Summary and Analysis – Carrots and Parsnips

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
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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
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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)
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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
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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
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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
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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
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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
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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
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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
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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
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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