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Prepared Witness Testimony The House Committee on Energy and Commerce
Status of Methyl Bromide under the Clean Air Act and the Montreal Protocol.
Subcommittee on Energy and Air Quality
Mr. Rich Siemer
Thank you Mr. Chairman and members of the Committee. I am Rick Siemer, president of Siemer Milling Company. Siemer Milling Company operates flour mills in Teutopolis, Illinois, Hopkinsville, Kentucky and Gainesville, Missouri. Together, the three Siemer Milling Co. facilities produce more than 2.1 million pounds of product each day. Siemer Milling Company is a family- and employee-owned company. It was founded in 1882 with my great grandfather Joseph Siemer as proprietor. Siemer Milling Company's primary product is wheat flour milled to different specifications for the making of such foods as cookies, crackers, cakes, pretzels, bread and buns. We are proud to have received numerous awards including the 2000 Business Ethics and Social Involvement Award from Eastern Illinois University and East Central Illinois Development Corporation. I am testifying today on behalf of the North American Millers' Association (NAMA). NAMA is the trade association representing 46 companies that operate 169 wheat, oat and corn mills in 38 states. Their collective production capacity exceeds 160 million pounds of product each day. Page 2 The purpose of my statement is to encourage Congressional action to extend the use beyond 2004 of methyl bromide as a food safety and sanitation tool by the flour milling and food processing industries. There are three reasons for this extension: 1) Methyl bromide is easily the most cost-effective tool - and for many facilities, the only practical tool - currently available to protect grain processing facilities against insect pests; 2) Food and agricultural uses of methyl bromide are not a critical environmental hazard; and 3) The internationally-established program to eliminate methyl bromide is environmentally irrational and profoundly unfair to U.S. growers and processors. Why and how we use methyl bromide At Siemer Milling Company, we use methyl bromide for one reason - to keep insects out of our nutritious, wholesome food products. Methyl bromide allows us to meet the U.S. Food and Drug Administration's strict rules for clean and wholesome food. We take those rules very seriously. We do so because it's the law, but just as importantly because clean food is something we want to provide and consumers expect. You may remember watching your grandmother or mother sifting flour when she baked. The main reason she sifted the flour was to remove the insects. Nobody sifts flour anymore because there are no insects in the flour. Methyl bromide helps us make sure of that. Our customers expect and appreciate that commitment to cleanliness and safety. Let me tell you how we use methyl bromide. We use it to fumigate the physical mill structure and the equipment contained in the mill. We do not use it to fumigate raw wheat or corn, nor processed products like flour. Our mills typically receive one or two general fumigations with methyl bromide over any two-year period. The fumigation usually occurs over a three-day weekend so as to minimize downtime. At the beginning of the fumigation process, grain is shut off entering the mill from the grain elevator storage facility. The mill continues to run until all incoming grain has been milled and conveyed into finished product or by-product storage. The machinery in the mill is opened and all remaining residues of grain and finished product are cleaned out. The machinery is left open to achieve maximum exposure to the fumigant. Deep structural cleaning is done also since fugitive dust and grain fractions in the structure will affect the effectiveness of treating the entire facility. There may also be treatment of empty storage bins at this time. The mill structure is then completely evacuated except for the trained applicators under supervision of the certified outside contractor who conducts the fumigation. The mill structure is sealed to prevent gas leakage. Applicators begin releasing the methyl bromide into the mill. Page 3 The label approved by the U.S. Environmental Protection Agency (EPA) allows for usage at up to 6.0 lb. per 1000 cubic feet. But the common dosage for a 100% methyl bromide fumigation in the milling industry is 1.0 - 1.5 lb. per 1000 cu. ft., depending on the tightness and structural integrity of the building. Since 1998, we have used a combination of methyl bromide and carbon dioxide; this reduces the dosage for methyl bromide to 0.75 - 1.0 lb. per 1000 cu. ft. We have cut our total methyl bromide usage by nearly 60% in the last decade. The gas is held in the facility for 24 hours. At the appropriate time, the applicators aerate the facility and test the atmosphere to ensure safety. Workers then enter the mill to re-assemble the mill systems, close up the equipment, remove the sealing materials and prepare the mill for start-up. After the equipment has been closed, the mill is re-started and the flow of grain into the mill begins. The first few minutes of production may be diverted into by-product storage to scour the milling equipment and spouting essentially free of methyl bromide residues before the product destined for human consumption flows through. On the subject of residues, it is worth noting that the milling industry association funded a methyl bromide residue study in 1993 to meet EPA requirements. Despite the earlier comments about methyl bromide not being used to fumigate wheat or corn, grain was fumigated with the compound in order to generate worst-case scenario data. Also, the fumigant was applied at an exaggerated rate of 8.0 lb. per 1000 cubic feet. Even with an extremely sensitive level of detection of 0.25 parts per million, there were no residues. Alternatives More than $140 million has been spent by the USDA alone to find alternatives for the many uses of methyl bromide, with very little success. The milling industry, too, is experimenting widely with potential alternatives, with mixed success. For example, high heat treatments have shown some promise in certain facilities. However, industry-wide experiences with heat treatments emphasize the importance of the structural integrity of the mill. In many mills heat treatments are not feasible. Those mills are not tight enough to facilitate raising and holding the temperature at high levels, nor do mills possess the heating capacity to raise the temperatures in the structure or equipment to insecticidal levels. There is considerable initial cost associated with outfitting a mill for heat-up, including changing sprinkler heads, kick-outs on motors, etc. Phosphine, effective in treating stored grain, empty bulk storage bins and grain and product transport vehicles, may not be a wise choice for the mill. This is mostly Page 4 due to the extensive electrical equipment present. Phosphine is highly corrosive and can seriously damage electrical contacts, motors, programmable controllers, etc. We believe that an effective integrated pest management (IPM) program is the best answer for ensuring good sanitation. This includes non-chemical and chemical means so as to minimize the reliance on any one tool. An alternative is not truly an alternative if it is not BOTH economically and technically viable. For example, an average wheat flour mill produces about one million pounds of flour each day. One likely alternative treatment currently being tested will require about 48 hours longer to complete than does a methyl bromide fumigation. At a sales price of about $0.12 per pound of flour, the miller will lose $240,000 in revenue every time the facility is treated with the slower-acting alternative. In the meantime, labor, depreciation, tax and overhead costs continue. And the compounds currently being considered for EPA approval will likely cost much more than methyl bromide. So while there may be other treatments that can control the insects in the mill, they are not viable if they are not affordable. U.S. milling is an extremely competitive industry. Our profit margins are razor thin. Approximately 10 percent of our industry capacity has closed in the last two years. For a mature industry like flour milling, that is a huge adjustment. Losing methyl bromide would likely make more mills subject to closure, taking good paying jobs and economic activity with them. As noted above, our industry has drastically reduced the amount of methyl bromide we use, but complete elimination does not yet appear to be generally practical, or even possible. Science EPA's web site states that human-made methyl bromide has contributed only about 4% to ozone depletion over the past 20 years, with only 2.5% attributed to agricultural uses. That raises a serious question as to whether delaying the ban on methyl bromide will aid in restoration of the ozone layer. If our uses of methyl bromide are, contrary to logic, very harmful to the environment, then it should be banned globally on the same date, and the sooner the better. However, the Montreal Protocol phase-out schedule suggests that it is not imminently harmful, since the schedule allows ten extra years of use for some very economically significant "developing countries." Banning methyl bromide in the U.S. while allowing its continued use elsewhere shifts jobs and economic activity offshore with no real gain to the environment. That is stupid and unfair to U.S. farmers and businesses, both small and large. Page 5 Critical Use Exemption Some potential alternatives have been identified, but for a significant range of uses, technically and economically viable alternatives do not exist. EPA and USDA have acknowledged this in the recent U.S. Critical Use Exemption (CUE) submission to the Parties of the Montreal Protocol. In fact, after an exhaustive objective review by government and university scientists, EPA confirmed that almost 40% of the baseline uses of methyl bromide do not have viable alternatives. There are several problems with the CUE process, not the least of which is that it doesn't take effect until 2005, the year when methyl bromide is scheduled to be banned in the U.S. Second, the U.S. cannot issue a CUE by itself, but must receive approval from the United Nations for exemptions. American agriculture is justifiably skeptical about fair treatment from the United Nations for the following reasons: The UN approval process is agenda-driven and highly politicized. Ultimately, the fate of the U.S. CUE applications that are recommended to the parties of the Montreal Protocol will be determined by a handful of individuals unaccountable to U.S. taxpayers, behind closed doors, despite the hours and expertise EPA committed to this process. It is inevitable that the decision-makers will be biased toward an ideological environmentalist agenda. A pervasive anti-U.S. antagonism in the group is not an unreasonable assumption. Some of the people are from countries that are agricultural competitors of the U.S., and they might be sorely tempted to maintain the competitive advantage that has been handed to their homelands. EPA did not allow us to see or comment on the conclusions it reached prior to submitting our CUE application to the Montreal Protocol. We had no chance to respond to any incorrect assumptions or resolve any open questions. In the end, the U.S. EPA recommended to the United Nations that a quantity of methyl bromide be made available for grain milling and other food processing industries that is much smaller than the quantity we requested for milling alone. If EPA is wrong and its recommended quantity is inadequate, how will the agency allot the available fumigant? Who gets to make that decision, and on what basis? In short, on one hand, the elimination of this tool will significantly adversely affect the food and agriculture industries in many states. This is certain. On the other hand, extending the phase-out will not impact the restoration of the ozone layer. Action needed In closing, let me state that NAMA believes the Administration must either (1) renegotiate the United Nations Montreal Protocol Treaty this year to allow the U.S. more time beyond 2005, or (2) support legislation to amend U.S. law to freeze the phase-out level at 50%, the level in effect prior to 2003. Page 6 That concludes my testimony, Mr. Chairman. I would be happy to answer any questions you or other committee members may have.
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