Chief Executive initiated reassessmentOrganophosphate and Carbamate based insecticides

New reassessments approachMoving from single substance to group reassessmentsOlder substances, often removed or restricted by other jurisdictions Engaging early – go out with early thinking

Aim:Avoid perverse outcomesConsistent controls to manage riskGreater certainty about tools available for use in medium termMore efficient use of resources

ConsultationCall for Information

To identify those that may have high risksTo obtain use informationFeasibility of possible controls or other controls to mitigate risk

HuiNorthland, Bay of Plenty, Rotorua and Marlborough

Scope of the reassessmentacephate maldison pyrazophoscarbarylc methamidophos benomylc

chlorpyrifos methomylc carbofuranc

diazinon phorate carbosulfanc

dichlorvos pirimicarbc chlorpyrifos-methyldimethoate pirimiphos-methyl dichlofenthionfenamiphos prothiofos ethionfenitrothion oxamylc famphurphoxim terbufos isazofos

omethoate

c=carbamates

HSNOProcess

May approve if the positive effects of the substance outweigh the adverse effects

• If risks are negligible then the approvals should be retained• If additional controls make the risks negligible, then the

approval should be retained with those additional controls. • If the risks are non-negligible even with extra controls a

risk/benefit analysis is conducted and: • If benefits are greater than the risks the approval is

recommended to be retained • If risks are greater than benefits the approval is

recommended to be revoked either with or without a phase-out period

EvaluationRisk vs BenefitQualitative descriptors allow a risk or a benefit to be negligible, low, medium or high to focus comparisonsLikelihood and magnitude for risks and benefits

Page 43 – 45 of the consultation report

ExampleDiazinon

widely used high risks and high benefitseffective alternatives not yet available

Analysis of risksRisk is a function of exposure and hazardExposure estimated using models/measured data

Use patterns established from product label and stakeholder feedback

Hazard: Use threshold values derived by other regulatorsRisks assessed with and without additional controls

Analysis of risksOperatorsRe-entry workersBystandersAquatic environment Birds Bees

Analysis of risksRisk Quotient = Predicted exposure/threshold value

Target Risk Quotient is <1

Risks - Qualitative DescriptorsRisk Quotient

Risk Parameter Operators Re-Entry workers Bystanders

<1 Overall Negligible Negligible Negligible

>1-10Magnitude Minor Minor Moderate

Likelihood Likely Very unlikely Unlikely

Overall Low Negligible Low

>10-100Magnitude Moderate Moderate Moderate

Likelihood Likely Unlikely Unlikely

Overall Medium Low Low

>100Magnitude Major Major Major

Likelihood Highly likely Likely Unlikely

Overall High Medium Medium

Risk Quotient

Risk parameter Aquatic Birds Bees

<1 Overall Negligible Negligible Negligible

>1-10Magnitude Minor Minor Minor

Likelihood Very unlikely Unlikely Very unlikely

Overall Negligible Low Negligible

>10-100Magnitude Moderate Minor Minor

Likelihood Unlikely Highly likely Very unlikely

Overall Low Medium Negligible

>100Magnitude Major Major Minor

Likelihood Likely Highly likely Very unlikely

Overall Medium High Negligible

Human health

Environment

Benefits - Qualitative DescriptorsCategory Criteria

Very unlikely

No evidence provided of actual use

Possible Used only rarely or when needed

Likely Some current use across industry

Highly likely

Significant and regular use across industry

Marginal cumulative benefits

Minor Difficult to ascertain material impacts.

Moderate Medium term regional effects with some national implications for GDP - $0-$15 million

Major Measurable beneficial effect on GDP - $15-$50 million

Massive Significant on-going beneficial effect on GDP - Above $50 million

LikelihoodMagnitude

Minor Moderate Major Massive

Very unlikely Negligible Negligible Negligible Negligible

Possible Negligible Low Medium Medium

Likely Negligible Low Medium High

Highly likely Negligible Medium High High

Generic BenefitsEfficacy Broad spectrumLower application ratesCheaperShort pre-harvest intervalsShort re-entry intervalsMaximum Residue LimitsResistance managementBiosecurity

Specific BenefitsMany OPCs are particularly effective in controlling specific pests. This makes them beneficial on a number of crops where these pests are difficult to control

Diazinon to control grass grub on pastureSupports large industries = large contribution to GDPSpecific pest to NZNo effective alternatives – ongoing research

Approach to controls AIM: Reduce risk levels to, or close to, negligibleControls are risk reduction measures, intended to reduce exposure to human health / environment

Default controls (arising from hazardous properties – s77)Additional controls (to manage risks not addressed by default controls, reflect parameters of scenarios – s77A)

Risks identified to the receptors identified in the risk assessment

Operators, re-entry workers, bystandersAquatic and terrestrial environment, birds, bees

Additional controls toolbox developed with stakeholders

Controls toolboxExample controls

Operational • prescriptive PPE requirements• permitted application methods (e.g. ground-based application only),

maximum application rates and frequencies• buffer zones and spray drift reduction measures (NZS:8409)• restricted entry intervals (REI)• notifications and signage

Obligations • Approved Handlers only• Authorised Person• Labelling statements

Restrictions • indoor use only• phase out/revocation

Recommendations Based on balance of risks and benefits

Controls selected to mitigate risks as far as possible

Recommendations – Diazinon Very high risks – but also very high benefits

Long phase-out period proposed to allow development of alternatives – plus additional controls e.g.

Maximum application ratesSemi-automated equipment for indoor applicationNo hand-held application of granules

Key issues raised in submissions

• Home garden uses• ADI/MRL relationship • Biosecurity uses • Information challenges/data gaps• UK COT

Updated recommendationsRetain dimethoateRetain outdoor uses of pirimiphos-methyl & methomylBiosecurity – Authorised Person-only control for fenamiphos after 5 years; Extend AP control to all OPCs we’re retainingExtend phase-in period to 2 yearsChange definition of automated application in greenhousesRemove droplet size requirements for chlorpyrifos and diazinonAllow shorter buffer zones through COPNew label warning for bee risks