OPC Reassessment Presentation from the Horticulture & Arable - - PowerPoint PPT Presentation

OPC Reassessment Presentation from the Horticulture & Arable Industries

07 March 2013

Nikki Johnson Market Access Solutionz Ltd

nikki@solutionz.co.nz

Outline of presentation

• Industry summaries
• Proposed Controls
• Biosecurity
• ADIs
• Conclusions
• Note toxicology has not been a focus of the

Hort/Arable review due to lack of time/resources

Summary of Industry

Industries represented contribute over $2.7 billion to NZ economy and employ around 35,000 permanent and seasonal staff. Horticulture industry's goal to achieve industry value of $10 billion by 2020- The 10/2020 strategy. The Foundation for Arable Research 11 Product Groups affiliated to Horticulture New Zealand: – Avocado Industry Council – NZ Citrus Growers Inc – Persimmon Industry Council – Strawberry Growers NZ – Summerfruit NZ – Tamarillo Growers Assn – Onions NZ – Potatoes NZ – Process Vegetables NZ – Tomatoes NZ – Vegetables NZ

Arable Industry

Mike Parker- Project Manager / Grower Foundation for Arable Research

Sector statistics (2011) Critical use OPCs recommended for retention:

• Chlorpyrifos, Oxamyl, Pirimicarb and Pirimiphos methyl - Agree

Crop

• No. growers No. employees Land area (ha)

Total value $(b) Arable crops

• incl. maize

4,000 5,750 262,300 1.1 Compound Phase out period (years) Comments Phorate 3 Agree – Assume diazinon retained Methamidophos 5 Disagree - Critical for green vegetable bug control Diazinon 10 Disagree - Critical for grass grub control

Diazinon and Methamidophos

• Proposed time frames not sufficient to find alternatives

– Grass grub = NZ pest, difficult to find controls – Green Vegetable Bug = probably requires new chemical group = more than 5 years

• FAR working towards finding alternatives through a SFF grass grub

research project to identify alternatives to diazinon (titled ‘Managing the number one soil borne pest in cropping’)

• Request reassessment 2 years prior to phase out to ensure alternatives are

available

Arable Industry

Arable Industry

Cereal production - Comparison between OP (left) and nil control (right) when grass grub is present

Persimmon Industry

Geoff Peach - Executive PIC Persimmon Industry Council Inc.

Sector statistics (2011) Critical use OPCs recommended for retention:

• Chlorpyrifos and Pirimiphos methyl – Agree

Pirimiphos methyl

• Revised recommendation appreciated

– Acknowledges benefits - critical for control of mealybug, leafroller, scale and thrips – Agree with revised recommendation to retain outdoor use

• No. growers
• No. employees

Land area (ha) Total value $(m) 50 150 250 10.7

Persimmon Industry

Thrips feeding damage Mealy bug with associated sooty mould damage

Avocado Industry

Dr Henry Pak- Technical Manager & John Cotterell, Grower Avocado Industry Council Ltd

Sector statistics (2011) Critical use OPCs recommended for retention:

• Acephate, Carbaryl, Chlorpyrifos, Maldison and Pirimiphos methyl - Agree
• No. growers
• No. employees

Land area (ha) Total value $(m) 1,600+ 1,062 4,247 82 Compound Phase out period (years) Comments Pirimiphos methyl Revised to long term retention Agree - critical for control of leafroller, thrips and scale Diazinon 10 Disagree - Critical for scale, thrips and leaf roller control

Diazinon

• Do not support restriction to 2 applications per year - require 4 per year

for thrips control

• No alternatives available that meet market restrictions
• Request reassessment 2 years prior to phase out to ensure alternatives are

available Pirimiphos methyl

• Revised recommendation appreciated

– Acknowledges benefits – Agree with revised recommendation to retain outdoor use

Avocado Industry

Avocado Industry

Thrips damage Leafroller damage

Citrus Industry

Rick Curtis - Chairman New Zealand Citrus Growers Incorporated

Sector statistics (2011) Critical use OPCs recommended for retention:

• Acephate, Malathion/maldison, Pirimicarb and Diazinon – Agree
• Acephate only option for control of Citrus Flower Moth
• NZCGI appreciates EPA’s acknowledgement of benefits acephate

provides to regional economy (Northland and Gisborne)

• No. growers
• No. employees

Land area (ha) Total value $(m) 421 1,521 (incl seasonal) 999 56.3

Citrus Industry

(A)Lemon bud infested with a citrus flower moth (CFM) larva, (B,C) Citrus flowers damaged by CFM larvae.

Photo: Plant & Food Research [Chhagan et.al., 2009]

Citrus Industry

(A, B, C) Rind-spot damage on immature lemon fruit.

Photo: Plant & Food Research [Chhagan et.al., 2009]

Strawberry Industry

Peter McIntyre- Strawberry Growers New Zealand

Sector statistics (2011) Critical use OPCs recommended for retention:

• Chlorpyrifos and Methomyl and Pirimicarb – Agree
• Diazinon: Request reassessment 2 years prior to phase out to ensure

alternatives are available

• Methomyl: New information from DuPont - request EPA re examine REI &

reduce to 24 hours

• No. growers
• No. employees

Land area (ha) Total value $(m) 110 7,380 (incl seasonal) 246 48 Compound Phase out period (years) Comments Methomyl Revised to long term retention Agree - critical for control of aphids and other chewing insects Diazinon 10 Disagree - Critical control of beetle and caterpillar

Strawberry Industry

Summerfruit Industry

Dr Stephen Ogden- Market Access Manager Summerfruit New Zealand

Sector statistics (2011) Critical use OPCs recommended for retention:

• Carbaryl, Chlorpyrifos and Pirimicarb- Agree
• SNZ appreciates EPA’s acknowledgement of the benefits these

compounds provide industry

• No. growers
• No. employees

Land area (ha) Total value $(m) 258 5,500 (inc. packhouses) 1,830 68.5

Tamarillo Industry

Robin Nitschke- Manager New Zealand Tamarillos Growers Assoc. Inc.

Sector statistics (2011)

• TPP has had an extreme impact on industry
• Compounds essential for resistance management to control TPP
• Recovery of industry relies on continued use until alternatives registered
• Request reassessment 2 years prior to phase out to ensure alternatives are

available

• Off label use critical
• No. growers
• No. employees

Land area (ha) Total value $(m) 50 15 110 1.8 Compound Phase out period (years) Comments Methamidophos 5 Disagree - Critical for TPP control Diazinon 10 Disagree - Critical for TPP control

Tamarillo Industry

Liberibacter affected fruit (normal fruit on left) and leaves. Tree is still capable of setting fruit, but they are small, insipid and of no economic value. Tree will not return to normal growth patterns.

Sector statistics (2011) Key crops include*:

• Beans
• Peas
• Field tomato
• Sweet corn

*processed potatoes and carrots covered in other sections

• No. growers
• No. employees

Land area (ha) Total value $(m) 680 268 (FTEs) 8,057 256.8

Process Vegetable Industry

Dr Stuart Davis- Leaderbrand & PVNZ Process Vegetables NZ

Compound Phase out period (years) Comments Phorate & terbufos 3 Agree – Assume diazinon retained Fenamiphos 5 Strongly disagree- Critical for nematode control in carrots Methamidophos 5 Disagree - Critical for TPP, green vegetable bug, aphid, tomato fruit worm (= corn ear worm) control Diazinon 10 Disagree - Critical for TPP and grass grub control

Process Vegetable Industry

Critical use OPCs recommended for retention:

• Chlorpyrifos, Oxamyl and Pirimicarb - Agree

Process Vegetable Industry

Benefits to sweet corn - Methamidophos for GVB control:

• Causes direct feeding damage
• Has challenging physical and behavioural characteristics = hard to

control

• Research started in mid-1990s, ~ 20 years later still no alternatives

Benefits to beans /peas – Diazinon for grass grub control:

• No alternatives

Benefits to field tomato – Methamidophos & Diazinon for TPP control:

• No alternatives, needed for resistance management

Benefits to carrots – Fenamiphos for nematode control

• Benefits of Fenamiphos for nematode control to carrots covered in

Vegetables NZ section Request reassessment 2 years prior to phase out to ensure alternatives are available

Potato Industry

Dr Stephen Ogden- Psyllid Coordinator Potatoes New Zealand

Sector statistics (2011) Critical use OPCs recommended for retention:

• Chlorpyrifos and Pirimicarb - Agree
• No. growers
• No. employees

Land area (ha) Total value $(m) 234+ ~2,500 11,717 560.3 Compound Phase out period (years) Comments Fenamiphos 5 Strongly disagree- Critical for potato cyst nematode (PCN) control Methamidophos 5 Disagree - Critical for Tomato Potato psyllid (TPP) and Potato Tuber moth (PTM) control

Benefits of Methamidophos for TPP control:

• Essential for control of TPP and zebra chip disease - affects both yield and

quality of tubers

• Used as part of a rotation in resistance management program
• Effective due to systemic action when crops at full canopy
• Since arrival of TPP (2006) large investment by PNZ. Total R&D expenditure

~$1.3m over last 2 years

Potato Industry

Benefits of Methamidophos for PTM control:

• Systemic action targets feeding insects - allows foliage to develop

without being attacked by larvae – plant able to produce healthier larger tubers

• Key component in resistance management of PTM
• Request reassessment 2 years prior to phase out to ensure alternatives are

available

Potato Industry

Benefits of Fenamiphos for PCN control:

• PCN causes cysts to form on potato roots - decreases yields
• Only compound currently registered in NZ for PCN control in potatoes
• PCN can stay in soil for up to 20 years – used where fields have large

numbers of PCN in soil

• Request extended phase out and reassessment 2 years prior to phase out

to ensure alternatives are available

Potato Industry

Potato Industry

Potato cyst nematode Increasing severity scale of zebra chip disease - makes potatoes unsaleable Potato tuber moth damage

Onion Industry

Mick Ahern- Chairman Onions New Zealand

Sector statistics (2011) Above includes garlic and shallots Critical use OPCs recommended for retention:

• Chlorpyrifos – Agree
• Onions not a minor crop in NZ but garlic and shallots are
• No. growers
• No. employees

Land area (ha) Total value $(m) 143 1,500 5,325 144 Compound Phase out period (years) Comments Methamidophos 5 Agree - alternatives will be registered for use in onions within 5 years

Greenhouse Industry

Lex Dillon (NZ Hothouse) and Ben Smith (Status) Tomatoes NZ & Vegetables NZ

Sector statistics (2011)

Above includes other glasshouse crops (Tomato, Capsicum, Chilli, Cucumber, Melon, Eggplant, Witloof and Courghette)

Critical use OPCs recommended for retention:

• Oxamyl, Methomyl and Pirimiphos methyl – Agree

Controls:

• Control wording ambiguous

– “Automatic application methods” EPA explanation = semi automatic but wording is “automatic” = confusing – Difference between hand gun & knapsack (Handgun prohibited)

• No. growers
• No. employees

Glass house area (ha) Total value $(m) 365 ~1,450 175 188.7

Vegetable Industry

Dr Stuart Davis- Director: Leafy Crops Vegetables New Zealand

Sector statistics (2011) Vegetables NZ represents range of crops - key crops impacted are:

• Brassica
• Celery
• Carrots and parsnips
• Kumara
• Lettuce/ baby leaf
• Cucurbit and squash
• Note that greenhouse capsicums are covered under greenhouse

Critical use OPCs recommended for retention:

• Acephate, Chlorpyrifos, Malathion/maldison, Methomyl, Oxamyl,

Pirimicarb and Pirimiphos methyl - Agree

• No. growers No. employees Land area (ha)

Total value $(m) 1,038 1,880 16,820 272.4

Vegetable Industry

Compound Phase out period (years) Comments Phorate 3 Agree – Assume diazinon retained Terbufos 3 Strongly disagree – Critical for symphilid, stem weevil and wireworm control in Kumara and grass grub in carrots Methamidophos 5 Disagree - Critical for black beetle and white fringed weevil control in kumara Fenamiphos 5 Strongly disagree – Critical for nematode control in carrots Diazinon 10 Disagree – Critical for springtails and symphilid control in Baby leaf, Grass grub, manuka beetle, porina, carrot rust fly and springtail in carrots and grass grub, black beetle, white fringed weevil and wireworm in Kumara & Celery

Vegetable Industry

Celery- Diazinon

• Can accept phorate phase out if diazinon is retained for control of carrot

rust fly.

• Request reassessment 2 years prior to phase out to ensure alternatives are

available Lettuce/ baby leaf – Methomyl

• Industry agrees with revised recommendation to retain - benefits
• utweigh risks.
• Support Dupont request to shorten REI

Carrot and parsnips: Fenamiphos

• Seriously impacted by proposal to phase out fenamiphos = only product

to control nematodes

• Commercial future production in NZ in jeopardy if phased out before

alternatives found = import carrot and parsnip

• Request phase out increased to 10 years and reassessment 2 years prior

to phase out to ensure alternatives are available or increase phase-out to 10 years

• EPA revised benefit of fenamiphos to carrot and parsnips as being high -

industry agrees

• Application restricted to authorized person control = not practical =

nematodes not new pest to trigger Biosecurity Act

Vegetable Industry

Vegetable Industry

Andre De Bruin - Vice Chair & Director: Root & Tuber Crops Vegetables New Zealand

Kumara: Terbufos

• 45 Kumara growers who employ 545 FTEs with industry value $25m-

significant to Kaipara region

• Used pre-plant to reduce larvae in soil – insects attack hairs of developing

plants, cause stunting, later direct damage to tuber

• Symphilid not known pest in other countries plus very minor crop = little to

no research done internationally

• Efficacious - granule formulation type = better pest control than liquid
• Long history of cultivation (over 500 years) special cultural significance -

taonga status - acknowledged in Waitangi tribunal Y262

• If domestic kumara production ceased, because fresh kumara cannot

be imported, no longer part of NZ diet

• Negative effect on employment in Northland region

Request reassessment 2 years prior to phase out to ensure alternatives are available or increase phase-out to 10 years

Vegetable Industry

An example of black beetle damage on kumara tubers An example of nematode forking

Proposed controls

• In general, can meet proposed controls due to strong uptake of

Growsafe in industry

• Industry appreciates removal of droplet size restrictions
• Issues:

– Implications for off label use on minor crops – Limiting number of applications of diazinon (2 per year avocado) – Application frequencies limited to per year instead of per crop cycle – Impractical notification requirements – 2 day – EPA explanation allows semi-automatic application, change appreciated but needs better wording – Buffer zone recommendations – apply to wide dispersal applications. Ground based boom not wide dispersive. – Still have some issues with buffer zone specifications – some movement possible with option for an approved COP

Proposed Controls

Phase out timeframes

If no alternatives, industry requests modified reassessment commences 2 years before phase out for:

• Diazinon
• Methamidophos
• Fenamiphos
• Terbufos

Or increase phase out period for:

• Diazinon to15 years
• Methamidophos and Fenamiphos to 10 years
• Terbufos to 10 years

Off label use

• In general, the use of compounds on crops for which there is no label is

legal and allowed – Must meet the default MRL of 0.1 mg/kg – A few compounds are restricted and can’t be used off label – this would be the case if there was a possible dietary intake concern – Minor crop = minor part of diet

• Many of the crops represented here are minor crops = rely on off label

use

• There is not sufficient economic proposition for companies to do research

required to support label

• Therefore it is essential that minor crops are allowed to use OPCs off label
• EPA needs to ensure ACVM will not place restriction on off-label use –

likely due to EPA controls on application parameters

• Industry is leading work to deal with off label registration issues but these

will only apply to new chemistry – requires industry to fund the work

Biosecurity

• Importance for biosecurity seems to be well understood
• Implications - Australia (APVMA) recently banned various OP insecticides

– already resulted in poor control of fruitfly in Australia and impacted on domestic and export supplies of fruit

• Same situation could occur in NZ – OPs known for their use in incursion

response including fruitfly, citrus psyllid and many others

• Availability of OPCs in incursion unlikely if not in use - product not able to

be stored as shelf life only 2 years, stocks unlikely to be held in NZ

• Emergency registrations would take too long

Issues

• EPA rationale for selection unclear – limited explanation on why

APVMA/USEPA/EFSA figure is chosen.

• APVMA alignment explanation is weak given its importance
• ADI section is given 2 paragraphs on P26 – insufficient given its

importance

• Manufacturers have not focussed on ADI issues as they normally

would given its limited attention by EPA – refer Acephate reassessment and submissions on ADI = substantial and not responded to by EPA or referred to in current assessment

• Basis of selection critical due to downstream effects

Acceptable Daily Intake (ADI)

Acceptable Daily Intake (ADI)

ACVM role

• EPA sets ADI, ACVM applies

Outcomes

• 5 compounds exceed ADI based on labelled uses
• Reduced to 3 compounds if only critical labelled uses included
• Extremely difficult for industry to consider response to the overall OPC

recommendations in absence of accurate inter-government information Implications for minor crops

• Majority of crops supported are used off-label (minor crops)
• Where ADI is exceeded, restriction likely to on-label crops only = overrides

EPA recommendations

ADI Example – Diazinon

• Current NZ ADI = JMPR ADI of 0.005 mg/kg bw/day
• Reassessment = ADI - 0.0002 mg/kg bw/day (US EPA )
• Result of new ADI - ADI exceeded by 1048.6% based on labeled uses
• EPA have recommended 10 year phase out but
• ACVM will revoke MRLs, cancel registrations immediately

Options

• Reduce number of uses – ACVM have modeled only those labeled uses

supported in the reassessment = 510.5% = still exceeded

• Reduce MRLs = expensive especially for 10 year phase out, and

especially for animal residues

• Does not allow for off-label use – this will be restricted

*Same applies to methamidophos and Fenamiphos (with different ADI figures) exceeded by 228% and 230% respectively

Acceptable Daily Intake (ADI)

Imported Food Inconsistency

• Codex

– NZ strong supporter of international standards including Codex – NZ accepts Codex MRLs for imported food – Strong trading advantages in supporting Codex MRLs – EPA has proposed different ADIs to Codex – Where ADI value lower than Codex, EPA allowing imported food to have higher levels than considered acceptable for domestic

• Different levels = not acceptable

– Discriminates against NZ growers – Benefits imported food producers

Conclusions

• Need extended phase out for Fenamiphos, Methamidophos, Diazinon
• Request review 2 years prior to phase out
• Some changes to controls to help with implementation
• Biosecurity is critical and OPCs are important compounds
• Off label use is important – EPA need to ensure off label use is not

restricted by ACVM as a result of the EPA decision

• ADI – request that EPA review their ADI selection,

– provide robust and detailed explanation on selection – ensure it is appropriate to NZ – consult on this issue specifically with manufacturers – resolve the conflict between import and domestic standards – understand that if ADI’s are not changed in the review, that there will be impacts on registrations – this information needs to be known before OPC review is complete

• OPCs are used when absolutely necessary and no other alternatives are

available