food products. 
Effectiveness comparable to methyl bromide's but poses concerns for
EPA about mutagenicity, carcinogenicity, and reproductive effects. 

Dichlorvos.  A volatile liquid compound with limited penetrative
powers.  Used primarily to control pests in nonperishable foods
(e.g., dried fruits and nuts, grains, and milled products) stored in
warehouses, including raw and processed products.  Classified by EPA
as a possible human carcinogen and under special review because of
concerns about neurotoxicity and carcinogenicity. 

Previously used/limited-use alternatives.  Include ethylene oxide and
other quarantine fumigants (hydrogen cyanide, ethylene dibromide,
carbon disulfide, and ethylene dichloride) that pose concerns about
health and safety.  As effective as methyl bromide for quarantine
treatments, but may need emergency-use permits such as USDA formerly
obtained to control specific pests on specified commodities.  Also
include methyl bromide recovery systems being researched for
quarantine applications, since use of the recycled chemical is not
banned after 2001.  Preliminary research indicates feasibility of
designing fumigation chambers to achieve 95-percent recovery.  But
full development of these systems may extend beyond 2001 and poses
liability concerns involving yet-to-be-established operational and
performance tolerances. 

Irradiation.  Uses low-level gamma radiation to sterilize or kill
pests in quarantine and nonquarantine applications.  Can be used on
most foods and grains and can be equal in effectiveness to methyl
bromide.  Requires considerable investment in facilities and
equipment, entails additional costs to dispose of spent cobalt, and
poses capacity limitation concerns.  USDA concerned about some
commodities' sensitivity to treatment.  Still requires USDA's
approval for quarantine uses, and public's acceptance is uncertain. 

Controlled/modified atmosphere.  Uses decreased amounts of oxygen
and/or increased amounts of carbon dioxide or nitrogen to suffocate
pests.  May require sealed facilities.  Has most potential for
treating nonperishable commodities.  Use in combination with other
treatments being evaluated for improving efficacy levels. 
Requirements for sealing facilities and long treatment times can pose
cost considerations.  Controlled atmospheres and low temperatures
used more cost-effectively than methyl bromide by the Department of
Defense to successfully ship perishables, according to EPA. 

Thermotherapy.  Can be used to control a broad spectrum of pests
infesting commodities and structures and is comparable in
effectiveness to methyl bromide.  Treatments include vapor heat, dry
heat, hot water, quick freeze, and cold.  Length of required
treatment, treatment facility's size, and commodities' sensitivities
to temperature pose limitations.  Experimentation begun with various
techniques.  Combination treatments likely to be required for some
combinations of pests. 

Combination treatments.  Chemical and/or nonchemical combinations
potentially usable to control pests on many commodities and in
quarantine treatments.  Combinations not yet identified for all
commodities or pests.  Chemical and nonchemical pest control
combinations indicate the best potential for controlling pests now
managed by methyl bromide, according to EPA. 


   SOURCES OF DETAILED INFORMATION
   ON POTENTIAL ALTERNATIVES
-------------------------------------------------------- Appendix II:3

Listed below are recent studies and reports that provide more
detailed information on these and other potential alternatives for
methyl bromide's many agricultural uses, the status of their
availability as viable substitutes, and research priorities for
meeting users' short-, mid-, and long-term needs. 

  Alternatives to Methyl Bromide:  Research Needs for California,
     California Department of Food and Agriculture (Sacramento: 
     Sept.  1995). 

  Status of Methyl Bromide Alternatives Research Activities, Crop
     Protection Coalition (July 1995). 

  Alternatives to Methyl Bromide:  Ten Case Studies--Soil, Commodity,
     and Structural Use, EPA, EPA430-R-95-009 (Washington, D.C.: 
     July 1995). 

  Out of the Frying Pan, Avoiding the Fire:  Ending the Use of Methyl
     Bromide--An Analysis of Methyl Bromide Use in California and the
     Alternatives, Ozone Action, Inc.  (Washington, D.C.:  1995). 

  1994 Report of the Methyl Bromide Technical Options Committee for
     the 1995 Assessment of the Montreal Protocol on Substances That
     Deplete the Ozone Layer, UNEP (Nairobi, Kenya:  Nov.  1994). 

  Annual International Research Conference on Methyl Bromide
     Alternatives and Emissions Reductions, sponsored by Methyl
     Bromide Alternatives Outreach (Orlando, Fla.:  Nov.  1994). 

Alternatives to Methyl Bromide, ICF Incorporated for EPA (Washington,
D.C.:  Sept.  1993). 

Alternatives to Methyl Bromide:  Assessment of Research Needs and
Priorities, USDA (Arlington, Va.:  June/July 1993). 

Methyl Bromide Substitutes and Alternatives:  A Research Agenda for
the 1990s, USDA (Arlington, Va.:  Jan.  1993). 


FOOD IMPORTS REQUIRING FUMIGATION
WITH METHYL BROMIDE OR AN
ALTERNATIVE TREATMENT AS A
CONDITION OF ENTRY INTO THE UNITED
STATES
========================================================= Appendix iii

Fresh fruits and vegetables         Other foods
----------------------------------  ----------------------------------
Apples                              Chestnuts, unprocessed or shelled
Apricots                            Citrus, frozen unpeeled or frozen
Asparagus                           peel
Avocado                             Cucurbit seeds, unprocessed,
Beans                               dried, roasted, or salted
Blueberries                         Cumin, unprocessed,
Cabbage (Brassica Oleraceae)        roasted, or ground
Cactus (Opuntia)                    Faba beans, unprocessed
Cherries                            Lentils, unprocessed
Cipollino                           Peppers, dried
Ethrog
Garlic
Grapes
Grapefruit
Horseradish
Kiwi fruit
Lemons
Lettuce
Limes
Nectarines
Okra
Oranges
Peaches
Pears
Peas
Pigeon peas
Pineapples
Plums
Quinces
Roselle
Tangerines
Thyme
Yams
----------------------------------------------------------------------
Source:  USDA's Animal and Plant Health Inspection Service. 


VALUE OF U.S.  EXPORTS FOR WHICH
RECEIVING COUNTRIES REQUIRE
TREATMENT WITH METHYL BROMIDE,
1994
========================================================== Appendix IV

                         (Dollars in thousands)

                                                                Dollar
Commodity                       Receiving country                value
------------------------------  ------------------------------  ------
Apples                          Japan                           $5,986
Blueberries                     Mexico                              12
Cherries                        Japan                           92,427
                                Korea                              535
Cotton                          Mexico                          198,39
                                                                     9
                                Bangladesh                      15,867
                                Pakistan                        36,695
                                El Salvador                     18,536
                                Guatemala                       16,990
                                Peru                            10,869
Oaklogs                         European Union                  21,209
                                Mexico                           4,331
Peaches/nectarines              Japan                               25
                                Mexico                           6,864
Strawberries                    Australia                          426
Walnuts in shell                Japan                            1,349
Walnuts, shelled                Korea                              990
======================================================================
Total                                                           $431,5
                                                                    10
----------------------------------------------------------------------
Source:  USDA. 


OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix V

The Ranking Minority Member of the House Committee on Commerce asked
that we review the concerns of the U.S.  Department of Agriculture
and the agricultural community about phasing out the U.S.  production
and importation of methyl bromide.  Specifically, we agreed to
develop information on (1) the scientific evidence that human uses of
methyl bromide contribute to the depletion of the stratospheric ozone
layer, (2) the availability of economical and effective alternatives
to methyl bromide, (3) the impact of the ban on U.S.  trade in
agricultural commodities, and (4) EPA's authority under the Clean Air
Act, as amended, to grant exemptions to the ban for essential uses. 
We conducted our work from November 1994 through November 1995 in
accordance with generally accepted government auditing standards. 

To review the scientific evidence, we consulted the reports of the
United Nations Environment Programme (UNEP) on its 1991, 1992 (update
of 1991), and 1994 scientific assessments of ozone depletion.  We
discussed the results of these studies with the Associate Director of
Environment, Office of Science and Technology Policy in the Executive
Office of the President and with scientists at the National
Aeronautics and Space Administration who participated in the 1994
assessment.  We also discussed the results with officials of USDA and
EPA, including EPA's Methyl Bromide Program Director.  We further
discussed the scientific evidence with the Methyl Bromide Working
Group, which was formed by methyl bromide producers and distributors
to address scientific issues related to the phaseout, and with the
Crop Protection Coalition, which represents methyl bromide users. 
Finally, we discussed the phaseout with a representative of the
Natural Resources Defense Council, which is coordinating methyl
bromide issues for various environmental groups, including the
Friends of the Earth and the Environmental Defense Fund. 

In addition, we reviewed scientific studies, reports, and other
information either prepared by EPA or submitted by others during
EPA's promulgation of the methyl bromide phaseout rule.  Furthermore,
we attended the "1995 Methyl Bromide State of the Science Workshop"
held in June 1995.  At the conference, which was sponsored by the
Methyl Bromide Global Coalition in cooperation with the National
Aeronautics and Space Administration, various papers were presented
on the latest research developments. 

At EPA, we discussed concerns about alternatives to methyl bromide
with officials of the Stratospheric Protection Division and Office of
Pesticide Programs.  At USDA, we interviewed officials of the
Agricultural Research Service, Economic Research Service, and Animal
and Plant Health Inspection Service, including the Chair of USDA's Ad
Hoc Committee for Alternatives to Methyl Bromide.  We further
discussed substitutes for and alternatives to methyl bromide with the
Methyl Bromide Working Group, the Crop Protection Coalition, the
California Strawberry Commission, and several strawberry growers in
California.  In addition, we reviewed studies, reports, and other
information on the availability and suitability of substitutes and
alternatives provided by these officials.  We also reviewed the
assessment reports of UNEP's Technology and Economics Assessment
Panel, Methyl Bromide Technical Options Committee, and Economics
Committee and attended the "Annual International Research Conference
on Methyl Bromide Alternatives and Emissions Reductions," which was
held in November 1994.  Furthermore we reviewed the applicable EPA
supporting documents and the information submitted to the agency
during the promulgation of the phaseout rule. 

We discussed the trade implications of the phaseout with officials of
USDA'S Economic Research Service, Agricultural Research Service, and
Animal and Plant Health Inspection Service; EPA's Methyl Bromide
Program; the Crop Protection Coalition; and the Methyl Bromide
Working Group.  In addition, we reviewed studies, reports, and other
documents prepared by these organizations on the phaseout's effects
on trade in agricultural commodities.  We also reviewed the 1994
assessment reports of UNEP's Technology and Economics Assessment
Panel, Methyl Bromide Technical Options Committee, and Economics
Committee.  Finally, we obtained information from the Animal and
Plant Health Inspection Service on U.S.  imports and exports of
commodities treated with methyl bromide. 

To determine whether the Clean Air Act provides EPA with the
authority to grant essential use exemptions to the phaseout rule, our
Office of General Counsel reviewed the Clean Air Act and its
legislative history. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI

RESOURCES, COMMUNITY AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C. 

Lawrence Dyckman, Associate Director
Edward A.  Kratzer, Assistant Director
J.  Kevin Donohue, Assistant Director
Raymond H.  Smith, Jr., Senior Evaluator
J.  Kenneth McDowell, Senior Evaluator
Donald E.  Pless, Senior Evaluator
Frank J.  Gross, Senior Evaluator

OFFICE OF GENERAL COUNSEL

Richard P.  Johnson, Attorney Advisor


*** End of document. ***