Methyl Bromide Regulatory Update

The methyl bromide situation for SWPM (Solid Wood Packaging Material) in international trade applications became much clearer on January 3, 2003.  On that date the US Environmental Protection Agency issued its final rule 40 CFR 82, “Protection of Stratospheric Ozone: Process for Exempting Quarantine and Preshipment Applications of Methyl Bromide” in the Federal Register (Volume 68, Number 1, Pages 237-254). 

In effect, this rule establishes exemptions that allow unrestricted use of methyl bromide for international trade applications of SWPM covered under the IPPC’s Guidelines for Regulating Wood Packaging Material in International Trade. 

The EPA’s final rule establishes an exemption for methyl bromide production, import reduction and phaseout schedule for quantities to be used for quarantine and preshipment applications. 

For the purposes of solid wood packaging material (SWPM), quarantine is generally recognized as the relevant application for a number of reasons.  First, quarantine applications are generally focused on a specific and officially recognized quarantine pest, such as the Asian Longhorn Beetle for SWPM, while preshipment applications are generally applied to a wider range of pests.    

Further, methyl bromide fumigation of SWPM for quarantine purposes requires very specific and intensive treatment parameters (including time, temperature, and concentration levels), as specified in the IPPC’s “International Standards for Phytosanitary Measures”. For SWPM, the treatment must penetrate the wood components sufficiently to ensure that the pest is completely eradicated.  Conversely, preshipment applications are generally of shorter duration and less intensive because they are applied to products such as fruits and vegetables where penetration is less of an issue.

Because of the inherent logistics of using SWPM in international trade (the length of time necessary to manufacture the packaging, to treat it, to ship it to the product exporter, to load the product into the SWPM, and to complete the domestic portion of export process), quarantine applications allow for treatment outside the 21-day window required for preshipment applications. 

Finally, preshipment applications are limited to the movement of goods from the US to another country and do not include movement of goods within the US.  In contrast, quarantine applications can apply to exports from the US, as well as applications to meet State, county or tribal quarantine requirements.