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Chief Executive initiated reassessment Organophosphate and Carbamate based insecticides. New reassessments approach. Moving from single substance to group reassessments Older substances, often removed or restricted by other jurisdictions Engaging early – go out with early thinking Aim:
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Chief Executive initiated reassessmentOrganophosphate and Carbamate based insecticides
New reassessments approach • Moving from single substance to group reassessments • Older substances, often removed or restricted by other jurisdictions • Engaging early – go out with early thinking Aim: • Avoid perverse outcomes • Consistent controls to manage risk • Greater certainty about tools available for use in medium term • More efficient use of resources
Consultation • Call for Information • To identify those that may have high risks • To obtain use information • Feasibility of possible controls or other controls to mitigate risk • Hui • Northland, Bay of Plenty, Rotorua and Marlborough
Scope of the reassessment acephate maldisonpyrazophos carbarylcmethamidophosbenomylc chlorpyrifosmethomylccarbofuranc diazinon phoratecarbosulfanc dichlorvos pirimicarbcchlorpyrifos-methyl dimethoatepirimiphos-methyl dichlofenthion fenamiphosprothiofosethion fenitrothionoxamylcfamphur phoximterbufosisazofosomethoate c=carbamates
HSNO • Process • 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
Evaluation • Risk vs Benefit • Qualitative descriptors allow a risk or a benefit to be negligible, low, medium or high to focus comparisons • Likelihood and magnitude for risks and benefits Page 43 – 45 of the consultation report
Example • Diazinon • widely used • high risks and high benefits • effective alternatives not yet available
Analysis of risks • Risk is a function of exposure and hazard • Exposure estimated using models/measured data • Use patterns established from product label and stakeholder feedback • Hazard: Use threshold values derived by other regulators • Risks assessed with and without additional controls
Analysis of risks • Operators • Re-entry workers • Bystanders • Aquatic environment • Birds • Bees
Analysis of risks • Risk Quotient = Predicted exposure/threshold value • Target Risk Quotient is <1
Risks - Qualitative Descriptors Human health Environment
Generic Benefits • Efficacy • Broad spectrum • Lower application rates • Cheaper • Short pre-harvest intervals • Short re-entry intervals • Maximum Residue Limits • Resistance management • Biosecurity
Specific Benefits • Many 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 pasture • Supports large industries = large contribution to GDP • Specific pest to NZ • No effective alternatives – ongoing research
Approach to controls • AIM: Reduce risk levels to, or close to, negligible • Controls 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, bystanders • Aquatic and terrestrial environment, birds, bees • Additional controls toolbox developed with stakeholders
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 rates • Semi-automated equipment for indoor application • No 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 recommendations • Retain dimethoate • Retain outdoor uses of pirimiphos-methyl & methomyl • Biosecurity – Authorised Person-only control for fenamiphos after 5 years; Extend AP control to all OPCs we’re retaining • Extend phase-in period to 2 years • Change definition of automated application in greenhouses • Remove droplet size requirements for chlorpyrifos and diazinon • Allow shorter buffer zones through COP • New label warning for bee risks