Trademark of Dow AgroSciences LLC ProFume is a Restricted Use Pesticide. Always read and follow label directions.

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2 Regulatory Update for ProFume Gas Fumigant Dave Barnekow Methyl Bromide and Alternatives in Food Plants: Past, Present, and Future Practical pest management methods for 2010 and beyond ProFume and is a Restricted Vikane are Use federally Pesticide. Restricted Use Pesticides.

3 Topics ProFume Registration Status Sulfuryl Fluoride Registration Review Schedule Update Expected Data Requirements Special Issues Proposed Label Amendments Climate Change

4 ProFume Registration Status Global Status update USA Status update

5 ProFume Global Registration Status First global registration in Switzerland for use in flour mills Since then, ProFume has been registered in an additional 16 countries 2004 USA, Italy, UK, Germany & Austria 2005 Belgium 2006 Canada & France 2007 Ireland, Spain, Trinidad and Tobago, Mexico, Australia 2009 Greece, Turkey 2010 (anticipated) Portugal and the Netherlands

6 ProFume Global Registration Status 2006 CODEX Alimentarius Commission approved MRLs for sulfuryl fluoride for international trade 2007 European Union Annex I listing of Directive 98/8/EC (Biocide) of the active ingredient sulfuryl fluoride for PT 8 (wood preservation) 2008 European Union set t-mrls (Maximum Residue Limits) for sulfuryl fluoride and fluoride in various commodities (Annex III of 396/2005/EC) European Union Annex I listing of Directive 98/8/EC (Biocide) of the active ingredient sulfuryl fluoride for PT 18 (food processing facilities) European Annex I listing of Directive 91/414 (plant protection); vote for inclusion is planned for May 2010

7 Registration Status of ProFume - USA 2004 Registration Grain Processing Facilities, Stored Cereal Grains, Dried Fruits and Tree Nuts First Establishment of Food Residue Tolerances 2005 Registration Food Processing Facilities Established Tolerances for food commodities in Food Processing Facilities 2009 Initiated Registration Review (June) Oct 2009 to Jun Case Development Oct 2014 to Registration Review Decision

8 Registration Review Process Opening the Docket Milestone Date Open Docket for Preliminary Work Plan (PWP) Jun 2009 Public Comment Period - PWP Jun - Aug 2009 Case Development Final Work Plan Oct 2009 Issue DCI Jul Sep 2010 Registrant Data Submission Jul Sep 2012 Preliminary Risk Assessment (RA) Jan Mar 2014 Public Comment Period - RA Apr Jun 2014 Registration Review Decision (RRD) Public Comment Period - RRD Oct Dec 2014 Final RRD and begin post-decision follow-up 2015

9 Anticipated Data-Call-In (DCI) Ecological Risk Avian Plant Human Health Risk Toxicity Studies Exposure Studies Product Use Information Environmental Fate Henry s Law Constant

10 ProFume Label - Future Change

11 Why Change the ProFume Label Two drivers for ProFume Label Changes Managing Fluoride Dietary Risk Address confusion in the industry what and how much can be fumigated during a facility fumigation Not for the management of food adulteration Tolerances are established

12 Dietary Risk Assessment - Fluoride Established Tolerances Challenged EPA addressing the challenge Dow AgroSciences providing Additional dietary exposure data Market driven refinements to the dietary exposure and risk assessment

13 Comparison of Fluoride Exposure Estimates U.S. General Population Exposure (mg/day) Sulfuryl Fluoride Cryolite Background Food Drinking Water Total % RfD EPA (2006) % Dow AgroSciences Refined % Fluoride exposures from use of ProFume gas fumigant constitute a very small portion of total fluoride exposure as calculated through a market use refined dietary assessment. %RfD based on 8.0 mg/day

14 ProFume Label Changes Adjust the commodity list to reflect risk assessment refinements Development of language that: Remove ambiguity in label directions Clears definition of Food Fumigation (commodity) Facility Fumigation (space) Pet Foods Defines in facility fumigations, what and how much

15 Regulatory and Policy Landscape Climate Change Background International Domestic Federal State

16 Climate Change - GWP Background The GWP compares the energy absorbing ability of a gas to a reference gas on a Kg per Kg basis, usually on a 100 year time frame. GWP is a Normalizing Factor (CO 2 equivalents) CO 2 is the reference gas and assigned a GWP of 1 The GWP value is used to compare other gases to CO 2 equivalents GWP is not the measure of impact on the climate Global impact of a gas as a greenhouse gas is a function of both its GWP and the volume of the gas found in the atmosphere

17 Kyoto Protocol (KP) International UN treaty developed to stabilize concentrations of greenhouse gases (GHG) at reduced levels, not to ban or phase them out Six gases or families of gases are included in the KP. The most significant are: carbon dioxide (CO 2 ), methane (CH 4 ) and nitrous oxide (N 2 O). SF is not on this list US signed but did not ratify the KP KP expires in 2012.

18 International UN Negotiations Successor Climate Treaty On-going process for past 4+ years Target: To gain global consensus on successor treaty that would be approved by all major GHG emitting Parties Esp. US, China and India Was scheduled to culminate in December Copenhagen (COP 15) with new treaty Result: Non-binding, non-specific Copenhagen Accord No consensus on GHG emission reduction mechanisms, goals or enforcement UN Efforts will continue in 2010 No indication at this point of the addition of minor gases to the GHG list within new treaty

19 European Perspective European Parliament Statement CO2eq emissions of sulfuryl fluoride would still represent a negligible share of global greenhouse gas emissions the EU, in line with its overall strategy for the negotiations on climate change, does not, at this stage, intend to propose the inclusion of sulfuryl fluoride in a future agreement under the United Nations Framework Convention on Climate Change (UNFCCC).

20 SF & Climate Change

21 SF Atmospheric Properties Climate Change Atmospheric Chemistry of Sulphuryl Fluoride, SO2F2. Dillon, T.J.; Horowitz, A.; Crowley, J.N. Atmospheric Chemistry and Physics : Experimental and Theoretical Study of the Atmospheric Chemistry and Global Warming Potential of SO2F2. Papadimitriou, V.C.; Portmann, R.W.; Fahey, D.W.; Mühle, J.; Weiss, R.F.; Burkholder, J.B., Journal of Physical Chemistry A (49): Atmospheric Chemistry of Sulfuryl Fluoride: Reaction with OH Radicals, Cl Atoms and O3 Atmospheric Lifetime, IR Spectrum, and Global Warming Potential. Sulbaek Andersen, M.P.; Blake, D.R.; Rowland, F.S.; Hurley, M.D.; Wallington, T.J. Environmental Science and Technology 2009 Sulfuryl Fluoride in the Global Atmosphere. Mühle, J.; Huang, J.; Weiss, R.F.; Prinn, R.G.; Miller, B.R.; Salameh, P.K.; Harth, C.M.; Fraser, P.J.; Porter, L.W.; Greally, B.R.; O Doherty, S.; Simmonds, P.G. Journal of Geophysical Research D (2009)

22 SF GWP in Perspective Key Facts The current atmospheric concentration is ~1.5 ppt Atmospheric concentration has been increasing approximately 5% per year since 1978 Most accurate estimate of the atmospheric lifetime is 36 ± 11 years GWP value is 4,780 (+ 30%)

23 SF GWP in Perspective Potential for Increase Annual SO2F2 Production Estimate 3,500 3,000 Total Dow Metric Tonnes 2,500 2,000 1, values estimated by linear interpolation from start of production in 1960 to first available production data in , Year Atmospheric Chemistry of Sulfuryl Fluoride: Reaction with OH Radicals, Cl Atoms and O3 Atmospheric Lifetime, IR Spectrum, and Global Warming Potential. Sulbaek Andersen, M.P.; Blake, D.R.; Rowland, F.S.; Hurley, M.D.; Wallington, T.J. Environmental Science and Technology 2009 Sulfuryl Fluoride in the Global Atmosphere. Mühle, J.; Huang, J.; Weiss, R.F.; Prinn, R.G.; Miller, B.R.; Salameh, P.K.; Harth, C.M.; Fraser, P.J.; Porter, L.W.; Greally, B.R.; O Doherty, S.; Simmonds, P.G. Journal of Geophysical Research D (2009), p. 8

24 SF Atmospheric Fate Limited Climate Impact Radiative forcing of SF is approximately 3.3 x10-4 W m Radiative Forcing - Kyoto Gases and SF Radiative Forcing (W/ m2) CO2 CH4 CFC-12 N2O CFC-11 HCFC-22 CFC-113 CCl4 HFC-134a CF4(PFC-14) Gas HFC-23 HCFC-142b SF6 HCFC-141b CH3CCL2 HFC-125 C2F6(PFC-116) HFC-152a SO2F2

25 SF Climate Change Impact SF is in a steady-state in the atmosphere Represents approximately 0.01% of greenhouse gases. Current SF uses results in a diminutive contribution to global warming Future growth of SF use will always represent a negligible contribution to global greenhouse gas impact

26 Discussion