Summary and Analysis – Carrots and Parsnips Scene setting Turnover ($) M 2011 40.1 Growers (number) 50 (carrots) 12 (parsnips) Size 200 (up to 1000 in supporting industries- carrots) Employees (number) 100 (40-50 in supporting industries-parsnips) Organophosphate carbamate use Registered Used and viewed as Application methods Oxamyl, diazinon, fenamiphos, maldison, phorate, dimethoate critical by sector Oxamyl, diazinon, chlorpyrifos, terbufos, fenamiphos, phorate, maldison All substances Boom, aerial, drill, spread, knapsack Main growing regions Canterbury, Auckland, Manawatu-Whanganui and Ohakune One large producer of carrot juice employs 20 fulltime staff in their factory, with a further 40-45 seasonal workers. To produce 40 Ha of carrots a typical operation would have 1 driller and 1 sprayer, 5 people harvesting, 15-20 washing and 20 staff in the packhouse. Therefore it is estimated around 1200 people are employed by the NZ Carrot industry. There are a number of very large fresh and processed carrot and parsnip producers in NZ. The fresh carrot industry is also very prominent in Ohakune and employs many of the local people in that region. The number of growers decreased by around 50% from 2008 to 2009. This may have been as a result of amalgamations and larger co-operatives producing carrots as the number of hectares planted has not altered over recent years. Carrot production for either the fresh market or carrot juice is a major contributor to the rural economy in South Canterbury, Southland and Ohakune. If one or more of these critical insecticide control options was removed without alternatives available this would severely impact production of carrot/parsnip and, and therefore a loss in quantity and quality of production will naturally impact on profit. This would have a domino effect to employment figures as growers would be unable to sustain their business and would not be able to employ harvesters, packers, graders, contractors and transport company staff (etc) if yields were affected. Obviously on farm employment is only possible if there is quality produce to harvest that will be saleable and generate a profit. This directly correlates to the off-farm/paddock employment as well. November 2012 2 Carrots and parsnips Summary and Analysis APP201045 Use patterns In response to feedback to its calls for information, EPA has modified its modelling of the risks from the use of OPCs in the Carrot Sector. Risks have been modelled for use patterns: Use scenarios used in risk assessment Use pattern Substance Formulation type Area (ha) Source of information* Critical/not critical to sector Carrots 1 Chlorpyrifos 7 10 Industry Critical (off label) Carrots 2 2 7 10 Industry Critical (off label) 325 4 14 10 Label Label (non-critical) Boom 1496 4 7 3 Label Critical (rate=label) Liquid Boom 1800 2 10 10 Industry Critical (off label) Oxamyl Liquid Boom 4800 1 10 Industry Critical (rate=label) Carrots 7 Oxamyl Water dispersible 1 granule Boom 4800 1 10 Industry Critical (rate=label) Carrots 8 Fenamiphos Liquid Boom 8000 1 10 Industry Critical (rate=label) Carrots 9 Chlorpyrifos Liquid Boom 500 1 10 Industry Critical (off label) Carrots 10 Phorate Granules Tractor drilled granules 2200 1 10 Industry Critical (rate=label) Carrots 11 Terbufos Granules Tractor drilled granules 600 1 10 Industry Critical (off label) Method Application rate (g a.i./ha) # applications Interval (d) Liquid Boom 500 3 Diazinon Liquid Boom 2400 Carrots 3 Dimethoate Liquid Boom Carrots 4 Maldison Liquid Carrots 5 Diazinon Carrots 6 1 This information was provided in feedback from industry, however, EPA staff were unable to find such a formulation on the Agricultural Compounds & Veterinary Medicines (ACVM) product register November 2012 3 Carrots and parsnips Summary and Analysis APP201045 Use scenarios used in risk assessment Use pattern Substance Formulation type Source of information* Critical/not critical to sector Carrots 12 Diazinon Granules 10 Plant and Food Report Critical (rate<label) Carrots 13 Diazinon 1 10 Label Critical (rate=label) Carrots 14 2200 1 10 Industry Critical (rate=label) Handheld granules 2200 1 1 Plant and Food Report Critical (rate=label) Granules Handheld granules 500 1 0.01 Label Critical (rate=label) Diazinon Granules Aerial granule 2200 2 10 10 Industry Critical (rate=label) Carrots 18 Diazinon Granules Aerial granule 3000 2 10 10 Industry Critical (rate>label) Carrots 19 Diazinon Granules Aerial granule 2200 1 10 Industry Critical (rate=label) Carrots 20 Diazinon Granules Aerial granule 3000 1 10 Industry Critical (rate>label) Application rate (g a.i./ha) # applications Tractor spread granules 500 1 Granules Tractor spread granules 2200 Phorate Granules Tractor spread granules Carrots 15 Diazinon Granules Carrots 16 Diazinon Carrots 17 Method * Plant & Food report: reports on acephate, diazinon, dichlorvos, methamidophos November 2012 Interval (d) Area (ha) 4 Carrots and parsnips Summary and Analysis APP201045 Results of risk modelling (risk quotients) Operator Use scenario Re-entry worker Bystander Aquatic Birds Bees Full PPE Full PPE RPE After REI Carrots 1 0.019 0.0081 0.29 0.035 16 14 170 Carrots 2 8.4 5.7 430 16 91 630 530 Carrots 3 0.16 0.083 0.79 0.25 0.012 11 65 Carrots 4 0.039 0.035 11 0.22 3.4 4.3 150 Carrots 5 6.3 4.3 300 11 64 430 400 Carrots 6 4.9 3.8 190 5.4 0.28 400 250 Carrots 7 9.8 3.8 190 5.4 0.28 400 250 Carrots 8 66 64 3600 62 99 2500 570 Carrots 9 0.019 0.0081 0.28 0.033 5.9 10 170 Carrots 10 14 2.4 Not calculated Not calculated Not calculated 560 Not calculated Carrots 11 9.7 1.6 Not calculated Not calculated Not calculated 11 Not calculated Carrots 12 8 1 Not calculated Not calculated Not calculated 2600 Not calculated Carrots 13 35 4.5 Not calculated Not calculated Not calculated 3000 Not calculated Carrots 14 15 2.8 Not calculated Not calculated Not calculated 560 Not calculated Carrots 15 520 450 Not calculated Not calculated Not calculated 3000 Not calculated Carrots 16 1.2 1 Not calculated Not calculated Not calculated 2600 Not calculated Carrots 17 34 4.1 Not calculated Not calculated Not calculated 3000 Not calculated Carrots 18 46 5.6 Not calculated Not calculated Not calculated 3000 Not calculated November 2012 5 Carrots and parsnips Summary and Analysis APP201045 Operator Use scenario Re-entry worker Bystander Aquatic Birds Bees Full PPE Full PPE RPE After REI Carrots 19 34 4.1 Not calculated Not calculated Not calculated 3000 Not calculated Carrots 20 46 5.6 Not calculated Not calculated Not calculated 3000 Not calculated November 2012 6 Carrots and parsnips Summary and Analysis APP201045 Sector’s comments on suggested controls Control Comment PPE/RPE Workable Closed cab technology Workable REI Some REI should be reduced to a maximum of 48 hours Maximum application rate GAP and current usage Buffer zones Per Growsafe. None for aerial application of diazinon granules as carrot rust fly does most damages at crop edges. We are unsure how the EPA justifies that there are still risks to operators, even with additional controls which include full PPE/RPE. A 3-4 day REI for all these products is feasible if risks would be reduced by such an extension. Sector suggestions for additional controls November 2012 7 Carrots and parsnips Summary and Analysis APP201045 Qualitative descriptors of risk with additional controls in place Additional controls triggered Qualitative risk descriptors (magnitude/likelihood=overall risk) with additional controls in place Operators Re-entry workers Bystanders Aquatic Birds Bees Carrots 1 PPE Buffer zone Do not apply when bees foraging Negligible Negligible Negligible Low Medium Negligible Carrots 2 Full PPE+RPE REI = 24 h Buffer zone Do not apply when bees foraging Low Medium Low Low High Negligible Carrots 3 PPE Do not apply when bees foraging Negligible Negligible Negligible Negligible Medium Negligible Carrots 4 PPE REI = 24 h Buffer zone Do not apply when bees foraging Negligible Low Negligible Negligible Low Negligible Carrots 5 Full PPE+RPE REI = 24 h Buffer zone Do not apply when bees foraging Low Medium Low Low High Negligible Use scenario November 2012 8 Carrots and parsnips Summary and Analysis APP201045 Additional controls triggered Qualitative risk descriptors (magnitude/likelihood=overall risk) with additional controls in place Operators Re-entry workers Bystanders Aquatic Birds Bees Carrots 6 Full PPE+RPE REI = 12 h Buffer zone Do not apply when bees foraging Low Medium Low Negligible High Negligible Carrots 7 Full PPE+RPE REI = 12 h Buffer zone Do not apply when bees foraging Low Medium Low Negligible High Negligible Carrots 8 Full PPE+RPE REI = 48 h Buffer zone Do not apply when bees foraging Medium Medium Low Low High Negligible Carrots 9 PPE Buffer zone Do not apply when bees foraging Negligible Negligible Negligible Negligible Low Negligible Carrots 10 Full PPE+RPE Low Negligible Negligible Negligible High Negligible Carrots 11 Full PPE+RPE Low Negligible Negligible Negligible Medium Negligible Carrots 12 Full PPE+RPE Negligible Negligible Negligible Negligible High Negligible Carrots 13 Full PPE+RPE Low Negligible Negligible Negligible High Negligible Use scenario November 2012 9 Carrots and parsnips Summary and Analysis APP201045 Additional controls triggered Qualitative risk descriptors (magnitude/likelihood=overall risk) with additional controls in place Operators Re-entry workers Bystanders Aquatic Birds Bees Carrots 14 Full PPE+RPE Low Negligible Negligible Negligible High Negligible Carrots 15 Full PPE+RPE High Negligible Negligible Negligible High Negligible Carrots 16 Full PPE+RPE Negligible Negligible Negligible Negligible High Negligible Carrots 17 Full PPE+RPE Low Negligible Negligible Negligible High Negligible Carrots 18 Full PPE+RPE Low Negligible Negligible Negligible High Negligible Carrots 19 Full PPE+RPE Low Negligible Negligible Negligible High Negligible Carrots 20 Full PPE+RPE Low Negligible Negligible Negligible High Negligible Use scenario November 2012 10 Carrots and parsnips Summary and Analysis APP201045 Benefits Generic The Carrot and Parsnip Sector noted that OPCs offer advantages because of: Area of benefit Comment No alternatives Y Cost Y Efficacy Y Resistance management Broad spectrum Y Short withholding period Y Pest incursions Biosecurity Residues/MRL The registration status of the products also affects choice. Specific Diazinon One submitter said that around 80% of carrot growers use diazinon to control Manuka beetle and Grass grub, which can cause significant crop loss by chewing on young carrots. Reject rates can be up to approximately 70% as irreversible damage occurs early in the carrot development cycle. Two applications of diazinon are required each season on slow growing carrot crops, one at cultivation prior to sowing, and again at emergence. Carrot and parsnip crops are relatively slow developing and are exposed to insect attack for a longer period. 80% of the Ohakune growers use diazinon granules on carrot crops. This equates to 140ha with an average crop of 150 tonnes/ha. A 70% reject rate would mean that 105t x140ha=14,700 tonnes of carrots from Ohakune would be dumped. If diazinon is phased out with no alternatives in place, this will seriously impact on the livelihood of growers and supply for the domestic and export market. Ohakune is the major supplier of carrots to the NZ domestic market from March till October. As explained above, even small amounts of pest damage will mean carrots cannot be sold on the fresh market. When used at emergence, diazinon prevents pests from destroying the seedlings that could otherwise result in a loss of the entire seedling population or significant crop losses. The cost of replanting is ~$200/ ha but the pests will still be present in the ground and the same thing could happen without better control. If growers lose crop later in the season, or produce is downgraded due to pest damage this figure is $12,000/ ha. Overall diazinon use represents an economic benefit in the region of $13m per year as a result of decreased pest damage and increased yield. November 2012 11 Carrots and parsnips Summary and Analysis APP201045 Diazinon provides excellent control of grass grub, Manuka beetle, porina, carrot rust fly and springtails. This product is applied to seedlings. No alternatives provide an adequate level of control. The granule is highly practical because it can be safely and accurately delivered to the target area beside the seedling roots. Diazinon is preferred over terbufos and chlorpyrifos for grass grub control, and over phorate to control grass grub and carrot rust fly. Grass grub control is especially important for parsnips as during the season there are two life cycles of grass grub and this puts pressure on the roots of the plant (i.e. the saleable commodity). Damage from carrot rust fly can cause up to 70% reject rate through feeding damage. If this occurred a 70% reject rate would be 105 tonnes per ha x 140ha = 14,700 tonnes of carrots that would be dumped every season if Diazinon was lost to the carrot industry. For one manufacturer of diazinon products making changes to the labels would cost approximately $9000. Fenamiphos Root knot nematodes have an extreme effect on carrot crops because they cause the carrot to be ‘forked’ and unsuitable for the fresh market. If left uncontrolled, nematodes cause a 40-60% total yield loss and a 75% fresh market yield loss in the first year and within 10 years 100% yield loss (as the soil becomes infested with nematodes and it can no longer be used for carrot or parsnip production). Without fenamiphos for control of this pest there are no alternatives and loss of crop would be in excess of 75%. This would be a total cost of over $30m to the industry. There is no efficacious alternative to this product. Growers try to reduce reliance on fenamiphos by utilising crop rotation, but in the major carrot growing regions it is not possible for growers to find paddocks free of nematodes. This product is applied once when the soil is bare. Carrot and parsnip growers regard fenamiphos the most important factor in production of their crop. The alternative to not having fenamiphos available for use on carrots and parsnips is to not produce carrots or parsnips in NZ. Oxamyl Provides controls for carrot rust fly, root knot nematode and argentine stem weevil. Oxamyl can be used for nematode control but it is not as efficacious and the cost per hectare is significantly more than Fenamiphos. Oxamyl costs around $1300/ha, whilst fenamiphos is $360/Ha. It is almost 75% cheaper to use fenamiphos than oxamyl and it delivers increased efficacy. Growers are unable to pass increased input costs to consumers and growing carrots would become uneconomical. November 2012 12 Carrots and parsnips Summary and Analysis APP201045 Qualitative Descriptors of Benefit Substance Status* Likelihood Magnitude Overall benefit Rationale Oxamyl C Possible Moderate Low Generic benefits Diazinon C Likely Major Medium See specific benefits Fenamiphos C Likely Major Medium See specific benefits Chlorpyrifos C Likely Moderate Low Grass grub and generic benefits-low populations Terbufos C Possible Minor Negligible Grass grub and generic benefits-last choice Phorate C Possible Moderate Low Less effective than diazinon Maldison C Possible Moderate Low Generic benefits and thrip control Dimethoate U Negligible Not used *C: used and viewed as critical by sector; NC: used but not viewed as critical by sector; U: unused by sector November 2012
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