SUBMISSION TO The Environmental Protection Authority on. Organophosphate and carbamate plant protection insecticides

Transcription

1 SUBMISSION TO The Environmental Protection Authority on Organophosphate and carbamate plant protection insecticides [APP201045] From Beef + Lamb New Zealand Ltd and Deer Industry New Zealand 22 January 2013

2 1. Introduction 1.1 Beef + Lamb New Zealand Ltd (B+LNZ) and Deer Industry New Zealand (DINZ) welcome the opportunity to make a submission to the Environmental Protection Authority (EPA) in response to the proposals set out in APP Organophosphate and carbamate plant protection insecticides. 1.2 B+LNZ is an industry-good body funded under the Commodity Levies Act through a levy paid by producers on all cattle and sheep slaughtered in New Zealand. B+LNZ s activities aim to increase preference for New Zealand beef and sheep meat internationally and domestically; to maintain and extend trade access for New Zealand red meat; and to fund research and development to help improve the profitability of New Zealand farmers. 1.3 B+LNZ represents the 13,000 New Zealand sheep and beef farmers responsible for approximately $5.9 billion in export receipts for These farmers are responsible for the care of 32 million sheep and 3.9 million beef cattle, in addition to an annual lamb crop in the region of 26 million animals B+LNZ promotes responsible and sustainable production. B+LNZ seeks to ensure that legislation and policies on environmental issues are informed by an understanding of their potential impacts on sheep and beef farming and associated communities. 1.5 New Zealand is the world s largest producer of farmed deer. The main products marketed from deer are venison and deer antler velvet and approximately 95% of products are exported. In the year ending 30 September 2011, deer products were worth $275m in export receipts to New Zealand. 1.6 Deer Industry New Zealand ( DINZ ) is a levy funded industry-good body established by the Deer Industry New Zealand Regulations 2004 under the Primary Products Marketing Act DINZ s functions (under regulation 5(1)) include the following: to promote and assist the development of the deer industry in New Zealand; to monitor, and from time to time report on, the economics and efficiency of all components of the deer industry; and to report from time to time to the Minister and to the Minister of Foreign Affairs and Trade on movements of costs and prices or other factors likely to affect the economic stability of the deer industry. 1.7 DINZ s levy payers are producers and processors of venison and velvet. There are roughly 3,000 deer farmers and 16 processing plants that slaughter deer, of which 12 slaughter only deer. 1 Stock Number Survey as at 30 June 2012, Beef + Lamb New Zealand Economic Service. Available at: df B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 2 of 16

3 1.8 This submission has also been approved by Tony Pearse, Producer Manager of DINZ on behalf of the New Zealand Deer Farmers Association, a voluntary membership organisation for deer industry participants. 1.9 The B+LNZ contact for this submission is: Chris Houston Senior Advisor Technical Policy Beef + Lamb New Zealand Ltd P O Box 121 Wellington Phone: chris.houston@beeflambnz.com 1.10 The DINZ contact for this submission is: Catharine Sayer Science and Policy Manager Deer Industry New Zealand P O Box Wellington Phone: catharine.sayer@deernz.org 2. Background the use of organophosphate and carbamate plant protection insecticides (OPCs) on pasture and forage for sheep, beef and deer production 2.1 It is important for animal health and welfare, productivity efficiency and product quality reasons that sheep, beef and deer receive an adequate and nutritious diet. New Zealand livestock, unlike those farmed elsewhere, are typically reared outdoors in paddocks year round. Their main diet is pasture which may be supplemented with forage crops grown by the farmer. It is therefore important to the New Zealand economy that farmers are equipped to produce sufficient feed by having access to good quality seed and being able to deal effectively with pests affecting production of pasture and forage. 2.2 Farmers run businesses highly dependent on ecosystem services, and have strict control of inputs into their systems based on cost, quality and impact considerations. Pesticides are not cheap nor potentially without ecosystem impacts. Accordingly they are not used routinely on pasture used to raise deer, sheep and beef cattle; rather pest control tends to only be undertaken once a production-limiting infestation has been identified and is considered severe enough to warrant the necessary investment. Pesticide use on forage crops is more common. B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 3 of 16

4 2.3 Comprehensive information on the quantum of different pesticides applied to pasture and forage, and the purposes of their applications, is lacking. This submission draws heavily from the consultation material published by the EPA, anecdotal evidence presented by farmers and from a recently published review of pastoral insecticide use on pastures in New Zealand The most recent survey of pesticide use in New Zealand 3 estimated a total annual application rate of 79 tonnes of active insecticide ingredient across all pastoral lands, with a mere 0.76 tonnes applied to sheep and beef pasture nationwide and 0.03 tonnes to deer pasture. It should be noted that this figure represents all classes of insecticide and that OPCs as a class are likely to account for a very small proportion of this total. 2.5 DINZ expects that with the decrease in the national deer herd from 1,756,900 in 2004 to 1,048,500 in 2012 and the major shift towards farming deer extensively in the hill country only, where pesticides are not routinely applied, the active ingredient of all pesticides applied by the deer industry would now be lower than 0.03 tonnes per annum. 2.6 B+LNZ and DINZ are not aware of any concerns among overseas customers about the continued use of organophosphates in New Zealand to control insect pests on pasture. 2.7 B+LNZ AND DINZ consider that it is important for human health, avoidance of pest resistance and environmental reasons to avoid administering chemical pesticides where there is no actual pest threat or to administer pesticide in excess of the amount needed for effective treatment. B+LNZ and DINZ promote responsible use of agricompounds and encourage sheep, beef and deer farmers to become Growsafe certified where appropriate and follow best practice at all times. 2.8 Further, in line with the Red Meat Sector strategy, an increasing proportion of beef and lamb production is being undertaken within commercial quality assurance (QA) schemes. These QA schemes frequently contain requirements pertaining to the appropriate storage and application of pesticides, which are audited by third parties on behalf of meat companies. 2.9 B+LNZ and DINZ understand that the following OPCs are registered for the control pests of pasture and forage: Carbaryl Dimethoate Methomyl Terbufos Carbofuran* Fenamiphos Oxamyl Chlorpyrifos Fenitrothion Phorate Diazinon Maldison Pirimicarb 2 Chapman R. B. (2010). A review of insecticide use on pastures and forage crops in New Zealand 3 Manktelow D, Stevens D, Walker J, Gurnsey S, Park N, Zabkiewicz J, Teulon D, Rahman A Trends in pesticide use in New Zealand: Report to the Ministry for the Environment, Project SMF4193. B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 4 of 16

5 Dichlorvos Methamidophos Pirimiphos-methyl This submission does not consider the proposals for the other compounds under assessment. (*Carbofuran is included as it is required for control of exotic pests of pasture). 3. Process 3.1 In principle, B+LNZ and DINZ agree that the EPA s approach in considering a large number of OPCs together is sensible. However, in hindsight the size and scope of the exercise has caused resourcing difficulties for stakeholders required to gather information to engage on the reassessment. 3.2 B+LNZ and DINZ would like to reiterate concern that the EPA has chosen to focus its efforts disproportionately on the characterisation of known and theoretical risks associated with the use of OPCs, rather than taking a more balanced approach to risks and benefits. B+LNZ and DINZ suggest that this is inappropriate and it is incumbent upon the EPA as a regulatory agency sponsoring the reassessment to adequately resource characterisation of both risks and benefits. In particular, section 6(e) of the Hazardous Substances and Noxious Organisms Act explicitly states that the economic and related benefits and costs of using a particular hazardous substance or new organism are to be taken into account during regulatory processes. 3.3 There is therefore a strong likelihood that EPA has significantly undervalued the benefits associated with OPC use, and that this deficiency will remain most stark for the small sectors lacking sufficient resource to undertake rigorous data collection and analysis and those, such as turf, where industry good bodies or representative organisations do not exist. 3.4 Further, B+LNZ and DINZ are dissatisfied that the reassessment may have been initiated primarily because of regulatory action overseas. B+LNZ and DINZ are wholly supportive of science and evidence-based policy and legislative development. However, in this instance the new science that may have prompted action by regulators in North America, Europe and Australia appears to have been a subordinate consideration to the mere fact that other countries have done something. 3.5 B+LNZ and DINZ remind the Panel that the risks and benefits associated with OPCs will vary considerably between different industries and countries, not just for physical reasons, but also having regard to the societal and regulatory context, all of which are explicit relevant factors to the regulatory approach (see sections 5 and 6 of the Hazardous Substances and New Organisms Act 1996 ( Act )). For example, it can be suggested that decision-making on environmental issues in the European Union has previously taken greater account of popular perception than elsewhere. Another example may be that societal benefits of use of pest control products increases in magnitude commensurate with the magnitude of a country s economic reliance on agriculture. 3.6 B+LNZ and DINZ have reassessed the proposals as a package, in particular in the context of the proposed retention of chloropyrifos with enhanced controls. Our B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 5 of 16

6 re-evaluation of the risks and benefits of the proposals would be different were the EPA minded to revoke chloropyrifos instead. 4. Assessment of risks human health 4.1 B+LNZ and DINZ agree with the EPA that there is good evidence for the acute toxicity of many of the compounds under assessment. For this reason, B+LNZ and DINZ are generally supportive of the suite of enhanced controls proposed for operators handling and applying these compounds. 4.2 The appropriate use of OPCs to control pests of pasture poses no risk to the safety of food produced from animals reared on pasture that may have been previously treated with OPCs. It is generally agreed that OPCs do not bioaccumulate The principal risk to human health considered in the reassessment is concern for adverse impacts on operator health arising from chronic or prolonged low level exposure as it is termed by the UK Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (COT). Epidemiological evidence to support such concerns is less convincing, as acknowledged by the COT Both the EPA and COT have considered neurological and neuropsychological human health impacts of prolonged low level exposure. In 1999 the COT reached the following conclusions: Neurophysiological outcomes: The balance of evidence does not support the existence of clinically significant effects on performance in neuropsychological tests from low-level exposures to OPs. If such effects do occur, they must either be relatively uncommon or so small that they are not consistently detectable by standard methods of testing Peripheral neuropathy: The balance of evidence indicates that low-level exposure to OPs does not cause peripheral neuropathy. If effects on peripheral nerve function sufficient to cause severe disability do occur, they must be rare Psychiatric illness: The available data indicate that exposure to OP sheep dips is not a major factor in the excess mortality from suicide among British farmers. However, in general, the evidence relating psychiatric illness to OPs is insufficient to allow useful conclusions. 4.5 As described in the EPA s Consultation Report, the COT has referred consideration of its own 2012 review of the more recent literature to a working group for detailed analyses and preparation of a position statement. Assessment 4 Britt J. (2003) Properties and effects of pesticides. In: Principles of Toxicology: Environmental and Industrial Applications. Williams P., James R. and Robers S. 5 Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (1999) Organophosphates B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 6 of 16

7 of the articles 6 included in this review indicates that the group s conclusions may not differ substantially from those reached in It would be ill-advised for the EPA to determine a relevant issue on the basis of limited expert advice shortly before relevant expert views become freely available. Given the breadth and rigour of the exercise currently being undertaken by the COT working group in respect of human health implications, B+LNZ and DINZ recommend that it is appropriate and advisable for the EPA to postpone decision-making until the final position statement is available from the COT. 4.7 In particular, B+LNZ and DINZ would like the Panel to reflect on the fact that the approach to the EPA reassessment relies on toxicological parameters determined by regulators in overseas jurisdictions and theoretical risk modelling, rather than recorded observations and assessment of association and causation, which is being considered by the COT. 4.8 OPs have been in use in New Zealand for approximately 40 years, yet no evidence for adverse impacts on human health arising from these activities has been presented, other than for numbers of poisonings leading to hospital admissions. Of these, only 11 (16%) of the 70 recorded incidents between 2006 and 2010 occurred in the workplace. To put this number into context, during 2010/2011 alone 275 people submitted claims to ACC for injuries caused by fireworks In summary, B+LNZ and DINZ suggest that there is little to no evidence that the appropriate use of OPCs by the pastoral industry has had any significant impact on human health The EPA has not described why evidence for health impacts, arising from scenarios it has modelled and determined to be potentially harmful to health, is lacking. The B+LNZ and DINZ view is that the reason for there being scant evidence of this nature is that users are using the products in accordance with current controls and that such uses are substantially safe The EPA has not explained why it is appropriate to move to theoretical risk modelling in the absence of evidence of actual harm such as there being a compelling reason to suspect under-reporting of harm. B+LNZ and DINZ urge the Panel to exercise caution when making decisions based upon the results of theoretical risk modelling that are inconsistent with data arising from decades of use in New Zealand and the body of available epidemiological evidence Further, in terms of principle and precedent it is worrying that wide-ranging and potentially economically damaging restrictions on New Zealand s primary producers are being proposed without adequately defined and quantified justification for doing so B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 7 of 16

8 5. Assessment of risks impact of OPCs on the environment 5.1 B+LNZ and DINZ are satisfied that there is good evidence that OPCs are potentially damaging to the environment. 5.2 In keeping with B+LNZ and DINZ s commitment to sustainable farming, managing the risks posed by OPCs to the environment is a further reason why B+LNZ and DINZ are generally supportive of enhancing the controls on a range of the OPCs under assessment, as proposed. 6. Benefits assessment 6.1 B+LNZ and DINZ are happy to see that the EPA has compiled an extensive list of the generic benefits attributable to OPCs. It is important that it is fully recognised that these benefits include those to the environment and potentially to human health, often stemming from the need to use lower quantities or fewer applications of active ingredient or less toxic chemistries than may otherwise be required if using alternatives. 6.2 Pests of pasture and forage are known to have significantly deleterious effects on pastoral production in New Zealand. Not only do pastoral pests directly affect production of pasture and forage grown by sheep, beef and deer farmers, they also indirectly affect the farmers ability to produce pasture and forage crops by affecting the quality and quantity of the commercially produced pasture and forage seed. Unfortunately the distribution, prevalence and burden of impact of pasture and forage pests remains poorly characterised. Accordingly, this state of affairs makes quantitative or qualitative assessment of the benefits associated with pest control tools challenging. 6.3 B+LNZ and DINZ are disappointed that the EPA has not collated detailed information on the efficacy of alternative control tools or the realistic speed by which they can be developed, approved and commercialised - to those under reassessment. This information is especially valuable when determining the benefits stemming from continued availability of any given OPC. B+LNZ and DINZ urge the Panel to pay particular regard to HortNZ s comments on the timeframe for the development of alternatives, drawn from the work of the Foundation for Arable Research in relation to development of a diazinon alternative. 6.4 The main capital assets of the livestock sectors are stock and land. Maintaining and growing the value of these assets relies on maintaining and improving the health of each. Looking after plant health and animal health is also necessary to safeguard animal welfare, maintain or improve livestock productivity, safeguard the safety to consumers of the meat and milk produced from the animals and maintain the quality of leather, wool and velvet. Keeping animals and pasture free of diseases that affect animal and plant health is thus a major concern of their asset holders, being landowners and farmers, and warranting considerable investment and planning. B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 8 of 16

9 6.5 The Government concurs in this, owing to the importance of the pastoral sector to the New Zealand economy. As stated by the Ministry for Primary Industries ( MPI ) at Biosecurity is vitally important to New Zealand as we are more reliant on agriculture and our natural environment than any other developed country. Our indigenous flora and fauna are precious to New Zealanders and tourists alike. We have unique native species that are a core part of our natural heritage and culture, and we pride ourselves on enjoying high standards for our agricultural products, lifestyle and wellbeing. The Government is committed to maintaining a clear and effective role as overall steward of the biosecurity system. (emphasis added) 6.6 Maintaining biosecurity not only involves the establishment of systems to prevent pest incursions, but also to respond quickly and effectively when incursions occur. It is therefore imperative that there is a suite of approved veterinary and plant protection products to treat pests for which there is a high risk of incursion and establishment. Such availability does not necessarily depend upon ready access by farmers through the usual retail channels of the products; so long as inprinciple regulatory approval of key tools is in place, those involved in biosecurity planning and governance can make customised arrangements for obtaining and distributing supplies to the right people at the right time. For instance, several animal vaccines are stockpiled by MPI for deployment only under biosecurity incursions whose response is controlled by the Chief Technical Officer of MPI. 6.7 In terms of exotic plant pests that threaten New Zealand pastures, a full risk assessment has not been undertaken. MPI management nevertheless recently agreed with the livestock industries that this is an omission that should be addressed. As the first step towards producing an exotic pest risk assessment for pasture, the Ministry, together with the livestock sectors representing dairy, beef, sheep and deer producers carried out an exotic pest hazard identification 8. In that exercise, the likelihood of entry and establishment of various types of pasture pests on ten significant pasture species to the pastoral sector regionally and nationally in New Zealand was characterised. 6.8 The results of that exercise show that there are several high priority pests for which some of the plant protection substances proposed to be revoked are effective means of control. In particular, table 1 illustrates the exotic pasture pests identified as posing a high hazard to one or more of the most significant pasture species to the New Zealand pastoral sector whose control depends on a substance that the EPA proposes to revoke. 8 Pasture Pest Hazard Identification A report prepared for the Ministry for Primary Industries and pastoral sector partners. (2012). B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 9 of 16

10 Table 1. High hazard exotic pests of significant pasture species and chemical controls proposed by the EPA for revocation. Priority pasture species include white clover, cocksfoot, lucerne, ryegrasses and fescue. Substance proposed for revocation Name of pest identified as a high hazard by MPI Priority pasture affected Carbofuran Common stalk borer Cocksfoot, Lucerne Diazinon Cranberry girdler Tall fescue Lucerne bug Sugarbeet wireworm Lucerne, White clover Lucerne Dimethoate Lucerne bug Lucerne, White Lucerne weevil clover Sweetclover weevil Fenitrothion Lucerne beetle Lucerne, White clover European crane fly Lucerne, Perennial ryegrass, White clover Methomyl 9 Lucerne weevil Lucerne, White clover Pirimiphos-methyl Lucerne beetle Lucerne, white clover 6.9 It is vital that the pastoral sector has means to control these exotic plant pests should an incursion occur. Given that the products listed above potentially play a key role in maintaining biosecurity for the pastoral sector, that role should be treated as a benefit under the Act and B+LNZ and DINZ considers that it would be very unwise to revoke their approvals. Revocation would also be contrary to the principle enshrined in section 5(b) of the Act, that regulation must allow the maintenance and enhancement of the capacity of people and communities to provide for their own economic, social, and cultural well-being and for the reasonably foreseeable needs of future generations B+LNZ and DINZ submit that the reasonable approach would be for the EPA to maintain approvals of non-redundant products 10 used to control the exotic pests identified by MPI as significant hazards unless and until- 9 Proposed to be revoked for outdoor uses, which affects pasture 10 Methomyl s function can be performed by dimethoate B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 10 of 16

11 the outcome of a full risk assessment is that the pests in question are identified as being of low risk of entry and low risk of establishment; or effective alternatives to these substances in respect of their action against these pests have been identified or developed B+LNZ and DINZ further submit that maintenance of the approvals of carbofuran and fenitriothion need only on be on a limited basis, for example, approval may be restricted to use during periods where an exotic pest incursion is under the management of the Chief Technical Officer or Deputy Chief Technical Officer under Part 6 of the Biosecurity Act. Limited approval such as this is consistent with the EPA s proposed stance regarding the regulation of chlorpyrifos methyl, dichlorvos and methomyl. B+LNZ and DINZ would be happy to work with the EPA and MPI to devise appropriate conditions to ensure that (assuming there is a commercial supply of the substances) use of the substances is permitted only in treating exotic pest incursions B+LNZ and DINZ would like to draw the Panel s attention to the issue of the potential impact of climate change on the pasture pest situation in New Zealand. Predicted changes to climate are likely to increase the potential geographic range and impacts for some endemic pests 11 and may increase the likelihood of establishment of other, currently exotic, species. Unfortunately, changing weather conditions, especially drought, can also make pasture and other crops more susceptible to infestation and damage by existing pests. In this context, benefits currently attributable to OPCs may increase in future. B+LNZ is not aware of any informed predictions about the nature and scale of these increases. 7. Recommendations and rationale comments on individual OPCs 7.1 B+LNZ and DINZ do not have the technical expertise necessary to carry out its own critical assessment as to whether some of the proposed additional controls would significantly reduce the practical utility of the chemicals assessed, for example limiting the application rate below a threshold required to effectively control target infestations. B+LNZ and DINZ draw the Panel s attention to the consideration of the reasonableness of controls that has been carried out by HortNZ. The focus of this submission is the issue of availability of OPCs in the pasture and forage pest control toolbox. 7.2 Carbaryl B+LNZ and DINZ support the EPA recommendations for carbaryl. 7.3 Carbofuran Carbofuran has been identified as being effective against high hazard exotic pest species, as discussed above. If not shown likely to be redundant for this 11 P.J. Gerard et al. (2010). Possible impacts of climate change on biocontrol systems in New Zealand. (2010). Report for MAF Pol Project B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 11 of 16

12 purpose following the outcomes of the reassessment, then B+LNZ and DINZ propose that limited approval should be retained for use in biosecurity incursions. 7.4 Chlorpyrifos B+LNZ is strongly supportive of retaining access to chloropyrifos for the control of pests of pasture and forage and agrees with the EPA that the benefits of the use of this OPC in the pastoral sector are high. Owing to it significance in the control of a large number of pests of pasture and forage and the production of commercial brassica seed, were chloropyrifos to be made either completely or effectively (through further controls that constrained useful application) unavailable then B+LNZ would be required to reassess its position with respect to most of the other OPCs currently under assessment. 7.5 Diazinon As described above, deer, sheep and beef farmers do not routinely apply OPCs to pasture. Diazinon represents a tool of last resort for the control of heavy infestations of grass grub that are potentially ruinous for an affected farm business. It is also used as a last resort in the commercial production of seed for several key pasture and forage species. B+LNZ reiterates the fact that no evidence for adverse health impacts associated with the low-level exposure to diazinon (or other OPCs) has been presented by the EPA. This is despite regular use of this compound across many sectors for several decades. Diazinon is also a key potential control of cranberry girdler, lucerne bug and sugarbeet wireworm, which are exotic pasture pests characterised as high hazards for New Zealand pasture species (see Table 1). For these reasons, B+LNZ and DINZ oppose the proposal to revoke approval for diazinon and instead encourages the EPA to consider a suite of additional controls that would mitigate risks yet permit its use in situations where no viable alternative exists, for example heavy infestations of grass grub in pasture. Without prejudice to its primary objection to revocation, B+LNZ and DINZ agree with the EPA that any revocation should occur after no less than a 10 year phase-out period, to allow for the development of alternative tools or practices. However, B+LNZ and DINZ are concerned that the history of developing efficacious alternatives to OPs has not been encouraging. Accordingly, any such revocation should be subject, at the very least, to a further review of the termination date, for example after year 8 of a 10-year phase-out period, to take into account- the availability of alternative control options; detailed characterisation of the scope and extent of impacts associated with grass grub; and robust analyses of the risks associated with the uses of diazinon. B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 12 of 16

13 7.6 Dichlorvos B+LNZ and DINZ are not opposed to the proposed recommendations for dichlorvos owing to the availability of taufluvalinate as an effective and bee-safe pest control alternative for clover casebearer moths. 7.7 Dimethoate B+LNZ and DINZ do not have good information on the use patterns of dimethoate in pastoral production but are very concerned that, in the benefits assessment for dimethoate, the EPA has characterised the forage and fodder industries as of low economic significance. Sapere s peer review questioned whether fodder and forage can be considered a distinct sector B+LNZ and DINZ suggest that it is more correctly considered a secondary facet of pastoral production, and therefore highly significant from an economic standpoint. For example, there are an estimated 300,000 hectares of forage brassicas grown in New Zealand every year and 20,000 hectares of cereals grown for fodder 12. In light of the fact that it is suggested by the EPA that dimethoate is critically important for fodder and forage sectors for the control of aphids, B+LNZ and DINZ are concerned by the proposed withdrawal of approval for dimethoate. Dimethoate is also a key potential control of exotic pasture pests characterised as high hazards for New Zealand pasture species (see Table 1). B+LNZ and DINZ therefore request that the EPA consider an alternative suite of control measures capable of mitigating residual risks of dimethoate associated with usage scenarios in the production of fodder and forage. 7.8 Fenamiphos B+LNZ and DINZ understand that the principal use of fenamiphos in the pastoral sector is control of nematodes in clover, with selective breeding replacing the need for chemical control of nematode problems in lucerne. The carbamate furathiocarb is understood to be an effective, commercially available alternative to fenamiphos. Accordingly, B+LNZ and DINZ do not oppose the proposed withdrawal of approval for fenamiphos. 7.9 Fenitrothion Fenitrothion is used for the control of porina, which is a major pest of pasture in New Zealand. B+LNZ and DINZ understand that chloropyrifos is similarly effective for this purpose as fenitrothion 13 and that the frequently preferred insecticide treatment is diflubenzuron unless infestation is particularly severe. However, fenitrothion is a means of control for the lucerne beetle and European crane fly which are exotic pasture pests that are high hazards for New Zealand pasture species (see Table 1). Accordingly, B+LNZ and DINZ oppose the proposed Stewart K and Ferguson C. (1989). Chemical control of porina in South Otago sheep pastures. New Zealand Journal of Agricultural Research, 1989, Vol. 32: B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 13 of 16

14 withdrawal of approval for fenitrothion unless effective and available alternative control methods can be identified Maldison Maldison-treated bait is valuable for the control of black field crickets in pasture. B+LNZ and DINZ support the EPA s recommendation for retaining access to maldison with the application of controls Methamidophos Methamidophos is registered for use against armyworms, a sporadically damaging pest of new pasture, particularly in northern North Island. B+LNZ and DINZ understand that other effective control options, including biological control and chloropyrifos, exist for armyworms and, therefore, B+LNZ and DINZ are not opposed to the proposed withdrawal of approval of mathamidophos Methomyl Methomyl is registered for use against armyworms and greasy cutworms. B+LNZ and DINZ understand that other effective control options, including chloropyrifos, exist for armyworms and, therefore, B+LNZ and DINZ are not opposed to the proposed withdrawal of approval of methomyl Oxamyl B+LNZ and DINZ agree with the EPA that it is important to retain an OPC for the control of nematodes. The continued availability of furathiocarb appears to meet the needs of the pastoral / forage sector for nematode control in clover but B+LNZ and DINZ are supportive of the EPA s recommendation to retain approval of oxamyl Phorate and terbufos B+LNZ and DINZ is aware that phorate and turbufos granules have utility in protecting seeds and seedlings from pest attack during establishment, such as the commercial production of white clover seed which is particularly important for sheep, beef and deer farmers. Anecdotal evidence suggests that other alternative tools may be available for these purposes. B+LNZ and DINZ offer no comment on the proposed withdrawal of approval for these compounds on account of the lack of information available on the benefits and risks to the pastoral industries of doing so. It is recommended that the Panel seeks further information on these before reaching a decision Pirimicarb B+LNZ and DINZ support the EPA s recommendation for retaining access to primicarb with the application of controls, given its use in the commercial production of clover and brassica seeds Pirimiphos-methyl Pirimiphos-methyl is currently the only compound registered for the control of brassica leaf miner on forage brassicas and B+LNZ and DINZ are not confident that the national benefits from its use are low, as assessed by the EPA. It is also understood to be used as a fumigant in silos where commercially-produced pasture and forage seeds are stored and where grain for animal feed is stored. B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 14 of 16

15 Owing to the potential lack of effective alternatives, and its comparably moderate toxicity, B+LNZ and DINZ oppose the proposal to revoke approval for outdoor use of piriphos-methyl and recommend that if there be a compelling need to amend its regulatory status at all, this be by way of additional controls. As regards the indoor use of the substance, such as in grain silos, B+LNZ and DINZ specifically support HortNZ s submission on the reasonableness of proposed additional controls. 8. Substances not used for plant protection purposes 8.1 B+LNZ and DINZ are concerned that the EPA is proposing the withdrawal of HSNO approvals for 11 OPCs without any serious consideration of the risks and benefits posed by these compounds. To claim that there is no benefit associated with these chemicals on account that they are not currently in use completely ignores potential future benefits, particularly with regard to the ready availability of tools for potential biosecurity incursions of new pasture pests. The proposed approach is contrary to the principle of evidence-based decision-making, the purpose of the Act and the matters relevant to decision-making under the Act as set out in sections 5 and 6 of the Act. 8.2 Further, B+LNZ and DINZ consider it short-sighted to determine a matter of principle based on the vagaries of current commercial distribution arrangements; the availability of products in particular markets is more than just a function of demand, and the inference that current non-supply of a product is indicative of the ease, difficulty or likelihood of its future supply is unsound. 8.3 B+LNZ and DINZ recommend that the Panel take no action in respect of substances for which there are no comprehensive risk assessments available to support principled decision-making. 9. Summary and Recommendations 9.1 The B+LNZ and DINZ position on each of the OPCs of relevance to sheep, beef and deer production, as part of the pastoral sector (which includes fodder and forage) is summarised in table 2. In particular: B+LNZ and DINZ strongly support the proposal to retain the approval of chloropyrifos with enhanced controls; and B+LNZ and DINZ oppose the recommendation that approval for diazinon be revoked and request that approval be retained, with enhanced controls, for the treatment of heavy infestations of grass grub in pasture. 9.2 The UK Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (COT) is currently reviewing a large volume of epidemiological literature on the potential impacts on human health associated with chronic exposure to OPCs. The outcome of this work is expected to be available in mid Accordingly, B+LNZ and DINZ recommend that it is appropriate and B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 15 of 16

16 advisable for the EPA to postpone decision-making on the reassessment of OPCs until the final position statement is available from the COT. Table 2. Summary of B+LNZ and DINZ position on the proposals for each OPC used by deer, sheep and beef farmers for the control of pests of pasture and forage. Compound assessment under Does B+LNZ Agree with EPA recommendation? Comments Carbofuran No Potentially required for control of Common stalk borer, so approval may need to be retained for emergency use (only) in event of pest incursion Carbaryl Yes Chlorpyrifos Yes Retention with controls a grounding prerequisite for B+LNZ and DINZ consideration of other proposals Diazinon No Critical for the control of heavy infestations of grass grub and potential control of cranberry girdler, lucerne bug and sugarbeet wireworm. Retention with tighter controls requested. Dichlorvos Yes Dimethoate No B+LNZ and DINZ concerned that benefits of utility in forage and fodder production underestimated; also potentially required for control of lucerne bug, lucerne weevil, sweetclover weevil Fenamiphos Yes Fenitrothion No Potentially required for control of lucerne beetle and European crane fly, so approval may need to be retained for use (only) in event of pest incursion. Maldison Yes Methamidophos Yes Methomyl Yes Oxamyl Yes Phorate Unable to form a position Insufficient information on benefits available to B+LNZ and DINZ Pirimicarb Yes Terbufos Unable to form a position Insufficient information on benefits available to B+LNZ and DINZ Pirimiphos-methyl No B+LNZ and DINZ concerned that benefits of utility in forage and fodder production underestimated B+LNZ & DINZ Submission on the Reassessment of Plant Pest Insecticides Page 16 of 16