Staff Presentation – Grizly Max APP202093 Hearing 19 July 2016

Outline Introduction to application Submissions Classifications, Risks, Controls Benefits Recommendation Supplementary information

Introduction Insecticide Thrips on onions Tomato Potato Psyllid (TPP) and aphids on potatoes Suspension concentrate containing 3 active ingredients Imidacloprid Novaluron Bifenthrin

Proposed use pattern Ground boom application - 2 applications every season with a 7 day interval Imidacloprid max application rate 210 g/ha for potatoes 156 g/ha for onions Bifenthrin max application rate 24 g/ha for potatoes 18 g/ha for onions Novaluron max application rate 36 g/ha for potatoes 27 g/ha for onions

Risk assessment Imidaclopird application rate significantly higher than existing approvals for ground boom application (78 g/ha) hence a risk assessment was carried out Bifenthrin application rate lower than existing approvals – no risk assessment carried out Novaluron application method different, hence need for a risk assessment

Submissions 3 submissions were received Carolyn O Fallon National Beekeepers Association Te Rūnanga o Ngāi Tahu

Key issues raised by submitters Concerns about risks to bees Risks to the environment Risks to Māori values including concerns about taonga species Level of information in the application

Classification Hazard endpoint Grizly Max 6.5 Contact sensitisation 6.5B 6.9 Target organ systemic toxicity 6.9B (oral) 9.1 Aquatic ecotoxicity 9.1A 9.2 Soil ecotoxicity 9.2B 9.3 Terrestrial vertebrate ecotoxicity 9.3B 9.4 Terrestrial invertebrate ecotoxicity 9.4A

Risks to human health For the proposed use patterns risks to human health were less than the level of concern Operators (specific PPE required) Re-entry workers (wait until spray has dried) Bystanders

Risks to the environment Risks were less than the level of concern Groundwater Non target plants Birds

Risks to the environment Aquatic risk assessment – risks driven by novaluron Downwind buffer zones needed to manage risks 24 m for potatoes and 12 m for onions Low boom application only (<50 cm from the ground) Application only in wind speeds > 3 km/hr and < 20 km/hr Application must only occur using coarse droplets (applicant has informed us that product efficacy will not be affected) No application into or onto water Control information should be on the product label

Risks to soil organisms Acute risk assessment Risks less than the level of concern Chronic risk assessment (risks driven by imidacloprid) Risk assessment indicated risks above level of concern both in and off field Risks driven by the fact that the application rate is significantly higher than alternative products Chronic No Observed Effect Concentration (NOEC) for earthworms is greater than 0.562 mg/kg soil Chronic NOEC for the soil-dwelling predatory mite Hypoaspis aculeifer > 120 g/ha

Risks to soil organisms Applicant has provided an argument that earthworms are already under pressure due to cultivation practices and that therefore the risks from the use of Grizly Max are not significant EPA staff do not accept this argument- Grizly Max could pose a chronic risk to earthworms and other soil organisms

Risks to soil organisms Lack of data on the chronic risks of the principal metabolite of novaluron Uncertainties about the environmental fate of imidacloprid at the higher application rate

Risks to bees Risk assessment identified risks above the level of concern Controls were identified to manage these risks to honey bees No application when bees are foraging or in the 10 day period pre flowering No application to any crops grown for seed production We cannot exclude the possibility of risks to bumblebees

Risks to Māori Largest area of concern related to risks to earthworms Indigenous species are less likely where soil disturbance is highest Benefits to vegetable growers and their employees some of whom are Māori With controls the risk could be minimised, hence use would be unlikely to breach the principles of the Treaty of Waitangi

Benefits In the application form the applicant has identified benefits related to the control of thrips on onion and TPP on potatoes EPA staff agree that these pests are a significant problem for important sectors

Benefits Applicant has provided us with an efficacy report which demonstrates that the substance does work at the application rates suggested by the applicant – need at least 900 ml product/ha All three active ingredients are already approved in separately products Unsure about the rationale for combining these three active ingredients

Benefits Approving the substance would provide a benefit to growers in terms of convenience and increased grower choice From the application form we were unsure about why the applicant requested such high application rates

Overall recommendation Based on the information provided by the applicant in their application form and subsequent reports we recommend a decline

Subsequent information provided by the applicant Applicant proposed to reduce the application rates for potatoes from 1200ml/ha to 900ml/ha Revised risk assessment has not been completed Applicant has agreed to controls suggested in the Evaluation and Review report and additional label statements

Thank you for listening