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OPC Reassessment Presentation
from the Horticulture & Arable Industries
07 March 2013
Nikki Johnson
Market Access Solutionz Ltd
Outline of presentation
• Industry summaries
• Proposed Controls
• Biosecurity
• ADIs
• Conclusions
• Note toxicology has not been a focus of the
Hort/Arable review due to lack of time/resources
Summary of Industry Industries represented contribute over $2.7 billion to NZ economy and
employ around 35,000 permanent and seasonal staff. Horticulture industry's
goal to achieve industry value of $10 billion by 2020- The 10/2020 strategy.
The Foundation for Arable Research
11 Product Groups affiliated to Horticulture New Zealand:
– Avocado Industry Council
– NZ Citrus Growers Inc
– Persimmon Industry Council
– Strawberry Growers NZ
– Summerfruit NZ
– Tamarillo Growers Assn
– Onions NZ
– Potatoes NZ
– Process Vegetables NZ
– Tomatoes NZ
– Vegetables NZ
Arable Industry Mike Parker- Project Manager / Grower
Foundation for Arable Research
Sector statistics (2011)
Critical use OPCs recommended for retention:
• Chlorpyrifos, Oxamyl, Pirimicarb and Pirimiphos methyl - Agree
Crop No. growers No. employees Land area (ha) Total value $(b)
Arable crops incl. maize 4,000 5,750 262,300 1.1
Compound
Phase out
period (years) Comments
Phorate 3 Agree – Assume diazinon retained
Methamidophos 5
Disagree - Critical for green vegetable bug
control
Diazinon 10 Disagree - Critical for grass grub control
Diazinon and Methamidophos
• Proposed time frames not sufficient to find alternatives
– Grass grub = NZ pest, difficult to find controls
– Green Vegetable Bug = probably requires new chemical group =
more than 5 years
• FAR working towards finding alternatives through a SFF grass grub
research project to identify alternatives to diazinon (titled ‘Managing the
number one soil borne pest in cropping’)
• Request reassessment 2 years prior to phase out to ensure alternatives are
available
Arable Industry
Arable Industry
Cereal production - Comparison between OP (left) and nil control (right) when grass grub is present
Persimmon Industry Geoff Peach - Executive PIC
Persimmon Industry Council Inc.
Sector statistics (2011)
Critical use OPCs recommended for retention:
• Chlorpyrifos and Pirimiphos methyl – Agree
Pirimiphos methyl
• Revised recommendation appreciated
– Acknowledges benefits - critical for control of mealybug, leafroller,
scale and thrips
– Agree with revised recommendation to retain outdoor use
No. growers No. employees Land area (ha) Total value $(m)
50 150 250 10.7
Persimmon Industry
Thrips feeding damage
Mealy bug with associated
sooty mould damage
Avocado Industry Dr Henry Pak- Technical Manager &
John Cotterell, Grower Avocado Industry Council Ltd
Sector statistics (2011)
Critical use OPCs recommended for retention:
• Acephate, Carbaryl, Chlorpyrifos, Maldison and Pirimiphos methyl - Agree
No. growers No. employees Land area (ha) Total value $(m)
1,600+ 1,062 4,247 82
Compound
Phase out period
(years) Comments
Pirimiphos
methyl
Revised to long
term retention
Agree - critical for control of
leafroller, thrips and scale
Diazinon 10
Disagree - Critical for scale, thrips
and leaf roller control
Diazinon
• Do not support restriction to 2 applications per year - require 4 per year
for thrips control
• No alternatives available that meet market restrictions
• Request reassessment 2 years prior to phase out to ensure alternatives are
available
Pirimiphos methyl
• Revised recommendation appreciated
– Acknowledges benefits
– Agree with revised recommendation to retain outdoor use
Avocado Industry
Avocado Industry
Thrips damage
Leafroller damage
Citrus Industry Rick Curtis - Chairman
New Zealand Citrus Growers Incorporated
Sector statistics (2011)
Critical use OPCs recommended for retention:
• Acephate, Malathion/maldison, Pirimicarb and Diazinon – Agree
• Acephate only option for control of Citrus Flower Moth
• NZCGI appreciates EPA’s acknowledgement of benefits acephate
provides to regional economy (Northland and Gisborne)
No. growers No. employees Land area (ha) Total value $(m)
421 1,521 (incl seasonal) 999 56.3
Citrus Industry
(A)Lemon bud infested with a citrus flower moth (CFM) larva, (B,C) Citrus flowers damaged by CFM larvae.
Photo: Plant & Food Research [Chhagan et.al., 2009]
Citrus Industry
(A, B, C) Rind-spot damage on immature lemon fruit. Photo: Plant & Food Research [Chhagan et.al., 2009]
Strawberry Industry Peter McIntyre- Strawberry Growers New Zealand
Sector statistics (2011)
Critical use OPCs recommended for retention:
• Chlorpyrifos and Methomyl and Pirimicarb – Agree
• Diazinon: Request reassessment 2 years prior to phase out to ensure alternatives are available
• Methomyl: New information from DuPont - request EPA re examine REI & reduce to 24 hours
No. growers No. employees
Land area
(ha) Total value $(m)
110 7,380 (incl seasonal) 246 48
Compound
Phase out period
(years) Comments
Methomyl
Revised to long term
retention
Agree - critical for control of aphids
and other chewing insects
Diazinon 10
Disagree - Critical control of beetle
and caterpillar
Strawberry Industry
Summerfruit Industry
Dr Stephen Ogden- Market Access Manager
Summerfruit New Zealand
Sector statistics (2011)
Critical use OPCs recommended for retention:
• Carbaryl, Chlorpyrifos and Pirimicarb- Agree
• SNZ appreciates EPA’s acknowledgement of the benefits these
compounds provide industry
No. growers No. employees Land area (ha) Total value $(m)
258 5,500 (inc. packhouses) 1,830 68.5
Tamarillo Industry Robin Nitschke- Manager
New Zealand Tamarillos Growers Assoc. Inc. Sector statistics (2011)
• TPP has had an extreme impact on industry
• Compounds essential for resistance management to control TPP
• Recovery of industry relies on continued use until alternatives registered
• Request reassessment 2 years prior to phase out to ensure alternatives are
available
• Off label use critical
No. growers No. employees Land area (ha) Total value $(m)
50 15 110 1.8
Compound
Phase out period
(years) Comments
Methamidophos 5 Disagree - Critical for TPP control
Diazinon 10 Disagree - Critical for TPP control
Tamarillo Industry
Liberibacter affected fruit (normal fruit on left) and leaves. Tree is still capable of setting fruit, but they are small, insipid and of no economic value. Tree will not return to normal growth patterns.
Sector statistics (2011)
Key crops include*:
• Beans
• Peas
• Field tomato
• Sweet corn
*processed potatoes and carrots covered in other sections
No. growers No. employees Land area (ha) Total value $(m)
680 268 (FTEs) 8,057 256.8
Process Vegetable Industry
Dr Stuart Davis- Leaderbrand & PVNZ
Process Vegetables NZ
Compound
Phase out
period
(years) Comments
Phorate &
terbufos 3 Agree – Assume diazinon retained
Fenamiphos 5
Strongly disagree- Critical for nematode
control in carrots
Methamidophos 5
Disagree - Critical for TPP, green vegetable
bug, aphid, tomato fruit worm (= corn ear
worm) control
Diazinon 10
Disagree - Critical for TPP and grass grub
control
Process Vegetable Industry
Critical use OPCs recommended for retention:
• Chlorpyrifos, Oxamyl and Pirimicarb - Agree
Process Vegetable Industry
Benefits to sweet corn - Methamidophos for GVB control:
• Causes direct feeding damage
• Has challenging physical and behavioural characteristics = hard to
control
• Research started in mid-1990s, ~ 20 years later still no alternatives
Benefits to beans /peas – Diazinon for grass grub control:
• No alternatives
Benefits to field tomato – Methamidophos & Diazinon for TPP control:
• No alternatives, needed for resistance management
Benefits to carrots – Fenamiphos for nematode control
• Benefits of Fenamiphos for nematode control to carrots covered in
Vegetables NZ section
Request reassessment 2 years prior to phase out to ensure alternatives are
available
Potato Industry Dr Stephen Ogden- Psyllid Coordinator
Potatoes New Zealand
Sector statistics (2011)
Critical use OPCs recommended for retention:
• Chlorpyrifos and Pirimicarb - Agree
No. growers No. employees Land area (ha) Total value $(m)
234+ ~2,500 11,717 560.3
Compound
Phase out
period (years) Comments
Fenamiphos 5
Strongly disagree- Critical for potato
cyst nematode (PCN) control
Methamidophos 5
Disagree - Critical for Tomato Potato
psyllid (TPP) and Potato Tuber moth
(PTM) control
Benefits of Methamidophos for TPP control:
• Essential for control of TPP and zebra chip disease - affects both yield and
quality of tubers
• Used as part of a rotation in resistance management program
• Effective due to systemic action when crops at full canopy
• Since arrival of TPP (2006) large investment by PNZ. Total R&D expenditure
~$1.3m over last 2 years
Potato Industry
Benefits of Methamidophos for PTM control:
• Systemic action targets feeding insects - allows foliage to develop
without being attacked by larvae – plant able to produce healthier
larger tubers
• Key component in resistance management of PTM
• Request reassessment 2 years prior to phase out to ensure alternatives are
available
Potato Industry
Benefits of Fenamiphos for PCN control:
• PCN causes cysts to form on potato roots - decreases yields
• Only compound currently registered in NZ for PCN control in potatoes
• PCN can stay in soil for up to 20 years – used where fields have large
numbers of PCN in soil
• Request extended phase out and reassessment 2 years prior to phase out
to ensure alternatives are available
Potato Industry
Potato Industry
Potato cyst nematode
Increasing severity scale of zebra chip disease - makes potatoes unsaleable
Potato tuber moth damage
Onion Industry Mick Ahern- Chairman
Onions New Zealand Sector statistics (2011)
Above includes garlic and shallots
Critical use OPCs recommended for retention:
• Chlorpyrifos – Agree
• Onions not a minor crop in NZ but garlic and shallots are
No. growers No. employees Land area (ha) Total value $(m)
143 1,500 5,325 144
Compound
Phase out
period (years) Comments
Methamidophos 5
Agree - alternatives will be registered
for use in onions within 5 years
Greenhouse Industry Lex Dillon (NZ Hothouse) and Ben Smith (Status)
Tomatoes NZ & Vegetables NZ
Sector statistics (2011)
Above includes other glasshouse crops (Tomato, Capsicum, Chilli, Cucumber, Melon, Eggplant, Witloof
and Courghette)
Critical use OPCs recommended for retention:
• Oxamyl, Methomyl and Pirimiphos methyl – Agree
Controls:
• Control wording ambiguous
– “Automatic application methods” EPA explanation = semi automatic
but wording is “automatic” = confusing
– Difference between hand gun & knapsack (Handgun prohibited)
No. growers No. employees Glass house area (ha) Total value $(m)
365 ~1,450 175 188.7
Vegetable Industry Dr Stuart Davis- Director: Leafy Crops
Vegetables New Zealand
Sector statistics (2011)
Vegetables NZ represents range of crops - key crops impacted are:
• Brassica
• Celery
• Carrots and parsnips
• Kumara
• Lettuce/ baby leaf
• Cucurbit and squash
• Note that greenhouse capsicums are covered under greenhouse
Critical use OPCs recommended for retention:
• Acephate, Chlorpyrifos, Malathion/maldison, Methomyl, Oxamyl,
Pirimicarb and Pirimiphos methyl - Agree
No. growers No. employees Land area (ha) Total value $(m)
1,038 1,880 16,820 272.4
Vegetable Industry
Compound
Phase out period
(years) Comments
Phorate 3 Agree – Assume diazinon retained
Terbufos 3
Strongly disagree – Critical for symphilid,
stem weevil and wireworm control in
Kumara and grass grub in carrots
Methamidophos 5
Disagree - Critical for black beetle and
white fringed weevil control in kumara
Fenamiphos 5
Strongly disagree – Critical for nematode
control in carrots
Diazinon 10
Disagree – Critical for springtails and
symphilid control in Baby leaf, Grass grub,
manuka beetle, porina, carrot rust fly and
springtail in carrots and grass grub, black
beetle, white fringed weevil and wireworm
in Kumara & Celery
Vegetable Industry
Celery- Diazinon
• Can accept phorate phase out if diazinon is retained for control of carrot
rust fly.
• Request reassessment 2 years prior to phase out to ensure alternatives are
available
Lettuce/ baby leaf – Methomyl
• Industry agrees with revised recommendation to retain - benefits
outweigh risks.
• Support Dupont request to shorten REI
Carrot and parsnips: Fenamiphos
• Seriously impacted by proposal to phase out fenamiphos = only product
to control nematodes
• Commercial future production in NZ in jeopardy if phased out before
alternatives found = import carrot and parsnip
• Request phase out increased to 10 years and reassessment 2 years prior to phase out to ensure alternatives are available or increase phase-out to
10 years
• EPA revised benefit of fenamiphos to carrot and parsnips as being high -
industry agrees
• Application restricted to authorized person control = not practical =
nematodes not new pest to trigger Biosecurity Act
Vegetable Industry
Vegetable Industry Andre De Bruin - Vice Chair & Director: Root & Tuber Crops
Vegetables New Zealand
Kumara: Terbufos
• 45 Kumara growers who employ 545 FTEs with industry value $25m-
significant to Kaipara region
• Used pre-plant to reduce larvae in soil – insects attack hairs of developing
plants, cause stunting, later direct damage to tuber
• Symphilid not known pest in other countries plus very minor crop = little to
no research done internationally
• Efficacious - granule formulation type = better pest control than liquid
• Long history of cultivation (over 500 years) special cultural significance -
taonga status - acknowledged in Waitangi tribunal Y262
• If domestic kumara production ceased, because fresh kumara cannot
be imported, no longer part of NZ diet
• Negative effect on employment in Northland region
Request reassessment 2 years prior to phase out to ensure alternatives are
available or increase phase-out to 10 years
Vegetable Industry
An example of black beetle damage on kumara tubers
An example of nematode forking
Proposed controls
• In general, can meet proposed controls due to strong uptake of
Growsafe in industry
• Industry appreciates removal of droplet size restrictions
• Issues:
– Implications for off label use on minor crops
– Limiting number of applications of diazinon (2 per year avocado)
– Application frequencies limited to per year instead of per crop cycle
– Impractical notification requirements – 2 day
– EPA explanation allows semi-automatic application, change
appreciated but needs better wording
– Buffer zone recommendations – apply to wide dispersal applications.
Ground based boom not wide dispersive.
– Still have some issues with buffer zone specifications – some
movement possible with option for an approved COP
Proposed Controls Phase out timeframes
If no alternatives, industry requests modified reassessment commences 2
years before phase out for:
• Diazinon
• Methamidophos
• Fenamiphos
• Terbufos
Or increase phase out period for:
• Diazinon to15 years
• Methamidophos and Fenamiphos to 10 years
• Terbufos to 10 years
Off label use
• In general, the use of compounds on crops for which there is no label is
legal and allowed
– Must meet the default MRL of 0.1 mg/kg
– A few compounds are restricted and can’t be used off label – this
would be the case if there was a possible dietary intake concern
– Minor crop = minor part of diet
• Many of the crops represented here are minor crops = rely on off label
use
• There is not sufficient economic proposition for companies to do research
required to support label
• Therefore it is essential that minor crops are allowed to use OPCs off label
• EPA needs to ensure ACVM will not place restriction on off-label use –
likely due to EPA controls on application parameters
• Industry is leading work to deal with off label registration issues but these
will only apply to new chemistry – requires industry to fund the work
Biosecurity
• Importance for biosecurity seems to be well understood
• Implications - Australia (APVMA) recently banned various OP insecticides
– already resulted in poor control of fruitfly in Australia and impacted on
domestic and export supplies of fruit
• Same situation could occur in NZ – OPs known for their use in incursion
response including fruitfly, citrus psyllid and many others
• Availability of OPCs in incursion unlikely if not in use - product not able to
be stored as shelf life only 2 years, stocks unlikely to be held in NZ
• Emergency registrations would take too long
Issues
• EPA rationale for selection unclear – limited explanation on why
APVMA/USEPA/EFSA figure is chosen.
• APVMA alignment explanation is weak given its importance
• ADI section is given 2 paragraphs on P26 – insufficient given its
importance
• Manufacturers have not focussed on ADI issues as they normally
would given its limited attention by EPA – refer Acephate
reassessment and submissions on ADI = substantial and not
responded to by EPA or referred to in current assessment
• Basis of selection critical due to downstream effects
Acceptable Daily Intake (ADI)
Acceptable Daily Intake (ADI)
ACVM role
• EPA sets ADI, ACVM applies
Outcomes
• 5 compounds exceed ADI based on labelled uses
• Reduced to 3 compounds if only critical labelled uses included
• Extremely difficult for industry to consider response to the overall OPC
recommendations in absence of accurate inter-government information
Implications for minor crops
• Majority of crops supported are used off-label (minor crops)
• Where ADI is exceeded, restriction likely to on-label crops only = overrides
EPA recommendations
ADI Example – Diazinon
• Current NZ ADI = JMPR ADI of 0.005 mg/kg bw/day
• Reassessment = ADI - 0.0002 mg/kg bw/day (US EPA )
• Result of new ADI - ADI exceeded by 1048.6% based on labeled uses
• EPA have recommended 10 year phase out but
• ACVM will revoke MRLs, cancel registrations immediately
Options
• Reduce number of uses – ACVM have modeled only those labeled uses
supported in the reassessment = 510.5% = still exceeded
• Reduce MRLs = expensive especially for 10 year phase out, and
especially for animal residues
• Does not allow for off-label use – this will be restricted
*Same applies to methamidophos and Fenamiphos (with different ADI
figures) exceeded by 228% and 230% respectively
Acceptable Daily Intake (ADI)
Imported Food Inconsistency
• Codex
– NZ strong supporter of international standards including Codex
– NZ accepts Codex MRLs for imported food
– Strong trading advantages in supporting Codex MRLs
– EPA has proposed different ADIs to Codex
– Where ADI value lower than Codex, EPA allowing imported food to
have higher levels than considered acceptable for domestic
• Different levels = not acceptable
– Discriminates against NZ growers
– Benefits imported food producers
Conclusions • Need extended phase out for Fenamiphos, Methamidophos, Diazinon
• Request review 2 years prior to phase out
• Some changes to controls to help with implementation
• Biosecurity is critical and OPCs are important compounds
• Off label use is important – EPA need to ensure off label use is not
restricted by ACVM as a result of the EPA decision
• ADI – request that EPA review their ADI selection,
– provide robust and detailed explanation on selection
– ensure it is appropriate to NZ
– consult on this issue specifically with manufacturers
– resolve the conflict between import and domestic standards
– understand that if ADI’s are not changed in the review, that there will
be impacts on registrations
– this information needs to be known before OPC review is complete
• OPCs are used when absolutely necessary and no other alternatives are
available