Apicultural NZ Technical Focus Group Apiculture NZ Technical Focus - - PowerPoint PPT Presentation

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Apicultural NZ Technical Focus Group Apiculture NZ Technical Focus - - PowerPoint PPT Presentation

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


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Submission APP202349 Apicultural NZ Technical Focus Group

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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
  • n 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.

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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.

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  • 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.

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  • 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.

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The ApiNZ TFG thanks the EPA for this opportunity to submit on this fungicide application.