TCS Daily

Parliament of Bans

By Henry I. Miller - July 12, 2006 12:00 AM

Scandals, incompetence, and profligacy at the UN are hardly news these days, but many of the organization's worst transgressions are hidden from public view. Among the worst examples are the organization's attempts to police all manner of scientific, technological and commercial activities.

The UN's regulation of various chemicals applied to agriculture and food production is among its most egregious failures. Consider, for example, the Montreal Protocol on Substances that Deplete the Ozone Layer, which took effect in 1989. In essence, this is an agreement to limit or phase out various chemicals, and although it stipulates that "measures taken to protect the ozone layer from depletion should be based on relevant scientific knowledge, taking into account technical and economic considerations," appropriate balancing of all these factors has been lacking.

One chemical on the Montreal Protocol hit-list is methyl bromide (MB), an important pesticide used to control harmful insects, rodents, pathogens and weeds. Used by a large cross-section of the world's agriculture producers, it is an essential tool for pest control. (If you have ever eaten a commercially-grown strawberry from California, chances are you have methyl bromide to thank.)

MB is being phased out, in spite of the absence of any proven alternative and its importance to farmers and food producers -- and the fact that it is an effective new way to kill anthrax spores.

The U.S. EPA will soon release figures showing that the volume of methyl bromide being held in inventories is at a four-year low and the product available to the market is at an all-time low. The reason is the restrictive and arbitrary approach that the U.S. EPA has taken in reviewing and granting critical use exemptions (CUEs), which are allowed under the terms of the Montreal Protocol.

In the CUE process, the U.S. government (that is, the EPA) nominates uses and volumes on behalf of American companies and must effectively persuade the international committee that there is in fact a critical need. Depending on the EPA to represent the interests of industry is like asking Dick Cheney to advise Nancy Pelosi on political strategy. Moreover, ceding to a foreign entity the right to make U.S. domestic regulatory decisions is insidious, as is the wording in U.S. law that permits CUEs only "to the extent consistent with the Montreal Protocol."

U.S. stakeholders have applied for CUEs for certain volumes of MB every year since 2002, but the EPA has conveyed requests for much smaller amounts. This is not surprising, given the consistently scientifically-challenged actions of the EPA, whose actions have been more a concession to European Union eco-babble than protection of U.S. interests.

More than 40 commodity and trade associations have argued for more rational, liberal policies toward MB. They have requested, for example, that field inventories be maintained at relatively high levels to provide a safety net in case of an interruption of production of the product. Such an interruption could result in a significant decrease in the supply and to skyrocketing prices for fresh fruits and vegetables B which in turn would lead inevitably to less consumption of these healthy foods, and even to insect and rodent contamination of many processed foods.

Meanwhile, industry, growers and researchers continue to search for suitable alternative products. (The USDA estimates that more than $120 million has been spent over the last 10 years, with no replacement found.) Proposed alternatives are insufficiently effective, cost too much, or have unacceptable environmental impacts or human health concerns.

Those most affected by the phase-out have attempted to get the EPA to press the UN for a more practical approach to the CUE process. Specifically, they want CUEs to be granted for more than one year and production levels frozen at 30 percent of the 1995-98 baseline production while scientists (both government and private sector) evaluate the impact of methyl bromide on the ozone layer and search for an alternative.

Regulators have made the process a nightmare for those who produce or need MB, but ironically, even if all manmade methyl bromide were eliminated, more than 80 percent of the current volume would still be released into the atmosphere.

How is that possible? Simple: It occurs naturally. Oceans, salt marshes, and the burning of biomass are a few of the "sources" of methyl bromide.

Thus, we have another absurd situation resulting from one-size-fits all UN regulation: significant economic damage, without commensurate benefit to the environment or human health.

How much economic damage? A USDA National Agricultural Pesticide Impact Assessment Program evaluation determined that there would be a huge adverse economic impact on the agricultural community, most strongly felt in California and Florida, the primary users of MB. The USDA estimated that a MB phase-out for pre-planting soil fumigation would cause $1.5 billion in lost production annually in the United States. And this estimate does not take into account other economic losses, such as post-harvest, non-quarantine use; quarantine treatments of imports; or lost jobs and markets.

The condemnation of methyl bromide is an example of regulators focusing on something because it's convenient, even if the effort affords little benefit and makes little sense.

Other pertinent factors in the methyl bromide fiasco are the corruption and malfeasance that often accompany UN regulation. Recently, an official working with the UN-funded Methyl Bromide Phase-Out Project was arrested in Malawi, accused of embezzling $70,000 worth of fuel coupons bought from BP Malawi.

The methyl bromide example -- losses of at least $1.5 billion annually in one country, from the ban of a single chemical, under a solitary UN regulatory agreement -- is just the tip of a vast iceberg of anti-consumer, anti-business regulation at the UN. The organization, once exalted by Harry S. Truman as "The Parliament of Man", is now the scourge of man, and of international trade.

Dr. Miller, a physician and fellow at the Hoover Institution, headed the FDA's Office of Biotechnology from 1989 to 1993. Barron's selected his most recent book -- The Frankenfood Myth -- one of the 25 Best Books of 2004.


What's the fuss?
I don’t understand what all the fuss is about. Once the USA and Europe have successfully destroyed their own agriculture and manufacturing capabilities the more deserving countries such as Argentina, Chile, China, and Sub-Saharan Africa will take their rightful place in the world. After all – just because Western Europe and the United States created modern civilization – IT JUST ISN'T FAIR that we continue to care for the world. And everyone knows the importance of making everything "equal and fair."

Chemistry to the Rescue
UC says methyl bromide could be replaced with new techniques
Central Valley Business Times, July 12, 2006

A new method for ridding harvested fruits and vegetables of insect pests and microorganisms, without the use of ozone-depleting chemicals like methyl bromide, has been developed by researchers at the University of California, Davis.

The technique, called "metabolic stress disinfection and disinfestation," essentially suffocates insects found in harvested produce. Forces produced by alternating vacuum and pressurized carbon dioxide applications cause irreversible changes in cell chemistry and damage to essential respiratory structures of insects, the Davis researchers say. Ethanol gas also is applied briefly to accelerate killing of fungi and bacteria and to damage insect eggs.

The process would be applied to pallets of fruits and vegetables to prevent damage during storage and shipping, and to avoid transporting potentially invasive insects from one country to another, according to UC Davis.

A patent is pending on the technology, which was reported in the July issue of the Journal of the Science of Food and Agriculture...

A couple of potential problems
1 We have no idea whether it will work on an industrial scale.

2 If it does, as it stands it will be more expensive than methyl bromide. This could have two potential effects. First is placing added costs on already slender farm incomes. Second and more likely is that requiring food maintained to such standards while banning MB will have the effect of creating yet another non-tariff barrier to 3rd World food imports.

Recovered Costs
Sterilisation method sucks life out of bugs, June 7, 2006

...Tim Essert, the principle electronics engineer on the project, told Chemistry & Industry magazine that the initial hardware cost of an MSDD system is higher than methyl bromide, but the cost of chemicals is much cheaper.

The system would eventually it would pay for itself, he claimed.

About $20 to $40 worth of methyl bromide is needed to fumigate one pallet of fruit, the scientists estimate. Carbon dioxide and ethanol used in an MSDD treatment would cost about $10, assuming no recovery of the gasses for further use.

"MSDD also has additional benefits to the environment, as the GASSSES CAN BE RECOVERED AND RECYCLED," the scientists stated.

Simple, Efficient
Metabolic stress disinfection and disinfestation (MSDD): a new, non-thermal, residue-free process for fresh agricultural products
Journal of the Science of Food and Agriculture, July 3, 2006

...The MSDD process is rapid (5 log10 microbial reduction), reproducible, practical, economically competitive and applicable to large volumes of commodities. It causes minimal or no sensory/functional effects in host commodities.

If developed commercially, it can be a SINGLE ALTERNATIVE TO A BROAD SPECTRUM OF POST-HARVEST PESTICIDES pesticides for disinfection and a likely alternative to methyl bromide fumigation or to irradiation for the post-harvest control of arthropods.

That first sentence should read:

"The MSDD process is rapid (5 log10 microbial reduction), reproducible...

Correction Redux
The comment software is stripping out the mathematical symbols and all the text in between. The first sentece should read:

The MSDD process is rapid (less than 4 h), effective (100% insect controls, greater than 5 log10 microbial reduction), reproducible,

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