APRIL 2014
WORKING WITH VERTEBRATE TOXIC AGENTS
3
Contents
WORKING WITH
VERTEBRATE TOXIC
AGENTS
Introduction 4
Training, licences and permissions 6
Communication 11
Warning signs at operations 13
Safety gear 17
Storage 19
Transport 22
Disposal 24
Tracking 25
Emergencies 27
Further information 32
Disclaimer 34
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Introduction
Vertebrate toxic agents (VTA) are substances that are designed to kill animals
with back-bones, such as rats, stoats, rabbits, feral pigs and possums. They
are highly dangerous if not used or stored correctly. Their use is controlled by
legislation including:
the Hazardous Substances and New Organisms Act 1996 (HSNO)
the Agricultural Compounds and Veterinary Medicines Act 1997 (ACVM)
the Health and Safety in Employment Act 1992 (HSE)
the Resource Management Act 1991
the Land Transport Rule: Dangerous Goods 2005.
These laws are designed to protect users, other people and the environment. This
guide is intended for people who use VTAs, such as cyanide, 1080, PAPP, DRC1339,
cholecalciferol, brodifacoum and MZP. It covers VTAs used in the field, or for
making baits, but not substances used for the manufacture of other products.
It gives a summary of the most important rules under HSNO that you need to
follow to stay safe, but does not represent legal advice.
The first places to look for
information on staying safe
are the product label and
safety data sheet (SDS) for
your VTA.
Staying safe with VTAs – where to start
The first places to look for information on
staying safe are the product label and safety
data sheet (SDS) for your VTA. These will provide
information on the hazards of the product and
how to manage them. You need to make a
list, or inventory, of all the VTAs you have, the
amounts you have and their hazards.
Under HSNO, VTAs are classified according to their hazards. The hazard
classification is important for identifying which rules apply to your VTA and
what you need to do to manage them. The rules vary according to the hazard
classifications, amount and approval conditions of the VTAs you use or store. They
can also vary with different application methods. The hazard classifications should
be in section 2 of the SDS for your VTA. The HSNO approval number is usually in
section 15 of the SDS.
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You can get more information on how to use VTAs safely from the Environmental
Protection Authority (EPA) website – www.epa.govt.nz – including:
detailed information about all the rules that apply to your VTA – from the
Approved hazardous substances with controls database
general guidance on the amount of each VTA you can store before triggering
rules about storage, transport and other matters – search for HSNO threshold
quantities.
It is important that you check the approval for all VTAs you use. This booklet
does not provide information on all the rules that may apply. Examples of other
rules include:
bait colour
keeping people out of the application area
keeping records of VTA use
the distance baits must be kept from waterways.
Staying safe with VTAs – the basics
Read and follow the safety information given on product labels and SDS.
Know the rules for the VTAs you intend to use and store.
Make sure you and your staff are trained to use VTAs.
Always wear the right safety gear for your VTAs.
Look after your safety gear and replace it before it wears out.
Plan and practise your response to emergencies.
Store VTAs under lock and key and put up warning signs.
Transport VTAs according to the rules.
Dispose of unused VTAs and containers properly.
Communicate with and notify people who could be affected by your VTAs
before using them.
Post warning signs at the treatment area.
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Training, licences and permissions
You must know about each VTA you use and any risk it poses. To use and handle
VTAs you must be trained. You must have an approved handler test certificate to
use most VTAs. For some VTAs you’ll also need
a controlled substance licence (CSL), which
You must know about each
shows that you are a ‘fit and proper’ person
VTA you use and any risks it
to use or have them in your possession.
poses. To use and handle
VTAs you must be trained.
Approved handler test certificates
An approved handler is someone who has
been certified to use very hazardous substances. In order to be an approved
handler you must show that you know about:
the hazards of the VTA you use and how to protect people and the
environment
the operating equipment, safety gear and protective clothing needed
what to do in an emergency involving the VTA
the HSNO legislation and how it applies to your VTA.
You will need an approved handler test certificate to use:
sodium cyanide or potassium cyanide (cyanide)
sodium fluoroacetate (1080)
phosphorous
3-chloro-p-toluidine hydrochloride (DRC 1339)
microencapsulated zinc phosphide (MZP)
para-aminopropiophenone (PAPP)
most pindone products
rotenone cube root powder
encapsulated sodium nitrite (ESN)
alpha-chloralose – solid for making baits
bromadiolone liquid bait
magnesium phosphide – if you have more than 3 kg of pellets
aluminium phosphide – if you have more than 3 kg of pellets.
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An approved handler test certificate is issued by a test certifier. A test certifier is
an independent service provider who is recognised as an industry expert and has
been approved by the EPA to issue test certificates. You can find a test certifier on
the EPA website – www.epa.govt.nz under the Search our registers tab. Approved
handler test certificates are valid for five years.
You will need training to get the skills and knowledge needed to be an approved
handler. This could be on the job training or through an industry training
organisation.
Controlled substance licences
A CSL is required to use the most hazardous VTAs and ensures that only qualified
’fit and proper’ people can use them. You need a CSL to use:
1080
PAPP
cyanide
MZP
phosphorus
DRC 1339
pindone soluble concentrate 34 g/l – required under ACVM
magnesium phosphide – if you have more than 3 kg of pellets
aluminium phosphide – if you have more than 3 kg of pellets.
To get a CSL, you must:
be at least 17 years old
need to use the VTA for your work
be a ‘fit and proper’ person
have an approved handler test certificate for the VTA.
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A fit and proper person is one of good character who abides by the law. There are
various criteria that will be assessed when considering whether you are fit and
proper. These include:
whether you have a criminal record
your behavioural history, including violence, drug or alcohol abuse
the results of a police check.
A fit and proper person
is one of good character
who abides by the law.
You should carry your CSL whenever you are
handling a VTA for which you are licensed. If the VTA
you use needs a CSL, you won’t be able to buy it
without your CSL.
A CSL is issued by the EPA and is valid for five years.
You would normally apply for a CSL with the support of the test certifier who
issued your approved handler test certificate. The CSL will become invalid if your
approved handler test certificate expires. The EPA can revoke CSLs if you are
found to be negligent or incompetent in your use of VTAs, or you are convicted
of any offence.
If you do not have a CSL you can still handle and use VTAs, provided you are
under the immediate supervision of a CSL holder. The licence holder must be
present and available – within ‘eye and ear shot’ – at all times.
Getting a permission
You may need a permission from the Department of Conservation (DOC), the
public health unit (PHU) of the local district health board (DHB), or both before
using a VTA. In some cases you will need a permission from the EPA to use
sodium nitrite.
Department of Conservation
If you wish to apply a VTA on land managed by DOC you must have a permission
from DOC. DOC can advise on what land they manage and how to apply for a
permission. A list of local offices is available on the DOC website – www.doc.govt.nz.
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You will need to fill out an application form or provide an assessment of
environmental effects. DOC will need information such as:
the VTA you will be using
when and where you will be using it
how you will be using it
consultation you’ve carried out when planning your operation.
Public health unit
You will need a permission from the local PHU to use some VTAs in a drinking
water catchment or where there is a risk to public health. You should check with
the local PHU whether you need a permission from them. For example, if you
use the following VTAs in an area where the public have access, such as regional
parks, you will need a permission:
1080
sodium cyanide or potassium cyanide
phosphorus
DRC 1339
MZP.
You can contact your local PHU through the local DHB or the Ministry of Health
website – www.moh.govt.nz.
You will need to provide detailed information in your permission application,
including:
when and where you will be using the VTA
the type of bait and application method
your assessment of public health effects
consultation you have done while planning your operation.
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Environmental Protection Authority
If you intend to use sodium nitrite to control feral pigs on land that is not
managed by DOC you will need a permission from the EPA. More information
and an application form are available on the EPA website – www.epa.govt.nz –
search for VTA permissions.
Permission conditions
Any permission given by DOC, the PHU or EPA will include conditions on the
use of the VTA. These conditions are set to manage any risks from using the VTA.
Make sure you read and understand the permission and comply with all of the
conditions.
Keep a copy of the permission with you so you can show everyone involved in
the operation what the requirements are and, if necessary, show an enforcement
officer that you have followed the conditions.
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Communication
Before using VTAs it’s important that you communicate with people who
could be affected by their use. How you communicate will depend on the VTA
and application method you use and its potential effects. There are specific
communication requirements for aerial application of 1080. These are set out in
the Communication guideline for aerial 1080 application that is available on the EPA
website – www.epa.govt.nz. This guideline is useful for
communications for other VTAs.
Before using VTAs it’s
important that you
communicate with
people who could be
affected by their use.
Consultation
You will need to provide evidence of consultation as
part of an application for a permission to use VTAs. You
need to consult people who own, live on or live next to
the land where VTAs are used. You also need to obtain
consent from any land occupiers and owners before
using any VTA on their land. You should keep written records of consultation and
consent from landowners.
Notification
You must notify people who may be affected when using some VTAs. In all cases
you will need to notify the land owner and occupier of the area to be treated and
include the following information:
the VTA you are using
when you will use it
where you will use it
contact details of the person using it.
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In addition to the basic notification requirements on the previous page, there are
specific requirements for different VTAs. These are summarised in the table below.
VTA
Who else to notify
1080
owners and occupiers of
adjacent land
the public – for aerial application
the police, if the VTA operator is
not the land owner – for aerial
application of cereal bait or
stock solution
When to
notify
What to tell
them
(in addition to the
basic needs)
up to 2
months
before
application
PAPP
land owners and occupiers
within 3 km of any bait station
up to 2
months
before
application
the possible
effects on pets
and how to treat
them
MZP
Medical Officer of Health
up to 1
month before
application
the possible
effects on pets
and humans
and how to treat
them
up to 1
month before
application
the possible
effects on pets
and humans
and how to treat
them
local veterinarians
the police, if the VTA operator is
not the land owner
sodium
nitrite
Medical Officer of Health
local veterinarians
the police, if the VTA operator is
not the land owner
aluminium
phosphide
magnesium
phosphide
the fire service, if the area to be
treated is close to dwellings,
schools or other areas that the
public have a right to enter
not less than
24 hours
before the
proposed
treatment
A VTA permission from DOC, the PHU or the EPA may include a condition
requiring notification.
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Warning signs at operations
You must post warning signs at the location where the VTA has been used.
Warning signs let people know which VTA has been used, what the hazards are
and what to look out for. They are an important communication requirement
when using VTAs.
Warning signs let
people know which
VTA has been used,
what the hazards
are and what to
look out for.
When warning signs are required
You must put up warning signs at all normal points
of entry to the treatment area when you use:
cyanide
1080
phosphorous
PAPP
MZP
DRC1339
sodium nitrite.
When using any other VTA, except for rotenone, in a place where there is public
access you must post warning signs at every normal access point. This includes
parks, reserves, roadsides and public rights of way.
What warning signs should say
Your signs must:
be easy to read, with key information readable from 10 metres away
let people know which VTA is being used
warn that it is toxic to humans and animals
state when it is to be applied
identify the person responsible for the operation and provide contact details
where they can be reached during normal business hours.
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The PHU, EPA or DOC may require extra information on signs through conditions
on permissions.
Examples of VTA warning signs are shown below. These and other signs are
available as templates on the EPA website – www.epa.govt.nz – search for
example warning signs.
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Sign maintenance
You should check your signs regularly and replace any that are broken or have
been vandalised or removed. The information on signs may fade over time, so
you may need to touch them up. Record the location of all signs – using GPS will
give accurate locations – as this makes it easier to find them for maintenance and
to remove them when necessary.
How long must signs stay up?
Signs need to remain in place until the VTA and carcasses have been removed
from the area or until the hazards associated with them no longer exist. They
must then be removed. For each VTA, there is a minimum time that signs must
remain in place after the last application. These are given in the following table.
VTA
Minimum time
1080
six months after the last application
earlier if 1080 and carcasses are removed or monitoring
shows that 1080 and carcasses are no longer toxic
alpha-chloralose
until the VTA is retrieved or has disintegrated
time to disintegration depends on the application method
and weather
aluminium phosphide
until the fumigation is finished
brodifacoum
12 months after retrieval of baits
bromadiolone
12 months after retrieval of baits
cholecalciferol
(biodegradable bait bag)
four months after the last application
cholecalciferol (other
application methods)
three months after retrieval of baits
coumatetralyl
two months after retrieval of baits
eight months after the last application if baits not retrieved
sodium cyanide paste
two months after the last application
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VTA
Minimum time
encapsulated paste
containing potassium
cyanide
four months after the last application
encapsulated pellets
containing potassium
cyanide (bait bags)
four months after the last application
encapsulated pellets
containing potassium
cyanide (other
applications)
two months after the last application
DRC 1339
one month after the last application
diphacinone
two months after retrieval of baits
eight months after the last application if baits not retrieved
flocoumafen
12 months after retrieval of baits
magnesium phosphide
until the fumigation is finished
MZP
six months after the last application
PAPP
until the VTA is retrieved
phosphorus
one month after the last application
pindone (ground-based
and not retrieved or
aerial)
eight months after the last application
pindone (ground based
and retrieved)
two months after retrieval of baits
sodium nitrite bait
two months after retrieval of bait and four months after last
application
The time that signs must stay in place can also be set by conditions on VTA
permissions from DOC, the PHU or EPA.
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Safety gear
Everyone using VTAs must always
wear the right safety gear, also called
personal protective equipment or PPE.
Read the product label and SDS and
follow the instructions carefully. The
SDS will tell you what safety gear you
need. Choose safety gear that meets
New Zealand or Australian Standards.
Always use the right safety gear for
the job you are doing. You may need
different safety gear for:
handling and unpacking
preparing baits
using and applying
different application methods
cleaning equipment and disposal.
Typically, the type of safety gear would
include:
nitrile or neoprene gloves
chemical resistant goggles or face
shield
disposable coveralls
rubber boots or gumboots with
steel caps
a chemical resistant apron
a respirator with the correct filter
hard hat and ear protection when
working near helicopters.
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Make sure your safety gear fits properly, if it doesn’t it won’t protect you. You must
look after your gear and replace it before it wears out. Your safety gear should be
cleaned at the end of the day and stored securely.
Make sure your safety gear
fits properly, if it doesn’t it
won’t protect you.
Safety tips
Have water, soap, nail brush and paper towels
available.
Thoroughly wash hands, arms and face after
working with VTAs and always before eating,
drinking, smoking or using the toilet.
Put used protective clothing in a sealed
container until it can be washed or disposed of
appropriately.
Filters in respirators get used up over time and
can no longer filter out any contaminants. To
stop the filters becoming ineffective between
uses, store them in sealed containers that are
labelled with the name of the user and date that
the filter packaging was opened.
Wash all equipment, including footwear, after use.
Make sure water used for washing equipment
doesn’t run into any waterway.
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Storage
All VTAs that need an approved handler test certificate must be locked away
when not in use. The key to the lock should be kept out of the hands of children
and unauthorised people. It’s best practice to lock away all VTAs, not just ones
that require an approved handler. Storage areas may need warning signs.
You should keep VTAs in their original packaging and never put them in a food
container. Keep the amount of VTA you store to a minimum. This makes it easier
to manage what you have and may reduce your compliance costs.
It’s best practice to
lock away all VTAs, not
just ones that require
an approved handler.
Storage location and construction
VTA storage areas should be located in a flood-free area,
soundly constructed, well ventilated, and set up so that
any leak or spill will be contained.
You also need to make sure you comply with any local
council rules for storing hazardous substances.
Storage in vehicles
VTAs should not be stored in a vehicle, unless there is no other more secure
storage available during an operation. If you have to store a VTA in a vehicle, it
should be stored inside a locked and labelled container that is out of sight and
preferably bolted to the body of the vehicle.
Signs for storage areas
Areas where you store VTAs may need warning signs to warn people what
VTAs are stored there and why they are dangerous. Signs provide important
information on what to do in an emergency and who to contact. Signs are
essential for emergency services to decide how to deal with a fire, natural disaster
or accident.
When you need signs
Signs are needed for your storage area when you store amounts of VTAs above
certain limits, or thresholds. However, it’s best practice to always have signs. The
following table shows the limits. When you have amounts of VTAs that are over
the limits stated at any site, you must have warning signs for your storage area.
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Limits for signage requirements
VTA
Limit
aluminium phosphide
50 kg or litres
magnesium phosphide
1080 gel or solution 5 % or more
sodium cyanide
1080 bait or gel 0.15 % to 1 %
100 kg or litres
bromadiolone liquid bait 0.06g/l
potassium cyanide
DRC 1339
PAPP paste A
phosphorus
pindone soluble concentrate
rotenone
encapsulated sodium nitrite
alpha-chloralose solid
250 kg or litres
MZP
1080 pellets and paste 0.1 % and less
1000 kg or litres
cholecalciferol (No Possums)
pindone liquid concentrate
sodium nitrite bait
alpha-chloralose treated seed and paste
brodifacoum
bromadiolone bait pellets
cholecalciferol (Feracol or Kolee)
coumatetralyl
diphacinone
flocoumafen
PAPP ready to use bait and paste B
pindone bait
10,000 kg or litres
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Where to put signs
If you need signs they must be displayed at all storage area entrances,
including vehicle access points. If VTAs are stored in a room inside a building,
signs must also be displayed at the entrance to that room. If VTAs are stored
in an outdoor area, signs must be displayed adjacent to the storage area. They
must be close to the VTA storage but not so close that people come across
VTAs before being warned.
HAZCHEM
IN EMERGENCY
DIAL 111, FIRE,
POLICE OR
AMBULANCE
FOR URGENT MEDICAL
ADVICE: NATIONAL
POISONS CENTRE
DIAL 0800 POISON
(0800 764 766)
IN CASE OF
SPILL CALL
REGIONAL
COUNCIL
POLLUTION
HOTLINE
0800 XXX XXX
HIGHLY TOXIC TO PEOPLE AND ANIMALS
What to put on signs
People need to be able to read
signs from 10 metres away. Signs
must tell people:
that the storage area contains
hazardous substances
the hazards of each VTA in the
store
the precautions needed to
manage them safely
what to do and who to contact
in an emergency.
An example sign is shown. More
details on signs for storage areas
are available on the EPA website –
www.epa.govt.nz – search for signs.
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Transport
Dangerous goods include substances that are toxic, flammable or ecotoxic.
Most VTAs are dangerous goods. When you transport VTAs by road you must
comply with the New Zealand Transport Agency’s (NZTA) Dangerous Goods
Rule (the rule). The rule sets out the requirements for ensuring dangerous goods
are transported safely. How it affects you will depend on the type and amount
of VTAs you are transporting and why they are being transported. The rule, and
factsheets summarising it, are available on the
NZTA website – www.nzta.govt.nz – search for
When you transport VTAs
dangerous goods.
by road you must comply
with the New Zealand
Transport Agency’s (NZTA)
Dangerous Goods Rule.
Dangerous goods are assigned to packing groups
according to how dangerous they are. Packing
groups determine the type of packaging that is
required for dangerous goods. You will find the
packing group in the transport section of the SDS
for your VTA.
Most VTA users only carry the small amount of VTAs they need for a pest control
operation. These small amounts are called ‘tools of the trade’ in the rule. Schedule
1 of the rule sets limits on the amount of different types of dangerous goods that
can be carried as tools of the trade. The table below shows the quantity limits for
each packing group.
Quantity limits for dangerous goods transported as tools of the trade
Packing group
Example VTAs
Maximum quantity
I
cyanide paste
5 kg
1080 stock solution
5 litres
MZP
50 kg or 50 litres
II
1080 pellets (0.15 to 0.2 %)
III
DRC 1339
250 kg
pindone liquid concentrate
250 litres
If you carry less than these amounts, you will not need warning signs on your
vehicle and will not need to be an approved handler to transport the VTAs.
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However, you must:
make sure the VTAs are properly packaged and identified
keep VTAs away from substances they may react with
secure the load on your vehicle
carry emergency response information
ensure safe handling practices and emergency procedures are in place and
are followed.
If you carry more than the amounts in the table on the previous page, or
transport VTAs for hire or reward, for example as a transport company, you will
have to comply with stricter rules. You should refer to the Dangerous Goods Rule
on the NZTA website – www.nzta.govt.nz.
Packaging and load security
When you buy VTAs they will be labelled to identify the hazards they pose and
be in packaging that meets the transport requirements. If you put VTAs into any
other container, you must make sure that it meets the packaging and labelling
requirements set out in the dangerous goods rule. Packaging must be strong
enough to transport the VTA safely without leaking.
You must secure the load so that no package can fall from the vehicle and the
VTAs can’t be accessed by unauthorised people.
Keeping VTAs away from other dangerous goods
VTAs may be incompatible and react with other dangerous goods. They must be
kept away from dangerous goods they are incompatible with. The SDS will tell
you if your VTA is incompatible with any substances. VTAs must also be kept away
from food items to prevent any possibility of the food being contaminated.
Emergency response information
You must know about the hazards of the VTAs, safe handling practices and
emergency procedures and carry emergency response information in the vehicle.
You can get emergency response information from each VTA’s SDS.
A handbook is available, for a fee, from Standards New Zealand, SAA/SNZ HB 76:2010
Dangerous Goods – Initial Emergency Response Guide at www.standards.co.nz.
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Disposal
You must dispose of part-used, excess or damaged VTAs and VTA containers
properly. This is to avoid possible impacts on people or the environment.
Containers can be as hazardous as the VTAs themselves if they are not
managed carefully.
Disposal of unused VTAs
The label and SDS must provide information about how to safely dispose of the
VTA. They must also provide advice on any precautions you should take. Read this
information and keep it with you at all times when handling the product.
Before disposing of any
VTA, you should contact
the district or regional
council to check what
their rules are.
If you do not understand the disposal instructions,
or cannot comply with them, ask the manufacturer
or importer for advice. Their contact details will be
on the product label and SDS.
Before disposing of any VTA, you should contact the
district or regional council to check what their rules
are, and also check the conditions of any permission
you have obtained.
Common disposal methods for VTAs include:
burying at a landfill that is approved to take hazardous waste
burying within the biologically active layer of soil (topsoil) in an area where
people can’t access them and where they can’t leach into the environment
chemical treatment.
You must not burn or incinerate unused VTAs.
Disposal of containers
All containers that have been used to store VTAs and any other packaging or
container that has come into contact with the VTA must be disposed of carefully.
Unless you re-use containers to store more of the same VTAs, they must be
crushed or destroyed so they cannot be used again for any other purpose.
Further guidance on disposal will be given on the product label and SDS. This
may be different to how excess product is disposed of. For example, plastic
containers cannot be buried in the biologically active layer of the soil.
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Tracking
Tracking is recording what happens to VTAs through their life cycle from
manufacture and import through distribution, use and disposal. The following
VTAs must be tracked:
alpha-chloralose solid 900–1000 g/kg
1080
DRC1339
phosphorus
PAPP
pindone liquid concentrate
cyanide
aluminium phosphide, if sold in quantities of more than 3 kg
magnesium phosphide, if sold in quantities of more than 3 kg
rotenone cube root powder
MZP.
What needs to be recorded?
Tracking records must include:
the name and amount of the VTA
the exact location of the VTA
name, position in the organisation and contact details of the approved
handler in charge of the VTA
every use of the product, where it was used and how much was used
details of any transfer of the VTA to another place
details of any disposal of the VTA and its container, including how much, how,
when and where it was disposed of
the unique identifier (if it has one) of the package the product was taken from.
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The unique identifier is an exclusive serial number for an individual package or
container of a VTA. By including it in the tracking records it allows the life cycle
of individual packages to be tracked.
Tracking records must be kept in easily understandable written form and be
available to an enforcement officer within 10 minutes. The records must be
kept for one year after the substance is transferred to
Tracking records must another user or for three years after use or disposal.
be kept in easily
understandable
written form and
be available to an
enforcement officer
within 10 minutes.
Transferring tracked VTAs to another place
If you send a tracked VTA to another place, you must
make sure there is an approved handler available who
will take responsibility for it. As part of your tracking
records, you will need to record details of the new
approved handler, as well as the address of the place
and the date the VTA was transferred.
Guidelines and templates
A good practice guideline, Tracking – Minimum requirements for tracking vertebrate
toxic agents, and tracking form templates are available from the National Pest
Control Agencies’ (NPCA) website – www.npca.org.nz. Further details on tracking
are also available on the EPA website – www.epa.govt.nz – search for tracking.
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Emergencies
Even the most safety conscious organisation can have an emergency.
It’s important that you know what to do in an emergency. Possible
emergencies include:
someone being poisoned by ingesting or inhaling a VTA
grazing animals being exposed to and poisoned by a VTA
a VTA spill at your depot or operation site
misapplication of a VTA in the wrong location.
Be aware of the hazards and risks
You must read and follow the instructions on the product label and SDS. The
label and SDS will give you information about:
the hazards from the VTA
first aid measures
what to do if there is a fire
what to do if there is a spill.
Prepare for an emergency
You must be prepared for an emergency regardless of the type and amount of VTAs
you have. If you have certain types and amounts of VTAs you must prepare an
emergency response plan, as shown in the table below.
Quantity limits for emergency response plan
VTA
Maximum quantity
1080
100 kg or 100 litres
alpha-chloralose solid
cyanide
DRC 1339
MZP
phosphorus
rotenone
ESN
aluminium phosphide
magnesium phosphide
PAPP paste A
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Quantity limits for emergency response plan
VTA
Maximum quantity
alpha-chloralose seeds and paste
1,000 kg or 1,000 litres
cholecalciferol (No Possums)
flocoumafen
pindone liquid and soluble concentrate
sodium nitrite bait
PAPP ready to use bait and paste B
brodifacoum
10,000 kg or 10,000 litres
bromadiolone baits
cholecalciferol (Feracol or Kolee)
coumatetralyl
diphacinone
pindone bait
The emergency response plan must have clearly documented procedures
to deal with all likely emergencies, including spills, fire or poisoning. It must
include details of:
who to contact and warn in an emergency
how people can protect themselves
what you will do in an emergency so that damage is limited.
You must make the plan available to all employees and test it at least once a
year to check that it works. Testing your plan could be a desk-top or simulated
exercise. If any problems are identified you need to update your plan. You need
to keep records of testing for at least two years.
You must update your plan if you change the VTAs you use or if there are changes
to the staff with specific emergency responsibilities. If the plan is updated, it must
be tested within three months of the change.
A template of an emergency response plan, the Emergency Response flipchart, is
available from the EPA – email [email protected] or call 0800 376 234.
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Controlling spills
You need to have procedures in place to contain any spill and know how to
clean it up. All staff should be trained to deal with spills. You must have clean-up
equipment handy, both in your storage area and when you are using VTAs in the
field. This equipment needs to be sufficient for the amount and types of VTAs at
the site.
If a spill occurs, you will need to safely dispose of the spilled product and any
materials used in the clean-up. You will also need to advise everybody affected
by the spill.
Spill procedures
A spill kit may be sufficient for small spills. You can purchase spill kits from safety
equipment suppliers or make one yourself. What goes into a spill kit will depend
on the VTAs you store and whether they are solid or liquid. All staff need to know
where the spill kit is and how to use it. In general it should include:
safety gear to wear when cleaning up spills
spill handling equipment, like a shovel
spill containment equipment like trays, drain guards or absorbent material
a leak proof container to put the waste in once it is cleaned up.
Secondary containment
Secondary containment is a physical barrier or container that can hold the
contents of any tank or container that may spill. Most users of VTAs will not
store enough to need secondary containment. However, if you store more than
100 litres of liquid pindone or 1080 stock solution you will need secondary
containment.
Reporting if things go wrong
You need to identify people who may be affected or need to be involved if
anything goes wrong with your VTA operation. You need to have a list of contact
details for them.
It is recommended that you contact the EPA in all cases where things go wrong
with a VTA application. For some VTAs there are specific people you must notify
within 24 hours of a spill, loss of product or misapplication in the wrong location.
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You should also notify them if you notice that bait stations have been tampered
with or bait removed. The relevant VTAs and who to contact are shown in the
following table.
Emergency contacts
VTA
Who to contact
cyanide
occupiers or owners of the land where the spill, loss or
misapplication happened
DRC1339
phosphorus
person you applied VTA for
officer in charge at nearest police station
local Medical Officer of Health
DOC or PHU if they granted a permission for the operation
1080
as above, plus:
PAPP
regional council
EPA
MZP
as above, plus:
sodium nitrite
local veterinarians who may treat poisoned animals
You must notify WorkSafe New Zealand in the event of a workplace accident that
causes serious harm. This includes accidents resulting in loss of consciousness or
acute illness caused by exposure to any substance. Full details of serious harm
and reporting requirements are available on the WorkSafe New Zealand website
– www.business.govt.nz/worksafe.
Reporting adverse events
The Ministry of Primary Industries (MPI) runs the Adverse Event Reporting
Programme under ACVM. This programme sets out requirements for reporting
unintended effects, including:
target animal welfare issues
effects on non-target animals
VTAs not working
problems with application, such as baits spilling from stations.
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If you notice an unintended effect, you should report it to the manufacturer or
importer. Their details will be on the product label. The importer or manufacturer
must then report it to MPI. You can also report directly to MPI. MPI will determine
what needs to be done to deal with the adverse effects. Adverse effects to
animals such as dogs or stock animals should be reported to the owner and a
veterinarian.
Details and reporting forms are available on the MPI website – www.mpi.govt.nz.
Fire extinguishers
It’s best practice to always have fire extinguishers at your depot and
in your vehicle. However, you must have fire extinguishers if you store
more than 50 kg of aluminium phosphide or magnesium phosphide.
You can get advice about the type of fire extinguisher you need from
your equipment supplier.
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Further information
This document gives a summary of the rules to follow when using VTAs. More
information is available from the following organisations.
Environmental Protection Authority – www.epa.govt.nz
The EPA website has more details on everything included in this booklet
including:
databases of controls for approved hazardous substances and test certifiers
guidance on approved handler test certificates and CSLs
guidance on limits for hazardous substance controls
the Communication guideline for aerial 1080 application
applying for a permission to use sodium nitrite
guidance, examples and templates for signs.
You can also get advice on hazardous substances and copies of the Emergency
Response flipchart at [email protected] or by calling 0800 376 234.
Department of Conservation – www.doc.govt.nz
For information about:
pest management guidance
land managed by DOC
how to apply for a permission
best practice when using VTAs
use your local phone book to find area offices.
Ministry of Health – www.moh.govt.nz
For information about:
how to apply for a permission
contact details for PHUs
local PHUs are also listed in the phone book.
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Ministry of Primary Industries – www.mpi.govt.nz
For information about:
how to comply with the Agricultural and Veterinary Medicines Act 1997
details of the Adverse Event Reporting Programme.
WorkSafe New Zealand – www.business.govt.nz/worksafe
For information and guidance about:
staying safe at work
reporting workplace accidents, unsafe situations or serious harm
contact centre – 0800 030 040.
New Zealand Transport Agency – www.nzta.govt.nz
The NZTA provides information and guidance about:
transporting dangerous goods
the Dangerous Goods Rule.
National Pest Control Agencies – www.npca.org.nz
The NPCA website has a wide range of guidance about using VTAs.
Standards New Zealand – www.standards.co.nz
Standards New Zealand produce standards to follow when using VTAs,
including selecting the right safety gear.
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Disclaimer
This document is guidance only and does not cover every aspect of the law.
What the law requires depends on the types and amounts of VTAs you use and
store. If you are in doubt about what the law requires, we recommend that you
contact the EPA, seek independent advice, or both.
There may also be additional rules set by your local and regional councils that
you need to follow. This document does not provide any guidance on those
requirements and the EPA recommends you contact your local or regional
council for further information.
We have tried to make the information in here as accurate and current as
possible. However, the law is constantly evolving and may have changed since
publication. It is your responsibility to make sure that you comply with the law.
If you find any information in this document that you believe may be inaccurate,
or you would like to provide any feedback, please email [email protected].
Environmental Protection Authority · Level 10 · 215 Lambton Quay · Private Bag 63002 · Wellington 6140 · New Zealand
Tel +64 4 916 2426 · Fax +64 4 914 0433 · www.epa.govt.nz
EPA 0332