Chief Executive initiated reassessmentOrganophosphate and Carbamate based insecticides

New reassessments approachMoving 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

HuiNorthland, Bay of Plenty, Rotorua and Marlborough

Scope of the reassessmentacephate maldison pyrazophos

carbarylc methamidophos benomylc

chlorpyrifos methomylc carbofuranc

diazinon phorate carbosulfanc

dichlorvos pirimicarbc chlorpyrifos-methyl

dimethoate pirimiphos-methyl dichlofenthion

fenamiphos prothiofos ethion

fenitrothion oxamylc famphur

phoxim terbufos isazofos omethoate

c=carbamates

HSNO

ProcessMay 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

Diazinonwidely 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 DescriptorsRisk

QuotientRisk Parameter Operators Re-Entry workers Bystanders

<1 Overall Negligible Negligible Negligible

>1-10

Magnitude Minor Minor Moderate

Likelihood Likely Very unlikely Unlikely

Overall Low Negligible Low

>10-100

Magnitude Moderate Moderate Moderate

Likelihood Likely Unlikely Unlikely

Overall Medium Low Low

>100

Magnitude Major Major Major

Likelihood Highly likely Likely Unlikely

Overall High Medium Medium

Risk

QuotientRisk parameter Aquatic Birds Bees

<1 Overall Negligible Negligible Negligible

>1-10

Magnitude Minor Minor Minor

Likelihood Very unlikely Unlikely Very unlikely

Overall Negligible Low Negligible

>10-100

Magnitude Moderate Minor Minor

Likelihood Unlikely Highly likely Very unlikely

Overall Low Medium Negligible

>100

Magnitude Major Major Minor

Likelihood Likely Highly likely Very unlikely

Overall Medium High Negligible

Human health

Environment

Benefits - Qualitative Descriptors

Category Criteria

Very

unlikelyNo evidence provided of actual use

Possible Used only rarely or when needed

Likely Some current use across industry

Highly

likelySignificant 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

Likelihood

Magnitude

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 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 pastureSupports 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

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 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 recommendationsRetain 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