The New Zealand Environmental Protection Authority has undertaken a systematic review of hazardous chemicals used in New Zealand. Some of these are used in the production and post harvest treatment of export cymbidiums. This section of the blog is intended to collect together the various reports and submissions made to the EPA on the chemicals relevant to cymbidiums. The most recent developments are listed first. With the most recent post appearing in bold blue print.
Organophosphates and Carbamates:
The Decision by the EPA on OPC's was released on 27th. June 2013. It was subsequently revised to incorporate the new non-contact periods (see below) and was re-released on 28th. July 2015. The revised decision can be accessed on the following link:
http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/APP201045_APP201045_Decision_Amended__with_s67As_and_APP202142_(2015.07.28).pdf
The revised Annex to the Decision can be accessed on the following link:
http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/APP202097_APP202097_Controls_vFINAL_plus%20revoked%20controls_(2015.09.24).pdf
OPC Non-contact period reassessment:
For some of the chemicals included in the OPC Reassessment the Environmental Protection Authority has undertaken a further review with a view to reintroducing non-contact periods (periods between when the chemicals are applied and when flowers are expected to open). This is to protect bees, and other insect pollinators, against adverse effects arising from post-application exposure to the substances. The chemicals involved in this reassessment were those containing acephate, dimethoate, methamidophos, methomyl or oxamyl. The submission period initially closed on 2 September 2014 but was subsequently extended to 16 September 2014. On the 19th. of August 2015 the following additional controls were announced: Non-contact periods of seven days for products containing acephate (except in lemons) or dimethoate; eight days for methomyl (except in strawberries and greenhouse tomatoes) and 10 days for oxamyl (except in greenhouse tomatoes). The controls come into effect on 1st. July 2016.
Dichlorvos Reassessment:
The decision on the dichlorvos reassessment was released by the EPA on 25th. of September 2015 and can be viewed on the following link:
http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/APP202097_Dichlorvos_Decision_FINAL.pdf
The Annex to the Decision which contains the controls can be found on the following link:
http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/APP202097_APP202097_Controls_vFINAL_plus%20revoked%20controls_(2015.09.24).pdf
Dichlorvos was removed from the OPC Reassessment as it has uses outside horticulture and agriculture. The plan to reassess dichlorvos was notified by the EPA in July 2014 and groups who had submitted information to the earlier reassessment were requested to provide updated information on usage etc.. On the 29th. of October the EPA advised that the period for submissions was open. It was originally scheduled to close on 10th. December but this period was subsequently extended. The Hearing was held in Wellington, on the 6th and 7th of May 2015. The final decision is required to be released within thirty days of the hearing being declared closed. An extension to this time-frame has been requested and granted.
The initial EPA Consultation Report recommended that the use of dichlorvos in greenhouses be phased out but that its use be retained for the post harvest treatment of cut-flowers. The proposed phasing out was based on the possible negative effects on the human health of bystanders. Quantitative information on this and other aspects from industry groups has been requested by the EPA in the past but none has been forthcoming. In the absence of quantitative data to support its continued use the EPA proposed it be withdrawn. (Note: Dichlorvos is banned in the EU, in Australia it is banned for use on in-door food crops but is allowed for use on ornamentals and cut-flowers. Canada is planning a reassessment of Dichlorvos and a number of other chemicals.) Supporting documents for the re-assessment can be found on the following link: http://www.epa.govt.nz/search-
As a result of further investigations and submissions by interested groups,the EPA has revised its recommendations. It is now proposed that the use of dichlorvos be retained with a raft of new controls. These can be found on the following link: http://www.epa.govt.nz/search-
A personal submission in relation to the dichlorvos reassessment can be found on:
Submission to EPA on Dichlorvos
A copy of the verbal transcript presented to the EPA Dichlorvos Hearing can be found on:
Verbal Submission to EPA on Dichlorvos
Personal Submission to OPC Hearing:
A personal submission was made to the EPA on the OPC Reassessment. This focused on the need for greater understanding of the hazards involved in the use of these chemicals by Approved Handlers and the need for bystanders (neighbours) to be better informed of the hazardous nature of the chemicals and the methods that can be used to reduce their exposure to them especially longterm low level exposure.
The submission made to the EPA can be found on:
Submission to EPA on OPCs
The written submission to the Hearing can be found on:
EPA OPC Hearing Submission
The transcipt of the verbal submission to the Hearing along with the question and answer session can be found on the following link (pp 131-142):
http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/APP201045_HEARING%20Trascription%207%20March%20Auckland%20hearing%20APP201045.pdf
As a follow-up to the Decision a summary of the main aspects and some recommendations concerning these was prepared for consideration by the NZEGO (New Zealand Export Orchid Growers Association) Committee. These are contained in the following attachments. The first contains the text and the second an Excel file which summarises the new controls for specifc chemicals used by the New Zealand cymbidium industry.
Summary And Suggestions for NZEGO
Table of New Controls
EPA Follow-up to the OPC Decision The EPA has released a series of "Fact Sheets" covering the organophosphates and carbamates that have been retained following the OPC re-assessment. These "Fact Sheets" can be accessed through the following link: www.epa.govt.nz/OPC/Pages/
In addition the EPA has released a document covering labelling, packaging and safety data sheets for the products that are to be retained. This document can be accessed through the following link: http://www.business.govt.nz/worksafe/information-guidance/all-guidance-items/hsno/hsno-guidance-pages/using-insecticides-safely
Most of the OPC's currently used by New Zealand cymbidium growers have been retained although tighter controls are to be placed on their use. Diazinon is the main exception with it to be phased out over a period of fifteen years. The tighter controls relate primarily to improved signage, clear re-entry times, specific requirements to inform neighbours in writing of the hazards and documentation of measures taken to minimise spray drift. Some chemicals are also only able to be applied using remote applicators (LVM etc.). The new regulations will become fully effective from July 2015.
The Decision does not cover dichlorvos which is the main OP used by New Zealand cymbidium growers. A decision on dichlorvos has been deferred but it appears most probable that access to it will be retained for indoor use and that the minimum re-entry time specified will be shorter than for most of the other OPs. In-doors in this context seems to mean in a building that is largely airtight. For practical purposes this probably means a building where a thermal fogger can be used effectively. It does not mean in-door as defined by Biosecurity for registration under the LBAM programme where the requirement is only that holes in the external wall do not exceed 7mm in diameter.
Whereas previously re-entry times have been specified in terms of contact re-entry and non-contact re-entry, in the current Decision entry restrictions remain in place until contact re-entry conditions are met. The re-entry periods are specified in terms of total venting time and therefore when limited venting is undertaken during cooler periods the re-entry times may span a number of days.
The period until the Decision becomes binding means that there is adequate time for those growers who use thermal foggers to develop remote systems for adjusting and moving the equipment using radio switches and travelling irrigator technology.
The onus of the current Decision is put on applicators (growers) to minimise the impact of spray drift and to inform all those that may be affected of the potential hazards. Most commercial cymbidium growers have sheds which have shade cloth covering all apertures that are not covered in glass or plastic film. This shade cloth is an effective trap for most chemical particles with protection rates of around 85% being quoted in the literature. Some growers with gull-wing roof vents do not have shade cloth protection there as it can interfere with the opening and closing mechanisms. These growers may need to look at shelter belts as a means of minimising spray drift to neighbours during venting. Shelter belts, one and half times the venting height and comprised of needle bearing tree varieties with good porosity, are recommended by some foreign extension agencies for this purpose. Growers with vents which do have mesh but which generate rapid air movement during venting as a result of location, structure design and or in-door and out-door temperature differentials may also need to consider the use appropriate shelter belts.
One of the indirect impacts of the EPA Reassessment will be the need for cymbidium growers to look more carefully at their mandatory Health and Safety Plans to take account of the health risks arising from long term low level exposure to OPs for young children and pregnant, lactating and potentially pregnant women. The Reassessment has highlighted the danger to these groups through a series of recent and on-going scientific studies. The health implications for these groups is long term rather than immediate and therefore require imposed rather than intuitive protective measures. The Decision is based on the trade-off between safety hazards and the economic benefits of continued access to the chemicals. (The re-entry periods imposed are those that are currently imposed in other similar countries and the Decision states that some EPA studies indicate that these are too short to be considered safe - i.e. compliance with them alone may not be adequate to comply with the safety requirements prescribed under the Health and Safety Act). From a health and safety aspect therefore the information from the earlier acephate study which showed that a clear area of sixty metres around treated growing sheds and a re-entry period of between nine and over one hundred days were required for complete safety are still relevant to safety programmes for staff and visitors to the production site. Of necessity the rules set in the Decision are based on modal occurrences and "safe" periods for re-entry in specific situations may vary greatly from these. Work on dichlorvos indicates that the safe re-entry period may vary from 4 hours to 4 days depending on the growing shed conditions. The safe contact re-entry period is also likely to be affected by the watering system with in-pot watering systems extending the period due to higher levels of dislodgeable chemical residues being present on the plant. The EPA have sourced a number of documents relating to the protection provided by gloves which may be relevant to cymbidium growers who need to reduce direct contact with chemical residues arising during tying, picking, grading and packing activities. OP field testing kits provide a means of determining safe re-entry times in specific situations.
The EPA identified specific information gaps in assessing the safety precautions necessary for the use of OPCs in cymbidium production. NZEGO did not initiation any specific actions to address these deficiencies during the course of the re-assessment. In its Decision the EPA has recommended that industry groups address the specific hazards associated with the continued use of OPCs in their specific production environments.
Hearings were held by the EPA during early March 2013 regarding the reassessment of organophosphates and carbamates. The final decisions, which are binding, arising from the reassessment are expected to be released in June 2013. Dichlorvos has been withdrawn from the current reassessment and decisions on this chemical will be released at a subsequent date. Submissions made to the hearings and transcripts of the actual hearings can be viewed under "Documents" on: http://www.epa.govt.nz/search-
Links to various documents and discussions that have arisen as a result of the Hearing can be viewed through the following link: http://www.epa.govt.nz/publications-resources/topics/Pages/Organophosphates-and-carbamates.aspx
In early November 2012 the EPA released the "Consultation Report" on organophosphates and carbamates. This report contains the recommendations of the EPA for increased controls on all of the chemicals reviewed and for some of the chemicals total removal from the market. Interested parties have until 20th. January 2013 to make submissions concerning the recommendations.
http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/APP201045_Consultation%20Report.pdf
A number of the submissions presented to the EPA on Diazinon alluded to the short-comings of assessing chemicals on a piecemeal basis. In order to end up with the most effective combination of chemicals taking into account both their hazardous nature and their usefulness to society, final decisions on the chemicals already assessed were put on hold and a number of other organophosphates and carbamates were identified for simultaneous evaluation. The following link contains notification by the EPA on this change of approach.
Notification of expanded coverage
Following a meeting of cymbidium growers in Northland the following submission was made to the EPA.
NZEGO Submission on Organophosphates and Carbamates
The submission re-enforced the findings of the Nuvos survey which indicated the importance of this chemical to the cymbidium industry and also emphasised the need for some organophosphates and or carbamates to remain available to enable the rotation of chemical groups in spray programmes in order to reduce the rate of resistance build up to the newer, softer chemicals. Reference was also made to cymbidiums being an in-door crop which required extensive handling during growing and harvest and which were grown largely by small owner operators. These features in combination meaning that there was limited risk to "by-standers" from the use of hazardous chemicals and the growers had a strong vested interest in making sure that they were used judiciously and safely. In addition the issue of off-label use, including the high cost of registration of new chemicals was highlighted.
In May 2012 the EPA released its report on organophosphates and carbamates. Responses from interested parties are required before 31st July 2012.
The following link gives access to all the individual crop reports of which cymbidiums is the only cut-flower report (there is also a report on ornamentals). There does not appear to be any other report specifically for in-door crops.
http://www.epa.govt.nz/publications-resources/topics/Pages/Organophosphates-and-carbamates.aspx
This link provides background information on the criteria used by the EPA in its assessments.
http://www.epa.govt.nz/Publications/Background%20Document%20for%20Sector%20Assessments.pdf
The EPA expects to take until the end of 2012 to integrate responses into their final report and some dialogue with interested parties may occur during this time. Following the release of their final report it will be open for public submissions. After consideration of these, a final decision will be made by an independent body within the EPA.
It seems that the current approach of the EPA is to get interested parties to propose what strategies they could use to balance the hazardous nature of the chemicals under consideration with the benefits they provide to the respective production groups. That is, rather than proposing a set of conditions which the industry regards as impractical or untenable they are requesting that the respective sectors put forward proposals that could be implemented and monitored effectively at field level while providing adequate protection for employees, by-standers and the environment in general.
Regulations once imposed are likely to be long standing and only subject to revision following an extended review process. It is therefore important to consider suggestions which will serve the industry in the long term rather than just under current conditions. Two important aspects in this regard is the likely availability of the public at large to detect chemicals through mobile phones and other portable devices and the outstanding issue of off-label use. One of the implications of freely available mobile detectors is that staff or by-standers may record false dangers so robust and recognised application and monitoring systems need to be in place to counter the potential disruption caused by these false positives. At the present time it seems that there is no legislative limitation on off-label use but some of the recent EPA recommendations (Diazinon) have proposed that chemicals can only be used according to label recommendations. An alternative view is that off-label use should be allowed but the manufacturer/supplier accepts no responsibility for effectiveness or damage arising from its use and the user accepts full responsibility for all safety and control measures applied to the product. A broader issue is the one of registration itself. Most countries assess and register chemicals. This is a high cost and time consuming exercise. Consideration should perhaps be given to accepting approvals from other countries as being sufficient to meet New Zealand's requirements in this regard (i.e. Australian, US or EU approvals). This is however an issue that faces all growers who use agricultural chemicals off-label and a coordinated approach from all grower groups in this situation would be more compelling than a single response from cymbidium growers. Another issue of importance to manufacturers and distributors is the broad classification covered by "ornamentals" which encompasses an enormous range of botanical families.
Diazinon:
The following link is to the report prepared by NZEGO in response to the New Zealand Environmental Protection Authority reassessment of the organophosphate Diazinon.
Diazinon Report EPA (Environmental Protection Agency)
A copy of the original report dated June 2011, by the EPA, can be found on the EPA website through the following link. http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/ERMA200398_Application%20-%20ERMA200398.pdf
Dichlorvos ((Nuvos):
The following three links contain the final report submitted to ERMA (now EPA) by the Northland Cymbidium Growers' Association on the use of dichlorvos (Nuvos) in the New Zealand export cymbidium industry. The report was submitted in January 2009.
Frontice - Dichlorvos Report
Preface - Dichlorvos Report
Main Body: Dichlorvos Report
The ERMA (now EPA) report can be found on the following link on the EPA website. http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/HRC08004_Dichlorvos%20application%20form%20(2010.11.24).pdf
The following link to the EPA website contains a copy of the letter dated February 2011 which was submitted to the EPA by NCGA/NZEGO in response to the findings of the dichlorvos reassessment. http://www.epa.govt.nz/search-databases/HSNO%20Application%20Register%20Documents/HRC08004_Submission%20-%20Northland%20Cymbidium%20Growers%20Association%20Inc.%20102374.pdf
Acephate (including Orthene):
The following link is to the January 2011 EPA report on acephate and methamidophos. http://www.epa.govt.nz/Publications/ERMA200399-Application-Form.pdf
No submissions were made by the cymbidium industry on acephate (Orthene). The preliminary recommendation of the EPA report was that Orthene be withdrawn from the market as it was considered that the 80 metre clear zone that would be required around greenhouses and the 9 to 130 day re-entry periods would be untenable for commercial horticulture.
Methyl Bromide:
Methyl bromide is a very toxic chemical and is used by the cut-flower industry as a post harvest fumigant. This is necessary as many of the export markets have a zero tolerance for live insects. Methyl bromide fumigation is undertaken in special facilities and is normally initiated by the flower exporters rather than the growers themselves. Trials have been undertaken using less toxic chemicals but to date these have proved to be either ineffective or have resulted in damage to the flowers.
Methyl bromide has been identified in the international arena as being a chemical of concern both because of its toxic nature and its adverse effect on the ozone layer. New Zealand is under international pressure therefore to curb its use.
In November 2010 the EPA completed its review of methyl bromide under which it agreed to the continued use of the chemical for fumigation purposes but with strict controls on its use. It also required that within ten years chemical re-capture facilities be operational to prevent further releases into the atmosphere. It banned the continued use of chemical formulations which incorporated methyl bromide as a soil fumigant. It also required that the banned formulations be disposed of at the owners expense within two months of the report being released (i.e. it was proactive in stopping the continued use of the chemicals through stock piled product).
In addition to limiting the use of methyl bromide to specific users at specific locations the additional controls require the establishment of secure buffer zones around treatment facilities and the implementation of air quality sampling and formal reporting of the results to the EPA. Minimum buffer zones are specified but the onus is still on the site operator to determine the level of methyl bromide in the vented air and to extend the buffer zone if minimum limits are exceeded. Particular emphasis is placed on "down-wind" monitoring.
The report clearly shows that information from industry on "safe" buffer distances were taken into consideration in the findings and exception clauses are included to cater for special cases.
The full EPA report on methyl bromide can be found at the following link:
http://www.epa.govt.nz/Documents/HRC08002-Methyl-Bromide-decision.pdf
Monitoring reports received by the EPA from methyl bromide users can be accessed through the following link:
http://www.epa.govt.nz/about-us/monitoring/Pages/Monitoring-methyl-bromide.aspx
The first reports are not scheduled to be submitted until June 2012 which will cover the period to the end of December 2011.
Other Relevant Links:
The following link contains a comprehensive list of abbreviations used in the United Kingdom relating to pesticides and other hazardous chemicals.
http://www.pesticides.gov.uk/guidance/industries/pesticides/topics/website/appendices/glossary-of-terms
The United Kingdom had a system of "Specific Off-label Approvals" for minor crops where commercial responsibility for the use of the product fell entirely on the user. Information about this system and its current replacement can be found on the following link.
http://www.pesticides.gov.uk/guidance/industries/pesticides/topics/pesticide-approvals/minor-uses
The following link is to the regulations issued by the EU in January 2010 on the import and export of selected hazardous chemicals which had been re-classified in the EU and includes chemicals such as dichlorvos and and diazinon.
http://eur-lex.europa.eu/
The following link is to a funding application for the development of a low cost field device for the detection of agricultural chemicals.
