chief executive initiated reassessment organophosphate and carbamate based insecticides
DESCRIPTION
Chief Executive initiated reassessment Organophosphate and Carbamate based insecticides. New reassessments approach. Moving from single substance to group reassessments Older substances, often removed or restricted by other jurisdictions Engaging early – go out with early thinking Aim: - PowerPoint PPT PresentationTRANSCRIPT
Chief Executive initiated reassessmentOrganophosphate and Carbamate based insecticides
New reassessments approachMoving from single substance to group reassessmentsOlder substances, often removed or restricted by other jurisdictions Engaging early – go out with early thinking
Aim:Avoid perverse outcomesConsistent controls to manage riskGreater certainty about tools available for use in medium termMore efficient use of resources
ConsultationCall for Information
To identify those that may have high risksTo obtain use informationFeasibility of possible controls or other controls to mitigate risk
HuiNorthland, Bay of Plenty, Rotorua and Marlborough
Scope of the reassessmentacephate maldison pyrazophoscarbarylc methamidophos benomylc
chlorpyrifos methomylc carbofuranc
diazinon phorate carbosulfanc
dichlorvos pirimicarbc chlorpyrifos-methyldimethoate pirimiphos-methyl dichlofenthionfenamiphos prothiofos ethionfenitrothion oxamylc famphurphoxim terbufos isazofos
omethoate
c=carbamates
HSNOProcess
May approve if the positive effects of the substance outweigh the adverse effects
• If risks are negligible then the approvals should be retained• If additional controls make the risks negligible, then the
approval should be retained with those additional controls. • If the risks are non-negligible even with extra controls a
risk/benefit analysis is conducted and: • If benefits are greater than the risks the approval is
recommended to be retained • If risks are greater than benefits the approval is
recommended to be revoked either with or without a phase-out period
EvaluationRisk vs BenefitQualitative descriptors allow a risk or a benefit to be negligible, low, medium or high to focus comparisonsLikelihood and magnitude for risks and benefits
Page 43 – 45 of the consultation report
ExampleDiazinon
widely used high risks and high benefitseffective alternatives not yet available
Analysis of risksRisk is a function of exposure and hazardExposure estimated using models/measured data
Use patterns established from product label and stakeholder feedback
Hazard: Use threshold values derived by other regulatorsRisks assessed with and without additional controls
Analysis of risksOperatorsRe-entry workersBystandersAquatic environment Birds Bees
Analysis of risksRisk Quotient = Predicted exposure/threshold value
Target Risk Quotient is <1
Risks - Qualitative DescriptorsRisk Quotient
Risk Parameter Operators Re-Entry workers Bystanders
<1 Overall Negligible Negligible Negligible
>1-10Magnitude Minor Minor Moderate
Likelihood Likely Very unlikely Unlikely
Overall Low Negligible Low
>10-100Magnitude Moderate Moderate Moderate
Likelihood Likely Unlikely Unlikely
Overall Medium Low Low
>100Magnitude Major Major Major
Likelihood Highly likely Likely Unlikely
Overall High Medium Medium
Risk Quotient
Risk parameter Aquatic Birds Bees
<1 Overall Negligible Negligible Negligible
>1-10Magnitude Minor Minor Minor
Likelihood Very unlikely Unlikely Very unlikely
Overall Negligible Low Negligible
>10-100Magnitude Moderate Minor Minor
Likelihood Unlikely Highly likely Very unlikely
Overall Low Medium Negligible
>100Magnitude Major Major Minor
Likelihood Likely Highly likely Very unlikely
Overall Medium High Negligible
Human health
Environment
Benefits - Qualitative DescriptorsCategory Criteria
Very unlikely
No evidence provided of actual use
Possible Used only rarely or when needed
Likely Some current use across industry
Highly likely
Significant and regular use across industry
Marginal cumulative benefits
Minor Difficult to ascertain material impacts.
Moderate Medium term regional effects with some national implications for GDP - $0-$15 million
Major Measurable beneficial effect on GDP - $15-$50 million
Massive Significant on-going beneficial effect on GDP - Above $50 million
LikelihoodMagnitude
Minor Moderate Major Massive
Very unlikely Negligible Negligible Negligible Negligible
Possible Negligible Low Medium Medium
Likely Negligible Low Medium High
Highly likely Negligible Medium High High
Generic BenefitsEfficacy Broad spectrumLower application ratesCheaperShort pre-harvest intervalsShort re-entry intervalsMaximum Residue LimitsResistance managementBiosecurity
Specific BenefitsMany OPCs are particularly effective in controlling specific pests. This makes them beneficial on a number of crops where these pests are difficult to control
Diazinon to control grass grub on pastureSupports large industries = large contribution to GDPSpecific pest to NZNo effective alternatives – ongoing research
Approach to controls AIM: Reduce risk levels to, or close to, negligibleControls are risk reduction measures, intended to reduce exposure to human health / environment
Default controls (arising from hazardous properties – s77)Additional controls (to manage risks not addressed by default controls, reflect parameters of scenarios – s77A)
Risks identified to the receptors identified in the risk assessment
Operators, re-entry workers, bystandersAquatic and terrestrial environment, birds, bees
Additional controls toolbox developed with stakeholders
Controls toolboxExample controls
Operational • prescriptive PPE requirements• permitted application methods (e.g. ground-based application only),
maximum application rates and frequencies• buffer zones and spray drift reduction measures (NZS:8409)• restricted entry intervals (REI)• notifications and signage
Obligations • Approved Handlers only• Authorised Person• Labelling statements
Restrictions • indoor use only• phase out/revocation
Recommendations Based on balance of risks and benefits
Controls selected to mitigate risks as far as possible
Recommendations – Diazinon Very high risks – but also very high benefits
Long phase-out period proposed to allow development of alternatives – plus additional controls e.g.
Maximum application ratesSemi-automated equipment for indoor applicationNo hand-held application of granules
Key issues raised in submissions
• Home garden uses• ADI/MRL relationship • Biosecurity uses • Information challenges/data gaps• UK COT
Updated recommendationsRetain dimethoateRetain outdoor uses of pirimiphos-methyl & methomylBiosecurity – Authorised Person-only control for fenamiphos after 5 years; Extend AP control to all OPCs we’re retainingExtend phase-in period to 2 yearsChange definition of automated application in greenhousesRemove droplet size requirements for chlorpyrifos and diazinonAllow shorter buffer zones through COPNew label warning for bee risks