1 Risk assessment Risk assessment Lack of assessment of - PDF document

Outline of presentation Dichlorvos Reassessment • Background Presentation from the Horticulture • Risk assessment Industries • Benefits assessment • Controls • Consistency 6 May 2015 • Future strategy for agchems • Summary Nikki Johnson • Industry presentations Market Access Solutionz Ltd nikki@solutionz.co.nz Industry Groups Represented EPA Proposals Industries that consider use of Dichlorvos critical: • Effective ban on outdoor uses (hand held • Greenhouse vegetables irrelevant) – 12 month phase in • Outdoor vegetables • Indoor greenhouse uses – proposal unclear – Squash  Measures could be imposed to manage risk – Brassica But recommendation is for small scale use only?  – Lettuce – Salad Leaf Small scale only = effective ban all uses  – Silverbeet/spinach  Large scale GH allowable with automatic uses only = – Others (Asian greens, herbs, baby veg) will ban use for most growers • Persimmon orchards • Asparagus Process Risk Assessment • EPA is the applicant, the assessor and the • Burden of proof is on submitters not applicant reviewer – Request for industry to provide additional information is not feasible in the timeframe of the process, may also be – Is this appropriate? uneconomic – Tested through bee reassessment – outcome unknown – No attempt to obtain identify data gaps and obtain • Timeframes insufficient to generate types of data information in advance of the statutory process EPA staff are requesting – No attempt to contact industry for more information – 30 days to gather feedback & prepare submission between written submissions and update report – 10 days pre hearing to respond to revised proposals • e.g. monitoring information discounted due to lack of detail but no clarification was sought • Adversarial approach (Section 2.3.2) • Process does not allow for information to be • Absence of data = EPA have chosen extremely generated - “ Information on semi-automatic methods was precautionary approach requested but not provided” – unachievable within 30 days. 1

Risk assessment Risk assessment • Lack of assessment of semi-automatic methods has • “Absence of records does not mean absence of severe implications for industry incidents” – could equally argue the opposite • Operator RQ values • ADI – impact of reducing it to below Codex level (0.004) to 0.001 is unclear – Automatic = 2.9 • Risks to birds from ingestion – safe for human – Manual = 7 consumption after 1 day – why not birds? • What information would be required to assess this? • Risk to food gathering – safe for humans to eat after 1 • Would provision of monitoring records assist – is EPA day – impact is limited. open to practical discussion? • Serious data gap – needs to be addressed before any decisions are made – who is responsible? Controls Benefits assessment • Independent review is appreciated • Industry suggested night applications to protect • However, the review does not consider sector bees – was this even considered? based cost benefit • If the risk to bees was controlled through night applications and the risk to birds was re-assessed – Benefits from removing household use are high – industry agrees that domestic use is not justified based on actual likelihood and found to be low – Costs associated with removing horticulture use are – then that leaves only aquatic to be managed. high $150-$333m – what are the specific benefits? • EPA comments that costs of installing automatic • Alternatives assessment is flawed – no equipment are not cost prohibitive – on what consideration of PHIs or fumigant activity basis is this claim made? • ‘Partial withdrawal’ – reality is full withdrawal if no large scale applications are retained Comparative risk Consistency Operator Re-entry Bystander Aquatic Bird Operator Re-entry Bystander Aquatic Bird Outcome Dichlorvos 2014 Diazinon H M M M H 15 years Indoor (auto) H L M/L Neg Neg Fenamiphos H M M M H 10 years Indoor (semi) ? ? ? ? ? Prothiofos H M M M L 10 years Indoor (Manual) H L M Neg Neg Dichlorvos H M M (H) (H) 1 year (outdoor) 2015 Persimmon H M M (H) (H) () assessments from 2013 and 2014 are not directly comparable Vegetable M/H L L (H) (H) OPC Review 2013 Indoor N N N/M N N Outdoor H N N VH VH () not directly comparable 2

Summary Future strategy • Question the process – data gaps identified in • Industry is looking for alternatives application but industry are given only 30 days to Vegetable Agchem Strategy  respond – how is this feasible? Minor Crops Initiative  • Question that the burden of proof is on submitters • EPA has reassessed two groups (26 compounds) • EPA acknowledge risks are overstated in the last two years • Data gap on semi-automatic - precautionary 11 declined • • Large scale indoor use proposal unclear – if risks can • 7 phased out be managed why has EPA not proposed it? • 7 retained • Impact of 12 month phase out will be severe • Dichlorvos effectively phased out • Proposed phase out inconsistent with decisions in the • Industry needs a phase out timeframe that 2013 OPC review allows alternatives to be developed. • Industry has a future strategy – needs more time. • 2 month phase-out is insufficient and impractical Greenhouse Industry Ben Smith (Status Produce) Dichlorvos Reassesment Ben Smith 6/5/15 About Me • Ben Smith • 16 years in and around growing tomatoes in NZ and UK – Both conventional and organic systems • Work for T&G – NZ’s largest tomato grower – 20ha, 3 sites, largest individual greenhouse 2.7ha 3

Whitefly Timeline Resistance Management • Prior to 2006 • Resistance management crucial in current ag – partial biocontrol of whitefly with Encarsia and ag- chems chem based strategy • 2006 • The current situation is fragile at best – Tomato-Potato Psyllid arrives in NZ • Considerable crop losses this summer • 2006-2014 • Concerns about resistance of almost every – Almost exclusive ag-chem based psyllid control in potatoes group of ag chems • 2015 – Dose rates sub-lethal to whitefly, but targeted at – Epidemic proportion whitefly issues other pests on other crops, probably responsible – Severe crop losses Alternatives • Only one other organophosphate – “Attack” ( Pirimiphos-methyl) • Not bee or IPM friendly – EPA reviews have already had some impact on alternatives • We currently use every other alternative we can think of but it still doesn’t result in an economically effective control program • We are very close to the edge 4

Caution When Comparing The Future Internationally • Most sustainable solution is back to an IPM based strategy, but… • NZ has pests that other nations do not have • We do not have all the beneficial insects we need – Combinations of pests important too • We do not have all the tools needed to fix problems – E.g., Whitefly + Tomato-Potato Psyllid together in IPM program if we had the beneficial insects • NZ does not have beneficial insects of pests • Products like dichlorvos have an important role in that other nations do not have fixing problems in IPM programs • There are significant hurdles to achieve this Application Method Cost of Fully Automated Fog Crop Area Cost • Spraying is significantly more efficacious than Tomatoes 120 $2,423,520 fogging Aubergine 6 $121,176 – Less repeat applications Capsicum 65 $1,312,740 • To install a fully automatic fogging systems Lettuce 50 $1,009,800 would cost T&G approx. $125k for the fogging Total 241 $4,867,236 system • Assumes 21% of growers already have fans • Fan system that goes with it approx. $287k • Assumes everyone will pay the same $/ha – Cheaper as we already have some fans in place • Total for Automatic Fogging $412k for T&G install costs • Prices calculated from actual capex work – Costs based on large installations. Majority of completed 2-3 years ago at 2 different growers operators smaller so will cost a lot more Reality of Fully Automated Fully Automated Spray Fog • Great in theory, but… • I only know 1 grower who has it • Still unreliable • It causes damage to the crop as it does not • Only suitable for new build glasshouses apply product very evenly across the area – Need higher rated pipe rail brackets • It isn’t as efficacious as spraying • Weight 587kg vs ~400kg currently (dangerous • He uses semi automatic spray robots instead enough now) – Glasshouse layout needs to be precise so sensors “catch” – Rough concrete floors aren’t suitable 5