Submission APP202349 Apicultural NZ Technical Focus Group
Apiculture NZ Technical Focus Group Submission • Supports the reassessment where it is based on the human health risk assessment. • Chlorothalinol is a widely used fungicide that is permitted for use on flowering plants in NZ. This puts NZ Bees and other pollinators at risk. • Chlorothalinol fungicide has; • Been the most common fungicide detected inside beehives in North American studies. Mullins et al 2010. • That high pesticide loadings of chlorothalinol in beehives resulted in high rates of Nosema infection in the bees. Pettis et al 2013. • Chlorothalinol is more sensitive to bee larvae in the hive at rates that are not toxic to adult bees. Zhu et al 2014.
This reassessment revokes only 5 products containing chlorothalinol. MPI has registered 23 pesticides containing chlorothalonil. The EPA have left 18 products in the commercial market not reassessed, when these 5 products are revoked from use. ApiNZ TFG is concerned that there is no evidence of involvement from any of the product proprietors at this hearing. Disappointed that all products containing chlorothalinol were not assessed with up to date environmental information.
• The ApiNZ TFG has identified that none of the products containing chlorothalonil in New Zealand have any controls in place to protect honey bees. • All labels permit direct spray application on flowers which bees may be foraging for pollen. • ApiNZ asks the EPA to ensure that sufficient controls are put in place to ensure that the exposure to honey bees used to pollinate those crops are put in place. • There should be no commercial crop applications when these crops are flowering and bees are likely to harvest pollen and nectar from these crops.
• ApiNZ TFG supports the EPA proposal to withdraw these home garden products from the market in New Zealand. • Asks the EPA to apply a control to chlorothalonil products used in commercial horticulture to prevent spraying during flowering of the crop when bees maybe foraging that crop. • That the EPA conduct a full and up to date quantitative environmental exposure and ecological risk assessment for chlorothalonil and apply those findings to the present controls for all existing and future uses. • The EPA cannot suggest ‘business as usual’ (spraying when plants are in flower) in the commercial sector and know that chlorothalinol tainted pollen is killing bee larvae.
The ApiNZ TFG thanks the EPA for this opportunity to submit on this fungicide application.
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