app201045 organophosphate and carbamate plant protection ... · organophosphate and carbamate...

Prepared by Market Access Solutionz Ltd for Horticulture Product Groups & the Arable Industry (January 2013) 1

APP201045 – Organophosphate and carbamate plant protection

insecticides Submission from the Horticulture and Arable Industries

22 January 2013

Contents 1. Executive Summary .......................................................................................................... 4 2. Submitter Details ............................................................................................................... 4 3. Purpose of this submission ............................................................................................... 5 4. ERMA/EPA Process ........................................................................................................... 5 5. Background to industries included in submission ........................................................ 6 6. Format of this submission ................................................................................................. 7 7. Terminology ....................................................................................................................... 7 8. Comments on consultation report ................................................................................ 7

8.1. Risk Assessment.......................................................................................................... 7 8.1.1. Poisoning incidents in New Zealand ............................................................... 8 8.1.2. International regulatory position ..................................................................... 9

8.2. Acceptable Daily Intake Values ............................................................................. 9 8.3. Additional data ....................................................................................................... 12 8.4. Specific benefits summary ..................................................................................... 12

9. Comments on proposed controls ................................................................................ 12 9.1. R - 1 Phase in of new controls ............................................................................... 13 9.2. R - 2 Phase out of approval ................................................................................... 13 9.3. R - 3 Application parameters ................................................................................ 13

9.3.1. Off label use ..................................................................................................... 13 9.3.2. Minor crops ....................................................................................................... 14 9.3.3. Application parameters ................................................................................. 15

9.4. R - 4 Buffer zones ..................................................................................................... 15 9.5. R - 5 Cover granules after application ................................................................ 16 9.6. R - 6 Droplet size ...................................................................................................... 17

9.6.1. Reducing off target exposure ....................................................................... 17 9.6.2. Avocado ........................................................................................................... 17 9.6.3. Carrot, Parsnip and Potato ............................................................................ 18 9.6.4. Summary ........................................................................................................... 18

9.7. R - 7 Restriction on method of application ......................................................... 18 9.7.1. Aerial application prohibited (Fenamiphos and Oxamyl only) ................ 18 9.7.2. Restriction to indoor use only via automatic application ......................... 19 9.7.3. Restriction on outdoor use ............................................................................. 19 9.7.4. Automatic delivery systems - Greenhouse indoor use ............................... 19 9.7.5. Maldison - baits only coloured blue/green. ................................................ 20 9.7.6. Prohibit handheld application of granules (diazinon only) ....................... 20

9.8. R - 8 Identification as an organophosphate or carbamate substance ......... 20 9.9. R - 9 Label warning of effect on bees.................................................................. 20 9.10. R - 10 PPE equipment ........................................................................................ 21 9.11. R-11 Notification .................................................................................................. 21

9.11.1. Current requirements .................................................................................. 21 9.11.2. Spray timings ................................................................................................. 22 9.11.3. Written Notice............................................................................................... 22 9.11.4. No notification .............................................................................................. 23 9.11.5. Immediate contact during application ................................................... 23


9.12. R -12 Restricted Entry Interval (REI) .................................................................... 23 9.13. R-13 Approved handler ...................................................................................... 23 9.14. R - 14 Signage ..................................................................................................... 24 9.15. R – 15 Transport restriction .................................................................................. 24 9.16. R - 16 Authorised person .................................................................................... 24

10. Comments by Compound ........................................................................................ 25 10.1. Acephate ............................................................................................................. 25

10.1.1. Critical Use Summary ................................................................................... 25 10.1.2. Risks ................................................................................................................ 25 10.1.3. Benefits .......................................................................................................... 25 10.1.4. Proposed controls ........................................................................................ 25

10.2. Carbaryl ................................................................................................................ 26 10.2.1. Critical Use Summary ................................................................................... 26

10.3. Chlorpyrifos .......................................................................................................... 26 10.3.1. Critical Use Summary ................................................................................... 26

10.4. Diazinon ................................................................................................................ 27 10.4.1. Critical Use Summary ................................................................................... 27 10.4.2. Risks ................................................................................................................ 27 10.4.3. Benefits .......................................................................................................... 27 10.4.4. Proposed controls ........................................................................................ 27

10.5. Dichlorvos ............................................................................................................. 29 10.6. Dimethoate .......................................................................................................... 29 10.7. Fenamiphos .......................................................................................................... 29


10.8. Fenitrothion .......................................................................................................... 31 10.9. Maldison ............................................................................................................... 31

10.9.1. Critical Use Summary ................................................................................... 31 10.10. Methamidophos .................................................................................................. 31


10.11. Methomyl ............................................................................................................. 34 10.11.1. Critical Use Summary ................................................................................... 34 10.11.2. Risks ................................................................................................................ 34 10.11.3. Benefits .......................................................................................................... 34 10.11.4. Proposed controls ........................................................................................ 34

10.12. Oxamyl .................................................................................................................. 35 10.12.1. Critical Use Summary ................................................................................... 35

10.13. Phorate ................................................................................................................. 35 10.13.1. Critical Use Summary ................................................................................... 35

10.14. Pirimicarb .............................................................................................................. 36 10.14.1. Critical Use Summary ................................................................................... 36

10.15. Pirimiphos methyl ................................................................................................. 36 10.15.1. Critical Use Summary ................................................................................... 36 10.15.2. Risks ................................................................................................................ 37 10.15.3. Benefits .......................................................................................................... 37 10.15.4. Proposed controls ........................................................................................ 37


10.16. Prothiofos .............................................................................................................. 38 10.17. Terbufos ................................................................................................................ 38


11. Comments by Industry ............................................................................................... 40 11.1. Arable ................................................................................................................... 40 11.2. Avocado .............................................................................................................. 40

11.2.1. Benefits of pirimiphos methyl to the Avocado Industry .......................... 41 11.3. Citrus ..................................................................................................................... 42 11.4. Persimmon ............................................................................................................ 42

11.4.1. Benefits of Pirimiphos methyl to the Persimmon Industry ........................ 42 11.5. Strawberry ............................................................................................................ 43

11.5.1. Benefits of methomyl to the Strawberry Industry ..................................... 43 11.6. Summerfruit .......................................................................................................... 43 11.7. Tamarillo ............................................................................................................... 44 11.8. Process Vegetables NZ ....................................................................................... 44 11.9. Potatoes NZ .......................................................................................................... 45

11.9.1. Benefits of Fenamiphos and Methamidophos to the Potato Industry . 45 11.10. Onions NZ ............................................................................................................. 45 11.11. Tomatoes NZ ........................................................................................................ 46 11.12. Vegetables NZ ..................................................................................................... 46

11.12.1. Celery ............................................................................................................ 47 11.12.2. Carrot/Parsnip Industry ................................................................................ 47 11.12.3. Kumara Industry ........................................................................................... 48

11.13. Home Garden Use .............................................................................................. 48 11.14. Biosecurity............................................................................................................. 49

Appendix 1: Project Brief for SFF grass grub research project ........................................ 50 Appendix 2: Benefits case – Avocado .............................................................................. 53 Appendix 3: Benefits case – Persimmon............................................................................ 57 Appendix 4: Benefits case – Strawberry ............................................................................ 61 Appendix 5: Benefits case – Tamarillo ............................................................................... 64 Appendix 6: Benefits case – Sweetcorn and Maize ........................................................ 69 Appendix 7: Benefits case – Potatoes ............................................................................... 71 Appendix 8: Benefits case – Carrot/Parsnip ..................................................................... 80 Appendix 9: Benefits case – Kumara ................................................................................. 86


1. Executive Summary

This submission is made on behalf of the Foundation for Arable Research and 11

product groups affiliated to Horticulture New Zealand. Together these industries

contribute over $2.7 billion to the New Zealand economy. The submission contains

detailed responses to the proposals made by EPA on the future use of

organophosphate and carbamate insecticides as plant protection compounds.

The main points covered in this submission include:

Industry is concerned at how the Acceptable Daily Intake (ADI) figures have

been set and the potential implications the proposed ADI levels may have on

future use and on the acceptance of Codex MRLs for imported food.

Industry has provided specific feedback on all proposed controls but has

particular concerns regarding:

o Implications for off label use on minor crops

o Limiting the number of applications of diazinon to two per year for

avocado

o Implementation of buffer zones

o Droplet size restrictions

o Automatic application restriction in greenhouses

o Notification requirements

Regarding proposed phase out timeframes, industry has provided supporting

information and requested changes as follows:

o Removal of the recommendation for phase out and instead allow long

term retention of use of pirimiphos methyl on avocado and persimmon

o Removal of the recommendation for phase out and instead allow long

term retention of use of methomyl on strawberry and salad leaf

o Increase phase out period for fenamiphos to 10 years

o Increase phase out period for terbufos to 5 years

Industry also requests a review period be put in place for diazinon,

methamidophos, fenamiphos and terbufos two years prior to the proposed

phase out date to ensure alternatives are available. If alternatives are not in

place, then the phase out should be extended. If a review period is not possible,

then industry requests increasing the phase out period for diazinon to 15 years

and methamidophos, fenamiphos and terbufos to 10 years.

The industries represented in this submission appreciate the opportunity to provide

feedback on the proposals for future use. Considerable resources have been

utilised to complete this and previous submissions and industry trusts that the EPA

and the decision making panel will review the information thoroughly. Should either

EPA staff or the panel require any additional information, industry would be pleased

to provide this, including arranging field trips so industry knowledge can be gained

first hand.

2. Submitter Details

Name of submitter for joint submission: Nikki Johnson

Organisation name: Market Access Solutionz on behalf of:

The Foundation for Arable Research

The following Product Groups affiliated to Horticulture New Zealand;

o Avocado Industry Council

o NZ Citrus Growers Inc


o Persimmon Industry Council

o Strawberry Growers NZ

o Summerfruit NZ

o Tamarillo Growers Assn

o Onions NZ

o Potatoes NZ

o Process Vegetables NZ

o Tomatoes NZ

o Vegetables NZ

Postal address: PO Box 10629 Wellington

Telephone number: 04 4736040

Email: [email protected]

All of the industries represented by this submission wish to be heard at the hearing.

Submitted Information

The information supplied is what industry has at the time of the submission deadline

(22 January 2013). If more information becomes available or is requested by the

EPA, it will be provided at the hearing.

The horticulture and arable industries have not had sufficient time to obtain

independent comments on the toxicological aspects of the reassessment however

industry may provide further information on toxicology at the hearing. During the

consultation on the methamidophos review, industry paid for an independent

review of the EPA toxicology assessment to be done by an international consultant.

The review was submitted as part of the industry submission but no formal response

to the review from ERMA/EPA was given. We understand that in the current

assessment revised toxicology methodology was used and the review is no longer

relevant. Given industry investment in obtaining this review, an earlier and formal

response from ERMA/EPA would have been appropriate.

3. Purpose of this submission

This submission is made on behalf of eleven product groups affiliated to Horticulture

New Zealand and the Foundation for Arable Research to respond to the EPA

recommendations on the future use of organophosphates and carbamates (OPCs)

as specified in the EPA consultation document (APP201045).

4. ERMA/EPA Process

The industry sectors represented in this submission consider it important to comment

on the process that previously ERMA, and now EPA have followed to reassess these

compounds. By providing this feedback, it is hoped improvements can be made to

future EPA initiated reassessments.

Key timelines in the process include:

Dichlorvos - Application documents released by ERMA November 2010

Dichlorvos – Submission by industry made February 2011

Acephate and Methamidophos – Application documents released by ERMA

January 2011

Acephate and Methamidophos – two separate submissions by industry made

March 2011

mailto:[email protected]


Diazinon – Application documents released by ERMA June 2011

Diazinon – Submission made by industry July 2011

All OPCs – call for information made by EPA September 2011

All OPCs – submissions made by industry November 2011

All OPCs – sector assessment documents released by EPA May 2012

All OPCs – 21 separate responses to sector assessments made by industry July

2012

Withdrawal of the initial four OP reassessments by EPA (i.e. Acephate,

Methamidophos, Diazinon and Dichlorvos) October 2012

All OPCs – Consultation report (APP201045) released by EPA November 2012

Industry groups have had to fund input into this process from the first consultation

round in November 2010 until now and further funding will be required to complete

the process. The funding required has been substantial and the input of time from

grower representatives to feed into this process across the range of industries

involved is incalculable. Industry recognises the reasons for extending the review

from the four individual substances to the full group of organophosphates. However,

industry considers that the process that EPA has undertaken has been inefficient and

wasted valuable time and resources. In many cases, the points made in the current

round of consultation mirror comments made at the very beginning which have still

not been addressed. A review of submissions from the first four compounds would

have assisted industry with understanding changing EPA viewpoints or assessment

methodology and perhaps the current submission process would have been simpler

and had less of a financial and intense resource (time) impact on growers and

industry representatives.

Industry appreciates the openness that ERMA/EPA staff has shown in meeting to

discuss the process and thanks them for taking some comments onboard. Industry

considers that the timeframe set to complete this phase of the process (submission

review to final decision) is unrealistic and will place EPA staff under considerable

pressure that could compromise the quality of the outcome. In order to meet a

completion deadline of June 2013, EPA has had to consult on the current round

during the busiest time of the year for many growers from a production perspective.

The consultation process is further complicated by the Christmas holiday break. It

would be unfortunate if in trying to meet an unrealistic timeframe and consulting for

only a short term over the Christmas/New Year timeframe that key elements of

feedback from stakeholders were missed.

The industry has provided detailed submissions on benefits and the rationale for use

for the various compounds during the time period from 2010 until now including the

sector assessments and on the dichlorvos, acephate and methamidophos and

diazinon applications. Industry trusts that these documents will be made available

to the panel as background information to assist them in making their decisions.

5. Background to industries included in submission

Table 1: Production information for crops in this submission

Crop No. growers Land area (ha) Total value $(m)

Avocado 1,051 4,247 82.00

Citrus 421 999 56.30

Persimmon 50 250 10.70

Strawberry 110 246 25.80


Summerfruit 258 1,830 68.50

Tamarillo 50 110 1.80

Arable and seeds 2,535 182,300 738.00

Maize 5,400 80,000 366.20

Beans and peas 460 1,500 188.10

Brassica 260 3,875 82.40

Capsicum 65 55 65.30

Carrot and Parsnip 62 1,450 40.10

Cucurbit and squash 427 8,458 68.10

Field tomato 20 757 8.10

Glasshouse 300 120 123.40

Kumara 45 1,500 25.00

Lettuce and salad leaf 150 1,331 43.40

Onion (plus other) 143 5,325 144.00

Potato 234+ 11,717 560.30

Sweetcorn 200 5,800 60.60

Other Vegetables 94 206 13.40

TOTAL 12,335 312,076 $2,771.50

Source: FreshFacts 2011, sector assessments and grower estimates. Value is for fresh

and processed crops, the total of domestic plus export. Attempts have been made

to include statistics (where available) for very minor crops such as shallot production

information.

These sectors have a combined value of over $2.7 billion and are critical to regional

economies. As a whole they provide national benefit in to New Zealand.

6. Format of this submission

This submission provides overall comments on the risk assessment and the proposed

controls and then addresses each of the compounds individually. Finally, comments

from each industry group are presented. The submission focuses on the proposals

made in the consultation document. Where industry agrees with a proposal, no

further information is provided. Extensive background and supporting information

has been provided to EPA by industry previously. Should EPA or the panel have any

specific questions, industry would be happy to address those issues directly.

7. Terminology

The following errors in terminology have been identified in the consultation

document and the EPA may wish to amend these in future documents.

Page 172 definition of ‘application area’ in the interpretation section states

‘soil’. This should be amended to ‘land’.

Page 27 has a definition listed for short withholding periods. This explanation

of the term actually relates to restricted entry interval, not to short withholding

periods.

8. Comments on consultation report

8.1. Risk Assessment

In the short timeframe available, industry has been unable to undertake a review of

the risk assessment methodology used by EPA. Instead, industry has focussed on the

proposed controls and the impact of these on each of the crops.


For many compounds, industry considers the risks have been overestimated by

including use patterns that are not supported as critical. EPA should restrict their risk

assessment only to those use patterns for which they have received requests for

continued use. This would enable the commentary under each compound to focus

only on critical uses and help identify controls specific to those critical uses. It is

extremely difficult to trace which use scenarios are responsible for which risks. For

example, methomyl (page 80), 22 use patterns are referred to in the risk tables but

the 22 are not listed. The horticulture and arable industries are only supporting use in

the strawberry, baby leaf and greenhouse vegetables industries and in total there

are eight use patterns supported by these groups. It is not easy to ascertain the risk

levels determined by EPA for these eight use patterns and that makes it difficult to

suggest specific risk management measures. Industry considers that only those use

patterns supported by industry as critical should be included and that greater

transparency on which use patterns attract which risk rating would be beneficial.

8.1.1. Poisoning incidents in New Zealand

In part 2, section 5 (page 23) EPA states that the data from the Centre for Public

Health research at Massey University indicate that 70 people were admitted to

hospital between 2006 and 2010 following exposure to OPCs. Industry requested a

copy of these data from the EPA and our analysis of the data suggests that there

were actually only 62 patients (if the person was admitted more than once to the

hospital the same ID was used for each admission). The data show there were four

patients admitted more than once. Further, a thorough investigation of the data

shows errors in the EPA conclusions. As an example, it is recorded in the data that

one patient presented 6 times as a result of intentional misuse.

The data are extremely limited and vague in terms of being able to draw any robust

conclusions relating to exposure. In many cases it is unclear if the incident can be

directly attributed to the use or exposure to an actual OPC compound. As “the

identity of the active ingredient or product was not reported” it is hard to conclude

that the incident relates to OPC exposure patients, especially if the patient cannot

identify the product name or active. Industry also notes that EPA state only 16% of

the patients reported the location of the exposure was on farms, orchards, industrial

and construction (i.e. commercial settings). The majority of the reported cases

related to children and incidents that took place in the home.

Industry agrees with EPAs comments on page 24 around these incidents providing a

limited picture of OPC poisonings in New Zealand and wonders why this report was

even commented on or used as a basis for this section. As demonstrated by this

data and by industry sourced National Poisons Centre data (in previous submissions),

a high proportion of misuse and adverse events reported to the National Poisons

Centre relate to home garden/domestic use. Industry believes that growers

represented in this submission have the appropriate training and skills to use these

products in a responsible manner whilst mitigating risks.

Industry notes that the majority of growers and contractors in the horticulture and

arable industry are Approved Handlers and Growsafe® accredited, and therefore

have undergone training to encourage responsible use of agricultural chemicals

and know how to mitigate risks of exposure and spray drift by using correct

equipment and PPE. The recommendations of this reassessment include a range of


controls that should reduce the risk of incidents. The removal of the use from

domestic users is supported by the Horticultural/arable industries especially as these

account for the majority of incidents reported.

Industry notes that there are existing systems with both MPI1 and EPA for reporting all

adverse events. Therefore industry strongly disagrees with EPA’s statement that the

lack of information could be due to lack of reporting as there are at least two robust

compliance programs operating in New Zealand, and very few incidents have been

reported from commercial horticultural use. Industry concludes that the lack of

information relates to the lack of incidents in New Zealand.

8.1.2. International regulatory position

As stated in previous submissions, care needs to be taken when referring to

registration reviews that have been conducted in other countries. The assessment

undertaken by these countries may not reflect the situation in New Zealand.

Changes in registration may also have occurred due to commercial reasons rather

than risk reasons. In many cases, chemical companies will withdraw use of a

product rather than provide additional and substantial technical information,

especially if they have a new product which can replace use of the old product. If

a registrant does not support a regulatory review, the associated use pattern will be

withdrawn. It is important to understand the reasons for withdrawal of uses in other

countries rather than assuming they are withdrawn due to risk concerns.

8.2. Acceptable Daily Intake Values

As part of the risk assessment, EPA has selected Acceptable Daily Intake (ADI)

values. While selected by the EPA, the responsibility for implementation of these

values is undertaken by the ACVM2 group of the MPI. It is ACVM’s role to ensure that

residues of the compounds in food products are below the ADI and food is safe to

eat. Industry has consistently advised both EPA and ACVM that there are significant

implications in changing the ADI figures for the OPCs and that it is important to

understand the impact of any reduced ADI values during the submission process.

Industry encouraged EPA and ACVM to share the ADI figures in advance of any

consultation and ensure they understood and advised industry of the implications.

This is important because although EPA may propose retention of a compound (or a

long phase out period), the revised ADI values may require ACVM to remove some

uses or change use patterns to ensure that food safety requirements are met.

Unfortunately, there appears to have been little communication between EPA and

ACVM, and industry is now faced with making decisions on which compounds to

support without understanding the implications for food safety. For example,

industry is prepared to accept a short phase out for phorate on the basis that they

will be able to use alternative OPCs such as diazinon. However, industry is aware

that the much reduced ADI figure set by EPA will generate food safety issues and

ACVM will need to remove some uses or change use patterns to get a reduction in

residues in food. The result being that although EPA may recommend continued use

of a compound, ACVM may be forced to revoke the use. It is extremely difficult for

industry to make decisions on which compounds they need to support without

knowing the impact of revised ADI figures. It is disappointing that EPA has been

aware of this impending issue but has not addressed it prior to the consultation

1 Ministry for Primary Industries 2 Agricultural Compounds and Veterinary Medicines


period.

Industry also has a number of concerns about the way the revised ADI figures were

selected by the EPA.

Rationale for selection

In Section 5.3 (p26), the EPA has advised that they have used ADI figures set by

international regulators rather than undertaking their own assessment. They indicate

that they have favoured selection of the Australian regulator’s ADI because there

are advantages in aligning Australian and NZ values. Industry would appreciate a

greater explanation of what these harmonisation advantages are since the systems

used for agrichemical registration in NZ and Australia are very different. Further,

Australia does not accept Codex MRLs3 for imported food. Given the importance of

this issue and the potential implications arising from the selection of ADI’s, industry

considers that greater justification for this policy is appropriate.

The explanation provided by the EPA says that where no Australian value is available

or is not considered appropriate, a value has been derived from other sources and

an explanation is provided. Industry disputes this as no commentary has been

provided by the EPA explaining when the Australian figure is considered appropriate

and when it is not. For every substance an ADI is listed as being set by Australia, but

for some compounds, a different regulator figure has been selected. No

explanation on why the Australian figure has been substituted with that of another

regulator is provided. Further there is limited, if any, explanation on why EPA has

chosen the particular ADI that it has. Given the importance of ADI selection and the

implications for continued use, industry considers that EPA should provide greater

commentary to explain their rationale and enable stakeholders to comment on

that.

International standards

New Zealand is a member of the World Trade Organisation and a strong supporter

of the various international standards set under this umbrella, including the Codex

standards for pesticide residues. New Zealand is a strong supporter of the JMPR4, the

meeting of experts that proposes Codex standards, including MRLs and ADI figures.

New Zealand accepts Codex MRLs as the standard for imported food, even when

those figures exceed MRLs set within New Zealand. There are strong trading

advantages for New Zealand in supporting the Codex MRLs and encouraging other

countries to accept the same standards for food imported into their countries.

Codex sets ADI’s for compounds as part of the MRL setting process. These values

are outlined in Table 69 of the document and in most cases they are higher than the

figure chosen by the EPA. Because NZ accepts Codex MRLs for imported food, NZ is

by default also accepting the Codex ADI figure. By selecting an ADI figure lower

than the Codex figure, the EPA is effectively accepting a different acceptable level

for imported food than for food produced in NZ. NZ growers will need to meet a

much high standard and could be disadvantaged. If the EPA truly believes that the

ADI should be set at the figure they have selected in order to produce safe food,

then they should also be enforcing that figure for imported food. Industry does not

3 Maximum Residue Limits 4 Joint Meeting on Pesticide Residues


consider it acceptable to have two different levels of acceptable food safety for

imported and domestic food products. This discriminates against New Zealand

producers and benefits imported food producers. The alternatives are that Codex

MRLs are not accepted for imported food for these compounds, or that the EPA

revises their ADI figures to align with those set by Codex. Industry strongly cautions

the EPA (and ACVM) to consider the implications of deciding to not accept Codex

MRLs for some compounds. This has implications across a wide range of

Government activities given New Zealand’s strong endorsement of the Codex

system. New Zealand’s position on support of Codex standards for our exports

would be weakened if New Zealand chooses not to accept Codex in some

circumstances.

Industry understands that there are concerns over the age of the JMPR assessment

for some of the compounds and that the JMPR figure may not reflect the latest

science. It would be useful for the EPA to indicate for which compounds they have

these concerns. There is a periodic review process in place for all compounds and

EPA should consider when the next review for each compound is and whether it is

appropriate to wait for the outcome of that review by JMPR.

Implications of reduced ADIs

If the ADIs proposed by the EPA are implemented, this will trigger a review of MRLs

by ACVM. ACVM will need to ensure that revised ADIs are not exceeded based on

current MRLs. Industry understands that for a number of substances, the ADI will be

exceeded by the existing MRLs and this will trigger the following responses:

Uses currently on the label (where an MRL is set) may have to be removed. In

some cases, this will be possible because not all uses on the label are still

supported and removing the non-supported uses will have limited impact. In

other cases removal will cause significant issues e.g. acephate on citrus.

Off-label use may be restricted. The calculation on whether MRLs exceed the

ADI can only be done where MRLs are set. Off-label uses are very difficult to

include because it is not known which crops use the product or what the residue

levels might be. Off label use must have less than 0.1 mg/kg residue and while a

calculation can be done on this level, there is no way of knowing how many

crops may be using the product off-label. Therefore the logical outcome is for

ACVM to restrict off-label use. The majority of crops supported in this submission

are off-label as they are minor crops and companies will not support their

inclusion on the label (see Section 9.3.1). ACVM could use the critical uses

supported in the EPA documents to determine which crops are using the product

off-label but they would still need to allow off-label use.

In many cases, the MRL has been set at a level above that which is likely to be

present in the food crop. Therefore residues are over-estimated. New data

could be developed to support a lower MRL which would potentially reduce the

overall level to below the ADI. However, this will require trial work to be

undertaken and chemical companies are unlikely to fund this. There is no data

protection for this work and if one company pays for the work, other companies

will copy the label at no cost. There is no advantage in a company paying for

work to be done on this basis. Further, if the compound is scheduled to be

phased out (e.g. diazinon) then companies are unlikely to invest in the necessary

trial work. Industry groups do not have sufficient funds available to undertake this

work as much of their available funding will be used in trying to identify

alternatives to the OPCs under phase out.


The overall implication is that while EPA may allow continued use of a compound, if

the ADI is exceeded, then the product is unlikely to be able to be used. It is

extremely difficult for industry to consider a response to the overall OPC

recommendations in the absence of this important information.

Industry requests that EPA reconsiders the way they have set ADIs and ensures that it

is completely justified given the impacts the reduction in ADI will have on future use

of the compounds. In the absence of information on ADI impact on future

availability, industry has had to ignore this issue when reviewing EPA proposals. It

would have been more efficient if this information was incorporated into these EPA

consultation documents.

8.3. Additional data

The EPA report requests that additional toxicology data be provided for certain

substances in order to refine the risk modelling. Industry does not have access to this

data but has been in contact with registrants to ask that they provide the

information if they have access to this. In the time period available, industry has

focussed on use patterns and the proposed controls and has not been able to

spend time searching for additional data. Industry hopes that the EPA has directly

and specifically asked registrants for the information that they need to refine the risk

assessment. Expecting registrants to read the full report to determine what data are

missing is unrealistic given the number of compounds involved.

In the majority of cases, the registrant for the products in New Zealand is a generic

company that does not have specific technical support within their company to

either obtain or generate the information. There is no data protection for

reassessments and there is no incentive for companies to generate data.

Industry has undertaken a brief review of the cost of undertaking dermal absorption

testing for fenamiphos which is applicable to other similar types of testing. Industry

was advised that funding in the region of NZ$174,000 to NZ$186,000 would be

needed. Clearly this level of funding is out of reach for any company or industry

group in New Zealand, particularly if there is a risk the compound will still be phased

out.

8.4. Specific benefits summary

Section 6.2 of the EPA consultation report summarises specific benefits of OPC use.

There are some benefits which have been missed from this section in relation to use

in horticulture and arable sectors. These benefits have been fully described under

each compound in Section 10 of this submission so they can be added to the table.

9. Comments on proposed controls

Industry appreciates that the EPA staff have taken into account the previous

feedback from industry and (for the most part) have suggested practical controls

that can be adhered to. EPA correctly points out (in section 8, page 39) that there

are already a number of regimes in New Zealand which help to ensure the safe and

efficient use of agrichemicals (such as OPCs).

In some of the sections below industry has suggested that the current GROWSAFE®


program and NZS8409 has existing practical controls and that duplication is not

necessary. Therefore EPA should simply reference existing controls in NZS84095. In

recognition of the fact that growers need to be alerted to the new controls on these

OPCs (once they come into force) and acknowledging that text in some cases will

be too big to fit onto a label, industry suggests that EPA instead require that each

control be referred to on the label in brief (i.e. using the R1-16 coding system), with

further explanation provided in an OPC controls pamphlet. This could be given out

at point of sale with all OPCs. The text should be directly taken (i.e. copied from)

NZS8409 to ensure that any tweaks to the wording does not result in confusion. As this

standard is also recognised and referenced under GROWSAFE® and Regional

Council regulations many growers are familiar with the obligations in the sections

already (e.g. control R-11 Notification).

9.1. R - 1 Phase in of new controls

For all currently registered agricultural chemicals EPA has proposed 18 month phase

in of the new controls.

Where practical, the best way to convey the new controls to growers is on the label.

Therefore EPA should seek advice from registrants of the relevant products to see if

this allows enough time to make necessary label changes to reflect the additional

controls.

EPA should clarify if this means that growers who use existing stock of these products

after the phase in (that will not display the additional label wording) will be in

breach of these additional controls.

9.2. R - 2 Phase out of approval

See section 10 and 11 for specific comments on the proposed phase outs (if any) for

each compound. EPA needs to clarify how they plan to implement and convey the

additional controls to growers to ensure they are aware and compliant.

9.3. R - 3 Application parameters

EPA has suggested a maximum rate and frequency to cover all uses. In most

instances this is the maximum that sectors have indicated would be used per

application according to GAP (for both on and off label uses). There are a number

of other potential issues as outlined below.

9.3.1. Off label use

It is not clear how the EPA intends to reflect the maximum rate and frequency on the

label for off label uses. Industry understands that the application rates, frequencies

and intervals specified are not proposed to apply to specific crops but are proposed

as generic maximum values for each OPC active ingredient as part of a formulation.

EPA’s current proposed label wording is unlikely to be acceptable to the ACVM

Group of MPI because under current ACVM policy only registered (food and feed)

claims are allowed to be displayed on the label as a result of the registrant supplying

data that demonstrates that the use pattern (rates, frequencies and intervals)

reflects GAP for a particular crop. Residue and efficacy data must be supplied (to

support all food and feed crop claims) in order to allow MRLs to be set. Therefore in

5 New Zealand Standard NZS8409 Management of Agrichemicals 2004 (NZ8409)


the absence of data, ACVM are unlikely to allow generic maximum rates and

frequency statements on labels to cover all uses (both on and off label) as

suggested by the EPA.

9.3.2. Minor crops

Growers of minor crops (i.e. the majority of crops represented in this submission) will

be unable to use the compounds if ACVM put any restrictions on off label use as a

result of the EPA controls. Many of these compounds are used off label as there are

almost no registered label claims for minor crops. It is legal under the ACVM Act to

use these products off label and growers’ only obligation is to ensure residues are

below the default MRL (0.1mg/kg). However this can only be done if there is no off

label restriction.

There is no incentive for chemical companies to register new claims (i.e. for minor

crops) on these compounds as they are all outside of the period of data protection,

and if one company was to invest in trials and gain new label claims, generic

companies can mirror this label with no capital outlay. Currently New Zealand data

protection legislation only allows for five years protection of intellectual property for

new active ingredients and data that is generated for these older compounds is well

out of this protection period. Therefore there is insufficient commercial return on

investment for chemical companies to undertake the residue trials necessary to

obtain a label claim.

Even under the proposed new data protection changes6 there is unlikely to be

sufficient economic benefit in undertaking work, particularly if the compounds are

scheduled for phase out.

Further, the labels that are in place refer to specific pests but the use is much wider

than the pests specified on the label because most of the compounds under

reassessment are broad spectrum insecticides. If use is restricted to only uses

displayed on the label, this would mean the product could only be used for the

pests and crops on the label and this is highly restrictive. Chemical companies are

not going to undertake the research necessary to revise labels to add all of these

crops and insects. Continued off label use under the current controls is practical

and vital for growers of minor crops.

One of the key reasons to maintain use of OPCs is to manage outbreaks of pests.

These often occur on minor crops (e.g. psyllid on tamarillos). Restricting the range of

crops that OPCs may be applied to will have a negative effect on many small

industries. See table 1 below for a list of all off label uses for the compounds

supported as critical use in this submission.

Table 1: List of off label uses supported by this submission

Compound Off label use

acephate Baby leaf (but has lettuce)

chlorpyrifos Other Onion, Sweetcorn, Potato, Strawberry, Persimmon,

Kumara, Processed Veg (Carrots and Peas/ Beans), Other Veg

(Chinese Greens & Spinach)

diazinon Passionfruit, Kumara, Arable crops (Vegetable seed crops),

6 As presented to AVMAC (of which EPA is a member) in December 2012


Peas, Baby/ Salad leaf

fenamiphos Parsnip

methamidophos Other onion, Tamarillo, Kumara

oxamyl Green House (Tomato & Capsicum), Parsnip

phorate Parsnip, Kumara, Celery, radish seed

pirimicarb Strawberry, Citrus, Chinese Greens

terbufos Kumara, Processed vegetables (Peas/ Bean and Carrots)

If this control prevents off label use, growers of crops that do not carry a label claim

will not be able to comply with this control. It is not clear how the EPA plans to allow

for off label use as a result of conflicting policies and risks that are managed under

the ACVM Act and the HSNO Act. EPA needs to clarify this situation in their

recommendations to the panel to give certainty to the sectors represented in this

submission.

9.3.3. Application parameters

This control seeks to limit application rates and frequencies. If the number of

applications is limited, in some seasons when adverse weather patterns occur (e.g.

drought) late pest outbreaks could result in significant or total crop loss. There needs

to be some flexibility to ensure that growers have tools available for late pest control.

If there is only a maximum of 2 applications per year and due to weather patterns

there is a late season pest outbreak, growers need the flexibility to use additional

applications. A need for more applications can also occur even when using IPM

monitoring techniques to assess pest prevalence. In some seasons if a particular pest

is very prevalent or present for an extended period, monitoring may indicate a

requirement for a greater frequency of applications of an OPC than would normally

be required in a ‘typical’ season. In these circumstances, risk to human health and

or the environment can be managed via the other controls (e.g. R-10 RPE/ PPE).

Some crops are planted multiple times during the year. Therefore industry requests

that EPA alter the maximum frequencies to be the number allowed per crop cycle

(rather than per year) as this is more practical. As an example, a crop such as

apricots produces one crop per year, but a crop like baby leaf lettuce can have 2

or more different crops produced on the same land area per year and each crop

requires insecticide applications. Therefore, in terms of crop management it is more

appropriate to state the number of applications allowable per crop cycle in the

controls and on the label (in the directions for use).

Sections 10.4.4 and 11.2 explain that the restriction to two applications per season

for diazinon will be an issue for the avocado industry and an increase to four

applications per year is requested.

9.4. R - 4 Buffer zones

Industry strongly opposes the setting of buffer zone distances without taking into

account other factors (such as nozzle type, shelter belts etc). Industry is pleased that

the EPA has utilised some of the Buffer Zone criteria specified in the NZS8409 and

acknowledges that as part of best practice, growers are already complying with

practical and sensible buffer zone guidelines as set out in GROWSAFE®.

However, the buffer zone section in NZS8409 is only a suggested guideline and the


distances given are an indication only. NZS8409 states (in section G6, page 106 - 107)

that the distances are subject to a range of other factors that can affect the width

of the buffer zone and include:

a) The application technique (e.g. projecting spray into the air)

b) The agricultural chemical used (e.g. volatility)

c) The physical nature of structures such as shelter belts

The requirements of NZS8409 and GROWSAFE® are currently adhered to by growers

and this manages the risk of spray drift. Applications of these products are targeted

with correct nozzles and this results in very little spray drift (i.e. spray is delivered

directly onto the crop).

Sprays are applied during favourable weather conditions (correct air temperature,

fog, wind speed and direction) often very early in the morning or late at night. These

factors all contribute to a maximum targeted application of these products onto the

crop and pests. See section 5.9G of the Call for Information Submission from the

Horticulture and Arable Industries for further information.

NZS8409 also allows growers to take into consideration pest movement patterns

(from the edge of blocks inwards). Aerial buffer zones of the currently

recommended sizes could place crops at risk from pest infestations within the buffer

zone not sprayed.

In the EPA consultation document, page 172 ‘Interpretation’, shelter belt is defined

as being a ‘live vegetative shelter’. Artificial shelter belts are widely used in New

Zealand as a means of instant drift mitigation and industry requests that the EPA

update this interpretation to include artificial shelter structures.

Suggested control: As the distances given in NZS8409 (table G2) are guidelines only,

and the additional text in section G6.1 gives further context to the buffer zone

distances in as a means of drift management, industry suggests that the EPA change

this buffer zone control to a guideline to allow flexibility. EPA should duplicate the

text from this section of the guidelines in the ‘OPC controls pamphlet’. This would

allow growers to have continued ability to reduce distances (or in some instances

increase distances) depending upon the technology (such as drift reducing nozzles)

they may be utilizing in order to mitigate drift. This will also allow flexibility depending

upon shelter belt presence/absence and size. It is better to not specify parameters

as these can vary with changing technologies and then controls and label text must

be constantly updated.

For aerial applications it is suggested that there be a differential buffer based on

whether release height is above or below the height of the shelter.

Suggested label wording: The EPA could require a label statement such as ‘A person

applying this substance should follow the Buffer zone guidelines in the EPAs OPC new

controls pamphlet’.

9.5. R - 5 Cover granules after application

EPA is only recommending this control for chlorpyrifos granules. The use of

chlorpyrifos granules in the arable industry is supported and they can comply with

this control.


However, if this control was extended to other compounds and/or crops the control

may not be feasible. The proposed control may not be practical as it may affect

follow up applications where the crop is established and therefore soil cannot be

disturbed or shifted. This is particularly true for root crops where any soil disturbance

will impact on production and therefore yield. New machinery may need to be

developed for pre-plant applications as current grower machinery may not be able

to achieve coverage when applying some compounds.

The currently proposed control can be complied with as it only relates to Chlorpyrifos

for the arable sector only.

9.6. R - 6 Droplet size

EPA have recommended a droplet size restriction on chlorpyrifos and diazinon

(when aerially applied), and fenamiphos (when ground applied).

Industry advises that there are a number of issues associated with coarse droplets.

They may shatter and bounce and cause more run off in to the environment than

medium sized droplets that are more commonly used for insecticide applications.

The GROWSAFE® manual (page 88) recommends that the coarse droplet size be

used only for herbicides and soil application as coverage is low. If coverage is not

adequate when using these insecticides, efficacy will be reduced and may result in

repeat applications to achieve control.

Also, the specificity of this control will be extremely difficult for growers to comply

with, as some droplets will be smaller and some larger. “Droplet size” in general terms

refers to the average size. When applying a spray under specified conditions, 50% of

droplets produced in a nozzle designed to deliver a droplet size of (e.g.) 400

microns, will be smaller than this.

Therefore the risks of non-compliance (due to natural variation in droplet size) as a

result of an impractical control are a concern for growers.

9.6.1. Reducing off target exposure

Growers are required under GROWSAFE® to ensure equipment used is appropriate

for the product and formulation type used. Growers are aware of the risks and the

implications of improper use and are educated in correct use of these compounds.

They are aware that the use of other products (such as adjuvants and drift reduction

agents) can prevent and minimise off target exposure and follow best practice

guidelines that stipulate guidelines such as spraying only when weather conditions

are favourable. This decreases the risk of exposure as a result of spray drift.

9.6.2. Avocado

The avocado industry utilises aerial application (by helicopter) to achieve coverage

at the top of the tree canopy for control of target pests. Avocado trees are terminal

bearers meaning that the majority of fruit on older trees is at the top where there is

good light exposure. The proposed 400µm (coarse) minimum droplet size will seriously

compromise coverage on avocados and may lead to growers increasing volumes

or numbers of applications to compensate for reduced efficacy.

The coarse droplet size is only suited to herbicide applications or where coverage is


not critical (in the case of systemic insecticides). Diazinon and chlorpyrifos mode of

action is via contact and ingestion. Therefore control of any non-motile insects such

as scale will be seriously compromised. Good penetration into the canopy is

essential and control of off target drift is managed with medium droplet sizes and by

using shelterbelts. Avocado orchards mainly have vegetative shelter belts that

mitigate risks from off target spray drift when aerially applying these two

compounds.

9.6.3. Carrot, Parsnip and Potato

While the carrot, parsnip and potato industries can comply with this control, industry

needs the flexibility to utilise new technologies (such as adjuvants and new

machinery etc) that may not produce a certain droplet size, but serve to reduce

drift.

9.6.4. Summary

For the compounds where EPA considers the droplet size a risk, industry does not

believe that the EPA should specify parameters. Instead EPA should refer to NZS8409

and GROWSAFE® (by duplicating the wording in the OPC pamphlet) as these

currently address the issue of utilising droplet sizes to manage exposure as a result of

spray drift of all substances (i.e. not just aerial application and not just chlorpyrifos,

diazinon and fenamiphos). NZS8409 is a national standard that is backed up by a

robust training programme (GROWSAFE®). Growers demonstrate they can comply

with NZS8409 by completing a GROWSAFE® course and undergoing regular renewal

training to gain updated certificates.

Technologies (such as nozzles) can change and it is better to not specify parameters

for a particular compound and instead mirror current best practice. NZS8409 must

be complied with under many regional council air plans and is an existing control

and is therefore a better way to manage drift.

Suggested label wording: The EPA should only require a label statement such as ‘A

person applying this substance must follow controls set out in the EPAs OPC new

controls pamphlet’. This should directly duplicate the requirements in Appendix Q of

NZS8409.

Industry is pleased that for all of the other compounds supported in this submission

there is no droplet size restriction and growers can continue to follow NZS8409 and

GROWSAFE® guidelines that suggest using a range of methods to manage spray

drift.

9.7. R - 7 Restriction on method of application

EPA has proposed a droplet size restriction (coarse) for diazinon when applying the

liquid form aerially. As discussed above (section 9.6.2), the avocado industry cannot

comply with this control. There is no mention of restrictions on aerial application

using granules therefore industry assumes this use will continue while diazinon is in

use.

9.7.1. Aerial application prohibited (Fenamiphos and Oxamyl only)

Prohibition of aerial application is only being recommended for fenamiphos and

oxamyl. Neither fenamiphos nor oxamyl is applied aerially by any of the crops

represented in this submission. Therefore industry can comply with this control for


these two compounds.

Industry is pleased that EPA have taken the benefits of aerial application of the

OPCs into consideration and recommended continued retention of aerial

application for all other uses.

9.7.2. Restriction to indoor use only via automatic application

Grain silos and seed storage warehouses can comply with this control and are

pleased to see indoor use of pirimiphos methyl retained. Industry understands that

as per the EPAs Summary and Analysis for the Arable sector, use scenarios ‘Arable

40-43’ of pirimiphos methyl via grain conveyor, will continue as this is regarded as

indoor use and critical to the arable sector. It would be helpful for EPA to include a

definition in the interpretation section (page172) around indoor use to ensure the

filling of grain silos via conveyor is recognised as being permitted under the

proposed control R-7.

9.7.3. Restriction on outdoor use

See specific sections 10.11 and 10.15 where the restriction of the compound to use

indoor only is not acceptable to industry and industry needs outdoor use to be

retained for the following crops and compounds:

Crop/s Compound

Strawberries and lettuce/ salad leaf Methomyl

Avocado and Persimmon Pirimiphos methyl

Further benefit information for the above crops can be found in sections 10.11.3 and

10.15.3. The benefits from retention of outdoor use for the above compounds

outweigh the risks which are comparatively low and warrant this control to be

removed.

Industry notes that there are restrictions on Dichlorvos indicated in the EPA report.

While we are aware that Dichlorvos is not being considered by EPA at this time, if the

restrictions were imposed at some time in the future, they will cause problems.

Industry intends to provide further comment on this compound when EPA consults

on this in the future.

9.7.4. Automatic delivery systems - Greenhouse indoor use

In the documents EPA defines automatic delivery systems as:

‘An automatic system is a delivery system that is operated remotely and does not

require an operator to be present in the application area during release of the

substance. This means that operators will not be exposed to the substance during

application.’ The greenhouse industries (tomato and capsicum) cannot comply

with this control.

As per the Greenhouse sector assessment previously submitted to EPA, industry

stated there were three types of equipment currently used. These are:

Ultra low volume (ULV) - This system is automatic and the operator is not

required to be in the greenhouse during spraying. The system uses stationary

fans to distribute droplets, and when the fans turn off, droplets settle on the

plants.

Foggers - The operator can be present in the application area, but is wearing

RPE and a full PPE suit and therefore does not come into contact with the


chemicals via skin or inhalation. The operator is away from the “machine”

and does not come in direct contact with the treated plants.

Trolley boom sprayers - these are automated or manually operated.

Automated options travel down the rows automatically and an operator

waits at the end to move it to the next row. The machine is not spraying while

being moved.

These machines are operated by trained staff with full PPE gear. Whilst some

greenhouses may have fully automatic sprayers (ULV), as these are very expensive

pieces of equipment not all greenhouses can justify this capital investment. Many

growers cannot afford this equipment and use foggers and/or trolley boom sprayers.

Therefore the requirement to apply compounds automatically is of concern and will

impact on greenhouse production. Industry requests that EPA consider other

methods to manage risk as the automatic application control is not feasible.

Industry understands that EPA considers application through irrigation to be remote

and so this method of application is acceptable.

9.7.5. Maldison - baits only coloured blue/green.

Industry has confirmed with one registrant of maldison that treated baits are dyed

green at the point of manufacture. It is assumed that other registrants will provide

comment on whether this control can be complied with.

9.7.6. Prohibit handheld application of granules (diazinon only)

Industry currently only uses machinery to apply diazinon, therefore this control can

be complied with. Growers use protective gloves and PPE when loading

application machinery.

9.8. R - 8 Identification as an organophosphate or carbamate

substance

This control is currently on many OPC labels already and is supported. This serves to

alert growers to the fact that the product is an OPC. If they are aware of the

additional controls that EPA have imposed this will also help to alert them to follow

these controls over and above what they already comply with if they have

GROWSAFE® certification.

9.9. R - 9 Label warning of effect on bees

NZS8409 (sections 2.4.3, 5.3.1.2, Appendix F5.2) lists a series of practical precautions

on how to avoid risks to bees when using agricultural chemicals, whilst accepting

that in some situations it may not be possible to totally eliminate all flowers from the

application zone (due to weeds around the perimeter of some blocks). EPA has

suggested label text “Do not apply this product to any flowering plant, tree or weed

likely to be visited by bees”. This is conservative, risk averse and impractical in most

instances.

The June 2004 Schedule 4 transfer notice for some compounds specifies the number

of days after flowering before spraying can take place. In all cases where this

control is included, the current consultation document states the EPA has now found

that there are only negligible risks to bees (APP201045 acephate - table 9,

methamidophos - table 36, methomyl - table 39 and oxamyl - table 42). The report


states that ‘bees are only expected to be killed when they are directly exposed to

the spray solution and that controls are assumed to be effective in restricting

application to times when bees are not present’. Given this assessment, the

restriction is now unwarranted and the Schedule 4 transfer notice should be revoked

in light of this new information.

Best practice is for OPC compounds not to be sprayed when bees are foraging.

Once the product has dried, bee toxicity issues are only negligible and there are no

risks to bees. There are no risks to bees when using granule formulations, therefore

these products should not require a bee safety label statement.

Suggested control: A label warning such as ‘Do not spray when bees are present’

should mitigate risks from these compounds to bees.

9.10. R - 10 PPE equipment

EPA have increased the PPE requirements by specifying that full PPE is required for all

OPC uses and that chemical resistant coveralls must be worn over a long sleeved

shirt and long legged trousers. This is impractical and this control could become a

health and safety issue as a result of operators getting excessively hot under two

layers of full length clothing - especially when spraying during summer months. A

long sleeved shirt and long legged trousers are unnecessary under chemical

resistant coveralls as the coveralls will prevent exposure to the OPC compounds.

Minimum PPE is currently best practice under GROWSAFE® and there are clear

requirements specified in Appendix P of NS8409. These requirements are sufficient to

manage operator exposure risk.

Suggested control: Any person who is mixing, loading or applying the substance, or

entering an application area within the Restricted Entry Interval (REI), must wear the

appropriate PPE and RPE equipment as specified in the EPA OPC controls pamphlet.

The wording should directly duplicate the text from Appendix P of NZS8409.

Industry appreciates that the EPA has allowed for closed cab application to be used

instead of wearing full PPE/RPE. EPA may wish to clarify that a full set of PPE should

be available if the grower needs to leave the cab and handle the chemical (e.g. if

nozzles are blocked). Growers with GROWSAFE® certification will already be aware

of the need for this.

9.11. R-11 Notification

EPA has specified that a ‘neighbour’ is regarded as ‘an occupier and owner of land,

dwellings or buildings immediately abutting the application area or buffer zone’.

9.11.1. Current requirements

EPA has suggested new notification requirements need to be implemented. Industry

has no issue with existing notification requirements as they are currently set out by

regional councils, GROWSAFE® and NZS8409 and considers that these controls are

sufficient.

Current controls around notification that already exist include:

Various regional and local authority regulations (including local government

regional air plans).

Section 6 of the GROWSAFE® manual 2011 ‘Using Agricultural Chemicals’ sets

out practical notification requirements and allows for flexibility and annual


notifications and instructs growers to check and comply with local authority

requirements.

Appendix M of NZS8409 sets out notification and signage requirements that

are in addition to local authority regulations.

As an example, the Environment BOP Regional Air Plan states the following under its

permitted Activity for aerial applications:

The owner/occupier or agent must notify the occupier of any adjoining properties

within 200m of that agrichemical use. If an agreed form of notification has not been

reached, such as an annual spray or application plan and individual notification of

certain chemicals to be used, notification must be no earlier than 20 days and no

later than 12 hours before the agrichemical use. This condition does not apply to

agrichemical use on public land or land used for road or rail purposes. The property

owner or agent acting on behalf of the property owner must advise the aerial

applicator that notification has occurred before the aerial application of any

agrichemical is undertaken.

Given the current controls that must be complied with, most of the EPA proposed

controls are already regulated and duplicate regulation is unnecessary and

impractical. Industry cannot comply with some of the impractical requirements that

EPA has suggested (such as providing written notice at least 2 days, but not more

than 4 weeks in advance of each application).

9.11.2. Spray timings

Insecticides are not calendar sprayed. Growers review crop monitoring of pest

numbers, compare results with established industry thresholds, ratio of beneficial

insects and crop phenology prior to a decision being made to apply a targeted

spray. The weather is very important for safe application. If a weather window exists

to apply a compound safely and the results show it is imperative for the economic

protection of the crop then the additional requirements around notification of at

least two working days in advance of application are not practical. In most

instances growers cannot predict when conditions will be right to spray. If they are

required to notify two days in advance it will lead to applications occurring outside

optimum weather windows.

9.11.3. Written Notice

For some properties that border many neighbours (e.g. DOC and Iwi owned land) it

is not practical to advise all neighbours, especially those that do not reside on their

properties. Other uncontrollable factors such as neighbours that may be on their

property infrequently (e.g. in a holiday home situation) or where a grower may have

already started spraying cannot be regulated and will always fall outside of sensible

and practical regulation.

Currently under NZS8409 annual notification is required and all local authority

regulation requirements must be compiled with. This is practical and is current

practice that already covers the application of all chemicals (including OPCs). All

interested parties have access to individual crop agrichemical spray plans and if

neighbours request more frequent updates this is done.

Oral and text notification (such as door to door, by phone or other mutually agreed

format) is also currently acceptable and should be allowed to continue as it is in the


NZS8409 standard, and Regional Council air plans recognise this standard.

9.11.4. No notification

For some formulations (such as granular products and in greenhouses/silos)

notification is unnecessary as there is no risk of drift and there is no risk of the product

moving from the application area.

9.11.5. Immediate contact during application

The requirement for an operator (most growers are sole operators) to be in

immediate contact by phone during application is impractical due to noise of

machines. Operators cannot hear the phone ringing when they are applying

chemicals as the machinery is loud and it would be dangerous to stop and answer a

mobile phone when in the middle of spraying.

EPA should mirror the existing requirements under NZS8409 to ensure that practical

controls around notification are placed on users and growers do not need to have

one set of notification controls when applying OPCs, and other controls when

applying all other agricultural chemicals. There are already minimum requirements

under three systems that must be complied with.

Suggested control: No person may apply, or engage another person to apply, the

substance unless that person has followed the notification requirements set out in

the OPC controls pamphlet. The wording should directly duplicate the text from

Appendix M of NZS8409.

9.12. R -12 Restricted Entry Interval (REI)

For all substances, the EPA has recommended an REI of a maximum of 48 hours. This

time period is practical in most instances. The 48 hour REI is less than ideal for

strawberries given that crops can be harvested as often as every 2 days. A 48 hour

REI will impact on growers and industry asks that EPA reconsider if this is necessary for

methomyl (refer section 10.11).

9.13. R-13 Approved handler

It is a current requirement to hold an approved handler certificate for the

application of many agricultural chemicals, therefore industry can comply with this

control.

This control also mentions the 9A ‘exception to the approved handler requirement

for transportation of packaged pesticides’. Industry understands that growers need

only be approved handlers, and transporters (if not approved handlers), must have

the special license (i.e. growers will not be required to get a special class of licence).

Currently it is not mandatory to display a statement on the label if the product

requires the user to be an approved handler. However in the interests of providing

sufficient user information, industry suggests that the EPA place a control on OPCs

that requires a statement to be on the label. This will let growers know that they must

be an approved handler to use the OPCs.

Suggested wording: This product must be under the control of an approved handler.


Industry also notes that approved handler has no prescribed content as a basis for

the training. Therefore holding an approved handler certificate does not necessarily

mean that the operator has appropriate knowledge and training to apply OPCs

correctly. Approved handler certification is required only for the supervisor, and may

not necessarily be held by the actual operator. Industry supports the GROWSAFE®

programme as a means of ensuring growers are adequately trained.

9.14. R - 14 Signage

Industry notes that this is a requirement for indoor use only. The sectors that use these

OPCs indoors can comply with this control and signage as currently used.

9.15. R – 15 Transport restriction

Industry understands that this is a current regulation and is a practical control for

mitigating risk when transporting these compounds.

9.16. R - 16 Authorised person

Industry understands that this is a person with a relevant appointment under section

103 of the Biosecurity Act and agrees this is an important control that will allow

higher rates to be used and flexibility around the controls if a Biosecurity incursion

occurs.


10. Comments by Compound

10.1. Acephate

10.1.1. Critical Use Summary

Acephate is being supported by horticulture and arable as summarised below:

Crop Pest

Avocado Armoured scale, mealy bug, grass grub

Baby leaf Diamond back moth, looper caterpillar, leafminer, springtail

Lemon Citrus flower moth and Kelly’s Citrus Thrips

Industry notes that EPA have listed a further 5 uses from the horticulture industry that

are not supported. The horticulture industry is only requesting continued use for the

three crops listed above.

10.1.2. Risks

The risks associated with the uses supported by this submission range from negligible

to medium. The use pattern for baby leaf attracts the lowest risk with either

negligible or low risks and the risks associated with avocado and citrus are assessed

low or medium for human health and bird risks. There are negligible risks to aquatic

organisms and bees. While there are some medium risks to birds associated with use

in citrus, the RQ is 13 which is only just above the cut-off to medium risk.

10.1.3. Benefits

Industry is pleased the EPA have recognised the significant regional benefits that

acephate provides to the citrus industry particularly in Northland and Gisborne.

Acephate is critical to the production of blemish free fruit and despite significant

investment, industry has been unable to find an alternative. Detailed information on

the benefits to citrus, avocado and lettuce industry has been previously provided.

10.1.4. Proposed controls

Industry strongly supports the EPA proposal to allow continued use of acephate with

controls. Notwithstanding the comments provided in section 9 on the controls,

industry generally supports all of the controls proposed aside from control R-9.

Control R-9 requires a label warning of effects on bees. Industry notes that the EPA

assessment shows that risks to bees are negligible as bees are only expected to be

killed when they are directly exposed to the spray solution. As described in our

comments in section 9.9 on control R-9, a label warning is only necessary to ensure

that the product is not applied when bees are present. The requirement to avoid

spraying for a number of days during flowering is not necessary as the compound is

only toxic to bees directly sprayed. Growers apply acephate in the evening or early

morning before bees are foraging and this mitigates risk of bees being affected.

Industry agrees that a label warning for bees is appropriate but considers the

wording of the control R-9 needs to be amended. If not, lemon growers will be

unable to use the compound when they need too as lemon trees flower all year

long and it is not possible to avoid spraying during the flowering period.


10.2. Carbaryl


Carbaryl is being supported by horticulture and arable as summarised below:

Crop Pest

Avocado Leafroller, greenhouse thrips, armoured scales

Summerfruit Leafroller, oriental fruit moth, thrips

Industry notes that EPA have listed a further seven uses from the horticulture industry

that are not supported. The horticulture industry is only requesting continued use for

the two crops listed above.

Carbaryl is an important pest control compound for the avocado and summerfruit

industries. Industry is pleased that the EPA has proposed retention of this product

with controls. Notwithstanding the comments provided in section 9 on the controls,

industry generally supports all of the controls proposed.

10.3. Chlorpyrifos


Chlorpyrifos is being supported by horticulture and arable as summarised below:

Crop Pest

Arable (Maize, Brassica seed

and cereals)

Aphid, leaf miner, springtails, argentine stem weevil,

armyworm, corn earworm, grass grub

Avocado Leafroller, armoured scales, six spotted mite

Cucurbit (Squash) Aphids, caterpillars, thrips

Kumara Army caterpillar, black beetle

Onion (& other) Thrips

Other Veg (Chinese Greens &

Spinach)

Leaf miner, maggot pupae, spring tail, symphilid,

lepidoptera pupae, cut worm

Persimmon Scale, leafroller, mealy bug

Potato Aphids, stem weevil, thrips, springtails, cutworm,

porina, leafroller, tomato/potato psyllid (TPP)

Processed Vegetables

(Carrots and Peas/ Beans) Grass grub

Strawberry Aphid, scale

Summerfruit Leafroller, mealybug, thrips

Sweetcorn Aphids, armyworm, corn earworm, cutworm.

Chlorpyrifos is an important pest control compounds for a wide range of horticultural

and arable industries. Industry is pleased that the EPA has proposed retention of this

product with controls. Notwithstanding the comments provided in section 9 on the

controls, (particularly in relation to droplet size restriction) industry generally supports

all of the controls proposed.


10.4. Diazinon


Diazinon is being supported by horticulture and arable as summarised below:

Crop Pest

Arable crops (maize,

cereals, grass, pasture,

clover and vegetable seed

crops)

Cereal aphid, aphid, caterpillar, thrips, grass grub,

porina, carrot rust fly

Avocado Leafroller, mealy bug, scale, thrips

Baby/ Salad leaf Springtails, symphilid

Carrot (processed)

Grass grub, manuka beetle, porina, carrot rust fly and

springtails

Citrus (all) Kelly’s Citrus Thrips, greenhouse thrips, Australian Citrus

Whitefly, aphids, mealybug, scale

Kumara Grass grub, black beetle, white fringed weevil,

wireworm

Peas/ Beans Grass grub

Strawberry Black beetle

Tomato (processed) tomato/potato psyllid (TPP)

10.4.2. Risks

Diazinon is widely used in agriculture including across sectors in the horticultural and

arable industry. There are a wide range of application methods used resulting in

variable levels of risk. The uses supported by this submission range from negligible to

high risk for birds. It is clear that some application types are less risky than others but

given the proposal to phase out the use of diazinon across all uses in 10 years, there

is little point in differentiating those that are lower risk. Industry acknowledges that

the EPA assessment shows there are risks associated with the use of this compound,

particularly for birds.

10.4.3. Benefits

The benefits of using diazinon have been documented and accepted by the EPA.

Given the wide range of industries across agriculture that it is used in and across a

wide range of pests, its importance is clear on a national level. The proposal to

allow the use of diazinon for 10 years means that industry can agree to phase out

other compounds such as phorate, however as discussed below, industry considers it

crucial that effective alternatives are registered before diazinon is phased out.


EPA has proposed a 10 year phase out for diazinon across all industries. Industry

appreciates that EPA have recognised the importance of this compound and the

need to retain it while alternatives are identified. However, industry is concerned

that due to the complexity of pest control research (particularly for grass grub), 10

years may not be sufficient to ensure that alternatives are registered and available

for use. As explained in previous submissions, grass grub is a pest native to New

Zealand which means that any research on alternative pest control measures need

to be undertaken here. This means the research will take longer, and cost a

significant amount of money which New Zealand industry groups will need to fund.


To a large extent the burden of this research will fall to the pastoral industry where

the biggest impacts are felt, and where the funds are available. Once a potential

control is found in the pastoral industry, the horticultural industry will be able to trial

the same control in the industry to ensure it works. Horticulture does not have

sufficient funds to embark on its own independent research programme.

The pastoral industry (in collaboration with the arable industry) has begun an

intensive research programme to identify alternative pest control for grass grub. A

copy of the project brief is included as Appendix 1.

Photo 1: A trial from SFF project 12/013 showing OP treatment on the left and no

control on the right. (Source: Foundation for Arable Research)

The results from the first year of trials have not identified a clear alternative to OPs

(see Photo 1). It is hoped that one or several possible alternatives will be identified in

the remaining two years of the project. If that happens, these alternatives will then

need to be field trialled for 2-3 years to refine the control mechanism and then

registration work can begin. This will take 3-5 years depending on the type of

compound. If it takes a further 2 years to identify a compound, 3 years to field trial

and 3 years to register then the best case scenario for an alternative to be available

in the major industries is 8 years. This assumes that the current project will identify an

alternative with appropriate efficacy. If it doesn’t then the replacement process will

take even longer. Industry recognises that there are risks associated with Diazinon

but considers that it is crucial that an alternative is available before Diazinon is

phased out. Industry accepts that the EPA may be reluctant to increase the phase

out period and suggests that instead, a review is undertaken in year 8 of the 10 year


period to determine if alternatives will be available. If they are not, then the EPA

can consider what further phase out period is necessary. Industry will need to

demonstrate that they have been actively searching for alternatives during this

period.

If EPA is unable to grant a review period to the 10 year phase out proposal, then

industry requests that the phase out period be extended to at least 15 years. This

provides a time buffer to allow for alternatives to be identified and developed

although there are no guarantees an alternative with equivalent efficacy will be

found.

Aside from the phase out and notwithstanding the comments provided in section 9

on the controls, (particularly in relation to droplet size restriction) industry generally

supports all of the controls proposed except control R-3 which restricts the number of

applications to two per year. The avocado industry has provided use pattern

information that supports a maximum of four applications per season. Four

applications can be required to control thrips populations which can increase

explosively during late summer and autumn while fruit is still be harvested, requiring

repeated applications for effective control. Chemical choice is not only limited but

at this time of the season may lead to market restrictions unless a product with a

relatively short PHI for most markets is used. Diazinon fits this profile and this accounts

for its widespread use. The avocado industry requests a maximum of four

applications per season be allowed.

10.5. Dichlorvos

In accordance with the EPA explanation in Section 10.5 (page 64), industry

understands that the formulations of dichlorvos that are supported by the arable

and horticultural industries are not under assessment in this application. Therefore no

comments have been provided on the proposal for this compound. Industry

strongly supports the continued use of this compound and wishes to be involved in

any consultation undertaken by EPA on potential changes.

10.6. Dimethoate

This compound is not supported by the horticulture and arable industries.

10.7. Fenamiphos


Fenamiphos is being supported by horticulture and arable as summarised below:

Crop Pest

Carrot/ Parsnip Root knot nematode

Potato Root knot nematode, Potato cyst nematode

10.7.2. Risks

The EPA risk assessment shows low and medium risks for carrots/parsnips and medium

or high risks for potatoes with both crops assessed as having a high risk to birds. The

difference in risks between the crops appears to be related to the area treated

which is higher for potatoes than for carrots/parsnips. Industry has tried to find more


information on dermal absorption and other toxicological information for

fenamiphos but has been unsuccessful. As discussed in Section 8.3 of this submission,

the cost of generating data is prohibitive especially given the high potential that the

product will be phased out.

Industry recognises that there are risks associated with this product but also notes

that it is applied only once in the season to paddocks where nematodes need to be

controlled. In the absence of refined toxicological data, it is likely that the risk has

been overestimated.

10.7.3. Benefits

Industry considers there are strong benefits cases for the use of fenamiphos in

carrots, parsnips and potatoes. The EPA has recognised the high benefit to the

potato industry and has assessed the benefit to carrots/parsnip as medium.

Fenamiphos is the only product registered for control of nematodes on potato and

the main product used for carrots/parsnips. Oxamyl is registered for nematode

control on carrots/parsnips but is significantly more expensive and does not provide

the same level of control. The future registration of oxamyl is also in doubt (Refer

Section 10.12).

Industry considers that given the impact on regional economies dependent on

carrot production, the benefit for carrot/parsnip should also be assessed as high.

Specific detailed benefit information is provided in Appendix 8 for Carrots and

parsnips and Appendix 7 for potato.


EPA has recommended a 5 year phase out for fenamiphos in recognition of the

potential impact and lack of alternatives available to the industry. However,

industry considers that this timeframe will be insufficient.

As demonstrated in Appendix 7 and 8, industry must retain these compounds until

alternatives are identified and registered. It will take some time to coordinate and

undertake the necessary research and there are no guarantees that alternatives will

be found in the timeframe available. Nematodes are particularly difficult to

research as their presence in the soil can be sporadic and hard to identify prior to

the start of trial work. Successful research relies on having populations of nematodes

present in the trial area and consistently spread through the plots. It is difficult to

determine if the nematodes are present in sufficient numbers before the trial work

begins and it is often not until the research is underway that this information is known.

Trials on nematodes often need to be repeated across multiple years to get a

consistent response. In addition, there are limited new options being introduced

internationally for control of nematodes that can be trialled. Often new pest control

options will be discussed up to 5 years before they are available for trial work, but at

present industry is unaware of any specific compounds that could be trialled in the

next few years. Development work by international companies is underway but will

take time.

The industry requests that they be allowed continued use of fenamiphos until

alternatives are found and registered for use. It is recognised that an open-ended

timeframe is difficult for EPA, and therefore industry requests that the timeframe for

phase out of fenamiphos be extended to 10 years. Secondly, industry suggests that


2 years before the phase out period ends a review is carried out to determine if

alternatives are available. If appropriate alternatives are not available and the

industry can demonstrate that work has been done to identify alternatives, industry

requests that the phase out is extended for a further 5 years. This will provide growers

and other people reliant on the compound some certainty beyond the next few

seasons of production.


on the controls, (particularly in relation to droplet size restriction) industry generally

supports all of the controls proposed.

10.8. Fenitrothion

This compound is not supported by the horticulture and arable industries.

10.9. Maldison


Maldison is being supported by horticulture and arable as summarised below:

Crop Pest

Avocado Greenhouse thrips, armoured scales

Citrus Citrus Flower Moth, Kelly’s Citrus Thrips, greenhouse Thrips

Kumara Crickets

Maldison is an important pest control compound for the avocado, citrus and

kumara industries. Industry is pleased that the EPA has proposed retention of this

product with controls. Notwithstanding the comments provided in section 9 on the

controls, industry generally supports all of the controls proposed.

10.10. Methamidophos


Methamidophos is being supported by horticulture and arable as summarised

below:

Crop Pest

Kumara Caterpillars, cricket, black beetle

Maize Green vegetable bug

Onion (& other) Thrips

Potato Potato tuber moth, tomato/potato psyllid (TPP)

Processed Tomato tomato/potato psyllid (TPP)

Processed

Sweetcorn

Aphids, tomato fruit worm, green vegetable bug, corn ear

worm

Tamarillo tomato/potato psyllid (TPP)

10.10.2. Risks

Methamidophos is used across the fruit and vegetable sectors to control specific

pests, in particular TPP and green vegetable bug. There are a number of

application methods and parameters used resulting in variable levels of risk with

aerial application showing lower risks in some areas. The uses supported by this


submission range from negligible to medium risk but there are no high risks.

Note that Appendix H of the EPA consultation document (page 188 - 189) shows

that methamidophos is still registered for use on potatoes in Australia by the APVMA

until mid 2014. The approvals were voluntarily cancelled by the registrants prior to

review completion so conclusions as to the outcome of that review had it continued

should not be drawn.

10.10.3. Benefits

EPA has recognised the high benefit of methamidophos to the potato industry due

to the need to control TPP and potato tuber moth. Detailed benefit information is

provided in Appendix 7 for the potato industry. TPP also affects the tamarillo and

tomato industries and methamidophos is critical for the same reasons – largely

resistance management and systemic pest control. Control of TPP is crucial to the

ongoing existence of both industries.

Tamarillos are a relatively new crop that was increasing in size and export value prior

to the arrival of TPP. Appendix 5 provides further information on the benefits of

retaining methamidophos until equivalent registered alternatives become available.

Control of TPP is critical to the production of field tomatoes which are used for

processing. The effects of not being able to grow field tomatoes due to inadequate

controls for TPP would be strongly felt in the Hawkes Bay where the crop is not only

grown, but provides product to the Heinz Wattie tomato processing factory. If crops

were no longer grown in Hawkes Bay, Heinz Wattie would either have to shut this

part of the tomato processing factory down (and rely on overseas factories), or be

forced to import tomato ingredients to supplement the shortage of local supply. The

impact of shutting down the tomato processing factory on the Hawkes Bay (in

particular Hastings) regional economy would be significant.

The benefits of the use of methamidophos in the kumara industry have been

assessed as medium by the EPA. Appendix 9 provides additional benefit information

on the use of this compound and demonstrates its importance to the regional

economy in Northland.

Methamidophos is used in the production of sweetcorn and maize to control several

pests including green vegetable bug. Due to the life habits and direct feeding

damage inflicted by this pest, finding alternative methods of control is proving

difficult. GVB has particularly challenging physical and behavioural characteristics

which make it especially hard to control. Research on finding alternative controls to

methamidophos for GVB in North Island process sweet corn started in the mid-1990s

with important work by Plant & Food Research and Lincoln University, financed by

Heinz Wattie. However, nearly 20 years later the industry still hasn’t found a

satisfactory alternative (Bruce Snowdon pers. comm.7).

Appendix 6 provides information previously presented to EPA in the sector

assessment consultation round that supports the benefits of methamidophos to

these sectors. Given that maize provides supplementary feed for the pastoral sector

and in particular the dairy industry, industry considers the economic benefits

7 Bruce Snowdon is the Agricultural Technical Manager for Heinz Wattie


association with maize should be assessed as high.

The field tomato, sweetcorn, tamarillo and kumara industries are important to

regional economies and while the individual benefit on a national scale may not be

high, industry requests that EPA gives consideration to regional impacts for these

industries and assesses the cumulative national effect. When the effects of all of

these crops are considered together, the benefit from retention of methamidophos

on a national level is high.



on the controls, industry generally supports all of the controls proposed.

EPA has proposed a 5 year phase out for methamidophos across all industries.

Industry appreciates that EPA have recognised the importance of this compound

and the need to retain it while alternatives are identified. However, industry is

concerned that 5 years is unlikely to be sufficient to ensure that alternatives are

registered and available for use across the range of crops and pests necessary. The

onion industry is confident that 5 years will be sufficient to identify alternatives for

onion thrips given the amount of international research being undertaken on this

widespread pest. However, the following pests are difficult to control and finding

alternatives is likely to take longer than 5 years:

Cricket

Black beetle

Green vegetable bug

Potato tuber moth

Tomato potato psyllid (TPP)

It is likely that a number of different compounds will need to be found to address the

different types of pests that methamidophos currently controls. For example, it is

very possible that a single compound will not control TPP and the green vegetable

bug. It is likely to take 2-3 years to identify alternatives and undertake initial trial

work. These alternatives will then need to be field trialled for 2-3 years to refine the

control mechanism and then registration work can begin. This will take 3-5 years

depending on the type of control. If it takes 2 years to identify a compound, 3 years

to field trial and 3 years to register then the best case scenario for an alternative to

be available in the major industries is 8 years with longer for minor crops.

Industry recognises that there are risks associated with methamidophos but

considers that it is crucial that an alternative is available before methamidophos is

phased out. Industry accepts that the EPA may be reluctant to increase the phase

out period and suggests that if this is not possible, a review is undertaken in year 3 of

the 5 year period to determine if alternatives will be available. If they are not, then

industry requests that the EPA considers a further 5 year phase out period. Industry

will need to demonstrate that they have been actively searching for alternatives

during this period.

If EPA is unable to grant a review period to the 5 year phase out proposal, then

industry requests that the phase out period be extended to at least 10 years. This

provides a time buffer to allow for alternatives to be identified and developed

although there are no guarantees that alternatives with equivalent efficacy will be


found for all pests across all crops.

10.11. Methomyl


Methomyl is being supported by horticulture and arable as summarised below:

Crop Pest

Baby leaf/ Salad leaf

Diamondback moth, aphids, springtail, leaf

miner

Greenhouse (Tomato and Capsicum) Whitefly and a broad spectrum of other

pests

Strawberry

Wide spectrum including aphids and

chewing insects

The horticultural industries consider only three uses of methomyl critical. The EPA

report lists a number of additional uses that the horticulture industries represented in

this submission do not consider critical. Removing these additional uses could

potentially reduce the overall risk of using the compound and allow for continued

use in those crops where it is critical.

10.11.2. Risks

The uses supported by this submission have been assessed as having negligible to

medium risks. The greenhouse application risks are all negligible aside from re-entry

risk which is assessed as low. The risks from strawberry field use are all negligible

apart from re-entry and bird risks which are assessed as low. Likewise, aerial use in

strawberries is assessed as negligible except for bystander and aquatic risks which

are assessed as low. Risks associated with use in salad leaf crops are slightly higher

with medium risk to birds and low risk to re-entry but otherwise negligible. Compared

with many other compounds in the reassessment, methomyl is a low risk compound.

10.11.3. Benefits

The benefit has been assessed by EPA as negligible for lettuce, presumably due to

the size of the sector, and low for strawberries and greenhouse crops.

The strawberry industry considers the use of methomyl to be very important and

disputes the assessment of benefit as low. Appendix 4 provides more detailed

information on the benefits of this compound to the strawberry industry. EPA is

requested to review the benefits case for this sector.

Given the negligible risks to the greenhouse sector in all but re-entry, industry does

not consider that a full benefits case is necessary. Information supporting the use in

the greenhouse industry was presented in the sector assessment documents.


Industry does not agree that a phase out of outdoor uses is justified for methomyl,

particularly in the strawberry industry. The risks are negligible in most aspects and the

benefits have been clearly demonstrated. Industry requests that the EPA allows

continued use of methomyl in outdoor situations. Subject to comments provided in

Section 9, the controls specified in the document are sufficient to manage risk and

can be complied with.


Industry also disagrees that a ban on application indoors using a hand-gun is

justified. The only risk that is not negligible is re-entry risk and that is managed

through a 48 hour re-entry interval proposed in the controls.

Aside from the phase out for outdoor uses and hand gun application, and

notwithstanding the comments provided in section 9 on the controls, industry

generally supports all of the controls proposed. The 48 hour REI is less than ideal for

strawberries given that crops can be harvested as often as every 2 days. A 48 hour

REI will impact on growers and industry asks that EPA reconsider if this is necessary.

10.12. Oxamyl


Oxamyl is being supported by horticulture and arable as summarised below:

Crop Pest

Carrot/ Parsnip

(inc. Carrot seed)

Carrot rust fly, root knot nematode, argentine stem weevil

Greenhouse

(Tomato &

Capsicum)

Whitefly, stem borer, aphids, psyllids, shore fly, fungus gnats,

scarid fly

Oxamyl can be used in the carrot and parsnip industry (including seed production)

but the industry preference is to use diazinon (for carrot rust fly and argentine stem

weevil) and fenamiphos (for nematodes). While oxamyl does provide some control

for nematodes, the levels of control are better with fenamiphos which is also

significantly cheaper.

Oxamyl is also currently used in the greenhouse industry for control of a range of

pests. However, the use in the greenhouse industry is off-label and industry

understands this is not supported by the manufacturer. The manufacturer is currently

considering whether they will continue to supply this product to the New Zealand

market but if they do decide to retain the product for field production, they will not

support the use in greenhouse crops. This product cannot be considered an

alternative OPC for greenhouse crops and if removed from the market, may not be

an alternative for field crops either. EPA needs to consider this when reviewing the

continued use of fenamiphos where they currently list oxamyl as an alternative. If

oxamyl is removed from the market then fenamiphos will become even more

important – supporting the industry request to increase the phase out period for this

product to 10 years.

Should the manufacturer decide to retain the product in the New Zealand market

and notwithstanding the comments provided in section 9 on the controls, industry

generally supports all of the controls proposed.

10.13. Phorate


Phorate is being supported by horticulture and arable as summarised below:

Crop Pest

Arable (vegetable seed -carrot, radish & Grass grub, springtails


white clover)

Carrot/ Parsnip Carrot Rust fly, grass grub

Celery Carrot Rust fly, grass grub

Kumara Symphilid, stem weevil, wireworm,

beetles

Processed Carrot Carrot Rust fly, grass grub

Phorate is currently used to some extent in growing the crops listed above however,

diazinon is the preferred control option for these pests. Given the EPA proposal to

retain diazinon for 10 years to allow the development of alternatives, industry can

accept the EPA proposal to phase out the use of phorate over 3 years.

10.14. Pirimicarb


Pirimicarb is being supported by horticulture and arable as summarised below:

Crop Pest

Arable (Clover & Brassica seed, Cereals-

Wheat, Barley & Maize) Aphids

Citrus (all) Aphids

Chinese Greens Aphids

Cucurbit (Squash & Melons) Aphids

Potato Aphids, tomato/potato psyllid (TPP)

Processed Peas, Beans and tomato Aphids

Strawberry Aphids

Summerfruit (all) Aphids

Transplant Nurseries (Brassica, Lettuce

and tomato) Aphids

Vegetable Brassica Aphids

Pirimicarb is an important pest control compound for a wide range of industries.

Industry is pleased that the EPA has proposed retention of this product with controls.

Notwithstanding the comments provided in section 9 on the controls, industry

generally supports all of the controls proposed.

10.15. Pirimiphos methyl


Pirimiphos methyl is being supported by horticulture and arable as summarised

below:

Crop Pest

Avocado

Leafroller, armoured scale, greenhouse

thrips

Greenhouse (Tomato) White fly, psyllid and mealy bug

Grain Silo Beetles, moths, weevils

Persimmon Scale, leafroller, mealy bug

Processed Vegetables - seed storage

(various large seeds) Beetles, moths, weevils


10.15.2. Risks

The EPA risk assessment shows negligible risks for all seed/grain storage and

greenhouse tomato uses. The risks for these crops are assessed as negligible

regardless of application method or rate. That being the case, industry questions

why control R-7 prohibiting use indoor using a spray gun has been proposed. In the

greenhouse summary, scenarios 2 and 3 are based on knapsack application and

have been assessed as having negligible risks. EPA needs to clarify if the spray gun

prohibition applies to knapsack sprayers and if so, why they have proposed this

given the negligible risks. Similarly, control R-14 (signage) does not appear to be

justified given the negligible risks. While industry can comply with this control (and in

many cases does already), it should not be specified unless it is managing a risk

which does not appear to be the case.

With regards to outdoor uses, the horticultural industry is supporting use on avocado

and persimmon orchards. The risks of these uses have been assessed as negligible or

low for human health and medium for aquatic and birds. Industry considers that the

benefits outweigh the medium risks to aquatic and birds, especially given the low risk

to human health.

10.15.3. Benefits

Due to the assessed risks of pirimiphos methyl, particularly to aquatic and birds, it is

necessary to consider the benefits of use in the avocado and persimmon industries.

Detailed benefits information is provided in Section 11.2 for avocado and 11.4 for

persimmon. The impact of phasing out the use of pirimiphos methyl in these two

industries would be severe. While unlikely to trigger national benefits, both of these

crops are key contributors to the economies of Gisborne, Bay of Plenty and

Northland. Both are growth industries and will be impacted if pirimiphos methyl is

restricted.


Industry does not agree with the proposed control to phase out use on outdoor

crops and believes that there are sufficient benefits that outweigh the risks of

allowing continued outdoor use.

Notwithstanding the comments provided in section 9 on the controls, industry can

comply with all of the controls proposed, however, industry questions the need for

controls R-7 and R-14 as discussed above.

Industry notes that EPA has not proposed any specific controls for outdoor use due

to the proposed phase out. Subject to the comments provided in section 9, industry

recognises that some controls will be required and suggests the following:

R-3 Application parameters (max rate of 1425 g/hectare and a frequency of

4 times per crop cycle)

R-8 Label OP/Carbamate

Industry understands that as per the EPAs Summary and Analysis for the Arable

sector, use scenarios ‘Arable 40-43’ of pirimiphos methyl via grain conveyor, will

continue as this is regarded as indoor use and critical to the arable sector. It would

be helpful for EPA to include a definition in the interpretation section (page172)

around indoor use to ensure the filling of grain silos via conveyor is recognised as

being permitted under the proposed control R-7).


10.16. Prothiofos

This compound is not supported by the horticulture and arable industries

represented in this submission.

10.17. Terbufos


Terbufos is being supported by horticulture and arable as summarised below:

Crop Pest

Kumara Symphilid, stem weevil, black beetle,

grass grub

Processed Peas/ Beans and Carrots Grass grub

Terbufos is important to the kumara industry for pre-plant control of symphilid, stem

weevil and wireworm. Terbufos is also currently used in the production of processed

peas, beans and carrots to control grass grub however, Diazinon is a suitable

alternative in these crops.

10.17.2. Risks

In assessing the risk in relation to kumara, there is only one use pattern to be

considered, referred to as Kumara 6 in the Kumara Summary. This risk assessment

shows RQ values of:

Risk RQ Qualitative descriptor

Operator with full PPE RPE 16 Medium

Bystanders Negligible

Aquatic Negligible

Birds 11 Medium

Bees Negligible

Other risk quotients were not calculated presumably due to the granular nature of

the product.

It is been assumed that a low risk relates to an RQ >1-10 and a medium risk relates to

RQ values of >10-100. On that basis, the bird risk is only just a medium risk at the

value of 11 (when the cut off is 10). Similarly the risk to operators (with full PPE/PPE) is

16 which is at the low end of medium risk. Industry is unaware of any additional

information that might be available to refine the risk assessment despite making

contact with registrants in New Zealand and specialists internationally.

As a granular formulation that is normally drilled into soil pre-planting, the exposure

to the operator is limited to loading of the product prior to application. The risk to

birds is also reduced as the granules are generally covered by soil, reducing their

availability to birds.

10.17.3. Benefits

Industry is supporting the use of terbufos primarily for kumara as the processed

vegetable industry is able to use diazinon for control of grass grub under the current

EPA proposal. Should the proposal to retain diazinon for at least 10 years change,

then the processed vegetable industries would need to re-evaluate the use of

terbufos.


The main benefit for the kumara industry is the control of symphilid, stem weevil and

wireworm. The product is applied prior to planting of the kumara seedlings and

without it, the roots of the seedlings would be attacked and cause the death of

plants. A detailed benefits case for the continued use of terbufos is provided in

Section 11.12.3 and Appendix 9. It demonstrates that there are no alternatives

currently available and that the loss of the product would result in significant impacts

on the Northland regional economy.


Industry believes that there are sufficient benefits that outweigh the risks of allowing

continued use of terbufos in the production of kumara. Industry notes that EPA has

not proposed any specific controls due to its proposed short phase out. Subject to

the comments provided in section 9, industry recognises that some controls will be

required and suggests the following:

R-3 Application parameters (max rate of 1500g/hectare and a frequency of

once per crop cycle)

R-7 Prohibit handheld application of granules

R-8 Label OP/Carbamate

R-10 PRE/PPE

R-13 Approved Handler


11. Comments by Industry

11.1. Arable

The Arable industry is supporting the following critical use compounds:

Compound Key recommendation Agree / disagree

Chlorpyrifos

Retain approvals with

additional controls Agree

Oxamyl



Pirimicarb



Pirimiphos methyl Retain indoor use Agree

Phorate

Revoke approvals with no

additional controls during

phase out (up to 3 years)

Agree – assume Diazinon is

retained as proposed

Diazinon

Revoke approvals. Apply


phase out (up to 10 years) Disagree

Methamidophos




Notwithstanding the comments provided in section 9 on the controls, the arable

industry generally supports the proposals for the use of chlorpyrifos, pirimicarb,

oxamyl and pirimiphos methyl. The arable industry can work with the phase out of

phorate as long as diazinon is retained until alternatives are available. In this regard,

the arable industry supports the comments made in Section 10.4 (Diazinon) and

Section10.10 (Methamidophos) that a review is necessary two years prior to the

phase out date to ensure alternatives are available before phasing out these two

compounds.

11.2. Avocado

The Avocado industry is supporting the following critical use compounds:


Acephate Retain approvals with


Carbaryl Retain approvals with


Chlorpyrifos Retain approvals with


Malathion/maldison Retain approvals with


Diazinon Phase out up to 10 years Disagree

Pirimiphos methyl

Phase out outdoor uses

(18 month phase out) Disagree


generally supports the proposals for the compounds in use in the avocado industry.

Comments are provided in Section 9 on the impact of the proposed restriction on

droplet size when aerially applied. The avocado industry does not consider that this


control provides the risk management that EPA is seeking and will also compromise

the effectiveness of the applications. The control could lead to greater number of

applications being made and therefore increased risks. The avocado industry does

not support the restriction to two applications per year for diazinon (see Section

10.4). Four applications are necessary to provide adequate thrips control in late

summer and autumn and there are no alternatives that provide the necessary

control and also meet market restrictions. The avocado industry supports the

comments made in Section 10.4 that a review is necessary, two years prior to the

phase out date to ensure alternatives are available before phasing out the use of

diazinon.

Primary benefits of diazinon are that it provides good control of armoured scale and

thrips, both difficult to control pests, as well as leaf roller. There are very few

chemicals available for thrips control, thiacloprid being the chemical of choice.

However, development of pesticide resistance is a possibility in greenhouse thrips

populations and for this reason the industry is keen to retain registration of those

chemicals that have demonstrated efficacy against thrips to prevent overuse of

thiacloprid.

11.2.1. Benefits of pirimiphos methyl to the Avocado Industry

The avocado industry does not support the proposed 18 month phase out for the

outdoor uses of pirimiphos methyl.

Pirimiphos methyl is a widely used pesticide on avocados, cheap and efficacious

with immediate knock down effect. It is particularly useful for combating three of the

key pest groups (leafroller, thrips and scales) in a single application rather than tank

mixes of more expensive alternatives. It is used later in the season than chlorpyrifos

due to residue issues. Losses of between $7m and $19.4m are expected if pirimiphos

methyl is phased out, depending on the future use of chlorpyrifos as an aerial spray.

Appendix 2 provides further information on the benefits of pirimiphos methyl use in

the avocado industry. AIC considers that the benefits of continued use of pirimiphos

methyl outweigh the risks, particularly considering the negligible or low risks to human

health. AIC considers that controls can be implemented to mitigate risks and allow

long term use.

Incursion response

The avocado industry has faced a number of “pest incursions” and has had to

develop assurance programmes at short notice in order to maintain trade. A key

element in this process is the use of chemicals which are supported by referred

publications or other reputable sources to demonstrate efficacy against a particular

pest. This library of available information grows the longer a chemical has been in

use. From a biosecurity risk management perspective, maintaining access to a

range of chemistry that can be used with very short notice is essential to maintaining

access to key markets. Unless a compound is registered and available off the shelf

this can lead to substantive delays in resuming any trade that has been suspended

with a key market. The compounds AIC are supporting control a broad spectrum of

pests and could be useful in an incursion. The avocado sector supports the

continued use of pirimiphos methyl as the product ‘Attack’ is of specific interest as a

potential tool to deal with any incursions. This is due to the broad spectrum of

activity aided by the fact that the product contains two active ingredients, namely

the OP pirimiphos methyl and the synthetic pyrethroid permethrin. As an example


synthetic pyrethroids are showing promise as a line of defence against two new

diseases of avocados in the USA and Israel. The Californian and Israel avocados are

under threat from Tea Shot Hole Borer. This is a disease complex where Fusarium spp.

is vectored by the Tea Shot Hole borer (Euwallacea fornicatus). The disease complex

is spreading through both regions, leading to tree death and is a major threat to the

economic survival of the Israeli industry. In Florida, laurel wilt is threatening the

avocado industry as avocados are a member of the laurel family. The disease is a

complex with a fungal pathogen (Raffaelea lauricola) vectored by the red bay

ambrosia beetle (Xyleborus glabratus). Spread of both the diseases is through

infested wood which raises the possibility of an unintentional introduction to NZ

through contaminated wooden packaging. There is a real risk of these pests and

diseases entering New Zealand and the AIC strongly believes pirimiphos methyl

needs to be retained in commercial use to ensure it is available in the event of an

incursion.

11.3. Citrus

The NZ Citrus Growers Inc (NZCGI) is supporting the following critical use compounds:


Acephate



Malathion/maldison



Pirimicarb



Diazinon Phase out up to 10 years Agree


generally supports the proposals for the compounds in use in the citrus industry. The

citrus industry appreciates EPA’s acknowledgement of benefits case for the use of

acephate and wishes to emphasise the impact on the regional economy if

acephate was phased-out.

11.4. Persimmon

The Persimmon Industry Council is supporting the following critical use compounds:


Chlorpyrifos



Pirimiphos methyl


(18 month phase out) Strongly disagree


generally supports the proposals for the continued use of chlorpyrifos. The industry

notes however that chlorpyrifos is not an alternative for pirimiphos methyl.

11.4.1. Benefits of Pirimiphos methyl to the Persimmon Industry

Pirimiphos methyl is a key insecticide for successful and profitable persimmon

production. EPA has recommended a phase out of all outdoor uses of pirimiphos

methyl in 18 months and PIC strongly opposes this proposal. Due to the benefit that

this compound provides to the persimmon industry, PIC believes that the compound

should remain available for growers without phase out. Information on the benefits


of pirimiphos methyl to the persimmon industry is contained in Appendix 3.

PIC requests that the EPA allows long term use to be retained and suggests that in

addition to controls R-10, R-12 and R-13, the EPA considers requiring controls R-3

(application parameters), R-4 (buffer zones), R-8 (label OP/carbamate) and R-9

(bee warning label).

11.5. Strawberry

The Strawberry industry is supporting the following critical use compounds:


Chlorpyrifos



Pirimicarb




Methomyl


(18 month phase out) Strongly disagree


generally supports the proposals for the continued use of chlorpyrifos and pirimicarb.

The strawberry industry supports the comments made in Section 10.4 regarding

diazinon that a review is necessary two years prior to the phase out date to ensure

alternatives are available before phasing out the use of diazinon.

11.5.1. Benefits of methomyl to the Strawberry Industry

Methomyl is a critical insecticide for successful and profitable strawberry production

(Geoff Langford pers. comm.8). EPA has recommended a phase out of all outdoor

uses of methomyl in 18 months and Strawberry Growers New Zealand (SGNZ) strongly

opposes this proposal. Information on the benefits of methomyl to the strawberry

industry is contained in Appendix 4. Due to the significant benefit that this

compound provides to the strawberry industry and the negligible-low risks it presents,

it is essential that the compound remains available for growers without the need for

phase out.

11.6. Summerfruit

The Summerfruit industry is supporting the following critical use compounds:


Carbaryl



Chlorpyrifos



Pirimicarb




generally supports the proposals for the compounds in use in the summerfruit

industry.

8 Geoff Langford is the Science and Research Advisor to Strawberry Growers NZ and a berryfruit specialist.


11.7. Tamarillo

The Tamarillo industry is supporting the following critical use compounds:



Methamidophos




The tamarillo industry currently relies on both diazinon and methamidophos for

control of the tomato potato psyllid which has devastated tamarillo orchards since

its introduction to NZ. The recovery of the industry relies on the use of these

compounds until new alternatives can be registered for use on tamarillo. The

tamarillo industry supports the comments made in Sections 10.4 and 10.10 that a

review period is necessary to ensure alternatives are available before phasing out

either of these compounds.

Comments on the use of OPCs in the tamarillo industry were provided in the Sector

Assessment process and relevant parts of this submission have been reproduced in

Appendix 5.

11.8. Process Vegetables NZ

The Processed Vegetable industry is supporting the following critical use compounds:


Chlorpyrifos



Oxamyl



Pirimicarb



Phorate






Terbufos






Diazinon




Methamidophos




Fenamiphos



phase out (up to 5 years) Strongly Disagree (carrots)

The process vegetable industry includes crops that are already covered by fresh

vegetable submissions. The key crops covered in this section are peas, beans, and

sweetcorn. Field tomatoes are also grown for processing but are not represented by

Process Vegetables NZ. Potatoes are also a process crop but are covered by the

Potatoes section (11.9).


In general, Process Vegetables NZ supports the proposals for the ongoing use of

chlorpyrifos, oxamyl and pirimicarb. The industry is prepared to accept the

proposals to phase out phorate and terbufos but only if diazinon is retained as

proposed. The industry supports the comments made in Sections 10.4 and 10.10 that

a review period is necessary to ensure alternatives are available before phasing out

Methamidophos and Diazinon. The process carrot industry will be affected by the

proposal to phase out fenamiphos. The comments made in Section 11.12.2 and

Appendix 8 also apply to some degree to process carrots.

11.9. Potatoes NZ

Potatoes NZ is supporting the following critical use compounds:


Chlorpyrifos



Pirimicarb



Methamidophos




Fenamiphos



phase out (up to 5 years) Strongly Disagree

The potato industry can support the proposals for the ongoing use of Chlorpyrifos

and pirimicarb. The potato industry supports the comments made in Section 10.10

that a review period at 3 years is necessary to ensure alternatives are available

before phasing out Methamidophos. However, the potato industry will be seriously

impacted by the proposal to phase out fenamiphos within 5 years. The risks of the

compound are discussed in section 10.7.2 and information on the benefits to the

industry is presented below.

11.9.1. Benefits of Fenamiphos and Methamidophos to the Potato Industry

Fenamiphos and methamidophos are critical insecticides for successful and

profitable potato production (Dr Stephen Ogden pers. comm.9). EPA has

recommended a 5 year phase out for fenamiphos and methamidophos. Due to the

significant benefit that these compounds provide to the potato industry, it is essential

that these two compounds are retained until alternatives are found. Information on

the benefits of these two compounds to the potato industry is contained in

Appendix 7.

11.10. Onions NZ

Onions NZ is supporting the following critical use compounds:


Chlorpyrifos



Methamidophos


additional controls during Agree

9 Dr Stephen Ogden is the Potatoes NZ Psyllid coordinator and has been involved in the NZ Potato industry for 18

years



Notwithstanding the comments provided in Section 9 on the controls, industry

generally supports the proposals for the compounds in use in the onion industry.

11.11. Tomatoes NZ

Tomatoes NZ is supporting the following critical use compounds:


Oxamyl



Methomyl

Retain indoor uses with

additional controls.

Agree

Pirimiphos methyl Retain indoor use Agree

Notwithstanding the comments provided in section 9 on the controls, and sections

10.11 and 10.15 (in relation to control R-7), industry generally supports the proposals

for the compounds in use in the greenhouse tomato industry. Tomatoes NZ does not

support the control requiring automatic application methods in greenhouses. This

type of technology is largely unavailable in greenhouse crops and will prevent the

use of the compounds. As per comments in section 9.7.4, industry requests that EPA

reconsider the need for controls and apply alternative measures to manage the risk

if necessary.

11.12. Vegetables NZ

Vegetables NZ are supporting the following critical use compounds:


Acephate Retain approvals with

additional controls

Agree

Chlorpyrifos Retain approvals with

additional controls

Agree

Malathion/maldison Retain approvals with

additional controls

Agree

Oxamyl Retain approvals with

additional controls

Agree

Pirimicarb Retain approvals with

additional controls

Agree

Pirimiphos methyl Phase out outdoor uses

(18 month phase out)

Agree

Phorate Revoke approvals with no



Agree – assuming Diazinon

is retained as proposed

Methomyl Phase out outdoor uses

(18 month phase out)

Agree – assuming

Chlorpyrifos and

acephate are retained as

proposed

Diazinon Revoke approvals. Apply



Disagree

Methamidophos Revoke approvals. Apply


Disagree



Terbufos Revoke approvals with no



Strongly disagree –

Kumara

Fenamiphos Revoke approvals. Apply



Strongly Disagree

Vegetables NZ represents a wide range of vegetable crops but in terms of the

proposed controls for OPCs, the key industry groups that are impacted are:

Celery

Carrots and parsnips

Kumara

11.12.1. Celery

Subject to the comments provided in Section 9, the celery industry can support the

proposals for chlorpyrifos and pirimicarb. The proposal to phase out phorate is less

than ideal, but the industry is prepared to accept this given the proposal to retain

diazinon for 10 years. The celery industry supports the comments made in Section

10.4 that a review period at 8 years is necessary to ensure alternatives are available

before phasing out diazinon.

11.12.2. Carrot/Parsnip Industry

Subject to the comments provided in Section 9, the carrot and parsnip industries can

support the majority of proposals for the ongoing use of OPCs. The proposals to

phase out phorate and terbufos can be accepted as long as diazinon is retained for

at least 10 years. The carrot industry supports the comments made in Section 10.4

that a review period at 8 years is necessary to ensure alternatives are available

before phasing out Diazinon. However, the carrot and parsnip industry will be

seriously impacted by the proposal to phase out fenamiphos within 5 years.

Fenamiphos is the single most important insecticide for successful and profitable

carrot and parsnip production (Monty Spencer pers. comm.10). As pointed out in the

sector assessment feedback, the alternative to not having fenamiphos available to

carrot and parsnip producers is to not produce these crops, and instead import

them. Details on the benefits of fenamiphos to carrots and parsnips are presented in

Appendix 8.

Industry requests that they be allowed continued use of fenamiphos until alternatives

are found and registered for use in carrot and parsnip. It is recognised that an open-

ended timeframe is difficult for EPA, and therefore requests that for fenamiphos the

initial phase out period is extended to 10 years. The carrot and parsnip industry also

requests that 2 years before the phase out period ends a review is carried out to

determine if alternatives are available. If appropriate alternatives are not available

and the industry can demonstrate that work has been done to identify alternatives,

industry requests that the phase out is extended for a further 5 years. This will provide

growers and other people reliant on carrot and parsnip production some certainty

beyond the next few seasons of production.

10 Monty Spencer is an Agronomist for Wilcox and is based in Pukekohe. Wilcox is a 2,500 acre vegetable producing

company. http://www.aswilcox.co.nz/about/index.shtml

http://www.aswilcox.co.nz/about/index.shtml


11.12.3. Kumara Industry

Subject to the comments provided in Section 9, the kumara industry can support the

proposals for chlorpyrifos and maldison. The kumara industry supports to comments

made in Section 10.4 (diazinon) and Section 10.10 (methamidophos) that a review

period at is necessary to ensure alternatives are available before phasing out these

two compounds. The proposals to phase out phorate can be accepted as long as

diazinon is retained for at least 10 years. However, the kumara industry will be

seriously impacted by the proposal to phase out terbufos within 3 years.

Methamidophos and terbufos (in light soils) are critical insecticides for successful and

profitable kumara production (Andre de Bruin pers. comm.11) and the industry is

unable to accept the proposed phase out period for these two compounds.

Information on the benefits of terbufos and methamidophos is presented in

Appendix 9.

The industry requests that they be allowed continued use of methamidophos and

terbufos until alternatives are found and registered for use in kumara. It is recognised

that an open-ended timeframe is difficult for EPA, and therefore requests that the

initial phase out timeframe for terbufos be increased to 5 years. For both

methamidophos and terbufos, the kumara industry requests that 2 years before the

phase out period ends a review is carried out to determine if alternatives are

available. If appropriate alternatives are not available and the industry can

demonstrate that work has been done to identify alternatives, industry requests that

the phase out is extended for a further 5 years. This will provide growers and other

people reliant on kumara production some certainty beyond the next few seasons

11.13. Home Garden Use

Industry agrees that use in domestic situations use by the untrained public poses a

far greater risk to the applicator, the environment and bystanders than the use in

commercial circumstances where growers have to meet minimum safety

requirements. Therefore industry agrees with EPA’s comments in the second

paragraph, in section 10.18 (page 97) around operator training and agrees that

these compounds should be removed from general public retail sale.

Industry disagrees with the comments made in section 10.18 of the EPA document

(page 98) that the control requiring a person to be an approved handler will ensure

only trained agrichemical handlers will apply these OPC products in a domestic

setting. Approved handler certification has very little training and renewal requires

minimal re-training and there is no unit standard as a basis for the training. As per

section 9.13 in this submission, industry notes that holding an approved handler

certificate does not necessarily mean that the operator has appropriate knowledge

and training to use OPCs correctly. Approved handler certification is required only

for the supervisor, and may not necessarily be held by the actual operator applying

the compound. Industry supports the GROWSAFE® programme as a means of

ensuring operators (regardless if the setting is commercial or domestic) are

adequately trained.

Regardless, industry does not consider that the use of OPCs in a domestic

environment has sufficient benefit to outweigh the risks.

11 Andre de Bruin is the Chairman of the root & tuber crops advisory group of Vegetables NZ, a product group under

the umbrella of Horticulture NZ and a Kumara grower in the Kaipara region. He is also chairman of the Northern

Wairoa vegetables growers association.


11.14. Biosecurity

Stocks of OPCs are needed in the event of an incursion for all of the industries

represented in this submission for control of a range of possible pests. While the GIA

process has meant some industries have identified high impact pests not currently

present in New Zealand, the work to identify specific pest control activities has not

yet been undertaken. However, the broad spectrum pest control activity of OPCs

and their known activity against pests overseas means New Zealand must retain

stocks of these compounds as insurance against an incursion.

It is acknowledged that EPA has made a provision in the form of control R- 16 that

allows an OPC to be used at a higher rate by an authorised person (with the

relevant appointment under the Biosecurity Act) to eradicate a new pest incursion

during the response phase. Industry appreciates this, except this assumes that there

is sufficient availability and volume of a particular OPC to achieve an attempt at

eradication.

Once the response phase is stood down (e.g. due to failure to contain the pest) it

will be left to growers to manage the pest. A recent example of this is the arrival of

tomato/potato psyllid, where it was not eradicated, and it is now up to the growers

to manage. Having access to a number of broad spectrum insecticides will enable

growers to manage new pest incursions until more targeted approaches can be

developed. Therefore it is extremely important that these critical use OPCs are

retained for this possibility.

Industry agrees with EPAs last bullet point in section 6.1 (page 27) around the generic

benefits of these OPCs for biosecurity purposes. A few of the many examples of

pests that may be introduced into New Zealand and cause the continued

production of that crop to be at risk include:

Fruit fly across a very wide range of crops (controlled with malathion,

dimethoate, dichlorvos, fenthion)

Sweet potato weevil in kumara

Brown marmorated stink bug across a range of crops

Cereals - Bruchid beetles, ~ 20 different nematode species, aphids, midges,

mites, and stem borers that are not currently present in New Zealand. A

systemic OP (e.g. methamidophos) would be required for root dwelling pests

or at least with a diazinon/ chlorpyrifos granule into the soil. The above

ground pests would likely be controlled by a systemic or contact/fumigant

OP.

Maize and sweetcorn Corn rootworm (Diabrotica virgifera), Western Bean

Cutworm (Richia albicosta) and 2 thrips species – Frankliniella fusca, and F.

ewarti.

Asian citrus psyllid – devastating pest of citrus throughout the world, most

recently spread to California. Control options recommended include

chlorpyrifos, dimethoate and carbaryl12

Tea Shot Hole borer, red bay ambrosia beetle – avocado pests that are

controlled by pirimiphos methyl as described in Section 11.2.1

If any of these pests were to arrive in New Zealand and were unable to be

controlled due to a lack of available broad-spectrum insecticides, the success of an

eradication programme would be jeopardised.

12 http://www.ipm.ucdavis.edu/EXOTIC/diaphorinacitri.html


Appendix 1: Project Brief for SFF grass grub research project

Project Brief

Project Title: Managing the number one soil borne pest in cropping Grantee: Foundation for Arable Research (FAR) Grant Number: 12-013 Contact Person: Richard Chynoweth Address: P.O. Box 23133, Templeton, Christchurch 8445 Telephone: 03 345 5783 Facsimile: 03 341 7061 Email: [email protected] Related website links: Other links Project description (What is your project about?) This project aims to reduce the reliance of NZ’s cropping industry on organophosphate insecticides to control grass grub (Costelytra zealandica) by developing an integrated management approach and providing knowledge to farmers to enable adoption. We will investigate five exciting new management approaches: biological control, companion planting (catch crops), population dynamics, mating disruption and crop sensing. Organophosphate (OPs) insecticides currently form the basis of grass grub control options in New Zealand. EPA (previously ERMA) is reviewing organophosphates in the New Zealand market. This may result in removal of organophosphates, producing an urgent need to identify and establish alternative grass grub control options. The issue/opportunity (Briefly outline the issue/ opportunity the project seeks to address and the project objectives) The removal of organophosphate insecticides from the market, especially diazinon used for grass grub control, is a major risk for the seed and cereal farmers, unless alternative controls can be found. Even if these products are not removed there are environmental benefits to New Zealand agriculture if the usage of OPs can be significantly reduced. In pasture, moderate grass grub populations (e.g. 100-200/m2) can be sustained with little loss in productivity. However, grass grub significantly reduce the productivity and profitability of arable crops throughout New Zealand, as even low populations cause plant loss during winter by feeding on the root system when plant growth rates are slow. The establishment of healthy seedlings is critical to the success of crops and therefore the sustainability of the farming business. As few as 20 grubs/m2 can cause yield losses of over 10% or even crop failure in establishing crops. Row crops, such as carrots for seed production, are high risk because low plant populations (e.g. 80 plants/m2) require protection during establishment, where loss of just a few plants/m2 can result in significant productivity losses. The context/background (Why is this project important?) The cost of crop failure ranges from $4,000 up to $15,000/ha depending on crop species,


while low numbers of grubs can cost up to $400/ha in grass and cereal crops. Current control, particularly during establishment, relies heavily on OPs, which are subject to review and possible deregulation by the EPA. Approximately 80,000 ha are treated annually (costing approximately $11.2 million per annum) in crops where a 10% yield loss would cost approximately $32 million farm gate return. At risk crops include autumn-planted cereal and vegetable crops, ryegrass, brassica, clover and other seed crops that contribute up to $600 million of farm gate return. Without a range of effective options for grass grub control crops will fail, particularly autumn-planted crops. It is critical that alternative control options are developed and current and new knowledge transferred if grass grub is to be effectively managed in cropping systems. This project takes the opportunity to prepare for the removal of OPs by determining which cultural, biological and alternative chemical controls should be combined to best control grass grub in cropping systems. Methods (what do you propose to do?) This project will examine methods of reducing grass grub populations under cropping rotations through targeted management with the aim of minimising pesticide input. The project will consist of two components: (i) small plot experimental work and (ii) large scale, half paddock comparisons.

Year One: Identifying potential control options to reduce chemical inputs and investigating promising management options. This will be undertaken on a small plot scale to expand from previous pot trials that have shown the potential of seed treatment with biologicals and will include: the use of biological control agents (Serratia entomophila or Yersinia entomophaga) either as a seed treatment (this technology has not been tested under field conditions) or drilled as a granule with the seed; non-organophosphate seed treatments; the use of close by and inter-sown species as ‘catch crops technology’ (some containing endophytes that may have grass grub activity); and the use of currently available insecticides for comparison. This trial will be undertaken at two sites in cereal crops following at least one year (preferably two) of white clover, a high risk crop rotation position for grass grub damage. These trials will provide data to identify options that can be further developed to reduce pesticide input and examine the cost benefit of controlling grass grub in arable farming.

We will investigate the use of crop sensors for determining areas within paddocks that have grass grub present. GPS technology could be used to apply OP insecticides only where required, thereby significantly reducing the amount of active ingredient applied. The greenseeker™ has the ability to differentiate crop cover up until row closure, and therefore may be an ideal tool for identifying areas that are under attack from grass grub.

At the end of Year One we will have developed an understanding of cultural control methods, how grass grub perform under different crops and the potential to disrupt the mating flights, and we will have collected one year of data on reducing the impacts though catch crops and biological control.

Year Two: Understanding seasonal and multi-year effects to better understand and refine control recommendations. Trials will continue in year two at two sites where we will monitor grub numbers in the trial area for carryover effects. In year two, a field day will be held to demonstrate trials and discuss the findings from year one. In year two additional case study/focus paddocks will be set up in three locations, two in Canterbury and one in Southland. These will consist of half paddock demonstrations, featuring grower standard practice and incorporating the most promising practices identified in year one. The treatments imposed will reflect the results from year one and the farming philosophy of the host farmer. For example this could include the use of seed treatment and/or a biological control agent versus standard grower practice or, example two, the use of a catch crop such as endophyte containing ryegrass sown with white clover versus white clover monoculture.


Year Three: Communicating recommendations to encourage uptake and gathering a third season of data from research to validate findings. The demonstration paddocks will continue at the same sites with grass grub numbers monitored under both systems. A grower field day will be held at each site in the spring. At the end of year three we will have produced and demonstrated various tools to form a strategy that, when combined with local grower knowledge, will lead to the reduced usage of broad spectrum insecticides for grass grub control.

FAR will continue the paddock comparisons in years four and five to monitor long term trends and deliver the outcomes to ensure grower uptake.

This project incorporates a wide range of possible technologies. We see the biological seed coating as a realistic outcome in three years, the ‘catch crop technology’ as a useful tool in approximately three years while the disruption of mating requires a detailed understanding of grass grub phenology which may extend beyond the three year timeframe.


Appendix 2: Benefits case – Avocado

1. Background

The avocado industry is currently using a number of OPCs including acephate,

carbaryl, chlorpyrifos, malathion, diazinon and pirimiphos methyl.

Subject to the comments in this submission regarding proposed controls (particularly

aerial application restrictions) the Avocado Industry Council (AIC) supports the EPA

proposals for acephate, carbaryl, chlorpyrifos and malathion. Subject to the

comments on aerial application and proposed phase out period, AIC can also

support the proposed controls for diazinon.

Pirimiphos methyl is an important insecticide for successful and profitable avocado

production (Dr Henry Pak pers. comm. 13) and the industry is unable to accept the

proposed phase out for this compound.

EPA has recommended a phase out of all outdoor uses of methomyl in 18 months

and AIC opposes this proposal. Due to the benefit that this compound provides to

the avocado industry AIC believes that the compound should remain available for

growers without phase out.

2. Industry profile

There are approximately 1,600 avocado growers in New Zealand producing over

~34,000 tonnes of fruit from 4,200 ha. The main growing regions are Bay of Plenty

(73%) and the mid and far north (24%). The value of the domestic market was

assessed at $19.2m in 2011. In the same year, approximately 77% of the total volume

was exported with a value of $62.8m14 . In 2012, the export value increased to $97m.

The avocado industry is growing and is a key contributor to regional economies in

the Bay of Plenty and Northland.

The Avocado industry utilises the AvoGreen® to manage chemical use. AvoGreen®

aims to increase the profitability and improve the sustainability of avocado growers

by ensuring better control decisions and by focusing on the market desire for safe

and healthy fruit grown with minimal impact on the environment and the

community. AvoGreen® uses the principles of Integrated Pest Management (IPM) to

ensure pesticides are used only when needed. The export industry has totally

adopted the AvoGreen programme, with the 2011-12 harvest the first crop entirely

grown using the AvoGreen® programme15.

3. Avocado production

There are four main pests or pest groups in Avocado; leafroller (LRs), greenhouse

thrips (GHT) & 6-spotted mite (6SM) and armoured scale (AS). Growers monitor for

each pest to justify all spray applications with scale control determined either by

previous harvest results or by direct monitoring.

The harvest period is extended with up to three picks or more from August to May.

Flowering generally occurs while mature fruit are still present on the trees. This, and

13 Dr Henry Pak is the Technical Manager for the Avocado Industry Council

14 New Zealand Horticulture – barriers to our export trade, 2012

15 Avocado Industry Council website (http://www.nzavocado.co.nz/) (Annual reports; Insect biology)


the long period of flowering (October to December), both present issues for

spraying, e.g. the choice of sprays can be severely limited by the imminent harvest,

while sprays to protect the fruit from rot may also harm pollinating insects.

Pirimiphos methyl is used in a product combined with permethrin known as Attack. It

is a widely used pesticide on avocados, cheap and efficacious with immediate

knock down effect. It is particularly useful for combating three of the key pest groups

(leafroller, thrips and scales) in a single application rather than tank mixes of more

expensive alternatives.

Extensive commentary on insecticide use in the avocado industry was provided in

the Sector Assessment response in May 2012.

4. Benefits

AIC estimates that if pirimiphos methyl was phased out losses would be felt due to 4

contributing factors:

Direct loss of product by damage decreasing both total production and

exportable quality.

Increased quarantine clearance failure rates adding to cost of handling and to

the amount of fruit lost.

Avocado growing becoming unprofitable and growers exiting from the sector.

Increased difficulties managing pests with all market access due to loss of

chemicals with established MRLs in key markets, whereas newer chemistry

generally lacks MRL’s.

The first two points would also impact as well on local market returns as greater

reject rates push more fruit onto the local market and drive down returns.

Loss of pirimiphos methyl (assuming retention of chlorpyrifos) would result in an

estimated loss of 8% ($7m), due principally to the conflict of theneed to export to

more markets clashing with the long PHI of chlorpyrifos giving rise to greater quality

losses. However, EPA has proposed a restriction on droplet size for aerial applications

of chlorpyrifos which if retained, will restrict its usefulness to avocado production (See

section 9.6.2). Chlorpyrifos also carries strong negative perceptions for some

consumer groups and has been ranked as the pesticide most likely to become

banned by supermarkets, and so has poorer prospects in the 3 – 8 year time frame.

AIC estimates that if chlorpyrifos is unable to be used and pirimiphos methyl was

phased out as proposed, an estimated overall loss of export earnings of 20% after 3

years could be expected. This equates to $16.4m annually based on the 2011 total

estimated industry value of $82m.

There are approximately 1,600 avocado growers based on the regions of Bay of

Plenty and Northland. An additional 1000 people are estimated to be employed on

orchard and a further 800 in packhouses and contracting businesses. The avocado

industry is therefore an important contributor to regional employment and regional

economies in the Bay of Plenty and Northland. The Bay of Plenty in particular has

been severely affected by the impact of PSA on kiwifruit and further impacts on the

horticultural industry would be noticeable.

The EPA has assessed the benefits of pirimiphos methyl use in avocado to be low.

Given the regional impacts, industry believes this should be re-evaluated and set at


medium benefit.

5. Alternatives

There are some alternatives to pirimiphos methyl available but the situation is

complex. Table 1 shows compounds available for use on avocados in New Zealand

showing the pests listed in the label claim for avocados (normal font) and also pests

against which activity is probable (in italics) as the same or a closely similar pest is

listed as controlled on other crops. Red highlights show OPs/carbamates scheduled

to be phased out or where controls may limit use and yellow highlights

OPs/carbamates scheduled to be retained.

Table 1: Pest control options for key pests of avocado

Principal Pests of avocados

Leafrollers

LRs

Greenhouse Thrips

GHT

6-Spotted Mite

6SM

Armoured Scales

AS

abamectin * abamectin

acephate acephate

Bt

carbaryl carbaryl carbaryl

chlorantraniprole

chlorpyrifos chlorpyrifos chlorpyrifos chlorpyrifos

diazinon diazinon diazinon

emamectin

etoxazole

maldison

milbemectin

oil, mineral oil, mineral oil, mineral

Attack

(P. methyl)

Attack

(P. methyl)

Attack

(P. methyl)

pyrethrum

silicon dioxide1 silicon dioxide1 silicon dioxide1 silicon dioxide1

spinosad

taufluvalinate taufluvalinate

**

tebufenozide

methoxyfenozide

thiacloprid thiacloprid ** * rate varies with pest, * = lower (** =higher) than for avocado label claim 1 silicon dioxide label claims may not have been substantiated, and list “scales” not ‘AS’

Red highlights show OPs/carbamates scheduled to be phased out or where controls may limit use

Yellow highlights OPs/carbamates scheduled to be retained.

The major use of pirimiphos methyl is where both leaf roller and GHT are present,

particularly late season when pressure from GHT is increasing. The alternative is to

use a tank mix of two separate chemicals with specificity for the target pests. Cost is

the key reason for use of Attack over the tank mix as in general terms pest specific

products tend to be more expensive. As an example a single application of Attack

for control of leaf roller and GHT costs $89/ha whereas the use of pest specific

chemistry (Calypso for GHT at $107/ha and Proclaim for leafroller at $167/ha) gives a


total of $274/ha. This adds up with repeated applications and while the figures seem

small this must be viewed in the context of the average OGR of $8,679/ha.

Another key consideration is a pesticide resistance management strategy to prevent

overuse of any one chemical group for the control of GHT. In this context both

pirimiphos methyl and diazinon reduce reliance on use of thiacloprid for GHT control,

especially when leafroller is also present.

6. Risks

The risks of pirimiphos methyl use have been assessed by the EPA as negligible or low

for human health and medium for aquatic organisms and birds. The risk of aquatic

organisms can be managed through buffer zones. Use of ultra-low volume (ULV)

applications technology will also mitigate any potential for contamination of

aquatic organisms by reducing runoff. Since being released to the industry in 2008,

ULV now accounts for 16% of pesticide applications to avocado compared with 70%

for high volume applications and 15% by helicopter. Note however that the

minimum droplet size control proposed for some OP’s will act as a disincentive to

uptake of ULV.

7. Conclusions

Pirimiphos methyl is a widely used pesticide on avocados, cheap and efficacious

with immediate knock down effect. It is particularly useful for combating three of the

key pest groups (leafroller, thrips and scales) in a single application rather than tank

mixes of more expensive alternatives. It is used later in the season than chlorpyrifos

due to residue issues. Losses of between $7m and $19.4m are expected if pirimiphos

methyl is phased out, depending on the future use of chlorpyrifos as an aerial spray.

Avocado production is key part of the regional economy in the BOP and Northland.

It is a growth industry that contributes $97m to the NZ economy from exported fruit

sales and is a significant employer in these regions.

AIC considers that the benefits of continued use of pirimiphos methyl outweigh the

risks, particularly considering the negligible or low risks to human health. AIC

considers that controls can be implemented to mitigate risks and allow long term

use.

8. Phase out period

AIC strongly opposes the 18 month phase out on outdoor uses proposed by the EPA.

AIC requests that the EPA allows long term use to be retained and suggests that in





Appendix 3: Benefits case – Persimmon

1. Background

The persimmon industry is currently using the OP’s chlorpyrifos, pirimiphos methyl and

dichlorvos.

Subject to the comments in this submission regarding proposed controls, the

Persimmon Industry Council (PIC) supports the EPA proposal for retention of

chlorpyrifos. PIC also supports the retention of dichlorvos which is an

organophosphate but is not being considered in this reassessment.

Pirimiphos methyl is a key insecticide for successful and profitable persimmon

production. EPA has recommended a phase out of all outdoor uses of pirimiphos

methyl in 18 months and PIC strongly opposes this proposal. Due to the benefit that

this compound provides to the persimmon industry, PIC believes that the compound

should remain available for growers without phase out.

2. Industry profile

There are approximately 50 persimmon growers in New Zealand are producing

~2,250 tonnes of fruit from 250 ha. The main growing regions are Gisborne (47%),

Northland, North Auckland (20% each) and they are also grown in South Auckland

and Waikato. The value of the domestic market was assessed at $4m in 2011. In the

same year, approximately 64% of the total volume was exported with a value of

$6.8m in 201116, giving a total industry value of $10.7m. In 2012, the export value

increased to $7m. The persimmon industry is growing and is an important contributor

to regional economies. Persimmons are a potential alternative for kiwifruit growers

affected by PSA and planted areas are estimated to increase.

3. Persimmon production

The PIC IPM Manual called the “Green and Gold Manual” was developed in 2001.

The manual was produced in response to historical ‘calendar’ spraying and

recognition by the industry that this approach was not sustainable. IPM involves the

use of a range of approaches to manage pests to prevent economic losses as

opposed to relying solely upon chemicals. The manual contains:

Techniques to monitor pests to determine when control measures are

required

Information on the life history and biology of pests

Pests include those that:

Affect crops directly by damaging fruit

Affect crop indirectly by weakening trees and reducing yields

Contaminate fruit resulting in export certification failure

In addition to information on how to recognise pests and determine action

thresholds, information on possible chemical and cultural (non chemical) control

options is provided. Alongside the manual, a crop protection programme is issued

that contains information on compliance with importing country requirements for

chemical residues.

16 New Zealand Horticulture – barriers to our export trade, 2012


There are four key pests of concern to persimmon growers:

mealybugs

scales

leafollers

thrips

Pirimiphos methyl is used in a mix with permethrin in a product called Attack. The

crop protection programme records efficacy against mealybug, leafroller, scale

and thrips. It is used mostly mid season because it is not accepted by all export

markets and residues in fruit can be a problem for exported fruit. While it is registered

for use in New Zealand and has a 7 day PHI, for some export countries, the PHI is 70

days. Most large persimmon growers in New Zealand will be targeting export markets

for their main crop. Pirimiphos methyl is used in the programme after chlorpyrifos

(which as very long pre harvest intervals of 100 days).

Thrips are a key pest issue and can cause damage throughout the growing season.

Damage can be up to 70% in years of high pest pressure (such as particularly wet

and humid summers). Thrips eat the skin and cause marking or scars on the fruit. Any

marking on the fruit will downgrade it so that it cannot be sold on the local or export

fresh market. There is no value in downgraded fruit and there is no process market

for persimmon.

The presence of the calyx in persimmon is a major issue. It is a prime hiding spot for

leafroller, various mites, spiders and woodlice and is difficult to cover with a spray

plume. Harvest occurs in May and persimmon trees defoliate prior to the completion

of harvest. The calyx becomes a convenient over wintering site for mealy bug,

spiders and other passenger insects. Pirimiphos methyl provides control of all the key

pest groups leading into harvest and then dichlorvos is used close to harvest to

eradicate any remaining pests which would cause phytosanitary failures for export

crops. The broad spectrum nature of pirimiphos methyl is key in controlling

passenger pests such as spiders which can cause export consignments to be

rejected.

4. Benefits

The benefits of using pirimiphos methyl are twofold – control of phytosanitary pests

and control of pests that cause damage to the fruit. Damage from thrips is known to

cause up to 70% rejection of fruit. Without pirimiphos methyl, this damage could

occur mid-season between the control periods of chlorpyrifos and dichlorvos. In a

worst case scenario, damage could cost the industry $7.5m. The export market is

worth $7m annually and is reliant on control of hitchhiker pests. The key issue with

persimmons is that to gain access to key profitable markets (Australia, Thailand,

Japan, and in the future China and USA) a very high level of pest control is required.

The AQIS standards for Australia are hard to meet and single finds may result in the

rejection of a block of fruit (20,000 trays or 150 pallets). “Stealthy spider” has been a

regular cause of rejection by AQIS. Persimmons failing access to these key markets

are sent to the domestic market or lower value export markets – Malaysia,

Singapore. This leads to a reduction in price estimated to be at least 20% (Brian

Pepper, pers. comm.)17 and if the secondary markets are over supplied further price

reductions occur.

17 Brian Pepper, Product Manager, First Fresh (NZ) Ltd www.firstfresh.co.nz

http://www.firstfresh.co.nz/


Without pirimiphos methyl, other options would need to be found and growers

would need to rely on a late season application of dichlorvos for complete clean-

up. This is also in doubt as dichlorvos is an OP that will be reassessed in the near

future. Indications from early work by EPA suggest that dichlorvos could also be at

risk of phase out. Losing pirimiphos methyl now, and dichlorvos in the near future

would leave the persimmon industry with no control options for phytosanitary pests.

5. Alternatives

Pirimiphos methyl and chlorpyrifos are the only compounds with efficacy against all

four of the key pest groups but chlorpyrifos is not registered for use on persimmon.

Buprofezin is the only non OPC compound registered for use on persimmon and

controls only mealybug and scale. Buprofezin is used in only early in the season due

to its long pre-harvest interval period for off-shore markets.

When alternatives do become available they will likely only be effective on a single

life stage which means that multiple applications of the same or different products

are required when a single application of pirimiphos methyl or chlorpyrifos would

suffice. These alternative compounds are unlikely to control hitchhiker pests such as

spiders because they are designed to specifically target pest species. Some

alternatives (such as fipronil and success) are also toxic to bees and growers do not

use these products because of this.

The Sapere report states that ”Technical advice indicates that there are alternatives

for all the pests identified but cost and efficacy concerns are likely to be primary

drivers behind the use of organophosphates and carbamates.” PIC contends that

efficacy of alternatives is the main concern. More information on the alternatives

that the Sapere report refers to is necessary to make further comment. PIC reminds

the EPA that non-registered compounds should not be considered alternatives. In

addition, compounds must have MRLs set in export markets to be considered as

alternatives and PIC is unaware of alternatives that meet this criteria.

6. Risks

The risks of pirimiphos methyl use have been assessed by the EPA as negligible or low

for human health and medium for aquatic organisms and birds. The risk of aquatic

organisms can be managed through buffer zones.

7. Conclusions

Pirimiphos methyl is a widely used pesticide on persimmons. It is particularly useful for

combating all four of the key pest groups (mealybug, leafroller, thrips and scales)

plus contaminant pests in a single application. Without pirimiphos methyl, the

industry faces losses on both the domestic and export markets.

PIC considers that the benefits of continued use of pirimiphos methyl outweigh the

risks, particularly considering the negligible or low risks to human health. PIC

considers that controls can be implemented to mitigate risks and allow long term

use.

8. Phase out period

PIC strongly opposes the 18 month phase out on outdoor uses proposed by the EPA.

PIC requests that the EPA allows long term use to be retained and suggests that in


Appendix 4: Benefits case – Strawberry

1. Background

The strawberry industry is currently using a number of OPCs including chlorpyrifos,

pirimicarb, diazinon and methomyl.

Subject to the comments in this submission regarding proposed controls, Strawberry

Growers NZ (SGNZ) supports the EPA proposals for chlorpyrifos and pirimicarb.

Subject to the comments on phase out of diazinon, SGNZ can also support the

proposed controls for diazinon.

Methomyl is a critical insecticide for successful and profitable strawberry production

(Geoff Langford pers. comm.18) and the industry is unable to accept the proposed

phase out for this compound.

EPA has recommended a phase out of all outdoor uses of methomyl in 18 months

and SGNZ strongly opposes this proposal. Due to the significant benefit that this

compound provides to the strawberry industry and the negligible-low risks it presents,

it is essential that the compound remains available for growers without the need for

phase out.

2. Industry profile

There are approximately 110 strawberry growers in New Zealand producing over

8,000 tonnes of fruit from 246 ha. Using an average value of $6/kg return to the

grower, the industry is worth $48m. The main growing region is Auckland with other

production areas in Waikato, Hawkes Bay, Horowhenua and Canterbury.

Approximately 6% of the total volume is exported with a value of $4.8m in 201219.

After several years of low export volumes, the industry is again growing and

estimated to continue growing and increase its exported fruit volumes. Adequate

pest control is critical to ensure importing country phytosanitary standards are met.

3. Strawberry production

Strawberries are a summer crop and are extremely sensitive to the affects of

weather and pests. The crop has a short shelf life and picking takes place multiple

times over the same crop to harvest berries when they are ripe. Plants are

constantly flowering and fruiting over the period from September to May depending

on region and weather. Strawberry harvest requires a lot of short term labour,

estimated at 15 people per hectare. Over the national crop, this equates to

employment figures of 3,690 and while the majority of this is seasonal, it provides

important and consistent employment each year to regions where strawberries are

grown. In addition to harvest, it is estimated that a further 1,000 people are

employed in activities during the season including planting, cleaning, straw laying

and weeding.

Methomyl is a key pest control product for strawberries as it is the only product

available that can control the range of pests found in strawberries and that can be

used during the harvest season where plants are continually flowering and fruiting.

18 Geoff Langford is the Science and Research Advisor to Strawberry Growers NZ and a berryfruit specialist. 19 New Zealand Horticulture – barriers to our export trade, 2012


4. Benefits

Methomyl provides control for a wide range of pests in strawberries (G. Langford,

pers. com.):

Aphids and leafhoppers – the pests weaken the plant through direct feeding and

also spread diseases caused by viruses and phytoplasmas which further attack

the plant. It is estimated that yield losses of 20% are likely if these pests are not

controlled, which equates to 1,600t or $9.6m in value to the grower (based on

$6/kg).

Leafrollers and chewing insects – these pests infest the fruit, with their feeding

damage resulting in fruit that cannot be sold, or in rejected export consignments.

Saleable yield losses of 5% are estimated but when combined with lost export

earnings, total impact is estimated at $3.2m annually.

Other insects – the main impact from other insects will be on export crops where

the presence of quarantine pests triggers fumigation with methyl bromide or

rejection of the crop.

Fumigation of export crops is used as a last resort. The costs associated with

fumigation usually render the shipment uneconomic and the fumigation has an

extreme effect on fruit quality. Fruit that has been fumigated has a very short shelf

life and if not sold very quickly in the import country, will rot before sale resulting in

lost revenue to the grower and exporter.

If export crops are infested with insects but are not fumigated, they will not be able

to be exported and instead will need to be sold on the domestic market. If the loss

of methomyl resulted in no fruit being exported, the overall impact of that fruit

appearing on the domestic market would be severe on local market prices. It is

expected that a 10% drop in local prices would occur because of the extra volume

sold on the local market. The long term impact of this would probably be a

reduction in the size of the strawberry industry of ~20% (G. Langford pers. comm.).

This equates to a direct economic loss to regional New Zealand of an estimated

$12.8m.

Based on average labour usage at harvest on strawberry farms of 15 people per

hectare, a 20% reduction in strawberry production would also have a direct loss of

over 700 jobs with more people affected in associated services industries. These jobs

would be lost from rural communities. Further job losses from activities that are

undertaken earlier in the season are also likely if production decreases.

The strawberry industry disputes the EPA assessment that the benefit from the use of

methomyl is low. The cumulative effect from lack of insect control and loss of

production from oversupply equates to $25.6m. While this is a crude calculation, it

indicates that the EPA assessment is undervaluing the benefits to the strawberry

industry.

5. Alternatives

At present there are no known alternatives to methomyl that can control the range

of pests necessary during the flowering and fruiting season in strawberries where a

short pre-harvest interval is required. A project has commenced this past season

funded by SGNZ to look for alternative strategies to the present pest and disease

management approach but possible alternatives are a long way off. There are no

Government funded research programmes supporting the strawberry industry


research programme at present, so the industry has to fund all its own research

within its limited budget.

Natural control of the pests using predators and parasites does not provide the

necessary level of control in a short time frame. For predators and parasites to be

effective, they need to be able to build up populations and that requires a base

level of the pest to be present also. Because the presence of one pest can result in

rejection of an export consignment, growers cannot risk letting pest numbers

increase to the levels where natural control would work. Natural control is also

inappropriate for control of aphids and leafhoppers that transmit disease. Just one

feeding by these pests is enough to distribute viruses and phytoplasma that results in

disease.

6. Risks

The EPA has assessed the risks from strawberry field use as negligible and low. The

low rated risks are for bystander and aquatic risks for aerial application and re-entry

and bird risks for boom applications. The industry believes these risks can be

managed by controls such as buffer zones. SGNZ does not believe that these low

risks justify the proposed 18-month phase out for outdoor uses. SGNZ considers that

controls are sufficient to allow long term use of methomyl in the strawberry industry.

7. The Sapere report

The Sapere report provides no explanation as to how they have determined the

marginal magnitude of low nor the overall national impact as low. Further, there is

no explanation for the comment “…less reliant on organo-phosphates and

carbamates for pest control – they appear helpful rather than “essential”. Given the

lack of supporting commentary or evidence, SGNZ considers the Sapere report

should be discounted in considering benefits.

8. Conclusions

SGNZ considers that the ongoing use of methomyl in the production of strawberries is

justified both from a risk and benefits perspective. With an estimated annual benefit

of $25m, the benefits are significant. Methomyl is the only product available for

control of a wide range of pests during the flowering/fruiting period and with only

low risks, SGNZ considers controls can be used to adequately manage these risks.


Appendix 5: Benefits case – Tamarillo

This Appendix contains extracts from the Sector Assessment submitted by the

Tamarillo Growers Assn. Information relevant to the benefits assessment has been

reproduced to support comments in the overall submission.

Sector profile Size of the sector

Table 1: Sector statistics Year 2007 2008 2009 2010

Hectares planted 200 200 194 110

Yield (tonnes) ? ? 605 477

Main growing region/s Bay of Plenty, Northland, Auckland

Table 2: Crop sales value ($ millions) Year 2007 2008 2009 2010

Exports (FOB) 0.9 1.1 0.4 0.2

Domestic sales 1.9 1.6

Total sales 2.3 1.8

The main export markets are USA and Australia. However, as a result of the establishment of

tomato potato psyllid (TPP) in New Zealand, Australia closed imports of tamarillo along with

all other solanaceous crops from New Zealand. All tamarillo exported to Australia now

require mandatory pre-export fumigation with methyl bromide. Unfortunately this process

reduces the shelf life and negatively affects the appearance of the fruit.

Sector demographics Table 3: Sector demographics

Year 2007 2008 2009 2010

Number of growers 175 175 69 50

Number of employees (directly

employed ) 15

Number of employees in

supporting businesses (e.g.

packhouses , rural contractors)

10

Approach to pest management Pest management systems It is important to understand how the sector manages insecticide use.

1. Describe the management systems you have in place to regulate insecticide use.

Comment on any sector-wide programmes or private standards used by growers, and

estimate what percentage of your sector follows these practices. Please reference or


attach your sources.

Our 5 step IPM program is based on prevention, observation and intervention and the

Suggested Insecticide Control Guide is a reference for the New Zealand Tamarillo

Industry (NZTGA).

This information is updated annually and provided to all registered growers prior to the

spray season.

In addition, monthly newsletters and updates are sent to all registered growers with

helpful advice, results of the latest chemical efficacy trials conducted by Plant and

Food Research (PFR), alternative chemicals that could be of benefit and images of

major pests and diseases and the damage they cause. This information is also posted

on our website.

This is provided to growers so when monitoring their own orchards they are able to

monitor, record, analyse and assess the current pest and health status of each block in

their orchard.

(A copy of our IPM program and the accompanying insecticide guide as well as a

sample growers newsletter can be provided to EPA if required.)

This data allows growers to:

Assess the effectiveness of each spray application

Make an informed decision when the threshold has been reached and

spraying is required.

Identify and compare trends with that recorded the previous year.

All growers are regularly informed of the requirement of MRL tests prior to harvest and

the reasons why this is so critical to our industry.

They are also made aware that they can contact our organisation for advice anytime

and many have made use of this service.

The NZTGA estimates that the majority of all growers follow Growsafe and NZ GAP

programs.

The NZTGA Export Market Strategy requires all export growersto be Growsafe and NZ

GAP approved.

Other links of interest:

NZ GAP: http://www.newzealandgap.co.nz/ Growsafe: http://www.growsafe.co.nz/

TPP In 2006 the Tomato Potato Psyllid (TPP) arrived in New Zealand and it has spread nationwide.

TPP, and the Liberibacter bacterium it vectors, is the largest ever threat to commercial

Tamarillo production. In 2009, TPP infestation caused up to 60% tree deaths, causing the

complete collapse of some orchards. Because TPP requires control for 8 months of the year,

insecticides used for this pest are often sufficient to control other pests as well, with the

exception of whitefly.

The tomato/potato psyllid (TPP) transmits a bacterial-like disease called Liberibacter and

may also transmit phytoplasma all of which can cause plant damage. Grower experience

and chemical efficacy trials conducted by PFR have shown that the only effective way to

minimise the impacts of the TPP/Liberibacter/Phytoplasma complex is through the

application of well-timed insecticides with the aim of controlling the psyllid which transmits

the Liberibacter and possibly the phytoplasma. The complex can be expected to destroy

plantings of tamarillo. The biggest issue for TPP management of tamarillo is resistance

management.


A large difference between tamarillos and other crops (e.g. tomato, potato) is that TPP

generally moves into tamarillos between September and May, so the period requiring

chemical control is longer. The key to maintaining control over a longer period is having a

sufficient number of different chemical groups to rotate, one of those being

organophosphates.

The NZTGA has trialed options for effective control of TPP (see summary under alternatives

section). Carbamates are thought to worsen the condition.

Methamidophos has been trialled by PFR and has been found to be very effective on TPP

Dichlorvos is also an important organophosphate due to its very short WHP and the need to

control TPP prior and during harvest.

2. What is the basis of your choice of active ingredients to manage your critical pests?

Be specific about the efficacy and cost differences between options.

Potential Alternatives for TPP control

Chlorpyrifos – organophosphate, not registered for use in Tamarillo, long withholding

period.

Methomyl – carbamate, no efficacy

Carbamates- this chemical group is not an option, as results from USA trials show it

can worsen TPP infestation.

Pymetrozine - registered for use in Tamarillo, showed poor control in orchard trials.

Worst performing product out of 13 tested. 36% control of nymphs after 7 days.

Thiacloprid - registered for use in Tamarillo, poor control in laboratory trials. Only 48%

of adults control after 3 days, and 50% nymph control after 7 days. Poor control in

orchard trials at higher chemical rates, and residue issues on fruit approaching

harvest.

Spinosad - not registered for use in Tamarillo, very poor control in orchard trials. Not

considered for further trials.

Chlorantraniliprole- not registered for use in Tamarillo. Poor control in orchard trials,

not considered for further trials.

Spirotetramat- not registered for use in Tamarillo, good control in laboratory trials.

Poor initial toxicity to all insect stages. Good residual action noted from 1-4 weeks.

Spiromesifen- not registered for use in Tamarillo. Poor knockdown control in

laboratory trials. No nymph control at all after 7 days. Same group as spirotetramat.

Imidacloprid- not registered for use in Tamarillo, poor control in laboratory trials. Only

21% of adult control after 3 days. Possible use as soil drench.

Abamectin- not registered for use in Tamarillo. Good control in laboratory trials. To

be included in residual action trials in 2011. No label claim or MRL set. This active is

translaminar .

Deltamethrin, Bifenthrin, Lambda-Cyhalothrin, Taufluvalinate - not registered for TPP.

Good TPP knockdown control in orchard field trials. No residual action. These actives

are contact insecticides so are ineffective at high TPP infestations. Long withholding

periods so major residue issues.

Azadirachtin- not registered for use in Tamarillo. Moderate success in laboratory

trials. Poor initial toxicity to all insect stages. Some residual action noted from 1-4

weeks. To be included in residual action trials in 2011.

Buprofezin- not registered for TPP control in Tamarillo, poor control in laboratory trials.

Second worst performing product out of 13 tested. 44.9% control of nymphs after 7


days. Very poor control in orchard trials. Not considered for further trials. Can be

effective for whitefly control.

All of these alternatives have greater cost than methamidophos and dichlorvos. From

an economic point of view, the costliest spray is the one that does not work.

Methamidophos is not considered for use based on cost, but as an effective control of

TPP that fills a specific niche during periods of intense TPP pressure. The NZTGA TPP

chemical control recommendations are based on the use of three effective chemical

groups that are rotated as a resistance management strategy.

Methamidophos is a very effective organophosphate for the following reasons:

It is the only systemic organophosphate and so its use is critical when applying

under heavy foliage

As the PFR trials confirm, it is one of the most effective chemicals to control TPP

It belongs to a different chemical group from the other three effective

chemicals (abamectin, spinetoram, spirotetramat) and so, it has an important

part to play in our resistance management strategy.

Although not registered for tamarillo, growers’ trials indicate that is has a short-

moderate withholding period.

Dichlovos is an important organophosphate for the following reasons:

It is registered for tamarillo

As it has a very short withholding period it is important as a control close to and

during harvest,

It belongs to a different chemical group and so assists in resistant management

strategy.

To withdraw methamidophos and dichlorvos from the market in these difficult times will

be financially devastating for Tamarillo growers and the wider tamarillo industry.

NZTGA have already eliminated a number of organophosphates where suitable

alternatives are available, but there are no suitable alternatives for methamidophos,

diazanon and dichlovos.

EPA requests a copy of recent PFR trials non-organophosphate or carbamates – these

are attached.

3. Tell us about pest control research undertaken by your sector, and any trials

underway or completed that would reduce your reliance on organophosphates and

carbamates. This could include a description of cultural or chemical control methods

that have been tried in the past and met with mixed success, or that are being

investigated currently. If you have identified alternatives please give us a timeline for

when they will be available for use (Reference or attach sources).

Organophosphates have always been regarded by the NZTGA as a short term solution

– certainly not sustainable in the long term.

When TPP was discovered to be causing enormous damage to our industry, we

instructed PFR to conduct trials on non-organophosphate chemicals searching for a

long term solution.

The first trial involved abamectin, buprofezin, bifenthrin, pyradym, delegate, DC-Tron

oil, thiacloprid, spirotetramat, spiromesifen, azadirachtin and imidacloprid. From these


just bifenthrin and acamectin showed any degree of efficacy.

The second trial involved testing the residue efficacy of spirotetramat, spiromesifen,

azadirachtin and spinetoram.

The third trial involved testing the residue efficacy of methamidophos,

chlorantraniliprole (HGW) and thiacloprid .

The results from these trials formed the basis for our IPM and spray guidelines –

abamectin, spirotetramat, spinetoram, methamidophos and dichlovos.

The cost of these trials, trap monitoring (to study the habits and lifecycle of TPP), and

EPG research program totalled $79,000 over a period of three years plus in-kind costs.

New chemicals to replace organophosphates are required, but for small product

groups who use relatively small volumes, chemical companies are reluctant to commit

to funding the trials necessary for new products to be registered in New Zealand

because of the considerable cost involved.

To reduce dependency on organophosphates, a major five year project involving

NZTGA together with 12 other grower groups and 6 chemical companies costing

$1.2M, is currently underway to identify, trial and register up to 25 new more effective,

pest-specific and environmentally acceptable chemicals.

The outcome from this joint SFF funded minor crops project will eventually allow for the

withdrawal of old chemistry as this new chemistry becomes registered for NZ.

Meanwhile, NZTGA is concerned that it will take up to five years to access compounds

which are congruent with our IPM programs and acceptable to our trading partners,

while critically needed organophosphates could be phased out with very short time

frames.

The aim of NZTGA is to reduce long term dependency on organophosphates.

4. How would the loss of any of the substances in Table 7 affect you? We are

particularly interested in those substances that are critical to the profitable

production of your crop. Please provide information separately for each substance.

It is difficult to calculate the likely financial impact of tamarillo management without

the use of methamidophos or dichlorvos.

The damage to tamarillo orchards due to TPP has been very severe – some very large

orchards have experienced 100% loss of trees. To estimate the loss which would result

from these organophosphates being withdrawn from the market would be impossible.

The additional cost to control TPP would be dependent on the frequency of

application (which would be dependent on the TPP population at any time) and the

management style of each orchard.

But if we look at a scenario where an orchardist might apply methamidophos 5 times

annually (over a period of 8 months), and at an additional cost on average

$55/hectare, equals $275/hectare.

At approx.100 hectares the total extra cost would be over $30,000/annum in chemical

costs alone.

However the far greater cost would be from applying an alternative product that was

not effective because of low efficacy due to the mode of action or, ineffectiveness

caused by resistance of existing chemicals from over-use. This would result from the

number of effective chemicals being reduced if organophosphates were withdrawn

from the market.

Unfortunately, this figure would be impossible to calculate.


Appendix 6: Benefits case – Sweetcorn and Maize

This Appendix contains extracts from the Sector Assessment submitted on maize and

sweetcorn. Information relevant to the benefits assessment has been reproduced to

support comments in the overall submission.

1. Maize

7. How would the loss of any of the substances in Table 7 affect you? We are particularly

interested in those substances that are critical to the profitable production of your crop.

Please provide information separately for each substance.

We are only supporting compounds are critical to the profitable production of maize. Our

comments on affect are provided on a pest basis.

Corn earworm – this pest affects the ability to produce quality grain and is of

particular importance for maize grain rather than maize silage. However, we note

that where pest damage is severe, there will be secondary fungal infections that

occur at the damage sites. If these fungi produce mycotoxins, then the resulting

plant material cannot be used for food or animal feed as mycotoxins are toxic. In

this case, 100% crop loss is possible at a cost of $4,600/ha for silage and $4,510 for

grain.

In general, corn earworm is controlled by a parasitic wasp. This wasp when

abundant can control corn earworm to a sufficient level for maize which can

sustain a small level of damage such as 1-2%. Sweetcorn cannot sustain any

damage and therefore the wasp is not sufficient to control corn earworm. Where

the parasite wasp is not present in sufficient numbers, an alternative control option

is needed. Damage in the absence of the wasp and without chemical control

could be 60% of crop value. This relates to lost sales value of $2,706/ha (60% of

$4,510/ha). The basic cost of growing is $3,000/ha so the grower would face a loss

of $294/ha from the growth of that crop. This means the grower makes a loss and

this is clearly unsustainable.

Army worm – this pest eats foliage of the plant during growth and grain at later

stages of development. In severe cases, up to 80% of the foliage of the plant can

be lost. Loss of foliage to this degree would affect the photosynthetic area of the

plant and mean that no grain would be harvested. This relates to lost sales value of

$3,608/ha (80% of $4,510/ha). The basic cost of growing is $3,000/ha so the grower

would face a loss of $608/ha from the growth of that crop. Silage crops would also

be affected to the same degree because yield of the foliage would be reduced by

80% relating to a lost sales value of $3,680/ha and similar costs to the grower. If the

armyworm was unable to be effectively controlled, growers would stop producing

the crop entirely and this would have a further impact on the food processing

industry (grain) and the animal feed industry (silage).

Aphids – this is a late season pest of maize grain crops whereby the aphids suck the

nutrients from the plants causing losses in grain weight and an inability for the grain

to develop completely. There is a secondary affect of sooty mould which develops

on the honeydew produced by the aphid. In the worst case scenario, losses of 10%

yield and 10% due to downgraded quality would be likely = 20% loss in total profit =

$902/ha. The grower may cover their costs of growing but would not generate

sufficient profit to be sustainable.

Green vegetable bug – this is a problem about 1 year in 3 in northern regions of

maize grain production. It sucks the nutrients from the grain kernels, discolours them

and contaminates harvested grain. Impacts of 10-15% on saleable yield could be

experienced at a cost of $676.50/ha.

See also ‘ERMA Reassessment of Diazinon Submission from Horticulture and Arable

Industries’ section 7.4.1.


2. Sweetcorn 7. How would the loss of any of the substances in Table 7 affect you? We are particularly interested in those substances that are critical to the profitable production of your crop. Please provide information separately for each substance.

McCain and Cedenco are frozen corn processors in Hastings and Gisborne respectively.

They estimate that the loss of methamidophos would increase crop weight deductions by

10-20% resulting in a loss of $400-800 per hectare across 2833 ha (being 85% of the cropped

area supplying those two processors). Taking the lower figure of $400 per ha, the total

estimated loss is $963,000 per year deducted from grower crop proceeds. Heinz Wattie’s

have a smaller area of sweet corn grown for canning in Hawke’s Bay. This crop has a

higher tolerance for GVB damage and Heinz Wattie’s estimate that the lost crop cost from

the loss of the use of methamidophos would average about $10,000 per year but they

point out that all of this loss could be experienced by a single grower. Hence, the total loss

to process corn growers in these two regions is estimated at $973,000 per year. This figure

can be considered conservative as it does not include any losses incurred by the

processors in sorting lower quality corn and higher fixed costs per tonne due to lower rates

of throughput of finished product.

For fresh market and pouch corn crops in Gisborne, the loss to growers from the loss of

methamidophos is estimated to be 15% loss on 75% of the total crop area of 440 ha of crop

with a value of about $7500 per ha which comes to $370,000 per year. Again, this does not

take into account the additional cost of sorting lower quality crop in the pouch processing

facility or the cost of rejections in the fresh market.

Hence, the total value of crop lost due to the loss of the use of methamidophos is

conservatively estimated at $1.3 million per annum. This is also without taking into account

other regions of NZ which have a lower incidence of GVB and aphids but may still suffer

some crop losses with the loss of the use of methamidophos.

An alternative analysis would be to assume that it might be possible to achieve the same

level of control as currently achieved using methamidophos (i.e. current level of crop

damage unchanged) by making an additional two applications of insecticide(s) to all of

the crop area currently sprayed with methamidophos in the Hawke’s Bay and Gisborne

regions (say 3500 ha per year). Assuming a cost of $90 per hectare ($55 for helicopter plus

$35 for chemical) x 2 applications x 3500 ha = approx. $630,000 per year of additional cost

to achieve a similar level of control. This is a conservative figure as the chemical cost per

hectare used is relatively low compared to the likely cost to growers of newer chemistry.

These can be expected to be long term additional costs as it may be a number of years

before a chemical is identified and available for use in New Zealand which is as effective

against GVB as 1-2 applications of methamidophos.


Appendix 7: Benefits case – Potatoes

1. Background

The potato industry is currently using a number of OPCs including chlorpyrifos,

fenamiphos, methamidophos and pirimicarb.

Subject to the comments in this submission regarding proposed controls, Potatoes

New Zealand supports the EPA proposals for chlorpyrifos and pirimicarb.

Fenamiphos and methamidophos are critical insecticides for successful and

profitable potato production (Dr Stephen Odgen pers. comm. 20) and the industry is

unable to accept the proposed phase out period for these two compounds.

EPA has recommended a 5 year phase out for fenamiphos and methamidophos.

Due to the significant benefit that these compounds provide to the potato industry,

it is essential that these two compounds are retained until alternatives are found.

Industry does not consider the 5 year timeframe sufficient to achieve this. The

financial risks for growers in reduced quality and yields without these insecticides/

nematicides are unacceptable. If these compounds are phased out, growers will be

faced with uncertainty for their businesses. As a result, growers may be unable to

profitably produce potatoes, causing a domino effect on the associated reliant

businesses. This will also have a negative effect on employment in the Pukekohe,

Hawkes Bay, Manawatu and Canterbury regions.

This section of the submission outlines the benefits to the potato industry from the

continued use of these two compounds and explains that the proposed phase out

period is not sufficient due to the benefits these compounds provide to the New

Zealand potato industry.

2. Industry profile

Potatoes are grown in all parts of the country with the principal growing areas being

Pukekohe, Hawkes Bay, Manawatu and Canterbury. New Zealand produces an

estimated 600,000 tonnes of potatoes from 11,717 hectares, with around 233 growers

involved in the industry. The bulk of potato production is consumed domestically,

however exports (both fresh and processed) represent about a third of the

production and make a significant contribution to the value of the industry. The

domestic value of the potato industry (both fresh and processed) was $451 million in

201121 with the export industry (both fresh and processed) being valued at over $102

million in 201222. Therefore the total value of the New Zealand potato industry

(domestic and export) is $553 million.

2.1. Export potatoes

Approximately one quarter of the annual crop is exported. By far the major form of

potato exports is French fries. Frozen processed potatoes make up the bulk of

exports (and accounts for 85% of export value).


years 21 Freshfacts 2011 22 New Zealand Horticulture Barriers to our export trade November 2012.


2.2. Exports of processed potatoes

The main frozen export market is Australia, which takes over 70% of New Zealand's

frozen processed potato exports and is a market which continues to grow.

There are four main potato processors in New Zealand. These are:

McCain Foods (New Zealand) Ltd has plants in Hastings and Timaru. The parent

company is Canadian and processes one-third of the total world production of

French fries. The New Zealand operation supplies French fries to McDonald’s in

New Zealand and Asia.

Simplot Mr Chips with plants in Auckland and Christchurch.

Heinz Wattie Ltd has plants in Hastings and Christchurch.

Talley's Group Ltd – New Zealand owned company with the potato processing

plant in Ashburton.

Also Bluebird, Heartland and other ‘crisps’ manufacturers

These processing plants employ significant numbers of staff and therefore contribute

positively to the local regions mentioned above.

The processing industry brings economic benefits to rural areas, with their factories

being major employers in towns such as Timaru, Ashburton, Christchurch, and South

Auckland. As an example one major French fry processor generates around $96

million in sales, puts $9 million of wages (to 157 staff) into the local economy, pays

growers $27 million for raw materials (who directly employ a further 100 staff), and

generates economic flow-on effects (services, energy, suppliers) in excess of $100

million (Source- Potatoes New Zealand).

2.3 Exports of fresh potatoes

The fresh export market is much smaller, however, in 2012 over 28,600 tonnes of fresh

potatoes were exported, 70% of which were sent to Fiji.

2.4 Export statistics

Table 1: Fresh and frozen potato export volume and value 2010-12 (year ending

June, tonnes & $NZ FOB)

2010 2011 2012

Volume Value Volume Value Volume Value

Fresh potatoes 30,627 $15,502,569 31,589 $20,087,093 28,611 $15,224,236

Frozen

potatoes 71,775 $77,580,459 66,886 $81,230,668 72,061 $87,022,086

Total export 102,402 $93,083,028 98,475 $101,317,761 100,672 $102,246,322

Source: New Zealand Horticulture Barriers to our export trade November 2012

There is also a small seed potato export market with around 215 tonnes being

exported in 2012 that was worth around $272,000.

3. Potato production

The potato industry, in general, applies compounds only where there are pest

outbreaks. Most growers monitor the crop regularly for signs of pests right from

planting to harvest and then spray as a result of pest detections and action

thresholds being reached.

In potato production, there are three main pests that methamidophos and

fenamiphos are used to control:


1. Fenamiphos is used to control potato cyst nematode (PCN) and is either;

broadcast sprayed prior to planting and incorporated into the soil, applied

following planting but before remoulding; or applied to a green crop of lupin

before being cultivated into the soil23. PCN causes poor growth and premature

plant death. Small cysts form on potato roots when female nematodes burrow

into root tissue. The root systems then fail to develop properly and tubers may be

small and distorted in size, with yields decreasing as infection rates increase. Yield

losses can be up to 70%24. Damage also causes the potatoes to be rejected from

the fresh market. PCN can be managed through long crop rotations, however if

nematodes reach high levels the only way to reduce the populations is to use a

nematacide.

Photo 1 - Damage on a potato from potato cyst nematode (source- Bonsak Hammeraas Norwegian Institute for

Agricultural and Environmental Research www.forestryimages.org)

2. Methamidophos is used to control tomato/potato psyllid (TPP). This psyllid vectors

Candidatus Liberibacter solanacerarum which causes ‘zebra chip’ in the potato

tuber and as a result causes low yields and poor quality potatoes. In combination

with Liberibacter, TPP causes rapid plant death and increased sugars in tubers

which lead to burning during cooking and processing (see photo 2 below). The

psyllid causes leaf curling and yellowing of leaves and reduced potato yields. If

the psyllids are not controlled, potatoes are rejected from the domestic and

export (both fresh and processed) market as they do not meet quality standards.

If psyllids are infected and transmit Liberibacter this can result in total crop loss.

Photo 2- Increasing severity scale of zebra chip disease that makes the potatoes unsaleable even as

potato crisps (source- John Anderson, Plant & Food Research)

23 ETEC Crop Solutions Limited Nemacur Label 24 Handbook of pests and diseases for New Zealand Potato growers (NZ Potato industry and Horticulture NZ)


3. Methamidophos is also used to control potato tuber moth (PTM). PTM larvae

burrow into the leaves, stems and tubers of potatoes. The resulting tunnels in the

tubers make them unsuitable for both the fresh and processing market, resulting

in a total loss. If damaged tubers can be graded out there will still be a reduction

in pack out. For example, any damage which reduces the percentage of Grade

1 tubers from 90% (the normal pack out) to less than 75% would result in the

grower making a loss on the crop25.

Photo 3- Damage on a potato from potato tuber moth (source- Nicholas Martin, Crop& Food Research)

4. Regional impacts due to loss of these two compounds

There are approximately 2,500 people employed either directly or indirectly by the

potato sector26. Employment in this industry is only possible if there are quality

potatoes to harvest that can be sold and will generate a profit. Continued and

successful potato production is essential to the Pukekohe, Hawkes Bay and

Canterbury regional economies.

5. Benefits

The potato industry needs to retain the use of these compounds to control key pests.

Inadequate control will cause a loss of profitability, decreased income and reduced

ability to employ staff and will have flow on effects to local communities.

Potatoes New Zealand has stated repeatedly that the New Zealand potato industry

(which includes the processors) is under threat due to the impact of TPP and

Liberibacter. The cost of potato production has risen considerably due to additional

agrichemical inputs and product being down-graded or rejected from processing,

which can then suppress local market prices.

The loss of these compounds would have a considerable impact on the potato

industries viability. Key components of this would be:

Less effective pest control leading to crop losses and increased crop

rejection rates;

Undersupply of potatoes to processing factories, factories running below

economic capacity, companies withdrawing from New Zealand and

replacing NZs local supply and exports with imported product;

25 Submission by Potatoes New Zealand on the ERMA preliminary recommendations on “An application for the

reassessment of azinphos methyl and formulations containing azinphos methyl under section 63 of the Act.” 26 Market Access Solutionz (Horticulture) submission on notified acephate/methamidophos application.


Continued withdrawal of growers from the potato industry to profitable crops.

Loss of employment at the field and factory level.

This will then mean that the 2500+ jobs created by the potato industry will be in

jeopardy with a serious impact on the local communities. There are no alternatives

to methamidophos in this industry for use against this relatively new pest incursion

and the effect on the local communities where potatoes are grown (such as

Pukekohe) will be significant.

5.1. Specific benefits of Methamidophos

Methamidophos is needed for effective control of TPP and PTM. Without adequate

control, both of these pests have a detrimental effect on quality and yield.

TPP control

Methamidophos is an essential tool in combating the impact of TPP (Bactericera

cockerelli) and zebra chip disease that is caused by the bacterium that it vectors

(Candidatus Liberibacter solanacerarum). Methamidophos is particularly effective

due to its systemic action, making it a product of choice when potato crops are at

full canopy (where the dense canopy is difficult for agrichemical sprays to

penetrate). The systemic action allows the product to be distributed throughout the

plant.

Since the arrival of the TPP (in 2006), there has been a large investment by Potatoes

New Zealand (PNZ) to try and combat this pest. PNZ financial statements show that

total R&D expenditure was almost $1.3 million over the last two years (2011 and

2012).

Potatoes New Zealand is in close communication with the USA potato industry

regarding research and advances in the control of TPP. The USA Government has

invested $6.9 million in TPP research and the New Zealand potato industry is

fortunate to have strong connections with the USA Potato industry and researchers

to enable this data sharing, as obviously the USA have greater resources and access

to funds than New Zealand. Information about the USA TPP research programme is

available at http://zebrachipscri.tamu.edu/.

The future of commercially grown potatoes in New Zealand will be in doubt if

methamidophos is phased out before alternatives are found due to the severe

impact of TPP on the yield and quality of potato tubers.

Further information on the impact of TPP can be found in the economic impact

report titled ‘Report on the Economic and Business Impacts of Potato Psyllid on the

Potato Industry’ which was commissioned by Potatoes NZ. The full report is available

on the Potatoes website:

http://www.potatoesnz.co.nz/users/Image/Downloads/PDFs/Potato%20Economic%2

0survey%20Report%20Jun%202011_V2.pdf

Psyllid News also has relevant information on TPP monitoring and grower advice. This

is published three times a year and helps growers keep up to date with research and

development with regards to TPP.

http://www.potatoesnz.co.nz/Overview/News/Potatoes%20NZ%20Psyllid%20News%2

0November%202012

http://zebrachipscri.tamu.edu/

http://www.potatoesnz.co.nz/users/Image/Downloads/PDFs/Potato%20Economic%20survey%20Report%20Jun%202011_V2.pdf

http://www.potatoesnz.co.nz/users/Image/Downloads/PDFs/Potato%20Economic%20survey%20Report%20Jun%202011_V2.pdf

http://www.potatoesnz.co.nz/Overview/News/Potatoes%20NZ%20Psyllid%20News%20November%202012

http://www.potatoesnz.co.nz/Overview/News/Potatoes%20NZ%20Psyllid%20News%20November%202012


Potato Tuber Moth control

PTM larvae burrow into and feed on the leaves, stems and tubers of potatoes.

Methamidophos allows foliage of the potato plants to develop without being

attacked by the larvae as it is systemic and so targets the feeding insects. As a result

the plant is able to produce healthier and larger tubers as the above ground foliage

flourishes.

Methamidophos provides effective control of PTM because when the soil opens up

later in the season and the PTM enter the soil to feed on the potato tubers.

Methamidophos provides efficacious control that other products do not deliver and

is also a key component in resistance management of PTM.

5.2. Specific benefits of Fenamiphos

PCN control

Fenamiphos is the only compound currently registered for PCN control in potatoes in

New Zealand.

PCN causes cysts to form on potato roots and decreases yields. As PCN can stay in

the soil for up to 20 years, fenamiphos is an essential control tool for potato growers

where fields may have large numbers of this pest in the soil. Fenamiphos also

controls False Columbia root knot nematode (Meloigyne fallax) and Potato rot

nematode (Ditylenchus destructor). These two nematodes could also have a serious

impact on potato production. These nematodes are not significant pests in the

potato industry yet, but if they were to establish in high numbers in the soil they could

become important economic pests.

6. Alternatives

The EPA has proposed a 5 year phase out period to allow alternatives to these two

compounds to be identified. Industry is concerned that the development and

registration of alternatives will not be possible within this short timeframe. Phase out

of these two compounds before suitable alternatives are found and registered will

result in negative effects to the potato industry as a result of loss of production

leading to financial implications for growers, their staff and communities.

If there were no alternatives available to methamidophos within 5 years and growers

were unable to use this compound to control these pests, potato production would

be uneconomical as a result of yield quantity and quality losses (Monty Spencer

pers. comm.27).

6.1. Alternatives to methamidophos for TPP control

The potato industry and agrichemical companies have been working together to

obtain registrations of new chemistry, many with new modes of action to add to the

suite of chemicals already available. This has resulted in several new products being

registered for use on TPP, or existing registrations extended to TPP (Dr Stephen Odgen

pers. comm. 28).

Research carried out in the USA has shown that TPP is highly susceptible to




years



developing resistance. The potato and agrichemical industries are aware of the

need to ensure that inappropriate use does not result in the development of

resistance, particularly to newer and highly effective agrichemicals. This is where

methamidophos is essential to the resistance management program for potato

growers, as without this OP group resistance could develop quickly to new actives,

further reducing the suite of available control options against TPP. The industry has

focussed on encouraging growers to rotate different chemical groups and not

repeat the use of insecticides in the same group during the growing season (or at

least to separate applications as far out as possible to ensure the same generation

of psyllid is not exposed to multiple applications).

Movento (spirotetramat) is the only systemic alternative to methamidophos.

Movento is used early season because spirotetramat rapidly travels in the xylem and

phloem of the young plants during active growth and as a result controls the psyllids

when they first fly into the paddocks and start feeding on new the young growth.

Methamidophos is used mid to late season as it has good efficacy and as it is

systemic can travel through the plant during later growth.

Movento is the only systemic product that has been registered in the last 5 years. If

methamidophos was phased out the potato industry would need another

compound to take its place and this could take in excess of five years as currently,

despite significant investment in research into alternatives, there have been no

promising chemicals found.

The industry is doing all it can to develop more effective pest control programmes

and ultimately reduce agrichemical inputs, however time is needed to do this. It is

important that the full suite of available agrichemicals, of which methamidophos is

one of the most effective, are retained until this can be done.

6.2. Alterative to methamidophos for PTM control

PTM is a problem particularly in the North Island. There are only a few effective

options for the control of PTM. Some synthetic pyrethroids are used but this group is

not as efficacious as methamidophos. The key product for control of PTM is azinphos

methyl but the EPA has already reviewed this compound and it is due to be phased

out (by the end of 2014) and is therefore not an alternative.

Regular application of methamidophos is the preferred organophosphate option.

There are other possible insecticide options from other chemical groups but they

have yet to be registered and/or trialled in New Zealand. Cultural control methods

are widely used in the South Island including remoulding or irrigating the seal cracks

in moulds and preventing moth access to tubers. Due to higher North Island rainfall

the use of irrigation as a cultural control is not a practical option29. North island

growers do not have irrigation systems as they rely on rainfall. During periods of

drought, cracks open up in the soil and these growers have no cultural control

methods available to them.

Therefore methamidophos is currently the only product that available to control this

key economic pest.

29 Sector assessment feedback form- Organophosphate and carbamate use in Potato production. Submitted to the

EPA August 2012.


6.3. Alternatives to fenamiphos for PCN control

PCN is extremely hard to control and cultural practices (such as crop rotation) alone

are not efficacious because PCN can remain viable in the soil for up to 20 years and

may be carried in infected soil, attached to tubers or farm machinery30. Crop

rotation is used as a means of pest (and disease) control and in most regions this

avoids PCN numbers building up to economically damaging numbers in the soil.

Potatoes NZ encourages best practice and has published a leaflet to promote farm

hygiene to prevent the spread of PCN between properties and prevent the build up

of numbers in the soil.

Industry has been seeking, and chemical companies trialling, alternatives however

to date there have been no efficacious products found. There has been a decline in

the number of products registered since 198831. There is only one other alternative to

fenamiphos which is soil fumigation (with metam sodium). However due to costs and

logistics of application (i.e. specialised machinery) this product is not currently used

in New Zealand.

Even if an alternative nematicide is found, to obtain a new product registration

requires the provision of an extensive and costly data set, which many chemical

companies may be unwilling to fund for the relatively small New Zealand potato

market. New product registrations and the establishment of MRLs can take several

years to complete.

EPA state that oxamyl is widely used for nematode control overseas. However

oxamyl is less efficacious than fenamiphos and is also not registered for control of

PCN on potatoes in New Zealand and therefore has no MRLs set.

The seed treatment carbamate furathiocarb is used by some sectors (e.g. the

pastoral industry) to control nematodes. This is not a practical option and it is not

registered for use in the potato industry. Seed potatoes are not grown from seed,

they are planted and seed treatment for nematode control is not an option.


The Sapere report (section 4.2.1) prepared for the EPA states that ‘technical advice’

received concurs with the information provided in the assessment. However, the

table on page 23 goes onto rate the overall impact ‘small to medium’ if fenamiphos

was not available and ‘large’ for methamidophos. EPA has determined that the

benefit to the potato industry is ‘High’. Industry supports the EPA assessment and

questions why the Sapere reviewer has given lower impact ratings if they agree with

the industry information and the technical advice which states the use of

fenamiphos is critical to the potato industry.

8. Conclusions

EPA has said that both fenamiphos (table 28, page 69) and methamidophos (table

37, page 77) provide a high level of benefit to the potato industry and industry

agrees. Both of these insecticides are essential to continued potato production.

If left uncontrolled these pests cause significant yield and quality loss and as outlined

30 Handbook of pests and diseases for New Zealand Potato growers (NZ Potato industry and Horticulture NZ) 31 PCN Report by John Marshall commissioned by Potatoes NZ


above, these two compounds provide significant benefit to the potato industry. If

these control options are removed without alternatives available this would severely

impact the quantity and quality production of potatoes and this will naturally impact

on profit. This would have a negative effect on employment figures as growers

would be unable to continue to produce potatoes and therefore would not be able

to employ staff (such as harvesters, packers, graders, contractors and transport

company operators) if potato production was no longer profitable.

9. Phase out period

The potato industry appreciates that EPA staff have recommended a 5 year phase

out for these two compounds in recognition of the potential impact and lack of

alternatives available to the industry. However, this timeframe will be insufficient.

The potato industry must retain these compounds until alternatives are identified and

registered. This work will need to be funded by Potatoes New Zealand. Already

Potatoes New Zealand has heavily invested in research (around 1.3 million in the last

two years alone). But it will take some time to coordinate and undertake the

necessary research and there are no guarantees that alternatives will be found in

the timeframe available.

Research into nematode control takes significantly more time than other pest

research given the inconsistent spread of the pest and the inability to ensure it is

present before trial work begins. Trials on nematodes often need to be repeated

across multiple years to get a consistent response. In addition, there are limited new

options being introduced internationally (and the two promising alternatives being

trialled in the UK that industry is aware of are also in the OP group) for control of

nematodes that can be trialled. Often new pest control options will be discussed up

to 5 years before they are available for trial work, but at present industry is unaware

of any specific compounds that could be trialled in the next few years.

Development work by international companies is underway but will take time.


fenamiphos until alternatives are found and registered for use in potatoes. It is

recognised that an open-ended timeframe is difficult for EPA, and therefore requests

that for fenamiphos the initial phase out period is extended to 10 years. For both

methamidophos and fenamiphos, the potato industry requests that 2 years before

the phase out period ends a review is carried out to determine if alternatives are




people reliant on potato production some certainty beyond the next few seasons of

potato production.


Appendix 8: Benefits case – Carrot/Parsnip

1. Background

The carrot and parsnip industry is currently using a number of OPCs including

chlorpyrifos, diazinon, fenamiphos, oxamyl, phorate, and terbufos.

Subject to the comments in this submission regarding proposed controls, the carrot

and parsnip industry supports the EPA proposals for chlorpyrifos and oxamyl,

Subject to comments on the phase out period, the carrot and parsnip industry also

supports the proposal for diazinon which is a critical insecticide to the industry.

Because of the retention of diazinon, the industry is able to accept the phase out

recommendations for phorate and terbufos. However, fenamiphos is the single most

important insecticide for successful and profitable carrot and parsnip production

(Monty Spencer pers. comm.32). As pointed out in the sector assessment feedback,

the alternative to not having fenamiphos available to carrot and parsnip producers

is to not produce these crops, and instead import them.

Appendix H of the EPA consultation document (APP201045) ‘International context’

(page 185) states that in Australia fenamiphos is still approved for use on a number

of crops, including root vegetables and that this product was voluntarily withdrawn

in the USA by industry. If fenamiphos is phased out within 5 years, New Zealand may

have to import carrots from other countries including Australia that are potentially

produced using fenamiphos and this is discriminatory against New Zealand growers.

EPA has recommended a 5 year phase out for fenamiphos. Due to the significant

benefit that this product provides to the carrot and parsnip industry, we consider

that this product should be retained until an efficacious alternative is found which

may take longer than 5 years. The financial risks for growers in reduced quality and

yields without fenamiphos are unacceptable. If fenamiphos is phased out within 5

years, New Zealand growers will be faced with a certainty of phase out coupled

with an uncertainty of finding an efficacious alternative (pers. comm. Bruce

Snowdon33). The following information profiles the industry and further outlines the

benefits of fenamiphos and explains that 5 years is not a sufficient phase out period

due to the benefits this compound provides the New Zealand carrot and parsnip

industry.

2. Industry profile - size of the market

Currently there are approximately 50 carrot growers in New Zealand that produce

85,000 tonnes of carrots from around 1,450 hectares. The main growing regions are

Canterbury, Auckland, Ohakune and Southland, with some smaller volumes grown

in the Manawatu, Hawkes Bay and Waikato. The total industry value for carrots

(domestic and export) is over $40 million, with $30m of this being made up of

domestic sales.

New Zealand's largest juicing plant is located in Washdyke, Timaru. When operating

at full capacity this plant processes 100,000 tonnes of carrots into juice each year,


company. http://www.aswilcox.co.nz/about/index.shtml 33 Bruce Snowdon is the Agricultural Technical Manager for Heinz Wattie's



most of which (~90%) is exported to Japan34. There are approximately 50 staff

employed at this plant (http://www.stuff.co.nz/timaru-herald/509093/Biggest-juice-

factory-opens).

The Ohakune region provides almost all the carrots for the North Island domestic

market (Sue Deadman pers. comm.35).

Currently there are approximately 12 parsnip growers in New Zealand who produce

parsnips on around 300 hectares. The main growing regions are the same as for

carrot production (Canterbury, Auckland, Manawatu-Wanganui and Ohakune).

2.1. Carrot exports

Fresh carrot exports were worth $8 million in 2012. Japan is the main export

market for fresh carrots.

The value of frozen carrot exports has grown strongly since 2010 up by 162% to

over $2 million.

According to the New Zealand Horticulture ‘Barriers to our Trade November 2012’

report, the combined value of New Zealand’s carrot export industry is over $10

million.

There are approximately NZ$1 million exports of dehydrated carrot (mostly to

Japan)

Table 1: Fresh and frozen carrot export 2010-12 (year to June, tonnes & $NZ FOB)

2010 2011 2012

Volume Value Volume Value Volume Value

Fresh carrots 10,169 $6,595,726 13,575 $8,460,564 12,308 $8,105,773

Frozen carrots 742 $819,353 895 $1,075,751 1,548 $2,153,177

Total export 10,911 $7,415,079 14,470 $9,536,315 13,856 $10,258,950

Source: New Zealand Horticulture Barriers to our export trade November 2012

2.2. Carrot imports

Currently New Zealand grown carrots predominately supply the domestic market. In

the first three quarters of 2012, New Zealand imported a very small amount of carrots

(8.5 tonnes) from only two countries (Australia and USA). Therefore imports currently

represent only 0.1% of the total New Zealand market.

According to Statistics New Zealand’s ‘infoshare’ database, in 2010 and 2011 New

Zealand did not import any carrots.

3. Regional impacts due to loss of fenamiphos

Fenamiphos provides significant benefits to regions such as Ohakune where carrots

are produced on a large portion of the land in this area. Horticulture NZ estimates

that approximately 25-30% of the national total (including processed carrots) volume

is produced in the Ohakune region (John Seymour pers. comm.36).

Local business such as machinery and agricultural chemical outlets and contractors

rely on the successful production of carrots. People employed in the carrot and

parsnip industry are also reliant on the continued production of these crops.

34 New Zealand Horticulture Barriers to our export trade November 2012.

35 Sue Deadman of GM & SM Deadman is a grower who produces carrots on 60 hectares in Ohakune. 36 John Seymour is the Senior Business Manager of Vegetables NZ and Process Vegetables NZ for Horticulture New

Zealand

http://www.stuff.co.nz/timaru-herald/509093/Biggest-juice-factory-opens

http://www.stuff.co.nz/timaru-herald/509093/Biggest-juice-factory-opens


There are a total of 62 growers (producing both carrot and parsnips) with over 300

full time employees and over 1,040 people employed in supporting business. If

fenamiphos is phased out before a suitable alternative can be found this would

decrease production by at least 40% as a result of nematode damage. Growers

would be unable to sustain their businesses and people employed in the industry

would lose their jobs. Therefore regions such as Ohakune (and other carrot growing

regions mentioned previously), are very reliant on the continued availability of

fenamiphos.

New Zealand would lose over $10 million of revenue as a result of lost export

volumes, which as seen in table 2 is an industry that continues to grow.

The loss of fenamiphos will have a considerable impact on the carrot and parsnip

industries viability. Key components of this would be:

Less effective (or no) nematode control leading to crop losses and increased

crop rejection rates;

Undersupply of carrot and parsnips to pack houses and processing factories,

causing operations to run below economic capacity, companies

withdrawing from New Zealand and replacing NZs local supply with imported

carrots and parsnips;

Withdrawal of growers from the carrot and parsnip industry to profitable

crops;

Loss of employment across the whole sector.

This will then mean that the 1,000+ jobs created by the carrot and parsnip industry

will be in jeopardy with a serious impact on the local communities. There are no

alternatives to fenamiphos in this industry and the effect on the local communities

where carrots and parsnips are grown (such as Ohakune) will be significant.

4. Benefits of fenamiphos

4.1. Damage

Root knot nematodes cause carrots and parsnips to be ‘forked’ or galls to form and

render them unsuitable for the fresh market as well as decreasing yield for both the

fresh and process market. Control of nematodes is critical for the fresh market and

while less important for the process market which can deal with forked carrots, is still

needed to control heavy nematode populations that would affect yield.

Forking damage to carrots as a result of nematodes (source- google images).

The carrot and parsnip industry needs to retain the use of fenamiphos to control


nematodes. If left uncontrolled, nematodes cause a 40-60% total yield loss and a

75% fresh market yield loss in the first year and within 10 years 100% yield loss (as the

soil becomes infested with nematodes and it can no longer be used for carrot or

parsnip production). Without fenamiphos for control of this pest there are no

alternatives with equivalent efficacy and loss of crop would be in excess of 75%. This

would be a total cost of over $30m to the industry.

4.2. Alternatives

Root knot nematodes are extremely hard to control and cultural practices (such as

crop rotation) alone are not efficacious because nematodes can survive between

crops on alternate hosts and can lie dormant in egg masses in the soil. Industry has

been seeking, and chemical companies trialling, alternatives for the past ten years,

however to date there has been no effective products found.

EPA has said that fenamiphos only provides a medium level of benefit to the carrot

and parsnip sector, however carrot growers strongly disagree. Fenamiphos provides

a high benefit and is essential to continued carrot production, until a suitable

alternative is found (Sue Deadman pers. comm.37).

EPA state that oxamyl is widely used for nematode control overseas. However

oxamyl is less efficacious than fenamiphos and not used widely in New Zealand. The

efficacy profile of oxamyl means that it is not a suitable alternative for New Zealand

carrot and parsnip growers. The label for oxamyl recommends that the product be

applied in the furrow of carrot seedlings, where as fenamiphos is applied pre-plant

and worked into the soil. The advantage of soil incorporation is that it ensures

efficacy against the whole nematode population. If oxamyl is used, the nematode is

only controlled when it chews the small roots of the carrot seedling by which time

the damage has already been done to the carrot seedling (Kath Lee-Jones pers.

comm.38).

Cost is also a factor and the outlay per hectare of oxamyl is significantly more as

opposed to fenamiphos. Oxamyl costs around $1,300/ha, whilst fenamiphos is

$360/Ha. It is almost 75% cheaper to use fenamiphos than oxamyl and it has better

efficacy. Growers are unable to pass increased input costs to consumers and

growing carrots would become uneconomical.

The Sapere report (section 4.2.2) prepared for the EPA states that ‘technical advice’

given (which we assume comes from Plant and Food as per section 3) indicates that

cultural practices can prevent nematode damage and that losing fenamiphos may

not have the impact that industry infers. Nematodes must be controlled at the start

of the season (fenamiphos is applied once to bare soil prior to sowing). Crop rotation

is already used as a means of pest (and disease) control, however this is not a

reliable control method and chemical control is also needed. Land availability for

carrot production is limited and growers must lease land in their area where

infrastructure (such as pack houses, juicing plants etc) are nearby. Crop rotation

does not alleviate the nematode populations as they also have other hosts, and

even in pasture survive in the soil (pers. comm. Monty Spencer39).

37 Sue Deadman of GM & SM Deadman is a grower who produces carrots on 60 hectares in Ohakune. 38 Kath Lee-Jones is the Area Sales Manager for Fruitfed Supplies in Ohakune





Industry has been involved in work to identify alternatives to fenamiphos. A trial was

carried out to determine if soil tests could be used to monitor nematode levels in the

soil but it wasn’t accurate because the pest isn’t evenly spread. It was determined

that growers must treat all paddocks by default because the impact of nematode

damage is significant, even in patches.

Nematodes are a sporadic pest and nematode trials require multiple years of work.

Some trials have been undertaken but no alternative products have yet been

registered.

Funding is obviously also an issue due to the small size of the sector and the low profit

margins of carrot and parsnip production which do not leave extra funding for

research and development of new insecticides. Chemical companies will not invest

in trials with minor crops such as carrot/parsnip as profit margins are low as a result of

low volume of sales. Therefore it is not economically viable to register a label claim

for these crops.

The seed treatment carbamate furathiocarb is used by some sectors (e.g. the

pastoral industry) to control nematodes. However this does not provide season long

control. Nematodes are more of an issue during pasture establishment and so seed

treatment is a viable option for this industry. However nematodes feed on carrot and

parsnip roots throughout the crop cycle and other control options are needed.

5. Conclusions

EPA have said that fenamiphos (table 28, page 69) provides a medium level of

benefit to the carrot and parsnip industry, however growers and industry strongly

disagree. Until alternatives are found, fenamiphos is essential to continued carrot

and parsnip production and the benefits at a regional level are high.

Damage from uncontrolled nematodes would result in an estimated annual cost of

over $30m to the industry. This would have a negative effect on employment figures

as growers would be unable to continue to produce fresh market carrot and

parsnips and therefore would not be able to employ staff (such as harvesters,

packers, graders, contractors and transport company operators) if carrot and

parsnip production was no longer profitable.

In horticulture (compared to other industries) any increased cost of production

cannot be passed onto customers as consumers will not pay more, and the market

will be instead filled by imported carrots, that probably have OPC compounds used

to produce them. This creates and abnormally where by local New Zealand

producers are put out of business and unable to sustain their businesses, but where

because of trade agreements New Zealand will increase imports of carrots and this

is to the detriment of New Zealand society and communities.

All above arguments equally apply to parsnip.

6. Phase out period

The carrot and parsnip industry appreciates that EPA staff have recommended a 5

year phase out for fenamiphos in recognition of the potential impact and lack of

alternatives available to the industry. However, this timeframe will likely be


insufficient.

Industry must retain this compound until alternatives are identified and registered.

The carrot and parsnip sector is a small industry and although some trials are

currently underway, and have been for the last 10 years, it takes time to continue to

accumulate funds, coordinate and undertake the necessary research. Where the

pests are shared with other larger crops (such as potatoes), the carrot and parsnip

industry can (to some extent) collaborate with research done in these industries to

identify possible alternatives. The carrot and parsnip industry does not have

extensive research funding available to do this work alone. Registration work once

alternatives are identified will need to be funded by the carrot and parsnip growers

because carrot and parsnip does not present an economic option for chemical

companies.

Research into nematode control takes significantly more time than other pest

research given the inconsistent spread of the pest and the inability to ensure it is

present before trial work begins. Efficacy trials on nematodes often need to be

repeated across multiple years to get a consistent response. In addition, there are

limited new options being introduced internationally for control of nematodes that

can be trialled. Often new pest control options will be in development up to 5 years

before they are available for field trial work, and even longer before they are

available to the New Zealand market for trials. At present at number of compounds

are being trialled, but to date none have shown good efficacy. Development work

by international companies is underway but will take time.

Industry requests that they be allowed continued use of fenamiphos until alternatives

are found and registered for use in carrot and parsnip. It is recognised that an open-

ended timeframe is difficult for EPA, and therefore requests that for fenamiphos the

initial phase out period is extended to 10 years. The carrot and parsnip industry also

requests that 2 years before the phase out period ends a review is carried out to

determine if alternatives are available. If appropriate alternatives are not available

and the industry can demonstrate that work has been done to identify alternatives,

industry requests that the phase out is extended for a further 5 years. This will provide

growers and other people reliant on carrot and parsnip production some certainty

beyond the next few seasons of production.


Appendix 9: Benefits case – Kumara

1. Background

The kumara industry is currently using a number of organophosphate insecticides

including dichlorvos, chlorpyrifos, diazinon, maldison, methamidophos, phorate and

terbufos.

Subject to the comments in this submission regarding proposed controls, the kumara

industry supports the EPA proposals for chlorpyrifos and maldison. Subject to

comments on the phase out period, the kumara industry also supports the proposal

for diazinon which is a critical insecticide to the industry. Because of the retention of

diazinon and methamidophos, the industry is able to accept the phase out

recommendations for phorate. However, methamidophos and terbufos (in light

soils) are critical insecticides for successful and profitable kumara production (pers.

comm. Andre de Bruin40) and the industry is unable to accept the proposed phase

out period for these two compounds.

EPA has recommended a 3 year phase out for terbufos and a 5 year phase out for

methamidophos. Due to the significant benefit that these compounds provide to

the kumara industry, it is essential that they remain in use until alternatives are found.

Industry does not consider the 3-5 year timeframe sufficient to achieve this. The

financial risks for growers in reduced quality and yields without these insecticides are

unacceptable. If these compounds are phased out, growers will be faced with

uncertainty for their businesses. As a result, growers will be unable produce quality

kumara and the substantiality of the industry will be at risk. This will also have a

negative effect on employment in the Northland region.

This section of the submission outlines the benefits to the kumara industry from the

continued use of these two compounds and explains that the 3-5 year phase out is

not sufficient.

2. Industry profile

Kumara has a long history of cultivation in New Zealand (over 500 years) and has a

special cultural significance to New Zealand. The toanga status of New Zealand

kumara was acknowledged in the Waitangi tribunal findings into native flora and

Fauna (Y262). This is a unique vegetable that NZ consumers can readily access and

the Owairaka red variety of kumara (particularly sort after for use in hangi) is not

produced anywhere else in the world. If domestic kumara production ceased or

was reduced, because kumara cannot be imported into New Zealand, kumara

would no longer be part of the New Zealand diet.

In 2011, 17,500 tonnes of kumara was produced on an estimated 1,500 hectares.

Recent results from the 2012 season estimate a crop sales value of over $35 million.

Over 90% of Kumara (for both fresh and processed markets) is produced in the

Northland region of New Zealand41. In the Kaipara region, the majority of horticulture

land is used for kumara production with all but two of the commercial Northland

kumara operations located in this region (Andre de Bruin pers. comm.). The Kumara

industry is the second largest agricultural industry in the district (after pastoral

40 Andre de Bruin is the Chairman of the root & tuber crops advisory group of Vegetables NZ, a product group under

the umbrella of Horticulture NZ and a Kumara grower in the Kaipara region. He is also chairman of the Northern

Wairoa vegetables growers association. 41 New Zealand Horticulture Barriers to our export trade November 2012.


farming).

3. Regional impacts due to loss of Methamidophos and terbufos

In the Kaipara region there are an estimated 45 growers with 545 full time equivalent

staff employed in the kumara industry. This figure is made up of 60-120 staff (season

dependent) employed in the five kumara packhouses that operate year round and

approximately 100 full time jobs on farm operations during the off season rising to

over 1000 staff employed during peak periods (October to December plant out).

During the harvest period (February to April) the number again increases to over

1000, with many being local unemployed, and casual agricultural workers.

Kumara is a very important service industry where unemployed people often re-

enter the workforce by starting out working in the kumara industry and then go onto

full time employment in the meat works and related industries (pers. comm. Andre

de Bruin).

There are a number of related specialist industries in the Kaipara district with two

farm machinery dealers and four other specialist machinery/engineering firms that

are heavily reliant on the kumara industry. There are also related businesses such as

Farmlands, RD1 and Wrightsons that would be negatively impacted if Kumara was

not produced in the region, as demand would not sustain more than one of these

businesses.

Employment of locals in this industry is only possible if there are quality kumara to

harvest that can be sold and will generate a profit. Continued and successful

kumara production is essential to the Northland regional economy and in particular

the economy in Kaipara.

4. Kumara production

Methamidophos is used in kumara production to mainly control black beetle and

white fringed weevil. The larvae of these pests chew young roots and later mature

tubers and cause direct damage to the kumara tuber. They do the most damage

close to harvest. When these pests attack the young small tubers, they cause them

to split and this distorts the shape of the kumara causing them to be rejected from

the fresh market. Holes in kumara tubers caused by black beetle result in a taint in

the product which causes the produce to be rejected even from the processed

market. This equates to a direct loss in profit to the grower as the reject tubers are

dumped.

Terbufos is used pre-plant to to reduce the numbers of symphilid, stem weevil and

wireworm larvae in the soil. These pests attack the fine hairs of developing plants,

cause stunting in the kumara plant, and later on in the season cause direct damage

to the tuber. Any visual damage to the tuber results in the tuber being downgraded

and renders the produce unsuitable for the fresh market.

Crops on heavy soils are less susceptible to pest damage but more susceptible to

weather related crop issues. In order to spread the risk of losing a crop due to pest

(or disease) outbreaks, growers have invested in producing kumara on both heavy

and light soils. This also serves to mitigate risks if weather patterns are not favourable

during the season (e.g. flooding on heavy soils, or drought on light soils) and as a

result growers face different pest pressures on different soil types. Producing kumara


on both light and heavy soils also enables growers to have a longer production

window. It allows all year round availability of quality kumara to meet supermarket

requirements (through stored product) and consumer expectations (around having

kumara on the shelves 12 months of the year).

Without these two compounds there could be up to 100% loss of the crop in light soils

on high insect pressure years because pests thrive in lighter soils and the soil borne

pests cause direct tuber damage. If left uncontrolled, pest pressure builds quickly

and the impacts spread to neighbouring fields and properties.

5. Benefits

Producing a marketable kumara crop is challenging. These two organophosphates

provide significant benefits to the kumara industry. Insecticides are only used where

there are pest outbreaks and growers monitor the crop regularly for signs of pests

right from the early stages of crop growth to tuber development. In some seasons

when pest pressure is high, an entire crop can be destroyed if growers do not use an

adequate pest control programme. In the years of high pest pressure, if pests are

uncontrolled this results in an average 50% loss of yield due to direct tuber drilling by

the insects causing damage, which can amount to a loss of around $16-18,000/ha

for the grower.

Traditional Kaitiakitanga rights and responsibilities

Kumara has status under the Wai 262 Statement of Claim42 under section 6.4

‘traditional usages’. Kumara is recognised as significant to Maori and any impacts

on the availability of insect control could negatively impact continued production of

kumara. It is of significant cultural benefit to retain the use of these two compounds

in order for New Zealand to maintain production of kumara. The kumara industry

agrees with EPAs comments in section 7.3, page 35 around kaitiakitanga as this is in

keeping with HSNO principals and acknowledges that this is a factor that the EPA

must take into consideration. This kumara industry disagrees with the EPAs last

sentence in this section (7.3) on page 37 around the level of effect is only deemed

to be minor and suggests the level of effect would be significant.

5.1. Specific benefits of Methamidophos

Methamidophos provides efficacious control for a wide spectrum of pests, and in

particular black beetle. These pests causes both above ground (foliar) damage and

below ground (tuber) damage. Methamidophos controls pests both by contact and

systemic action. This compound kills insects when it is applied to them and also

moves through plant tissue and controls larvae (and other chewing/ sucking pests).

During humid tropical weather there is significant pest pressure on crops. This is when

a well timed methamidophos application is essential to get black beetle numbers

under control and ensure harvestable yields are achieved. Methamidophos

preserves the quality of produce against the black beetle damage and as

consumers demand a high quality product, this compound is essential. A well timed

methamidophos application at the peak of the black beetle flight time also has the

added advantage of reducing the number of other sprays required for the crop as it

also takes out caterpillars, crickets and weevils thus reducing the overall number of

spray applications required.

42http://www.waitangi-tribunal.govt.nz/doclibrary/public/wai262/matauranga_maori/Chapt06.pdf

http://www.waitangi-tribunal.govt.nz/doclibrary/public/wai262/matauranga_maori/Chapt06.pdf


In a field trial conducted in the 2010 summer in Dargaville in ground that had not

previously been used for kumara production (the land was in used for dairy

production) there were 0% marketable kumara in the field plot that had no

organophosphate applications due to black beetle damage. This is a total loss of

crop and therefore profit for the grower if no organophosphates are available.

It is important to note that in some crops in some seasons no organophosphates are

applied (because insect pressure does not get to an economic level for

intervention.) But in other seasons (e.g. 2010 and 2011) growers on light soil could not

produce a marketable crop of Beaureguard kumara without organophosphate

applications due to the high black beetle and cricket pest pressure.

5.2. Specific benefits of Terbufos

Terbufos is applied pre-plant at the beginning of ground work and combined into

the soil to reduce mainly symphilid (but also stem weevil and wireworm) numbers.

This allows roots to establish ahead of insect pressure. If uncontrolled, symphilids

attack the fine hairs of the roots and cause stunting in the kumara plant. If left

uncontrolled, this causes a yield decrease and a loss in profit to the grower (pers.

comm. Andre de Bruin).

Terbufos is very efficacious as the formulation type (granule) lends itself to better

pest control than a liquid formation type.

6. Alternatives

6.1. Crop rotation

Crop rotation is used as a means of pest (and disease) control, however this is not a

reliable control method alone and chemical control is needed. Pests (such as

crickets, black beetle and caterpillars) travel into kumara fields from neighboring

properties. Many kumara fields are surrounded by dairy farms with turnip and maize

crops where these insects are not (generally) actively controlled as quality is not

important for crops grown only for animal feed. Land availability for kumara

production is limited and growers must lease land in areas where infrastructure (such

as pack houses) are nearby.

Kumara growers work on a 6 month rotation, in the summer months for 6 months

kumara is produced in the field, and then it is sown in pasture for 6 months (during

the cooler winter months).

Normally the first season out of a long term pasture rotation is the worst for insect

damage particularly black beetle and cricket. Years 3, 4 and 5 in the rotation are

the best. A mixture of cultivation and active insect control has reduced the

population numbers. When the land is rotated out of kumara into grass for disease

control and soil structural improvement reasons, the pest numbers quickly build up

again.

6.2. Chemical alternatives

Kumara is a minor crop and this means that there is very little to no research done

internationally into alternative insecticides for use in kumara. Symphilids are not a

known cropping pest in other countries therefore there are not many insecticide


control options for this pest available and there is also no work done globally to

target this pest in kumara (or in other crops). Symphilids seem to be an issue in New

Zealand due to the very high organic matter in the soil.

Currently the only alternative group in use is the synthetic pyrethriods, but already

resistance to this group is building in the pest populations due to the heavy reliance

that the horticulture industry already has on this group.

With root crops such as kumara it is not easy to get insecticides into the ground

around the tuber where the insect pests cause direct tuber damage. As synthetic

pyrethroids are not translaminar/systemic these compounds do not reach pests that

are not contacted directly. Industry is cautious not to rely solely on synthetic

pyrethroids due to resistance management issues. For resistance management

programs to be successful at least two chemical groups are needed to control the

major kumara pests mentioned above. If the organophosphate group was phased

out without another group to replace it resistance issues could increase.


The Sapere report (page 23 section 4.2.2) prepared for the EPA acknowledges that

the kumara industry is particularly important in Northland and that crops suffer from

black beetle and grass grub damage which require organophosphates to control.

However, the report also states that ‘technical advice’ (which we assume comes

from Plant and Food as per section 3) indicates concern around the extent of

reliance on organophosphates given that alternatives are available for some pests

e.g. aphids.

Aphids were not one of the pests identified by the kumara industry as critical and

were not included in the kumara sector assessment submitted to the EPA in August

2012. It is unclear why ‘technical advice’ given has focused on this pest, as industry

already acknowledges that there are alternative insecticides for aphid control and

does not rely on organophosphates for control of aphids. However, for other pests

such as black beetle and symphilid, there are no alternatives available.

Andre de Bruin43 pest scouts at least twice a week and reports that aphids are not

an issue in kumara crops in the Kaipara region and he has never applied an

insecticide in his kumara fields to control aphids.

There are no alternatives that provide the same level of efficacy to these two

compounds recommended for phase out. The overall impact table on page 24 of

the Sapere report states that the loss of methamidophos would be low to medium

and terbufos low. However in light of the above information, we argue the impact of

loosing these two compounds to the kumara industry will be high and result in a

significant impact on the regional economy of Northland.

8. Conclusions

If left uncontrolled, these insects cause significant yield and quality loss and as

outlined above, these two compounds provide significant benefit to the kumara

industry. If these control options are removed without alternatives available this

43 Andre de Bruin is the Chairman of the root & tuber crops advisory group of Vegetables NZ, a product group

under the umbrella of Horticulture NZ and a Kumara grower in the Kaipara region. He is also chairman of the

Northern Wairoa vegetables growers association.


would severely impact the quantity and quality production of kumara and this will

naturally impact on profit. This would have a negative effect to employment figures

as growers would be unable to continue to produce kumara and therefore would

not be able to employ staff (such as harvesters, packers, graders, contractors and

transport company operators).

In the EPAs consultation document, table 37 states the benefit profile of

methamidophos to the kumara industry is medium. In table 58, EPA has placed the

benefit of terbufos to the kumara industry to be low.

The kumara industry regards the benefits of both methamidophos and terbufos to

continued production to be high when considered in a regional context.

9. Phase out period

The kumara industry appreciates that EPA staff have recommended a 3-5 year

phase out for these two compounds in recognition of the potential impact and lack

of alternatives available to the industry. However, this timeframe will be insufficient.

The kumara industry must retain these compounds until alternatives are identified

and registered. Kumara is a small industry and it will take some time to accumulate

funds, coordinate and undertake the necessary research. Where the pests are

shared with other larger crops (such as potatoes), the kumara industry will need to

rely on research done in these industries to identify possible alternatives before

testing in Kumara. The kumara industry does not have enough research funding

available to do this work alone. Registration work once alternatives are identified

will need to be funded by the kumara growers because kumara does not present an

economic option for chemical companies.


terbufos until alternatives are found and registered for use in kumara. It is recognised

that an open-ended timeframe is difficult for EPA, and therefore requests that the

initial phase out timeframe for terbufos be increased to 5 years. For both

methamidophos and terbufos, the kumara industry requests that 2 years before the

phase out period ends a review is carried out to determine if alternatives are




people reliant on kumara production some certainty beyond the next few seasons

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