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

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Dichlorvos Reassessment Presentation from the Horticulture Industries

6 May 2015

Nikki Johnson Market Access Solutionz Ltd

nikki@solutionz.co.nz

Outline of presentation

• Background
• Risk assessment
• Benefits assessment
• Controls
• Consistency
• Future strategy for agchems
• Summary
• Industry presentations

Industry Groups Represented

Industries that consider use of Dichlorvos critical:

• Greenhouse vegetables
• Outdoor vegetables

– Squash – Brassica – Lettuce – Salad Leaf – Silverbeet/spinach – Others (Asian greens, herbs, baby veg)

• Persimmon orchards
• Asparagus

EPA Proposals

• Effective

ban

• n
• utdoor

uses (hand held irrelevant) – 12 month phase in

• Indoor greenhouse uses – proposal unclear
• Measures could be imposed to manage risk
• But recommendation is for small scale use only?
• Small scale only = effective ban all uses
• Large scale GH allowable with automatic uses only =

will ban use for most growers

Process

• EPA is

the applicant, the assessor and the reviewer

– Is this appropriate? – Tested through bee reassessment – outcome unknown

• Timeframes insufficient to generate types of data

EPA staff are requesting

– 30 days to gather feedback & prepare submission – 10 days pre hearing to respond to revised proposals

• Adversarial approach (Section 2.3.2)
• Absence of data = EPA have chosen extremely

precautionary approach

Risk Assessment

• Burden of proof is on submitters not applicant

– Request for industry to provide additional information is not feasible in the timeframe of the process, may also be uneconomic – No attempt to obtain identify data gaps and obtain information in advance of the statutory process – No attempt to contact industry for more information between written submissions and update report

• e.g. monitoring information discounted due to lack of detail but

no clarification was sought

• Process does not allow for information to be

generated - “Information on semi-automatic methods was

requested but not provided” – unachievable within 30 days.

2

Risk assessment

• Lack of assessment of semi-automatic methods has

severe implications for industry

• Operator RQ values

– Automatic = 2.9 – Manual = 7

• What information would be required to assess this?
• Would provision of monitoring records assist – is EPA
• pen to practical discussion?
• Serious data gap – needs to be addressed before

any decisions are made – who is responsible?

Risk assessment

• “Absence of records does not mean absence of

incidents” – could equally argue the opposite

• ADI – impact of reducing it to below Codex level

(0.004) to 0.001 is unclear

• Risks to birds from ingestion – safe for human

consumption after 1 day – why not birds?

• Risk to food gathering – safe for humans to eat after 1

day – impact is limited.

Benefits assessment

• Independent review is appreciated
• However, the review does not consider sector

based cost benefit

– Benefits from removing household use are high – industry agrees that domestic use is not justified – Costs associated with removing horticulture use are high $150-$333m – what are the specific benefits?

• Alternatives assessment is flawed – no

consideration of PHIs or fumigant activity

• ‘Partial withdrawal’ – reality is full withdrawal if no

large scale applications are retained

Controls

• Industry suggested night applications to protect

bees – was this even considered?

• If the risk to bees was controlled through night

applications and the risk to birds was re-assessed based on actual likelihood and found to be low – then that leaves only aquatic to be managed.

• EPA comments that costs of installing automatic

equipment are not cost prohibitive – on what basis is this claim made?

Comparative risk

Operator Re-entry Bystander Aquatic Bird Dichlorvos 2014 Indoor (auto) H L M/L Neg Neg Indoor (semi) ? ? ? ? ? Indoor (Manual) H L M Neg Neg Persimmon H M M (H) (H) 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

Consistency

Operator Re-entry Bystander Aquatic Bird Outcome Diazinon H M M M H 15 years Fenamiphos H M M M H 10 years Prothiofos H M M M L 10 years Dichlorvos (outdoor) 2015 H M M (H) (H) 1 year

() assessments from 2013 and 2014 are not directly comparable

3

Future strategy

• Industry is looking for alternatives
• Vegetable Agchem Strategy
• Minor Crops Initiative
• EPA has reassessed two groups (26 compounds)

in the last two years

• 11 declined
• 7 phased out
• 7 retained
• Dichlorvos effectively phased out
• Industry needs a

phase out timeframe that allows alternatives to be developed.

• 2 month phase-out is insufficient and impractical

Summary

• Question the

process – data gaps identified in application but industry are given only 30 days to respond – how is this feasible?

• Question that the burden of proof is on submitters
• EPA acknowledge risks are overstated
• Data gap on semi-automatic - precautionary
• Large scale indoor use proposal unclear – if risks can

be managed why has EPA not proposed it?

• Impact of 12 month phase out will be severe
• Proposed phase out inconsistent with decisions in the

2013 OPC review

• Industry has a future strategy – needs more time.

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

4

Whitefly Timeline

• Prior to 2006

– partial biocontrol of whitefly with Encarsia and ag- chems

• 2006

– Tomato-Potato Psyllid arrives in NZ

• 2006-2014

– Almost exclusive ag-chem based psyllid control in potatoes

• 2015

– Epidemic proportion whitefly issues – Severe crop losses

Resistance Management

• Resistance management crucial in current ag

chem based strategy

• The current situation is fragile at best
• Considerable crop losses this summer
• Concerns about resistance of almost every

group of ag chems

– Dose rates sub-lethal to whitefly, but targeted at

• ther pests on other crops, probably responsible

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

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The Future

• Most sustainable solution is back to an IPM based

strategy, but…

• We do not have all the beneficial insects we need
• We do not have all the tools needed to fix problems

in IPM program if we had the beneficial insects

• Products like dichlorvos have an important role in

fixing problems in IPM programs

• There are significant hurdles to achieve this

Caution When Comparing Internationally

• NZ has pests that other nations do not have

– Combinations of pests important too – E.g., Whitefly + Tomato-Potato Psyllid together

• NZ does not have beneficial insects of pests

that other nations do not have

Application Method

• Spraying is significantly more efficacious than

fogging

– Less repeat applications

• To install a fully automatic fogging systems

would cost T&G approx. $125k for the fogging system

• Fan system that goes with it approx. $287k

– Cheaper as we already have some fans in place

• Total for Automatic Fogging $412k for T&G
• Prices calculated from actual capex work

completed 2-3 years ago at 2 different growers

Cost of Fully Automated Fog

• Assumes 21% of growers already have fans
• Assumes everyone will pay the same $/ha

install costs

– Costs based on large installations. Majority of

• perators smaller so will cost a lot more

Crop Area Cost Tomatoes 120 $2,423,520 Aubergine 6 $121,176 Capsicum 65 $1,312,740 Lettuce 50 $1,009,800 Total 241 $4,867,236

Reality of Fully Automated Fog

• I only know 1 grower who has it
• It causes damage to the crop as it does not

apply product very evenly across the area

• It isn’t as efficacious as spraying
• He uses semi automatic spray robots instead

Fully Automated Spray

• Great in theory, but…
• Still unreliable
• Only suitable for new build glasshouses

– Need higher rated pipe rail brackets

• Weight 587kg vs ~400kg currently (dangerous

enough now) – Glasshouse layout needs to be precise so sensors “catch” – Rough concrete floors aren’t suitable

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Application Method

• Semi Automated spraying the only practical
• ption

Maximum Handling Quantity

• Needs to reflect reality of Semi Automatic

application

• Need to be able to apply ~2kg in one day

across a greenhouse

• Can use multiple operators to make it work
• 750-1000g per person per day is workable

using multiple operators

Exclusion Zone

• Is it proven that there is a need for one at all

when it is sprayed into an enclosed space?

• Is there a reason 20m is suggested?

– Where does this number come from? Is it backed up by something? – Will require section 95A permission in many instances – 20 days to obtain permission is impractical to plan a spray with

• Reducing this to 10m would make this vastly easier

to implement

– Likely to have greater compliance – Will reducing it to 10m actually make a difference to bystanders?

Other Proposed Controls

• We can make them work

– PPE/RPE – Maximum application rates – REI – Signage – Aspects of Exclusion and Notification – Phase in times assuming my proposals are adapted

• Phase in times need to be 3-5 years if EPA

Staff proposals are accepted as they are written

Whatever the decision is, please put ALL information needed by operators to do their job in a compliant way on the label in a clear and concise way

Summary

• Need semi automated application
• Need Maximum Handling quantity 750-

1000g/day for semi automatic application

• Question how the exclusion zone came about

and how workable this could be

• Phase in times need to be longer if EPA Staff

proposals are accepted as written

7 Outdoor vegetable industries (including squash)

Dr Stuart Davis Technical Director, LeaderBrand Produce Director - Leafy Crops, Vegetables NZ Inc

Summary of dichlorvos use in

• utdoor vegetables

Crop Target pests Growers Value ($m) Employees (FTEs) Squash caterpillars, aphids, thrips 40 $54 345 Brassicas caterpillars, aphids 420 $83 504 Lettuce caterpillars, aphids, cockroaches 40 $51 414 Salad leaf aphids, caterpillars, leaf miners, springtails, symphilids 50 $25 170 Silverbeet/spinach caterpillars, aphids, leaf miners, mites 50 $6 ? Others (Asian greens, herbs, baby veg) caterpillars, aphids, leaf miners, thrips, whitefly ? ? ? TOTAL >500 >$220 >1600

Squash

• Dichlorvos uses:
• early crop growth – thrips: 30%-40% yield loss on 5-

10% area

• close to harvest – tomato fruitworm, aphids: 10% yield

loss on 8% area

• fumigant action, bee compatibility, short PHI, market

acceptability

• Alternatives?:

– early crop growth – chlorpyrifos – close to harvest

• neonicotinoid seed dressings run out – foliar application

(another group) required

• no alternatives with fumigant activity and low PHI

– chlorpyrifos – PHI 10 days and market acceptability

Brassicas

• Dichlorvos uses:
• early crop growth
• resistance management
• close to harvest – caterpillars (esp DBM), aphids: $16-

24k/ha loss on 2-5 ha

• multiple modes of action, short PHI
• Alternatives?
• early crop growth – methamidophos
• close to harvest
• neonicotinoid and diamide drenches run out – foliar

application (another group) required for control and resistance management

• no alternatives with fumigant activity and low PHI

– methamidophos – PHI 7 days

Lettuce

• Dichlorvos uses:

– close to harvest – caterpillars (esp TFW), aphids, cockroaches

• up to 300-400 ha p.a., crop value $9.6m

– fumigant action, short PHI

• Alternatives?

– close to harvest

• no alternatives with fumigant activity and low PHI
• chlorpyrifos – PHI 10 days

Salad leaf

• Dichlorvos uses:

– short PHI: short crop durations and high crop value ($25k/ha) – intensive AYR crop production: resistance management

• Alternatives?:

– 2014 trial demonstrated usefulness of dichlorvos: PHI <1d – abamectin: PHI 3d, need to test efficacy (springtails, leafminer, DBM, ?symphilids) – chlorantraniliprole: PHI 3d, need to confirm 2015 trial (lepidoptera only) – spinetoram: no local knowledge on PHI (2015 trial) or efficacy (leafminer, springtails, caterpillars, thrips in

• ther crops)

8 Other minor vegetables

• silverbeet, spinach , herbs, Asian greens and baby

vegetables

• Dichlorvos uses:

– short PHI and fumigant action – spinach crown mite (used in conjunction with SP)

• Alternatives?:

– virtually no chemical industry trial work – growers require time to test residues and efficacy

Decision requested…(1) more time

• 12 month phase-out periods for key chemistry like

dichlorvos is not practical and is irresponsible

• Along with the OPC reassessment/ACVM ADI review, the

dichlorvos reassessment is part of a large amount of change imposed across a wide range of vegetable crops

• For the larger crops, time is required to identify new

groups that can be incorporated into established IPM and IRM programmes

• The salad leaf trial work shows that, given time, even

minor crops can find alternatives

• 5 years would be consistent with previous decisions

Decision requested…. (2) a better approach?

Minor crop industries have been pro-active…

• AgChem Strategy WG (since 2009, 5 vegetable PGs)
• SFF minor crops project (2011-15, 17 fruit & veg PGs)
• International linkages and data sharing with overseas

minor crop programmes (USA, Canada, Australia) and policy development initiatives (GMUS, CCPR)

• Working relationship with technical staff in chemical

companies in NZ and globally

• Attempting to build an ongoing minor crops programme

(20-25 horticultural PGs)… with no Gov’t support (so far..)

Asparagus

• Insectigas has been used by industry for markets
• ther than Japan
• It has now been determined that Insectigas is

not registered for use on food crops

• The Registrant will not support registration due to

cost of the process and uncertainty of future of the product

• Asparagus can no longer use Insectigas and

have withdrawn from the reassessment process

• There will be implications for export asparagus

while alternatives are developed.

Persimmon Ian Turk Persimmon Industry Council

Persimmon

The NZ persimmon role for Dichlorvos:

• Few applications each year
• Only used when there is a pest problem close to

harvest

• Used when climatic conditions correct for fumigant

activity

• Highest value per application spray for the

persimmon industry?

• Only applied by Growsafe and NZGAP accredited

growers

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Persimmon

The future?

• Dichlorvos is a very important component in our

current tool chest

• Is wide ranging – effective against mites, leafroller,

scale and spiders

• Its use has tangible benefits, at the very end of the

crop growth cycle

Persimmon

Dichlorvos

• It may be a grower’s only option for eligibility for

premium markets

• It is a key assurance in our pest management

programme for export to China.

• Is used wisely in the persimmon industry.
• The persimmon industry needs a longer phase
• ut to research possible alternatives.