SECTOR ASSESSMENT FEEDBACK FORM
Organophosphate and carbamate use in kumara
production
Introduction
In this assessment the EPA has documented what it understands is the current state of the kumara
industry in New Zealand (your sector), based on publicly available information and feedback from the
sector. When complete, this sector assessment will form part of the EPA’s formal application for
reassessment of organophosphate and carbamate insecticides.
To help complete the assessment, we need your input.
This document contains:
 A profile of your sector
 Some information on your sector’s use of organophosphates and carbamates and alternatives you
may use
 A preliminary assessment of the risks
 Possible options for managing risks
We acknowledge this document is not complete. Where there are gaps in our data please
include information to help us fully understand the current situation. We have put some
specific questions in grey boxes throughout the document for you to answer.
We need you to:
 Correct inaccuracies and provide us with additional information about your sector by editing this
document using “tracked changes” or printing the document out and writing onto it.
 Change or add information about yield, sales values, employment figures, major pests, and
insecticide use patterns, in the tables that we have started to populate.
 Answer the questions about your research, pest management programmes, proposed controls,
and the impacts the loss of organophosphates and carbamates would have on your sector.
 Suggest additional or alternative management options (controls) that would be practical and
effective.
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APP201045 Kumara Sector Assessment
Sector profile
We need to know the size and characteristics of your sector to help us understand the extent of the
impact if organophosphate and carbamate insecticides were restricted or removed. The tables below
contain the information we already have. Please add anything that you feel is missing or incorrect.
Size of the sector
Table 1: Sector statistics1
Year
2007
2008
2009
2010
Hectares planted
1,462
1,264
1,264
1,500
Yield (tonnes)
17,500
17,500
17,500
17,500
Main growing region/s
Northland
Table 2: Crop sales value ($ millions) 2
Year
2007
2008
2009
2010
33.8
33.8
33.8
35
Exports (FOB)
Domestic sales
Total sales
Sector demographics
Table 3: Sector demographics1
Year
Number of growers
2002
2007
2008
2009
2010
92
92
75
45
Number of employees
(directly employed )
Number of employees in
supporting businesses (e.g.
packhouses , rural
contractors)
You told us:
Market Access Solutionz, on behalf of the Horticulture New Zealand Fresh Vegetable Product Group
(including kumara), submits that kumara is an important contributor to the regional economy in
Northland. As well as growers, 60-1,000 staff are employed (season dependent). There are five
kumara packhouses in Northland that operate year round, employing 60-120 staff (season
dependent)3.
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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.
Organophosphate and carbamate use
We are interested in the pests for which organophosphate and/or carbamate use is critical to your
sector. Table 4 lists the active ingredients registered for use in your sector, as well as other uses you
have told us about. Please indicate which of these active ingredients you are and are not using, and
add rows to include information for other organophosphates and carbamates that are being used but
are not captured in the table.
Do you use any organophosphates/carbamates on your crop post harvest? If so, please add
this information into Table 4 below, and provide use information by updating Table 6.
We also need you to tell us for which pests the use of organophosphates and carbamates is critical,
and which are able to be managed using alternatives.
Please highlight the pests that are of most concern to your sector. We may have already highlighted
some where we have information to suggest they are significant pests to your industry.
Table 4: Organophosphates and carbamates used on kumara4
Insect pests
Chemical
group
Active
ingredient
Examples of
products
Aphids
OP
Dichlorvos
Divap, Nuvos
Army
caterpillar
OP
Chlorpyrifos
Dichlorvos
Black beetle
OP
Acephate
Chlorpyrifos
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Active in
use (Y/N)
Critical
(Y/N)
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APP201045 Kumara Sector Assessment
Insect pests
Chemical
group
Active
ingredient
Examples of
products
Active in
use (Y/N)
Critical
(Y/N)
Diazinon
Methamidophos
Phorate
Terbufos
Black field
crickets
OP
Maldison
Caterpillars
OP
Dichlorvos
Divap, Nuvos
Methamidophos
Crickets
OP
Methamidophos
Grass grub
OP
Diazinon
Terbufos
Mites
OP
Dichlorvos
Divap, Nuvos
Root knot
nematode
OP
* Fenamiphos
Canyon, Nemacur,
Nematak 400EC
Stem weevil
OP
Phorate
Terbufos
Symphilids
OP
Phorate
Terbufos
Tomato potato
psyllid
White-fringed
weevil
OP
Diazinon
Wireworm
OP
Diazinon
Phorate
*Registered for use on this crop
You told us:
The fresh vegetable sector has told us that kumara crops are often subject to pest pressure from
neighbouring crops. These pests include cricket, black beetle and caterpillar pests.
Tomato/potato psyllid (TPP)
The tomato/potato psyllid (TPP) Bactericera cockerelli [Sulc] is a pest of solanaceous crops and may
breed on kumara, especially if there are large populations of TPP nearby. TPP transmits a bacterial-
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APP201045 Kumara Sector Assessment
like disease called Liberibacter (Candidatus Liberibacter solanacearum) and may transmit
phytoplasma (Candidatus Phytoplasma australiense); both of these micro-organisms cause plant
damage. Market Access Solutions submits that in the years of high pest pressure, if pests are
uncontrolled this results in an average 50% loss of yield due to tuber damage. This can amount to
$16-$18,000/ha for the grower3,5.
Non organophosphate and carbamate use
Table 5 lists the non-organophosphate/carbamate insecticides used on kumara against the same
pests as the organophosphates and carbamates listed in Table 4. These substances are considered
to be possible alternatives. Please indicate which active ingredients you are and are not using, and
add information for those that are being used but are not captured in the table.
Table 5: Non-organophosphates/carbamates used on kumara against identified pests4
Insect pests
Chemical
group
Active ingredient
Examples of products
Black beetle
Neonicotinoid
*Clothianidin
Poncho
*Imidacloprid
Acclaim, Gaucho, Gaucho
(seed treatment),
Sombrero 600 Seed,
Dressing
*Lambdacyhalothrin
Cyhella
*Imidacloprid
Acclaim (seed treatment)
*Beta-cyfluthrin
Tempo
*Lambdacyhalothrin
Cyhella, Halex CS
Synthetic
pyrethroid
Black beetle
(adult)
Active being
used (Y/N)
Neonicotinoid
Synthetic
pyrethroid
*Registered for use on this crop
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.
The Fresh Vegetable Sector submits that the control of certain insect pests including black beetle and
caterpillar pests is very problematic. Particularly due to pest pressures from neighbouring crops. It is
submitted that OPs are the only efficacious group for control of certain pests. The industry indicates that,
due to its more efficacious control of black beetle, they would prefer to retain the use of methamidophos
over the other three organophosphates. Comments by this sector on methamidophos, dichlorvos and
diazinon in kumara are summarised below6.
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APP201045 Kumara Sector Assessment
Methamidophos:
During humid tropical weather there is a high pest pressure put on the kumara crops from neighbouring
crops. Therefore a well timed methamidophos application is essential.
Where possible softer chemistry is used and scouting programmes to ascertain pest pressure and
beneficial insect level are undertaken prior to spraying with methamidophos. This industry sprays on need.
Methamidophos is a very important clean up product when other sprays are not achieving results.
Methamidophos preserves the quality of produce against insect damage and as consumers demand a
high quality product, this compound is essential.
In a field trial conducted in the 2010 summer in fresh ground there was 0% marketable kumara in the
treatment 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 3,6.
Dichlorvos:
The continued use of dichlorvos for some vegetables is key to controlling pests close to harvest. It is the
only product that can be used within 3 days of harvest and is used to ensure that pests are not internally
infesting crops. The insects will hide in between the leaves or in stems and contact insecticides will not be
successful in controlling them. A fumigant type activity is required to kill these pests very close to harvest.
If the pests are not adequately controlled, harvested vegetables will be rejected due to the presence of
insects or damage. Dichlorvos is the best organophosphate option when bees are present. Chlorpyrifos is
an alternative but has a 10 day withholding period compared with dichlorvos at 3 days. A 3 day
withholding period is required and there are no alternatives which provide this.
In kumara, dichlorvos is used in years when cracks in the ground due to the growth of tubers near harvest
means the tropical armyworm attacks the crop in high numbers. A product with a short withholding period
is needed to quickly control the pest without disrupting harvest. The product is only used in years when
this is an issue and there are no alternatives to dichlorvos that provide the necessary control close to
harvest7.
Diazinon:
Kumara growers do not look at diazinon in isolation when devising pest management programmes. They
instead look at target pests such as white fringed weevil, black beetle, grass grub and wire worm and then
use insecticides that to provide economic control of these pests.
Producing a marketable kumara crop is challenging, as when climatic conditions are favourable, large
flights of black beetle from surrounding paddocks (e.g. surrounding pasture, particularly sand country)
come into kumara crops, and this is when diazinon and/or methamidophos are the only effective
chemicals to avoid massive crop damage and subsequent loss as a result of direct tuber drilling by the
insects3.
Synthetic pyrethroids are not efficacious. They are already used for early season cutworm control where
summer pest pressure is high. The industry is cautious not to rely solely on synthetic pyrethroids due to
resistance management issues6.
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
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APP201045 Kumara Sector Assessment
carbamates. This could include a description of cultural or chemical control methods
that have been tried in the past and 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).
Example: Collectively New Zealand growers spend $x each year on research of which $y is spent
researching pest control. Currently projects are underway to establish the potential for...
4. List pests that are likely to pose a future threat to your sector, and comment on what is being
used to combat them elsewhere. This could include existing and potential pests.
Modelling risks on current use
Table 6 summarises our understanding of your sector’s use patterns for organophosphates and
carbamates. These use patterns are the basis for our preliminary risk assessment. Use patterns were
drawn from label statements as well as from industry feedback.
You have told EPA about several use patterns but not the application rate, without which we cannot
evaluate risks from use.
The EPA has only assessed the risks for the use patterns it has information about. Uses will
be restricted to those described in Table 6 unless we receive further information.
If your use patterns are different to those shown in Table 6, please amend the table. Please indicate
which rows are incorrect or not relevant to your sector. If rows in Table 6 are incomplete, please
complete them. If you have use patterns not covered by any of the rows in the table, please add extra
rows to describe the additional use pattern.
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APP201045 Kumara Sector Assessment
Table 6: Organophosphate and carbamate use data in kumara production
In the final column please indicate whether the scenario is relevant in your sector.
Key: Indicate Relevant , Not relevant X, Relevant as modified ().
You may modify a scenario using tracked changes so that we can see how it differs from the original, or add a row into the table.
Pest
Active
ingredient
Application
method
Source of use
information
Formulation
type
Application
rate
(g/ha)
Application
frequency
(per
season)
Application
interval
(days)
Application
area
(ha/day)
Kumara1
Army
caterpillar
Chlorpyrifos
Boom
Industry data
Liquid
250
2
7
20
Kumara2
Army
caterpillar
Chlorpyrifos
Boom
Industry data
WSB
250
2
7
20
Kumara3
Army
caterpillar
Dichlorvos
Boom
Industry data
EC
570
1
20
Kumara4
Beetles
Phorate
Drill
Industry data
Granule
2200
1
20
Kumara5
Black
beetle
Acephate
Boom
Plant and Food
Report
WSP
750
1
20
Kumara6
Black
beetle
Chlorpyrifos
Boom
Industry data
Liquid
250
2
7
20
Kumara7
Black
beetle
Chlorpyrifos
Boom
Industry data
WSB
250
2
7
20
Kumara8
Black
beetle
Diazinon
Unknown
Industry data
EC
unknown
2
21
20
Kumara9
Black
Diazinon
Spread
Industry data
Granule
300
1
Use
scenario
number
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Relevance
to sector
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APP201045 Kumara Sector Assessment
Use
scenario
number
Pest
Active
ingredient
Application
method
Source of use
information
Formulation
type
Application
rate
(g/ha)
Application
frequency
(per
season)
Application
interval
(days)
Application
area
(ha/day)
beetle
Kumara10
Black
beetle
Methamidophos
Boom
Plant and Food
Report
SC
600
1
Kumara11
Black
beetle
Methamidophos
Boom
Industry data
SC
720
3
14
20
Kumara12
Black
beetle
Methamidophos
Boom
Plant and Food
Report
SC
900
3
14
20
Kumara13
Black
beetle
Terbufos
Drill
Industry data
Granule
1500
1
Kumara14
Black field
crickets
Maldison
Aerial
granule
Industry data
Granule
150
2
Kumara15
Black field
crickets
Maldison
Spread
Industry data
Granule
150
1
Kumara16
Caterpillars
Methamidophos
Boom
Industry data
SC
720
3
14
20
Kumara17
Crickets
Methamidophos
Boom
Industry data
SC
720
3
14
20
Kumara18
Grass grub
Diazinon
Unknown
Industry data
EC
unknown
2
21
20
Kumara19
Grass grub
Diazinon
Spread
Industry data
Granule
300
1
20
Kumara20
Grass grub
Terbufos
Drill
Industry data
Granule
1500
1
20
Kumara21
Root knot
Fenamiphos
Boom
Label
EC
8000
1
20
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20
20
7
20
20
Relevance
to sector
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APP201045 Kumara Sector Assessment
Use
scenario
number
Pest
Active
ingredient
Application
method
Source of use
information
Formulation
type
Application
rate
(g/ha)
Application
frequency
(per
season)
Application
interval
(days)
Application
area
(ha/day)
nematode
Kumara22
Root knot
nematode
Fenamiphos
Boom
Industry data
Liquid
8000
1
20
Kumara23
Stem
weevil
Phorate
Drill
Industry data
Granule
2200
1
20
Kumara24
Stem
weevil
Terbufos
Drill
Industry data
Granule
1500
1
20
Kumara25
Symphilids
Phorate
Drill
Industry data
Granule
2200
1
20
Kumara26
Symphilids
Terbufos
Drill
Industry data
Granule
1500
1
20
Kumara27
Unknown
Acephate
Boom
Plant and Food
Report
WSG
776
2
7
20
Kumara28
Whitefringed
weevil
Diazinon
Unknown
EC
unknown
2
21
20
Kumara29
Whitefringed
weevil
Diazinon
Spread
Granule
300
1
Kumara30
Wireworm
Diazinon
Unknown
Industry data
EC
unknown
2
Kumara31
Wireworm
Diazinon
Spread
Industry data
Granule
300
1
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Industry data
Industry data
20
21
20
20
Relevance
to sector
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APP201045 Kumara Sector Assessment
Use
scenario
number
Kumara32
Pest
Active
ingredient
Application
method
Source of use
information
Formulation
type
Application
rate
(g/ha)
Application
frequency
(per
season)
Wireworm
Phorate
Drill
Industry data
Granule
2200
1
EC emulsifiable concentrate
SC suspension concentrate
WSP water soluble powder
WSG water soluble granule
WSB water soluble bag
May 2012
Application
interval
(days)
Application
area
(ha/day)
20
Relevance
to sector
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APP201045 Kumara Sector Assessment
Risks
Overview
The EPA has evaluated the risks to operators, re-entry workers, bystanders, the aquatic environment,
birds and bees from using these substances. All risk assessment results in this document should be
considered preliminary as they may change with additional feedback. The final risk assessment
results will be presented in the reassessment application.
Results are described as risk quotients (RQs) which compare predicted exposures and maximum
concentrations that will not cause adverse effects. All risk quotients have been normalised so that
RQs above 1 exceed the EPA’s Level of Concern where effects are likely to be seen.
Data gaps
There are significant data gaps that affect our understanding of the risks that fenamiphos pose to both
human health and the environment. Our risk assessment for fenamiphos could be refined if additional
data about its dermal absorption was provided. In the absence of information the EPA has assumed
that 50% of the fenamiphos in both the product and the spray would be absorbed through skin.
5. Please provide information about the dermal absorption of fenamiphos, and reference or attach
your sources.
Risk modelling
This section summarises our understanding of the risks of organophosphates and carbamates based
on modelling of the risks to human health and the environment.
Figures 1 and 2 show the maximum and minimum risk quotients for your sector’s use of each active
ingredient. Both figures depict risks assuming that operators wear full Personal Protective Equipment
(chemical resistant gloves, coveralls, sturdy footwear, a hood and visor), that re-entry workers do not
enter the crop for 24 hours after spraying and that Good Agricultural Practice is followed.
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APP201045 Kumara Sector Assessment
Figure 1: Maximum Risk Quotients (the black line indicates the level of concern)
100000
10000
1000
Max of Operator (Full PPE)
100
Max of Re-entry worker (no
gloves)
10
Max of Bystander
1
0.1
0.01
Max of Aquatic
Max of Birds
Max of Bees
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APP201045 Kumara Sector Assessment
Figure 2: Minimum Risk Quotients (the black line indicates the level of concern)
100000
10000
1000
Min of Operator (Full PPE)
100
Min of Re-entry worker (no
gloves)
10
Min of Bystander
1
Min of Aquatic
0.1
0.01
Min of Birds
Min of Bees
Quantitative estimates of risk to operators, re-entry workers, bystanders, the aquatic environment,
birds and bees have been made for all use scenarios except where the risks are assumed to be
negligible, namely:
 Re-entry workers, bystanders and environmental risks arising from drilling granules (phorate and
terbufos).
 Re-entry workers, bystanders, aquatic environment and risks to bees from spreading granules
(maldison, diazinon).
Maximum RQ values across your sector’s range of use scenarios are shown in Figure 1. These are
worst-case scenarios generally indicating high application rates and frequency. If the maximum RQ is
less than one, no additional risk management is needed, but if the RQ is greater than one, risk
management will be needed for at least some uses.
The minimum RQs depicted in Figure 2 indicate the best-case scenarios across your sector’s use of
these substances i.e. the lowest rates and safest formulations. Substances for which the minimum
RQ is greater than one for one or more endpoints require risk management.
Information and assumptions used for modelling risks can be found in the accompanying Background
Document.
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APP201045 Kumara Sector Assessment
Possible risk management options
It is possible that additional controls could help to manage the risks posed by organophosphates and
carbamates. The EPA has evaluated some possible controls to help reduce risks for each of the usescenarios. This could mean that for some substances uses with low risks would be retained while
others may require additional risk management.
Possible risk management options are listed in Table 7. Appendix A describes the possible options in
more detail and defines terms used in Table 7. Existing controls will continue to apply to a substance.
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APP201045 Kumara Sector Assessment
Table 7: Possible options for reducing risks for organophosphate and carbamate use on kumara
Substance
General
Operator
Chemical
class
identification
RPE (in
addition
to full
PPE)
Re-entry
worker
Closed
mixing /
loading
system
Closed cab
application
Minimisation
of dust or fine
particles
Bystander/
Aquatic
Maximum
application
rates (g
a.i./ha)
Re-entry
interval
Buffer
zone (m)
Concerns still exist
for:
Acephate (boom,
WSG)
Yes
Yes
Yes
776
24 h
Yes
Re-entry
Acephate (boom,
WSP)
Yes
Yes
Yes
750
24 h
Yes
Re-entry
Chlorpyrifos (boom,
liquid)
Yes
250
Yes
Aquatic
Chlorpyrifos (boom,
WSB)
Yes
250
Yes
Aquatic
Diazinon (boom,
liquid)
Unknown application rate – unknown risks
Diazinon (spread,
granule)
Yes
Dichlorvos (boom,
liquid)
Yes
Fenamiphos
(boom, liquid)
May 2012
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Operator, even with
additional controls
Birds
300
570
8000
24 h
48 h
Yes
Yes
Aquatic Bees
Operator, even with
additional controls Reentry Bystander Aquatic
Birds Bees
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APP201045 Kumara Sector Assessment
Substance
General
Operator
Chemical
class
identification
RPE (in
addition
to full
PPE)
Re-entry
worker
Closed
mixing /
loading
system
Closed cab
application
Minimisation
of dust or fine
particles
Maximum
application
rates (g
a.i./ha)
Bystander/
Aquatic
Re-entry
interval
Buffer
zone (m)
48 h
Yes
Concerns still exist
for:
Maldison (aerial,
granule)
Yes
Yes
150
Maldison (spread,
granule)
Yes
Yes
150
Methamidophos
(boom, liquid)
Yes
Yes
Phorate (drill,
granule)
Yes
Yes
Yes
Yes
2200
Operator, even with
additional controls
Terbufos (drill,
granule)
Yes
Yes
Yes
Yes
1500
Operator, even with
additional controls
Yes
Yes
900
Operator, even with
additional controls Reentry Aquatic
For your sector our preliminary risk assessment indicates there are substances which are still of concern for human health and the environment even after
additional controls have been considered.
The risk management options in Table 7 are based on an assessment of the substances’ risks alone. Data you provide on actual use patterns, alternative
risk information and additional controls will help us to re-evaluate this risk assessment.
We know that many of these substances have significant benefits, and the final decision on their future use will consider their risks, costs and benefits.
However, if the benefits are not shown to outweigh the risks phase out may be triggered for some uses.
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What is the impact?
We need your input about the practicality of the possible risk management options and, if these
controls are impractical, we are asking you to suggest alternatives to manage the risks.
When answering the questions below please consider what the impact on your sector would be if the
options above were applied. Please supply information to support your assessment.
6. Which of the possible risk management options in Table 7 would be workable if they
were implemented in your sector? Please describe how you could make them work in
the field.
Example: We always apply downwind buffer zones when applying these substances. Or: Wearing
respirators during application could reduce risks in a similar way to closed cab application, and is a
cheaper option for us.
7. If you think that any of the possible risk management options in Table 7 are not
workable please explain why.
Example: The maximum application rate is too low to control XYZ insect populations. Or: We often need
to re-enter fields during the summer within the first 24 hours to apply irrigation.
Be specific
In the questions below we are asking you to indicate what economic impact the possible risk
management options would have e.g. how a lower application rate would affect your costs or, if the
controls are unworkable, what effect the phase out of a substance would have.
Much of the feedback that we have received to date has included generalisations such as, “without
organophosphates our crop would be decimated”, and localised facts like, “without organophosphates
my farm would lose $70,000 per year”. This feedback is useful to give us an idea of the nature and
extent of the problem, but we need more information to help us understand the effect of the changes
on your sector.
Please include the type of information provided in the example below when responding to questions 7
to 10.
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APP201045 Kumara Sector Assessment
You have told us:
In the years of high pest pressure, if pests are uncontrolled this results in an average 50% loss of
yield due to tuber damage. This can amount to $16-$18,000/ha for the grower3,5 Also that in a field
trial of methamidophos conducted in 2010 there was 0% marketable kumara in the treatment that had
no organophosphate applications, due to black beetle damage6.
Any additional information, particularly the basis for these calculations would be valuable.
8. 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.
9. How would the possible risk management options affect your production costs?
10. Please describe how employment in your industry would be affected if the risk
management options were implemented and if high risk uses of some substances
were phased out. If possible indicate changes to on-farm and off-farm employment
separately.
11. How would the possible options affect production/yield, and your income or the value
of your sector? Include information for the possible loss of high risk uses requiring
the substitution of alternatives. Please quote average per annum figures and show
your workings.
May 2012
21
APP201045 Kumara Sector Assessment
12. Comment on how any impacts would change with time. Would the impact on yield
and value of implementing the possible risk management options be short term or
long term, and would the effects increase or decrease over time?
Example: If application rates were reduced we would see little difference in yield short term, but over time
pest pressure would increase along with costs. Yield and value may reduce in the mid-term until effective
alternatives were available.
Alternative options to manage risks
In Table 7 we have outlined a range of possible options for managing the risks of organophosphate
and carbamate use on kumara. We are interested in any alternative measures to manage these risks
which may be more appropriate. You may have existing obligations under product stewardship or
good agricultural practice schemes that you think address the concerns that we have identified. Less
toxic alternatives may have been identified which the sector is planning to adopt. It may also be
possible to reduce the levels of exposure through use of specific technology like recapturing
application equipment which applies less substance within a treatment area. There may also be
alternative management strategies that you might use.
13. Please suggest other control measures to reduce the risks of using organophosphates and
carbamates. Provide us with specific details which will enable us to evaluate the impact of
your proposals. For example include details of reduced exposure that would be achieved by
lowering application rates to a specified amount, reducing applications to an identified
number, or using recapture technology. Explain what mix of management techniques and/or
alternative substances you would prefer to use. Make sure that you explain which
substances the controls would apply to, and if they are stand-alone measures or
implemented as a suite of controls.
Substance
Proposed risk management option
How this would reduce risks
14. How effective would your alternative management strategy be in terms of pest
control?
May 2012
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APP201045 Kumara Sector Assessment
15. How would your alternative options affect production/yield, costs, employment and
your income or the value of your sector? Please show your workings and use
average per annum figures.
16. Comment on how any impacts of your alternative risk management strategy would
change with time. Would the impact on yield and value of implementing your strategy
be short term or long term, and would the effects increase or decrease over time?
We welcome all feedback.
Please respond by 31 July 2012 either:
 Through your industry body, or
 Directly to the EPA by emailing [email protected] or
 faxing to OP Reassessment 04 914 0433
May 2012
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APP201045 Kumara Sector Assessment
Sources
1 Fresh
2 NZ
Facts,2007, 2008, 2009, 2010. Plant and Food Research Institute of New Zealand Ltd.
Horticulture – Barriers to Our Export Trade (November 2010) Prepared by Market Access
Solutionz.
3 Market
Access Solutionz (Horticulture) submission on notified diazinon application.
4 Novachem
5 Plant
New Zealand Novachem Agrichemical Manual website www.novachem.co.nz
& Food Research Report commissioned by ERMA New Zealand for diazinon.
6 Market
Access Solutionz (Horticulture) submission on notified acephate and methamidophos
application.
7
Market Access Solutionz (Horticulture) submission on notified dichlorvos application.
May 2012
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APP201045 Kumara Sector Assessment
Appendix A
Tables 8 and 9 provide explanations of the possible options and definitions of the terms used.
Table 8: Descriptions of possible options for reducing risks
Description
A restriction on the permitted application methods is applied so that the
substance may only be applied using [application method]. This
requirement must be stated on the label.
Application equipment
Buffer Zone
In circumstances where a particular application method poses high risks,
a restriction may be imposed to prohibit that use. Alternatively, in order
to retain a particular use pattern (such as a critical use), use of a specific
application method may be specified.
Application of the substance is only permitted in conjunction with a buffer
zone as described in NZS 8409:2004 The Management of
Agrichemicals, which is available from Standards New Zealand
(www.standards.co.nz or call 0800 STANDARDS). This requirement
must be stated on the label.
A Buffer Zone is the minimum separation distance downwind of an area
where a substance is applied and a sensitive area.
Application of the substance is only permitted using a vehicle equipped
with a fully enclosed closed operator cab, where the cab air intake is
fitted with chemical filters. This requirement must be stated on the label.
Closed cab application
A reduction in the exposure of a person applying a substance can be
achieved by using application equipment where the operator is within a
fully enclosed cab, fitted with chemical filters to ensure that the airsupply for the operator is not contaminated with chemicals.
The substance must be loaded into the application equipment using a
closed system. This requirement must be stated on the label.
Closed loading systems
Granule application restriction
Closed mixing and loading systems can be used in order to remove the
exposure to operators during this phase of the substance lifecycle.
Liquids may be charged to the spray tank using closed pumping systems
in a spray shed, or by charging mechanisms on the sprayer. For
granules used in aqueous sprays, water soluble packaging can be used.
The substance must be applied below the surface of the soil, or be
covered completely with soil immediately after application. This
requirement must be stated on the label.
This restriction will put an obligation on the applicator to ensure that the
substance does not pose a post application risk to birds.
A maximum application rate is set for this substance. This requirement
must be stated on the label.
Maximum application rates
May 2012
The risk assessment for a given substance has been carried out for
particular use parameters. Use of a substance in excess of the
quantities assessed can give rise to greater levels of risk, and as a
25
APP201045 Kumara Sector Assessment
result, the proposed controls may not adequately manage the risks
posed.
This substance must not contain more than 1.5%(w/w) with a particle
size of less than 150 µm.
Minimisation of dust or fine
particles
This condition is to ensure that fine particles or dust are excluded from
the substance, so that handling of the substance does not result in
exposure to dust or fine particles.
In the case of an organophosphate-containing substance, the main label
must clearly identify the substance as containing an organophosphate
chemical; or
Chemical class identification
In the case of a carbamate-containing substance, the main label must
clearly identify the substance as containing a carbamate chemical.
This additional labelling condition will provide clear identification of the
chemical class of the substance, and is to ensure that the end-user is
aware of the type of substance being handled.
Personal Protective Equipment
(PPE)
Respiratory Protective
Equipment (RPE)
Use of specific RPE is prescribed. This requirement must be stated on
the label.
The additional requirement for RPE details the specific minimum
requirements for RPE and are in addition to the requirement for use of
full PPE when handling the substance or entering a treated area within a
REI.
After [date], use of this substance on [crop/sector] is no longer permitted.
Phase-out Period
For substances that have use patterns that are to be phased out, a
period of time is established to provide an opportunity for use or disposal
of the substance. After the Phase-out Period has elapsed, use of that
substance will no longer be permitted for that particular use pattern. For
substances that are used in different sectors, such a restriction may be
imposed for certain uses or application methods in certain sectors, whilst
being retained in others.
Entry into treated areas is not permitted until the Restricted Entry
Interval has elapsed since the end of application of the substance,
unless PPE (and RPE where prescribed for operators) is worn for the
time that the person is within the treated area. This requirement must be
stated on the label.
Restricted Entry Interval (REI)
May 2012
A Restricted Entry Interval (REI) is the period of time which must elapse
after application of a substance before entry into the treated area is
permitted without use of PPE and RPE (as required). Entry into a treated
area before the REI has elapsed is only permitted if full PPE is worn
(and RPE if required for application of the substance). Additionally, the
entry restriction may limit the tasks that may be carried out within the
treated area, and the time per day that a person may spend in the
treated area within the REI.
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APP201045 Kumara Sector Assessment
Table 9: Definitions of terms used in the possible options
Description
Implementation Period
It is appropriate to allow a period of time in order to implement any
changes of controls applied to a substance. If an Implementation Period
is specified, then the controls that currently apply to a substance are
valid until the end of the implementation period. Once the
Implementation Period has elapsed, any new controls, or changes to the
existing controls, must be followed.
PPE is protective equipment that is specifically designed to prevent nonrespiratory exposure of a person handling chemicals.
Full PPE constitutes the following clothing and equipment:
Personal Protective Equipment
(PPE)
Respiratory Protective
Equipment (RPE)
 Chemical resistant gloves;
 Coveralls;
 Sturdy footwear;
 A hood and visor.
RPE is protective equipment that is specifically designed to prevent
exposure of the respiratory system to chemicals, such as using a
respirator fitted with an appropriate chemical filter.
A sensitive area is a location that may be sensitive to drift of an applied
substance. Sensitive areas include:
 Residential buildings and areas;
Sensitive area (definition)
 Private property;
 Places where public may lawfully be (e.g. schools, parks,
playgrounds, day care facilities, prisons, hospitals, nursing homes);
 Waterways.
Waterway (definition)
May 2012
A waterway includes modified water courses such as reservoirs,
irrigation canals, water supply races, canals for supply of water for
electricity generation or farm drainage canals, as well as natural water
bodies.
27
APP201045 Kumara Sector Assessment
Appendix B
Table 10: Risk quotients from modelling risks of using organophosphates and carbamates on kumara
Re-entry
worker
Operator
Use
scenario
number
Full
PPE
RPE
Closed
cab
Birds
Full PPE
No
mix/load
Full PPE
RPE
No
mix/load
Full PPE
Closed
cab
No
mix/load
Full PPE
RPE
Closed
cab
No
mix/load
No
gloves
With
gloves
Bystander
Full PPE
Full
PPE
RPE
Full
PPE
Closed
cab
Kumara1
0.019
0.0081
0.0073
0.0024
0.013
0.0063
0.0013
0.00063
0.32
0.067
0.079
Kumara2
0.013
0.0063
0.0013
0.00063
0.013
0.0063
0.0013
0.00063
0.32
0.067
Kumara3
4.1
3.8
1.2
1.1
3.1
3
0.31
0.3
98
Kumara4
28
4.8
Kumara5
21
8.1
16
3.9
4.8
4.6
0.48
0.46
Kumara6
0.019
0.0081
0.0073
0.0024
0.013
0.0063
0.0013
Kumara7
0.013
0.0063
0.0013
0.00063
0.013
0.0063
0.0013
Kumara8
Unknown application rate – unknown risks
Kumara9
9.6
1.2
Kumara10
12
9.5
4
2.8
9.2
7.4
0.92
0.74
240
50
20
Kumara11
15
11
4.8
3.4
11
8.9
1.1
0.89
440
91
12
May 2012
Aquatic
Bees
Min
Max
1100
3.7
14
85
0.079
1100
3.7
14
85
20
1.6
160
4.5
17
390
150
31
7.3
0.22
0.33
1.2
13
0.00063
0.32
0.067
0.079
1100
3.7
14
85
0.00063
0.32
0.067
0.079
1100
3.7
14
85
0.59
2200
20000
3.3
13
8.8
18000
5.3
20
11
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APP201045 Kumara Sector Assessment
Kumara12
18
14
6
4.2
14
11
1.4
1.1
550
110
45
62000
6.7
25
13
Kumara13
48
8.2
Kumara14
0.033
0.0067
Kumara15
0.036
0.008
Kumara16
15
11
4.8
3.4
11
8.9
1.1
0.89
440
91
12
18000
5.3
20
11
Kumara17
15
11
4.8
3.4
11
8.9
1.1
0.89
440
91
12
18000
5.3
20
11
Kumara18
Unknown application rate – unknown risks
Kumara19
9.6
1.2
0.59
2200
Kumara20
48
8.2
Kumara21
160
160
49
47
130
120
13
12
4000
830
190
270
1100
2500
570
Kumara22
160
160
49
47
130
120
13
12
4000
830
190
270
1100
2500
570
Kumara23
28
4.8
Kumara24
48
8.2
Kumara25
28
4.8
Kumara26
48
8.2
Kumara27
7.6
5.9
3.1
1.6
5
4.8
0.5
0.48
250
52
12
0.42
0.48
1.8
13
0.59
2200
Unknown application rate – unknown risks
Kumara28
Kumara29
9.6
Kumara30
Unknown application rate – unknown risks
May 2012
1.2
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APP201045 Kumara Sector Assessment
Kumara31
9.6
1.2
Kumara32
28
4.8
May 2012
0.59
2200