Staff Presentation - Solvigo APP201999 Hearing: 25 September 2014
2 Application Timeline 9 Dec 16 Jan 29 Jan 26 Feb 28 Mar 11 Sept 2013 2014 2014 2014 2014 2014 Further Information Submission Application Formally Publically made E&R period lodged Received Notified available closed released
3 Reason for public notification The application was publically notified because Solvigo contains thiamethoxam, which is a neonicotinoid insecticide and the use of thiamethoxam has been restricted in Europe due to concerns about risks to bee health
4 Submissions 4 submissions were received: 2 opposed • Hugh Halliday • Te Rūnanga o Ngāi Tahu 2 neutral • National Beekeepers Association • Federated Farmers of New Zealand, Bee Industry Group
5 Key Issues Toxicity testing on native species The level of publicly available technical/ confidential information The level of cultural risk assessment by the applicant Benefits of Solvigo Impacts on groundwater Human exposure during application Effects on bees Label statements to protect bees Risks to aquatic organisms
6 Outline Broader issues The level of benefits Impacts on ground water Human health effects Risks to bees Risks to aquatic organisms
7 Broader issues (1) Native species testing We currently use data for surrogate species tested using internationally standardised methods Our risk assessment includes uncertainty factors to address sensitivity differences We are working on ways to complement this approach and address the concerns of Ngāi Tahu and others
8 Broader issues (2) Confidential information We encourage applicants with notified applications to consider providing more detailed and technical information for submitters This is the first application where this approach was used
9 Benefits Active ingredient not previously used on onion crops, that can replace more hazardous older active ingredient e.g. organophosphates Solvigo is less hazardous to human health and environment than organophosphate alternatives New actives with different modes of action that can be alternated with the older products are important for managing pest resistance
10 Impacts on ground water The staff have modelled the values for ground water residues using the US EPA’s SciGrow model. This model was not available at the time when the ERA for Solvigo was performed. Adsorption/desorption tests and field dissipation studies were used to evaluate ground water contamination. No risk of accumulation for annual application is expected assuming proper degradation conditions in the agricultural soil.
11 Human health Occupational • Risks identified during mixing, loading and application, and for re-entry workers • Exposure can be reduced by using PPE Bystander • Exposure assessment is based on a toddler playing on contaminated surfaces 8 m away from the sprayed area • Exposure was below the level of concern
12 Controls to protect human health Personal Protective Equipment (PPE) Mixing and loading: minimum of gloves Application: minimum of full PPE (gloves, coveralls, footwear) Workers re-entering a sprayed area within 24-hours of application must wear gloves Note: not exact control wording
13 Risks to bees (1) Summary of submitter comments Thiamethoxam is highly toxic to bees Bee health is more important than onions in the broader ecological context There is a risk it will be used on flowering plants either intentionally or accidentally Bee safety statements on labels should be “must - do’s” not “nice -to- do’s”
14 Risks to bees (2) Staff comments Solvigo is intended to be applied to onions that are not in flower and not about to flower. This will reduce exposure to bees The risks to bees can be managed through the application of the following controls
15 Controls to manage the risks to bees Solvigo must not be applied to flowering plants (including weeds) or an area where bees are foraging Solvigo must not be applied to plants that will flower within 14 days after application These restrictions must be included on the label Note: not exact control wording
16 Risks to aquatic environments (1) Submitter comments The range of aquatic species is limited Testing is not representative of and not protective of New Zealand native species Impacts of spray drift on taonga aquatic species
17 Risks to aquatic environments (2) Staff comments Abamectin and thiamethoxam both pose a risk to aquatic organisms The effects are not synergistic because the toxicity of Solvigo to fish and crustacea is not higher than when the actives are tested individually. The chronic and acute risks of Abamectin to aquatic organisms is of particular concern
18 Proposed controls Must not be applied into, onto or over water Application using low boom and course spray only A maximum application rate of 750 mL Solvigo/ha Minimum interval between applications of 7 days Maximum application frequency of 4 times per year Buffer zone of 70 m from a downwind water way Note: not exact control wording
19 Buffer zone options The E&R presented two options for buffer zones that manage the risks to the aquatic environment 70 m buffer zone and a maximum of 4 applications a year 50 m buffer zone and a maximum of 3 applications a year The applicant has indicated that they want 4 applications a year Therefore staff consider a 70 m buffer zone should be applied
20 Recommendation With the proposed controls in place, including a 70m buffer zone and a maximum of 4 applications per year, the staff recommend approving Solvigo with controls
21 Issues raised in the submissions Questions
22 Issues raised in the submissions Full control text
23 Buffer zone A buffer zone of 70 m between the application area and any downwind water body must be observed when applying this substance. A buffer zone is defined as a non-sprayed area between the target application area and sensitive area, such as a water body. Footnotes: A waterway includes modified water courses such as reservoirs, irrigation canals, water-supply races, canals for the supply of water for electricity generation or farm drainage canals, as well as natural water bodies. For the purposes of this approval 70m shall be measured from the edge of the sprayed field to the closest edge of the waterway.
24 Application Rate The substance must not be applied at rates exceeding 750 mL Solvigo/ha per application. The substance must not be applied to the same area more than four times per year. An interval of at least 7 days between applications of the substance must occur.
25 Application Method The application of the substance is limited to ground based application methods only. When this substance is applied in a wide dispersive manner, it must only be applied using a low height boom spray with a nozzle set to provide a coarse spray. Ground-based methods of applying pesticides include, but are not limited to, application by ground boom, airblast or knapsack, and do not include aerial application method. Footnote: A coarse quality spray according to the American Society of Agricultural & Biological Engineers (ASABE) droplet size classification scheme
26 Label Statements - application The maximum application rate (750 mL of the substance/ha), maximum number of applications (4 per year) and minimum interval (7 days) between applications must be stated on the label. When this substance is applied in a wide dispersive manner it must only be applied using a low height boom spray with a nozzle set to provide a coarse spray. This substance must not be applied less than 14 days before the crop flowers. This substance must not be applied within 70 m of a downwind water body Footnote: for the purposes of this approval 70m shall be measured from the edge of the sprayed field to the closest edge of the waterway.
27 Flowering Plants s.49 (Hazardous Substances (Classes 6, 8 and 9 Controls ) Regulations. With proposed variation applied. (1) A person must not apply a class 9.4 substance in an application area — (a) if bees are foraging in the area and the substance is in a form in which bees are likely to be exposed to it; or (b) to any plant or tree that is likely to be visited by bees if — (i) the plant or tree is in open flower or part bloom; or (ii) the plant or tree is likely to flower after application of the substance within a period of 14 days
28 Label Statements - bees This substance must not be applied if flowering weeds are present in the area to be sprayed. The following statement must be specified on the label of this substance: "This product is very toxic to bees and other beneficial insects. Do not apply this product to any plant likely to be visited by bees at the time of application; or immediately after application until spray has dried; or in areas where bees are foraging" Coarse quality spray according to the ASABE droplet size classification scheme
29 Re-entry & PPE If re-entry work is required within 24 hours of the application of this substance, personal protective equipment must be worn (gloves as a minimum) The public must not be permitted to access any area where this substance has been sprayed within 24-hours of application. A minimum of gloves must be worn during mixing and loading and Full PPE must be worn when applying this substance.
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