SUBM ISSION ON APP201941 Importation of RANM AN containing active - - PowerPoint PPT Presentation

SUBM ISSION ON APP201941 – Importation of RANM AN containing active ingredient cyazofamid, for use as a foliar applied fungicide.

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TE RŪNANGA O NGĀI TAHU

by

Gerry Te Kapa Coates

M ember, HSNO Komiti

Slide 2

Extends from Kaikoura in the north to Rakiura (Stewart Island) in the south, including the West Coast, T eTai Poutini. T e Rūnanga o Ngāi Tahu constitutes 18 Rūnanga representing geographical areas, generally based around traditional settlements.

THE NGĀI TAHU TAKIWĀ

“ Te Puna Waimaraarie, Te Puna Hauaitu, Te Puna Karikari” The pools of frozen water; The pools of bounty; The pools dug by the hand of humans ”

• Rakaihautu

Waihao Over 90% of the South Island & over 40% of NZ land mass.

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Kia tuohu koutou, Me he mauka teitei, Ko Aoraki anake. “If you must bow your head then let it be to the lofty mountain Aoraki”

Our takiwa

TE RŪNANGA O NGĀI TAHU HSNO KOM ITI

• 6 M embers
• Responsible for

monitoring new EP A applications

• HSNO Policy Statement

THE HSNO POLICY

a) Evaluate issues of importance to Ngāi Tahu b) Identify and assess effects (risks and benefits), from a Ngāi Tahu perspective c) Identify options to avoid or minimise adverse effects on Ngāi Tahu values d) Identify outcomes important to Ngāi Tahu (e.g. environmental, cultural, health and well-being, economic).

Ngāi Tahu have a unique body of knowledge and practice relating to the environment and the relationship of people to the environment. This knowledge and practice can complement scientific knowledge, and provide better understandings of the effects of hazardous substances and new organisms on the environment and our communities.

ISSUES CONSIDERED

• Lack of culturally relevant information in applications.
• Difficulties of assessing highly technical applications.
• Time and cost burden to T

e Rūnanga o Ngāi Tahu of assessing applications, particularly when applicants provide insufficient information on issues of cultural importance

• Pollution of the natural environment from the storage, use and

disposal of hazardous substances.

• Potential effects on native species (positive and adverse) from

the use and disposal of hazardous substances.

• Risk to human health, posed by the storage, use or disposal of hazardous

substances, directly or indirectly (e.g. bioaccumulation in mahinga kai species and subsequent human consumption).

• Cultural and environmental effects of transport of hazardous substances.
• Long term effects of hazardous substance use.
• Risks of emergencies or accidents from the manufacture, use, disposal and

transport of hazardous substances .

• How cultural and Treaty concerns are reflected in EPA decisions on applications

TREATY CONSIDERATIONS

• T

e Rūnanga o Ngāi Tahu was statutorily recognised as the representative tribal body of Ngāi Tahu Whānui under section 6 of T e Rūnanga o Ngāi Tahu Act 1996.

• This means we exercise kaitiakitanga over our takiwā.
• The EPA must be ever mindful of its responsibilities

for ‘active protection’ under T e Tiriti o Waitangi.

• Active protection needs to operate in terms of Te Tiriti,

not through general concerns about health and safety issues and mechanisms.

• The EPA’s role must also include finding ways to acknowledge,

test and do research on the impacts of hazardous substances on 'down-stream' taonga native species including threatened species and ecosystems, in a similar manner to that required for introduced bio-controls.

SUBM ISSION ON APP201941 – Importation of RANM AN

We oppose the introduction of the insecticide Ranman (for use as a foliar applied fungicide that will be used to control sucking pests in horticultural crops primarily potatoes and

• nions) to New Zealand for the following reasons:
• The application does not provide a persuasive case for the

benefits as against any risks (little supporting evidence is provided apart from in a confidential appendix).

• Toxicity of this new fungicide (and) insecticide with the

active ingredient cyazofamid raises serious concerns over risks to bees in particular, and to the aquatic environment, and should demand that extensive testing be undertaken by the applicant, or as is now proposed by the EP A using precautionary safety factors to safeguard native species.

SUBM ISSION ON APP201941 – cont. 1

General comments on the application:

• As in many previous applications it is impossible to evaluate the

evidence and truth of the claims made with almost all the data being in a Confidential Appendix. The US EPA data sheet goes some way to remedying this.

• The International Regulatory status of the product is unclear.
• RANM AN appears to comprise 400 grams per litre of the active

ingredient cyazofamid, but no details are given of the rest of the ingredients in the formulation.

• Potential risks associated with the four primary metabolites

resulting from the degradation of the active ingredient cyazofamid in soil or water is difficult to assess because these chemicals were not named in the Application. However at least one (CCIM ) appears to be more acutely toxic than the active ingredient itself.

Specific comments:

• Risks and benefits: The benefits cited are “ new chemistry which

minimises the risk of disease resistance developing.” In fact this will

• nly delay the onset of the risk. There are significant risks the

substances will not be applied consistent with good practice and label instructions – especially for off label crops, and for bee protection.

• M āori Consultation: It is asserted without any evidence that “ the

applicant is unaware of any significant or adverse impact that importation, release and use of the substance would have on M aori cultural, spiritual, ethical and socio-economic values.” The assertions made about impacts on Māori can not be supported.

• Quantification: There is no quantitative information on the

benefits to be gained from the use of RANM AN or what the rationale is for adding another fungicide to the existing armoury of tools.

SUBM ISSION ON APP201941 – cont. 2

SUBM ISSION ON APP201941 – cont. 3

• Risks of ground spraying:

– Waterways: Contamination of domestic water supplies

especially waterways such as farm drains and streams from run-off as well as spray drift is particularly of concern to Māori who gather mahinga kai.

– Adjacent crops and plants: Native plants such as

watercress are just as important to Māori as commercial crops.

• Ngā Kaihautū report: None apparently done.

SUM M ARY

We request the Application be declined because:

• The Applicant appears to have taken a too casual approach to

the information requirements.

• No persuasive case including quantification of benefits has

been made.

• The supporting evidence provided is in a confidential

appendix not available to submitters except by proxy in the Staff Evaluation report, or by inference from the US EP A data sheet.

• The toxicity of this insecticide to bees, and the absence of

any testing or evaluation of the impact on native species raises serious concerns over risks to the aquatic environment, and to people.