opc reassessment presentation from the horticulture ... · persimmon industry geoff peach -...

OPC Reassessment Presentation

from the Horticulture & Arable Industries

07 March 2013

Nikki Johnson

Market Access Solutionz Ltd

[email protected]

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.



• 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



• Acephate, Carbaryl, Chlorpyrifos, Maldison and Pirimiphos methyl - Agree


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


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



• 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)


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



• 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



• Carbaryl, Chlorpyrifos and Pirimicarb- Agree

• SNZ appreciates EPA’s acknowledgement of the benefits these

compounds provide industry


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


available

• Off label use critical


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.


Key crops include*:

• Beans

• Peas

• Field tomato

• Sweet corn

*processed potatoes and carrots covered in other sections


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



• Chlorpyrifos, Oxamyl and Pirimicarb - Agree


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



• Chlorpyrifos and Pirimicarb - Agree


234+ ~2,500 11,717 560.3

Compound

Phase out


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


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


• Chlorpyrifos – Agree

• Onions not a minor crop in NZ but garlic and shallots are


143 1,500 5,325 144

Compound

Phase out


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


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

and Courghette)


• 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


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


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

Pirimicarb and Pirimiphos methyl - Agree


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.


available

Lettuce/ baby leaf – Methomyl

• Industry agrees with revised recommendation to retain - benefits

outweigh 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)


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


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

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