WORKING WITH VERTEBRATE TOXIC AGENTS APRIL 2014

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1 WORKING WITH VERTEBRATE TOXIC AGENTS APRIL 2014

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3 3 WORKING WITH VERTEBRATE TOXIC AGENTS Contents Introduction 4 Training, licences and permissions 6 Communication 11 Warning signs at operations 13 Safety gear 17 Storage 19 Transport 22 Disposal 24 Tracking 25 Emergencies 27 Further information 32 Disclaimer 34

4 4 WORKING SAFELY IN ANIMAL PEST CONTROL Introduction Vertebrate toxic agents (VTA) are substances that are designed to kill animals with back-bones, such as rats, stoats, rabbits, feral pigs and possums. They are highly dangerous if not used or stored correctly. Their use is controlled by legislation including: the Hazardous Substances and New Organisms Act 1996 (HSNO) the Agricultural Compounds and Veterinary Medicines Act 1997 (ACVM) the Health and Safety in Employment Act 1992 (HSE) the Resource Management Act 1991 the Land Transport Rule: Dangerous Goods These laws are designed to protect users, other people and the environment. This guide is intended for people who use VTAs, such as cyanide, 1080, PAPP, DRC1339, cholecalciferol, brodifacoum and MZP. It covers VTAs used in the field, or for making baits, but not substances used for the manufacture of other products. It gives a summary of the most important rules under HSNO that you need to follow to stay safe, but does not represent legal advice. The first places to look for information on staying safe are the product label and safety data sheet (SDS) for your VTA. Staying safe with VTAs where to start The first places to look for information on staying safe are the product label and safety data sheet (SDS) for your VTA. These will provide information on the hazards of the product and how to manage them. You need to make a list, or inventory, of all the VTAs you have, the amounts you have and their hazards. Under HSNO, VTAs are classified according to their hazards. The hazard classification is important for identifying which rules apply to your VTA and what you need to do to manage them. The rules vary according to the hazard classifications, amount and approval conditions of the VTAs you use or store. They can also vary with different application methods. The hazard classifications should be in section 2 of the SDS for your VTA. The HSNO approval number is usually in section 15 of the SDS.

5 5 WORKING WITH VERTEBRATE TOXIC AGENTS You can get more information on how to use VTAs safely from the Environmental Protection Authority (EPA) website including: detailed information about all the rules that apply to your VTA from the Approved hazardous substances with controls database general guidance on the amount of each VTA you can store before triggering rules about storage, transport and other matters search for HSNO threshold quantities. It is important that you check the approval for all VTAs you use. This booklet does not provide information on all the rules that may apply. Examples of other rules include: bait colour keeping people out of the application area keeping records of VTA use the distance baits must be kept from waterways. Staying safe with VTAs the basics Read and follow the safety information given on product labels and SDS. Know the rules for the VTAs you intend to use and store. Make sure you and your staff are trained to use VTAs. Always wear the right safety gear for your VTAs. Look after your safety gear and replace it before it wears out. Plan and practise your response to emergencies. Store VTAs under lock and key and put up warning signs. Transport VTAs according to the rules. Dispose of unused VTAs and containers properly. Communicate with and notify people who could be affected by your VTAs before using them. Post warning signs at the treatment area.

6 6 WORKING SAFELY IN ANIMAL PEST CONTROL Training, licences and permissions You must know about each VTA you use and any risk it poses. To use and handle VTAs you must be trained. You must have an approved handler test certificate to use most VTAs. For some VTAs you ll also need You must know about each VTA you use and any risks it poses. To use and handle VTAs you must be trained. a controlled substance licence (CSL), which shows that you are a fit and proper person to use or have them in your possession. Approved handler test certificates An approved handler is someone who has been certified to use very hazardous substances. In order to be an approved handler you must show that you know about: the hazards of the VTA you use and how to protect people and the environment the operating equipment, safety gear and protective clothing needed what to do in an emergency involving the VTA the HSNO legislation and how it applies to your VTA. You will need an approved handler test certificate to use: sodium cyanide or potassium cyanide (cyanide) sodium fluoroacetate (1080) phosphorous 3-chloro-p-toluidine hydrochloride (DRC 1339) microencapsulated zinc phosphide (MZP) para-aminopropiophenone (PAPP) most pindone products rotenone cube root powder encapsulated sodium nitrite (ESN) alpha-chloralose solid for making baits bromadiolone liquid bait magnesium phosphide if you have more than 3 kg of pellets aluminium phosphide if you have more than 3 kg of pellets.

7 7 WORKING WITH VERTEBRATE TOXIC AGENTS An approved handler test certificate is issued by a test certifier. A test certifier is an independent service provider who is recognised as an industry expert and has been approved by the EPA to issue test certificates. You can find a test certifier on the EPA website under the Search our registers tab. Approved handler test certificates are valid for five years. You will need training to get the skills and knowledge needed to be an approved handler. This could be on the job training or through an industry training organisation. Controlled substance licences A CSL is required to use the most hazardous VTAs and ensures that only qualified fit and proper people can use them. You need a CSL to use: 1080 PAPP cyanide MZP phosphorus DRC 1339 pindone soluble concentrate 34 g/l required under ACVM magnesium phosphide if you have more than 3 kg of pellets aluminium phosphide if you have more than 3 kg of pellets. To get a CSL, you must: be at least 17 years old need to use the VTA for your work be a fit and proper person have an approved handler test certificate for the VTA.

8 8 WORKING SAFELY IN ANIMAL PEST CONTROL A fit and proper person is one of good character who abides by the law. There are various criteria that will be assessed when considering whether you are fit and proper. These include: whether you have a criminal record your behavioural history, including violence, drug or alcohol abuse the results of a police check. A fit and proper person is one of good character who abides by the law. You should carry your CSL whenever you are handling a VTA for which you are licensed. If the VTA you use needs a CSL, you won t be able to buy it without your CSL. A CSL is issued by the EPA and is valid for five years. You would normally apply for a CSL with the support of the test certifier who issued your approved handler test certificate. The CSL will become invalid if your approved handler test certificate expires. The EPA can revoke CSLs if you are found to be negligent or incompetent in your use of VTAs, or you are convicted of any offence. If you do not have a CSL you can still handle and use VTAs, provided you are under the immediate supervision of a CSL holder. The licence holder must be present and available within eye and ear shot at all times. Getting a permission You may need a permission from the Department of Conservation (DOC), the public health unit (PHU) of the local district health board (DHB), or both before using a VTA. In some cases you will need a permission from the EPA to use sodium nitrite. Department of Conservation If you wish to apply a VTA on land managed by DOC you must have a permission from DOC. DOC can advise on what land they manage and how to apply for a permission. A list of local offices is available on the DOC website

9 9 WORKING WITH VERTEBRATE TOXIC AGENTS You will need to fill out an application form or provide an assessment of environmental effects. DOC will need information such as: the VTA you will be using when and where you will be using it how you will be using it consultation you ve carried out when planning your operation. Public health unit You will need a permission from the local PHU to use some VTAs in a drinking water catchment or where there is a risk to public health. You should check with the local PHU whether you need a permission from them. For example, if you use the following VTAs in an area where the public have access, such as regional parks, you will need a permission: 1080 sodium cyanide or potassium cyanide phosphorus DRC 1339 MZP. You can contact your local PHU through the local DHB or the Ministry of Health website You will need to provide detailed information in your permission application, including: when and where you will be using the VTA the type of bait and application method your assessment of public health effects consultation you have done while planning your operation.

10 10 WORKING SAFELY IN ANIMAL PEST CONTROL Environmental Protection Authority If you intend to use sodium nitrite to control feral pigs on land that is not managed by DOC you will need a permission from the EPA. More information and an application form are available on the EPA website search for VTA permissions. Permission conditions Any permission given by DOC, the PHU or EPA will include conditions on the use of the VTA. These conditions are set to manage any risks from using the VTA. Make sure you read and understand the permission and comply with all of the conditions. Keep a copy of the permission with you so you can show everyone involved in the operation what the requirements are and, if necessary, show an enforcement officer that you have followed the conditions.

11 11 WORKING WITH VERTEBRATE TOXIC AGENTS Communication Before using VTAs it s important that you communicate with people who could be affected by their use. How you communicate will depend on the VTA and application method you use and its potential effects. There are specific communication requirements for aerial application of These are set out in the Communication guideline for aerial 1080 application that is available on the EPA website This guideline is useful for communications for other VTAs. Before using VTAs it s important that you communicate with people who could be affected by their use. Consultation You will need to provide evidence of consultation as part of an application for a permission to use VTAs. You need to consult people who own, live on or live next to the land where VTAs are used. You also need to obtain consent from any land occupiers and owners before using any VTA on their land. You should keep written records of consultation and consent from landowners. Notification You must notify people who may be affected when using some VTAs. In all cases you will need to notify the land owner and occupier of the area to be treated and include the following information: the VTA you are using when you will use it where you will use it contact details of the person using it.

12 12 WORKING SAFELY IN ANIMAL PEST CONTROL In addition to the basic notification requirements on the previous page, there are specific requirements for different VTAs. These are summarised in the table below. VTA Who else to notify When to notify What to tell them (in addition to the basic needs) 1080 owners and occupiers of adjacent land the public for aerial application the police, if the VTA operator is not the land owner for aerial application of cereal bait or stock solution up to 2 months before application PAPP land owners and occupiers within 3 km of any bait station up to 2 months before application the possible effects on pets and how to treat them MZP Medical Officer of Health local veterinarians the police, if the VTA operator is not the land owner up to 1 month before application the possible effects on pets and humans and how to treat them sodium nitrite Medical Officer of Health local veterinarians the police, if the VTA operator is not the land owner up to 1 month before application the possible effects on pets and humans and how to treat them aluminium phosphide magnesium phosphide the fire service, if the area to be treated is close to dwellings, schools or other areas that the public have a right to enter not less than 24 hours before the proposed treatment A VTA permission from DOC, the PHU or the EPA may include a condition requiring notification.

13 13 WORKING WITH VERTEBRATE TOXIC AGENTS Warning signs at operations You must post warning signs at the location where the VTA has been used. Warning signs let people know which VTA has been used, what the hazards are and what to look out for. They are an important communication requirement when using VTAs. Warning signs let people know which VTA has been used, what the hazards are and what to look out for. When warning signs are required You must put up warning signs at all normal points of entry to the treatment area when you use: cyanide 1080 phosphorous PAPP MZP DRC1339 sodium nitrite. When using any other VTA, except for rotenone, in a place where there is public access you must post warning signs at every normal access point. This includes parks, reserves, roadsides and public rights of way. What warning signs should say Your signs must: be easy to read, with key information readable from 10 metres away let people know which VTA is being used warn that it is toxic to humans and animals state when it is to be applied identify the person responsible for the operation and provide contact details where they can be reached during normal business hours.

14 14 WORKING SAFELY IN ANIMAL PEST CONTROL The PHU, EPA or DOC may require extra information on signs through conditions on permissions. Examples of VTA warning signs are shown below. These and other signs are available as templates on the EPA website search for example warning signs.

15 15 WORKING WITH VERTEBRATE TOXIC AGENTS Sign maintenance You should check your signs regularly and replace any that are broken or have been vandalised or removed. The information on signs may fade over time, so you may need to touch them up. Record the location of all signs using GPS will give accurate locations as this makes it easier to find them for maintenance and to remove them when necessary. How long must signs stay up? Signs need to remain in place until the VTA and carcasses have been removed from the area or until the hazards associated with them no longer exist. They must then be removed. For each VTA, there is a minimum time that signs must remain in place after the last application. These are given in the following table. VTA Minimum time 1080 six months after the last application earlier if 1080 and carcasses are removed or monitoring shows that 1080 and carcasses are no longer toxic alpha-chloralose aluminium phosphide brodifacoum bromadiolone cholecalciferol (biodegradable bait bag) cholecalciferol (other application methods) coumatetralyl sodium cyanide paste until the VTA is retrieved or has disintegrated time to disintegration depends on the application method and weather until the fumigation is finished 12 months after retrieval of baits 12 months after retrieval of baits four months after the last application three months after retrieval of baits two months after retrieval of baits eight months after the last application if baits not retrieved two months after the last application

16 16 WORKING SAFELY IN ANIMAL PEST CONTROL VTA encapsulated paste containing potassium cyanide encapsulated pellets containing potassium cyanide (bait bags) encapsulated pellets containing potassium cyanide (other applications) DRC 1339 diphacinone flocoumafen magnesium phosphide MZP PAPP phosphorus pindone (ground-based and not retrieved or aerial) pindone (ground based and retrieved) sodium nitrite bait Minimum time four months after the last application four months after the last application two months after the last application one month after the last application two months after retrieval of baits eight months after the last application if baits not retrieved 12 months after retrieval of baits until the fumigation is finished six months after the last application until the VTA is retrieved one month after the last application eight months after the last application two months after retrieval of baits two months after retrieval of bait and four months after last application The time that signs must stay in place can also be set by conditions on VTA permissions from DOC, the PHU or EPA.

17 17 WORKING WITH VERTEBRATE TOXIC AGENTS Safety gear Everyone using VTAs must always wear the right safety gear, also called personal protective equipment or PPE. Read the product label and SDS and follow the instructions carefully. The SDS will tell you what safety gear you need. Choose safety gear that meets New Zealand or Australian Standards. Always use the right safety gear for the job you are doing. You may need different safety gear for: handling and unpacking preparing baits using and applying different application methods cleaning equipment and disposal. Typically, the type of safety gear would include: nitrile or neoprene gloves chemical resistant goggles or face shield disposable coveralls rubber boots or gumboots with steel caps a chemical resistant apron a respirator with the correct filter hard hat and ear protection when working near helicopters.

18 18 WORKING SAFELY IN ANIMAL PEST CONTROL Make sure your safety gear fits properly, if it doesn t it won t protect you. You must look after your gear and replace it before it wears out. Your safety gear should be cleaned at the end of the day and stored securely. Make sure your safety gear fits properly, if it doesn t it won t protect you. Safety tips Have water, soap, nail brush and paper towels available. Thoroughly wash hands, arms and face after working with VTAs and always before eating, drinking, smoking or using the toilet. Put used protective clothing in a sealed container until it can be washed or disposed of appropriately. Filters in respirators get used up over time and can no longer filter out any contaminants. To stop the filters becoming ineffective between uses, store them in sealed containers that are labelled with the name of the user and date that the filter packaging was opened. Wash all equipment, including footwear, after use. Make sure water used for washing equipment doesn t run into any waterway.

19 19 WORKING WITH VERTEBRATE TOXIC AGENTS Storage All VTAs that need an approved handler test certificate must be locked away when not in use. The key to the lock should be kept out of the hands of children and unauthorised people. It s best practice to lock away all VTAs, not just ones that require an approved handler. Storage areas may need warning signs. You should keep VTAs in their original packaging and never put them in a food container. Keep the amount of VTA you store to a minimum. This makes it easier to manage what you have and may reduce your compliance costs. It s best practice to lock away all VTAs, not just ones that require an approved handler. Storage location and construction VTA storage areas should be located in a flood-free area, soundly constructed, well ventilated, and set up so that any leak or spill will be contained. You also need to make sure you comply with any local council rules for storing hazardous substances. Storage in vehicles VTAs should not be stored in a vehicle, unless there is no other more secure storage available during an operation. If you have to store a VTA in a vehicle, it should be stored inside a locked and labelled container that is out of sight and preferably bolted to the body of the vehicle. Signs for storage areas Areas where you store VTAs may need warning signs to warn people what VTAs are stored there and why they are dangerous. Signs provide important information on what to do in an emergency and who to contact. Signs are essential for emergency services to decide how to deal with a fire, natural disaster or accident. When you need signs Signs are needed for your storage area when you store amounts of VTAs above certain limits, or thresholds. However, it s best practice to always have signs. The following table shows the limits. When you have amounts of VTAs that are over the limits stated at any site, you must have warning signs for your storage area.

20 20 WORKING SAFELY IN ANIMAL PEST CONTROL Limits for signage requirements VTA aluminium phosphide magnesium phosphide 1080 gel or solution 5 % or more sodium cyanide 1080 bait or gel 0.15 % to 1 % bromadiolone liquid bait 0.06g/l potassium cyanide DRC 1339 PAPP paste A phosphorus pindone soluble concentrate rotenone encapsulated sodium nitrite alpha-chloralose solid MZP 1080 pellets and paste 0.1 % and less cholecalciferol (No Possums) pindone liquid concentrate sodium nitrite bait alpha-chloralose treated seed and paste brodifacoum bromadiolone bait pellets cholecalciferol (Feracol or Kolee) coumatetralyl diphacinone flocoumafen PAPP ready to use bait and paste B pindone bait Limit 50 kg or litres 100 kg or litres 250 kg or litres 1000 kg or litres 10,000 kg or litres

21 21 WORKING WITH VERTEBRATE TOXIC AGENTS Where to put signs If you need signs they must be displayed at all storage area entrances, including vehicle access points. If VTAs are stored in a room inside a building, signs must also be displayed at the entrance to that room. If VTAs are stored in an outdoor area, signs must be displayed adjacent to the storage area. They must be close to the VTA storage but not so close that people come across VTAs before being warned. HAZCHEM IN EMERGENCY DIAL 111, FIRE, POLICE OR AMBULANCE FOR URGENT MEDICAL ADVICE: NATIONAL POISONS CENTRE DIAL 0800 POISON ( ) IN CASE OF SPILL CALL REGIONAL COUNCIL POLLUTION HOTLINE 0800 XXX XXX HIGHLY TOXIC TO PEOPLE AND ANIMALS What to put on signs People need to be able to read signs from 10 metres away. Signs must tell people: that the storage area contains hazardous substances the hazards of each VTA in the store the precautions needed to manage them safely what to do and who to contact in an emergency. An example sign is shown. More details on signs for storage areas are available on the EPA website search for signs.

22 22 WORKING SAFELY IN ANIMAL PEST CONTROL Transport Dangerous goods include substances that are toxic, flammable or ecotoxic. Most VTAs are dangerous goods. When you transport VTAs by road you must comply with the New Zealand Transport Agency s (NZTA) Dangerous Goods Rule (the rule). The rule sets out the requirements for ensuring dangerous goods are transported safely. How it affects you will depend on the type and amount of VTAs you are transporting and why they are being transported. The rule, and factsheets summarising it, are available on the When you transport VTAs by road you must comply with the New Zealand Transport Agency s (NZTA) Dangerous Goods Rule. NZTA website search for dangerous goods. Dangerous goods are assigned to packing groups according to how dangerous they are. Packing groups determine the type of packaging that is required for dangerous goods. You will find the packing group in the transport section of the SDS for your VTA. Most VTA users only carry the small amount of VTAs they need for a pest control operation. These small amounts are called tools of the trade in the rule. Schedule 1 of the rule sets limits on the amount of different types of dangerous goods that can be carried as tools of the trade. The table below shows the quantity limits for each packing group. Quantity limits for dangerous goods transported as tools of the trade Packing group Example VTAs Maximum quantity I II cyanide paste 1080 stock solution MZP 1080 pellets (0.15 to 0.2 %) 5 kg 5 litres 50 kg or 50 litres III DRC 1339 pindone liquid concentrate 250 kg 250 litres If you carry less than these amounts, you will not need warning signs on your vehicle and will not need to be an approved handler to transport the VTAs.

23 23 WORKING WITH VERTEBRATE TOXIC AGENTS However, you must: make sure the VTAs are properly packaged and identified keep VTAs away from substances they may react with secure the load on your vehicle carry emergency response information ensure safe handling practices and emergency procedures are in place and are followed. If you carry more than the amounts in the table on the previous page, or transport VTAs for hire or reward, for example as a transport company, you will have to comply with stricter rules. You should refer to the Dangerous Goods Rule on the NZTA website Packaging and load security When you buy VTAs they will be labelled to identify the hazards they pose and be in packaging that meets the transport requirements. If you put VTAs into any other container, you must make sure that it meets the packaging and labelling requirements set out in the dangerous goods rule. Packaging must be strong enough to transport the VTA safely without leaking. You must secure the load so that no package can fall from the vehicle and the VTAs can t be accessed by unauthorised people. Keeping VTAs away from other dangerous goods VTAs may be incompatible and react with other dangerous goods. They must be kept away from dangerous goods they are incompatible with. The SDS will tell you if your VTA is incompatible with any substances. VTAs must also be kept away from food items to prevent any possibility of the food being contaminated. Emergency response information You must know about the hazards of the VTAs, safe handling practices and emergency procedures and carry emergency response information in the vehicle. You can get emergency response information from each VTA s SDS. A handbook is available, for a fee, from Standards New Zealand, SAA/SNZ HB 76:2010 Dangerous Goods Initial Emergency Response Guide at

24 24 WORKING SAFELY IN ANIMAL PEST CONTROL Disposal You must dispose of part-used, excess or damaged VTAs and VTA containers properly. This is to avoid possible impacts on people or the environment. Containers can be as hazardous as the VTAs themselves if they are not managed carefully. Disposal of unused VTAs The label and SDS must provide information about how to safely dispose of the VTA. They must also provide advice on any precautions you should take. Read this information and keep it with you at all times when handling the product. Before disposing of any VTA, you should contact the district or regional council to check what their rules are. If you do not understand the disposal instructions, or cannot comply with them, ask the manufacturer or importer for advice. Their contact details will be on the product label and SDS. Before disposing of any VTA, you should contact the district or regional council to check what their rules are, and also check the conditions of any permission you have obtained. Common disposal methods for VTAs include: burying at a landfill that is approved to take hazardous waste burying within the biologically active layer of soil (topsoil) in an area where people can t access them and where they can t leach into the environment chemical treatment. You must not burn or incinerate unused VTAs. Disposal of containers All containers that have been used to store VTAs and any other packaging or container that has come into contact with the VTA must be disposed of carefully. Unless you re-use containers to store more of the same VTAs, they must be crushed or destroyed so they cannot be used again for any other purpose. Further guidance on disposal will be given on the product label and SDS. This may be different to how excess product is disposed of. For example, plastic containers cannot be buried in the biologically active layer of the soil.

25 25 WORKING WITH VERTEBRATE TOXIC AGENTS Tracking Tracking is recording what happens to VTAs through their life cycle from manufacture and import through distribution, use and disposal. The following VTAs must be tracked: alpha-chloralose solid g/kg 1080 DRC1339 phosphorus PAPP pindone liquid concentrate cyanide aluminium phosphide, if sold in quantities of more than 3 kg magnesium phosphide, if sold in quantities of more than 3 kg rotenone cube root powder MZP. What needs to be recorded? Tracking records must include: the name and amount of the VTA the exact location of the VTA name, position in the organisation and contact details of the approved handler in charge of the VTA every use of the product, where it was used and how much was used details of any transfer of the VTA to another place details of any disposal of the VTA and its container, including how much, how, when and where it was disposed of the unique identifier (if it has one) of the package the product was taken from.

26 26 WORKING SAFELY IN ANIMAL PEST CONTROL The unique identifier is an exclusive serial number for an individual package or container of a VTA. By including it in the tracking records it allows the life cycle of individual packages to be tracked. Tracking records must be kept in easily understandable written form and be available to an enforcement officer within 10 minutes. The records must be kept for one year after the substance is transferred to another user or for three years after use or disposal. Tracking records must be kept in easily understandable written form and be available to an enforcement officer within 10 minutes. Transferring tracked VTAs to another place If you send a tracked VTA to another place, you must make sure there is an approved handler available who will take responsibility for it. As part of your tracking records, you will need to record details of the new approved handler, as well as the address of the place and the date the VTA was transferred. Guidelines and templates A good practice guideline, Tracking Minimum requirements for tracking vertebrate toxic agents, and tracking form templates are available from the National Pest Control Agencies (NPCA) website Further details on tracking are also available on the EPA website search for tracking.

27 27 WORKING WITH VERTEBRATE TOXIC AGENTS Emergencies Even the most safety conscious organisation can have an emergency. It s important that you know what to do in an emergency. Possible emergencies include: someone being poisoned by ingesting or inhaling a VTA grazing animals being exposed to and poisoned by a VTA a VTA spill at your depot or operation site misapplication of a VTA in the wrong location. Be aware of the hazards and risks You must read and follow the instructions on the product label and SDS. The label and SDS will give you information about: the hazards from the VTA first aid measures what to do if there is a fire what to do if there is a spill. Prepare for an emergency You must be prepared for an emergency regardless of the type and amount of VTAs you have. If you have certain types and amounts of VTAs you must prepare an emergency response plan, as shown in the table below. Quantity limits for emergency response plan VTA 1080 alpha-chloralose solid cyanide DRC 1339 MZP phosphorus rotenone ESN aluminium phosphide magnesium phosphide PAPP paste A Maximum quantity 100 kg or 100 litres

28 28 WORKING SAFELY IN ANIMAL PEST CONTROL Quantity limits for emergency response plan VTA alpha-chloralose seeds and paste cholecalciferol (No Possums) flocoumafen pindone liquid and soluble concentrate sodium nitrite bait PAPP ready to use bait and paste B brodifacoum bromadiolone baits cholecalciferol (Feracol or Kolee) coumatetralyl diphacinone pindone bait Maximum quantity 1,000 kg or 1,000 litres 10,000 kg or 10,000 litres The emergency response plan must have clearly documented procedures to deal with all likely emergencies, including spills, fire or poisoning. It must include details of: who to contact and warn in an emergency how people can protect themselves what you will do in an emergency so that damage is limited. You must make the plan available to all employees and test it at least once a year to check that it works. Testing your plan could be a desk-top or simulated exercise. If any problems are identified you need to update your plan. You need to keep records of testing for at least two years. You must update your plan if you change the VTAs you use or if there are changes to the staff with specific emergency responsibilities. If the plan is updated, it must be tested within three months of the change. A template of an emergency response plan, the Emergency Response flipchart, is available from the EPA hsinfo@epa.govt.nz or call

29 29 WORKING WITH VERTEBRATE TOXIC AGENTS Controlling spills You need to have procedures in place to contain any spill and know how to clean it up. All staff should be trained to deal with spills. You must have clean-up equipment handy, both in your storage area and when you are using VTAs in the field. This equipment needs to be sufficient for the amount and types of VTAs at the site. If a spill occurs, you will need to safely dispose of the spilled product and any materials used in the clean-up. You will also need to advise everybody affected by the spill. Spill procedures A spill kit may be sufficient for small spills. You can purchase spill kits from safety equipment suppliers or make one yourself. What goes into a spill kit will depend on the VTAs you store and whether they are solid or liquid. All staff need to know where the spill kit is and how to use it. In general it should include: safety gear to wear when cleaning up spills spill handling equipment, like a shovel spill containment equipment like trays, drain guards or absorbent material a leak proof container to put the waste in once it is cleaned up. Secondary containment Secondary containment is a physical barrier or container that can hold the contents of any tank or container that may spill. Most users of VTAs will not store enough to need secondary containment. However, if you store more than 100 litres of liquid pindone or 1080 stock solution you will need secondary containment. Reporting if things go wrong You need to identify people who may be affected or need to be involved if anything goes wrong with your VTA operation. You need to have a list of contact details for them. It is recommended that you contact the EPA in all cases where things go wrong with a VTA application. For some VTAs there are specific people you must notify within 24 hours of a spill, loss of product or misapplication in the wrong location.

30 30 WORKING SAFELY IN ANIMAL PEST CONTROL You should also notify them if you notice that bait stations have been tampered with or bait removed. The relevant VTAs and who to contact are shown in the following table. Emergency contacts VTA cyanide DRC1339 phosphorus 1080 PAPP MZP sodium nitrite Who to contact occupiers or owners of the land where the spill, loss or misapplication happened person you applied VTA for officer in charge at nearest police station local Medical Officer of Health DOC or PHU if they granted a permission for the operation as above, plus: regional council EPA as above, plus: local veterinarians who may treat poisoned animals You must notify WorkSafe New Zealand in the event of a workplace accident that causes serious harm. This includes accidents resulting in loss of consciousness or acute illness caused by exposure to any substance. Full details of serious harm and reporting requirements are available on the WorkSafe New Zealand website Reporting adverse events The Ministry of Primary Industries (MPI) runs the Adverse Event Reporting Programme under ACVM. This programme sets out requirements for reporting unintended effects, including: target animal welfare issues effects on non-target animals VTAs not working problems with application, such as baits spilling from stations.

31 31 WORKING WITH VERTEBRATE TOXIC AGENTS If you notice an unintended effect, you should report it to the manufacturer or importer. Their details will be on the product label. The importer or manufacturer must then report it to MPI. You can also report directly to MPI. MPI will determine what needs to be done to deal with the adverse effects. Adverse effects to animals such as dogs or stock animals should be reported to the owner and a veterinarian. Details and reporting forms are available on the MPI website Fire extinguishers It s best practice to always have fire extinguishers at your depot and in your vehicle. However, you must have fire extinguishers if you store more than 50 kg of aluminium phosphide or magnesium phosphide. You can get advice about the type of fire extinguisher you need from your equipment supplier.

32 32 WORKING SAFELY IN ANIMAL PEST CONTROL Further information This document gives a summary of the rules to follow when using VTAs. More information is available from the following organisations. Environmental Protection Authority The EPA website has more details on everything included in this booklet including: databases of controls for approved hazardous substances and test certifiers guidance on approved handler test certificates and CSLs guidance on limits for hazardous substance controls the Communication guideline for aerial 1080 application applying for a permission to use sodium nitrite guidance, examples and templates for signs. You can also get advice on hazardous substances and copies of the Emergency Response flipchart at hsinfo@epa.govt.nz or by calling Department of Conservation For information about: pest management guidance land managed by DOC how to apply for a permission best practice when using VTAs use your local phone book to find area offices. Ministry of Health For information about: how to apply for a permission contact details for PHUs local PHUs are also listed in the phone book.

33 33 WORKING WITH VERTEBRATE TOXIC AGENTS Ministry of Primary Industries For information about: how to comply with the Agricultural and Veterinary Medicines Act 1997 details of the Adverse Event Reporting Programme. WorkSafe New Zealand For information and guidance about: staying safe at work reporting workplace accidents, unsafe situations or serious harm contact centre New Zealand Transport Agency The NZTA provides information and guidance about: transporting dangerous goods the Dangerous Goods Rule. National Pest Control Agencies The NPCA website has a wide range of guidance about using VTAs. Standards New Zealand Standards New Zealand produce standards to follow when using VTAs, including selecting the right safety gear.

34 34 WORKING SAFELY IN ANIMAL PEST CONTROL Disclaimer This document is guidance only and does not cover every aspect of the law. What the law requires depends on the types and amounts of VTAs you use and store. If you are in doubt about what the law requires, we recommend that you contact the EPA, seek independent advice, or both. There may also be additional rules set by your local and regional councils that you need to follow. This document does not provide any guidance on those requirements and the EPA recommends you contact your local or regional council for further information. We have tried to make the information in here as accurate and current as possible. However, the law is constantly evolving and may have changed since publication. It is your responsibility to make sure that you comply with the law. If you find any information in this document that you believe may be inaccurate, or you would like to provide any feedback, please

35

36 Environmental Protection Authority Level Lambton Quay Private Bag Wellington 6140 New Zealand Tel Fax EPA 0332

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