ENVIRONMENTAL RISK MANAGEMENT AUTHORITY
DECISION
19 December 2007
Application Code
HSE07002
Application Type
To import for release and use a hazardous substance in a
special emergency under Section 49D of the Hazardous
Substances and New Organisms Act 1996 (the Act)
Applicant
Ministry of Agriculture and Forestry, Biosecurity New
Zealand (the applicant)
Purpose of the Application
To import for release and use Hexaflumuron (Sentricon
Termite Bait) to eliminate termites in the Greater Auckland
Region in the event of a special emergency declared under
section 49B of the Act.
Date Application Received
22 November 2007
Consideration Date
14 December 2007
Considered by
Hearings Committee of the Authority
1 Summary of decision
1.1
The application to manufacture and use Hexaflumuron (Sentricon Termite Bait) in a
special emergency declared under section 49B is approved with controls in
accordance with the relevant provisions of the Act and the HSNO (Methodology)
Order 1998 (the Methodology).
1.2
The substance has been given the following unique identifier for the ERMA New
Zealand Hazardous Substances Register:
Hexaflumuron (Sentricon Termite Bait) (HSE07002)
2 Legislative criteria for application
2.1
This decision was determined in accordance with section 49F taking into account
matters to be considered in that section, the matters specified in Part II of the Act
(Purpose of Act) and the relevant provisions of the Methodology. Unless otherwise
stated, references to section numbers in this decision refer to sections of the Act and
clauses to clauses of the Methodology.
2.2
The Committee notes that an approval has previously been granted for use of
Hexaflumuron (Sentricon Termite Bait) on 26 January 2007 in a termite incursion
declared to be a special emergency at Coatesville, in South Rodney district.
Potential use of the substance in the Greater Auckland region was approved. The
existing approval (HSE000009) expires on 31 December 2007. The applicant has
lodged an application under section 28 to import or manufacture Hexaflumuron
(Sentricon Termite Baits) for release (HSR07104). However, the Committee notes
that this application is still undergoing evaluation by the Agency and has not yet
been considered. The applicant advises that, in these circumstances, the Minister of
Biosecurity, Hon. Jim Anderton, has again declared the adverse event of the exotic
subterranean termite incursion at Coatesville to be a special emergency under
section 49B of the Act on 26 November 2007. An expiry date for the special
emergency has not been specified.
2.3
Hexaflumuron (Sentricon Termite Baits) were also used in Otorohanga and Nelson
for termite incursions. However, approvals granted for these treatment programmes
cannot be used for the applicant’s current purpose. This is because the treatment in
Otorohanga was conducted in 1999/2000 prior to HSNO approval requirements.
For the Nelson treatment, the substance was covered by a containment approval,
with a control limiting the application area to Nelson.
2.4
In accordance with section 49F, the approach adopted when considering this
application was to consider all the information having regard to the particular
circumstances of the special emergency that the applicant provided under section
49E and determine whether:
 the hazardous substance is necessary for use in the special emergency; and
 the proposed plan adequately controls the adverse effects of the substance.
3 Application process
3.1
The application was formally received on 22 November 2007.
3.2
Evaluation of the application was undertaken by the ERMA New Zealand Project
Team which comprised the following staff members:
Bella Whittle
Advisor (Hazardous Substances)
Linda Robinson
General Manager (Maori Unit)
Noel McCardle
Senior Advisor (Hazardous Substances)
3.3
The applicant supplied the following documents:
 the application, including the following documents as appendices:
o Appendix I: the ‘Plan for Dealing with the Agricultural Compound or
Medicine in the special emergency’ (the Management Plan);
o Appendix II: Details of the containment and transitional facility at St. Johns,
Auckland;
o Appendix III: Subterranean Termite Infestation Otorohanga- Technical
Discussion Document;
 The Sentricon II Technical Manual (2004).
3.4
Pursuant to sections 49F(2)(a) and 49F(2)(b), the Agency consulted with
Department of Conservation (DoC), the Ministry of Health (MoH), the Department
of Labour, and the Ministry for the Environment on the proposal.
3.5
A representative of MoH commented that:
3.5.1
The Ministry has no objection to the proposed application based on nonconfidential information provided from a public health perspective (non-
ERMA New Zealand Decision: Application HSE07002
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occupational). The Ministry noted that the special emergency approval
[HSE000009] was granted to MAF BNZ in January 2007 queried why no
application for a full release has been lodged to ERMA New Zealand
earlier so that the special emergency release provision of the HSNO Act is
not used all the time.
3.5.2
The Ministry considers that the use of special emergency provisions
should be carefully assessed by ERMANZ particularly for biosecurity
eradication programmes, when the programme may be exempt from RMA
consent processes.
3.6
The Committee notes that, in its earlier approval (HSE07001), the Authority
recommended that the applicant should lodge a full release application. The
applicant has since lodged a full release application (HSR07104), which was
formally received on 6 November 2007. The time required to process an
application via the notified pathway may have been underestimated. The
Committee also notes the Ministry’s concern regarding the use of special
emergency provisions of the HSNO Act to deal with biosecurity eradication
programmes.
3.7
A representative of DoC commented that;
3.7.1
Hexaflumuron is an Insect Growth Regulator (IGR) and as such is
formulated to be as specific as possible. IGRs have a very low impact on
non-target species, including invertebrates, compared to most contact
insecticides, and therefore a lower impact on invertebrate biodiversity.
DoC also commented on the very low concentration of active ingredient
(0.5%) and the use of the substance within the bait station; which were
considered as beneficial factors to non-target species.
3.7.2
DoC commented that it would support conditions to safeguard aquatic
habitats including those proposed by the applicant.
3.8
The Committee took note of DoC’s comments in consideration of this application.
3.9
No comments from any of the other Government agencies were received.
4 Consideration
Sequence of the consideration
4.1
This application was considered by the following members of the Authority’s
Hearings Committee (acting under a delegation under section 19(2)(b)): Professor
George Clark (Chair), Mr Neil Walter, and Dr Manuka Henare on 14 December
2007.
4.2
In accordance with section 49F and clause 24, the approach adopted when
determining the application was to:
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


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consider whether the applicant had provided sufficient information to
determine whether the substance should be used in a special emergency;
consider the purpose of the application and determine whether the substance is
necessary for use in the special emergency;
consider the lifecycle of the substance and determine the hazardous properties
and adverse effects of the substance; and
consider whether the Management Plan provided by the applicant adequately
controls the adverse effects of the substance.
Information review
4.3
The Committee has reviewed the applicant’s information and additional
information available to it and considers that there is sufficient information to
determine whether Hexaflumuron (Sentricon Termite Bait) should be imported for
release and used in the special emergency.
Purpose of the application
4.4
The purpose of this application is to obtain approval under the Act to import for
release and use Hexaflumuron (Sentricon Termite Bait) to eliminate termites in the
Greater Auckland Region in the event of a special emergency declared under
section 49B.
4.5
As of mid-November 2007, the applicant was aware of only one infested property
in South Rodney, and considers that the possibility that during the course of
investigation more infested properties/locations are located cannot be excluded.
Should there be newly detected infested properties/locations in the Greater
Auckland Region, the applicant intends that the Sentricon baiting stations will have
to be used on those locations under the umbrella of the response.
4.6
Further, the applicant advises that the precise number of bait stations and quantities
of bait potentially required are unknown at this stage. The applicant is applying for
permission to import and use as many stations and baits as it finds appropriate for
eradication of subterranean termites in the Auckland Region.
4.7
As the purpose amounts to “import for release”; and the “use of an agricultural
compound in a manner that would contravene the Act”, the Committee considers
that the application qualifies for consideration under sections and 49D(2)(a) and
49D(2)(d).
Criteria for declining the application
4.8
Under section 49F(3) the Authority may decline the application only if it is satisfied
that –
(a) the hazardous substance is not necessary for use in the special emergency;
or
(b) the proposed plan does not adequately control the adverse effects of the
hazardous substance.
ERMA New Zealand Decision: Application HSE07002
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The necessity to use the hazardous substance to deal with the special
emergency
4.9
The applicant advises that the response to termites at South Rodney is still active.
The substance was laid in March 2007 and no further termite activity has been
detected since this date through continued monitoring. However, the applicant
advises that the termites may have been disrupted. Monitoring shall continue for up
to five years before eradication can be officially declared. The applicant asserts that
if termites are detected during this time, the baits will be required to achieve colony
elimination.
4.10
The Committee notes that a consideration and decision on the applicant’s full
release application (HSR07104) is not due until 2008. The special emergency
approval (HSE000009) to use the substance is due to expire on 31 December 2007.
This means that there will be a time period during which the substance will not be
available for use.
4.11
The applicant considers the Sentricon bait system will have a high probability of
success in eradicating termites. The applicant advises that termites have been
successfully eradicated in an ‘extensive’ termite infestation at Otorohanga in
1999/2000, and a colony in Nelson (considered eliminated in March 2007 and
currently under post-elimination monitoring)
4.12
The applicant has considered alternatives for eradicating the target pest. They
describe such alternatives as unsuitable, listing the reasons and supporting evidence
in their application (Section 5.1, p.14).
4.13
The applicant notes that a delay in applying the Hexaflumuron (Sentricon Termite
Bait) could result in the termite colony spread, which would increase the cost of
eradication, and reduce the likelihood of success.
4.14
The Committee has reviewed the information provided by the applicant and is
satisfied that it is necessary to use Hexaflumuron (Sentricon Termite Bait) for the
special emergency.
Controlling the adverse effects of the substance
Hazardous properties
4.15
The applicant has examined the properties of the components of the substance, and
considers that the substance triggers thresholds for eye irritancy, target organ
systemic toxicity (due to reported effects of hexaflumuron on blood, kidney, liver
and spleen and potential for methaemoglobinemia following excessive exposure).
4.16
With regards to adverse effects in the environment, the applicant indicates that
hexaflumuron is very highly toxic to aquatic invertebrates on an acute basis and is
slightly toxic to birds on a dietary basis.
ERMA New Zealand Decision: Application HSE07002
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Lifecycle
4.17
In assessing the adverse effects of the substance, the Committee reviewed the
lifecycle of the substance as described in the applicant’s Management Plan, as
summarised below.
The plan for dealing with the use of the substance in the special emergency
4.18
The applicant advises that once imported, the substance will be stored within a
contained facility in Auckland. The product is then intended to be used as soon as
possible. The product has no specific transport requirements hence can safely be
transported to Auckland by air or road.
4.19
The applicant advises that the product will be used on the termite infested property.
Sentricon baits are available in two forms. One in the form of a tube for use in
Sentricon In-Ground (IG) Termite Bait stations and one in the form of a the bait
matrix contained in a polyethylene bag for use in Sentricon Above-Ground (AG)
Bait stations. While the presentation of the two baits differs, the composition is the
same (0.5% hexaflumuron and 99.5% cellulose).
4.20
The applicant advises that when installed in-ground, the bait station initially only
contains wooden monitoring devices (no pesticide). These stations are inspected
periodically and only when termites are detected within the station, are the
monitoring devices replaced with the bait tube. The AG bait station consists of a
secure plastic box containing hexaflumuron in a cellulose matrix and is installed in
those locations above ground where active termite feeding is detected.
4.21
The Committee notes the applicant’s requirement in the Management Plan that
application, inspection and monitoring of the bait stations will be carried out by
authorised Dow AgroSciences’ agents from Pestforce Pty Ltd, Australia.
4.22
The applicant has included procedures for on-site management for both private
property and public land.
4.23
The applicant advises that at the conclusion of the response operations shall be
stored in the Investigation and Diagnostic Centre (IDC) Laboratory, or alternatively
exported or otherwise adequately disposed.
Identification and evaluation of the adverse effects of the substance for use in the
special emergency
4.24
In the application and Management Plan, the applicant identified and assessed
potential adverse effects, and detailed proposals for, and impacts of risk
management. The Committee has reviewed the applicant’s assessment of adverse
effects and agrees that that it is suitable for the consideration.
Adverse effects to the environment
4.25
The Committee considers that adverse effects to the environment may arise from:
 spillage of Hexaflumuron (Sentricon Termite Bait) during importation;
 spillage of Hexaflumuron (Sentricon Termite Bait) in transit;
 leakage or spillage of Hexaflumuron (Sentricon Termite Bait) during storage;
ERMA New Zealand Decision: Application HSE07002
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


spillage of Hexaflumuron (Sentricon Termite Bait) at the field location;
exposure to non-target species during use;
breach of packaging or bait stations;
spillage of Hexaflumuron (Sentricon Termite Bait) during disposal.
4.26
The application and accompanying Management Plan contain measures that must
be taken to avoid, remedy or mitigate the adverse effects to the environment arising
from the manufacture and use of Hexaflumuron (Sentricon Termite Bait). In
particular, the applicant advises that the bait presentation and provision for
monitoring for active termite feeding will reduce exposure to non-target organisms.
Further, the location of the bait stations will be chosen so as to prevent the
substance entering any surface water or ground-water systems.
4.27
The Committee has reviewed these proposals and is satisfied that they are adequate
to control the adverse effects of the substance in the environment.
Adverse effects on human health and welfare
4.28
The applicant has identified that adverse effects to the human health and welfare
may arise from:
 spillage of Hexaflumuron (Sentricon Termite Bait) during importation;
 spillage of Hexaflumuron (Sentricon Termite Bait) in transit;
 leakage of Hexaflumuron (Sentricon Termite Bait) during storage;
 spillage of Hexaflumuron (Sentricon Termite Bait) at the field location;
 operator or bystander contact with the bait stations while in use.
4.29
The application and the accompanying Management Plan contain measures that
must be taken to avoid, remedy or mitigate the adverse effects arising from the
manufacture and use of Hexaflumuron (Sentricon Termite Bait). In particular, he
applicant advises that the operator handling the substance will be a highly
specialised person. The applicant has also considered the risks to bystanders. The
baits are described as child-proof and provisions are included for notifying the
residents on treated and neighbouring properties, advising them to restrict access to
the baits by children (and pets).
4.30
The Committee has reviewed these proposals and is satisfied that they are adequate
to control the adverse effects of the substance to human health.
Māori issues and concerns
4.31
The Committee has considered this application in accordance with clauses 9(b)(i)
and 9(c)(iv) and sections 6(d) and 8. In addition, the Agency used the framework
contained in the ERMA New Zealand user guide “Working with Māori under the
HSNO Act 1996” to assess this application.
4.32
The Committee notes that Hexaflumuron (Sentricon Termite Bait) triggers a
number of hazard classifications giving rise to the potential for cultural risk
including the deterioration of the mauri of taonga flora and fauna species, the
environment and the general health and well-being of individuals and the
community. In addition, the introduction and use of this substance has the potential
to inhibit the ability of iwi/Māori to fulfil their role as kaitiaki, particularly in
ERMA New Zealand Decision: Application HSE07002
Page 7 of 14
relation to the guardianship of waterways given the highly ecotoxic nature of the
substance to aquatic environments.
4.33
The Committee also notes that the applicant does not appear to have consulted with
local iwi groups in relation to this special emergency application. However, an
extensive consultation effort was undertaken with the local iwi groups (namely
Ngāti Whatua Ngā Rima ō Kaipara, Te Runanga o Ngāti Whatua and Ngati Whatua
o Orakei) regarding the eradication programme last year which included
information about Sentricon Termite Bait. The Committee considers it important
that these and other appropriate groups be advised of this further eradication
activity and kept up to date on the success or otherwise of the programmes success.
Further the Committee recommends that in the event that a termite incursion
extends beyond the area specified that the applicant consults with other relevant iwi
groups prior to application of the substance.
4.34
On considering the information outlined here and elsewhere in this report, The
Committee considers a minor impact from Sentricon Termite Bait on the
relationship of Māori and their culture and traditions with their ancestral lands,
water, sites, wāhi tapu, valued flora and fauna and other taonga to be highly
improbable. In addition there is no evidence to suggest that the controlled use of
Sentricon Termite Bait will breach the principles of the Treaty of Waitangi.
4.35
The overall level of risk is therefore considered to be negligible given that the
substance is handled, stored, transported, used, and disposed of, in accordance with
the explicitly stated default and additional controls proposed in this report, and any
other controls required by other legislation.
4.36
However, the Committee notes that should inappropriate use, or accident, result in
the contamination of waterways or the environment generally, that users notify the
appropriate authorities including the relevant iwi authorities in that region. This
action should include advising them of the contamination and the measures taken to
contain and remediate.
Economic and related effects of the use of the substance
4.37
The applicant advises that subterranean termites can cause substantial damage to
houses, wooden furniture, trees, sawn wood and other forestry produce, and states
that a large proportion of buildings in New Zealand are made of wood. The
applicant advises that the success of New Zealand with economy based on primary
industries (e.g. forestry) can be negatively influenced with a new exotic unwanted
organism. Subterranean termites are an example of a pest with high potential to
impact negatively on our economy and society. The applicant states that the
eradication of known exotic termite colonies with the most efficient tool,
hexaflumuron (Sentricon Termite Bait) in this case, is of a national significance.
4.38
The Committee has not identified any potential economic costs that may arise due
use of the substance for the special emergency. However, the Committee considers
that the potential economic risks of exotic subterranean termites are significant, and
that eradicating the pest with Hexaflumuron (Sentricon Termite Bait), is likely to be
beneficial in this respect.
ERMA New Zealand Decision: Application HSE07002
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Effects related to New Zealand’s international obligations
4.39
The Committee notes that no effects related to New Zealand’s international
obligations have been identified.
5 Controls
5.1
The Committee has evaluated the adequacy of the arrangements proposed by the
applicant in the management plan and consider that these are adequate to control
the adverse effects of Hexaflumuron (Sentricon Termite Bait).
6 Recommendations
6.1
In light of the possibility of the applicant considering wider application of the bait
across the greater Auckland area, the Committee considers it appropriate that in the
potential emergency of an incursion occurring in other areas of the Auckland region
outside the rohe of Te Rūnanga ō Ngāti Whatua, Ngāti Whatua ō Orakei and/or
Ngāti Whatua Ngā Rima ō Kaipara, that the appropriate kaitiaki of those areas be
contacted also informing them of the proposed emergency state and incursion
response strategy.
6.2
Further, the Committee considers it appropriate that the local rūnanga be advised of
any accidental unanticipated use, impact, or contamination of waterways resulting
from the eradication programme. This action should include advising them of the
contamination and the measures taken to contain and remediate.
7 DECISION
7.1
The Committee has considered this application made under section 49D, and
pursuant to section 49F, the Committee is satisfied that the substance is necessary
for use in the special emergency.
7.2
Having considered the risks associated with the lifecycle of Hexaflumuron
(Sentricon Termite Bait), the Committee is satisfied that the Management Plan and
the controls imposed, including those in place under other legislation, will result in
the substance being adequately managed in accordance with the Act.
7.3
The Committee has also applied the following criteria in the Methodology:
 clause 9 – equivalent of sections 5, 6 and 8;
 clause 11 – characteristics of substance;
 clause 21 – the decision accords with the requirements of the Act and
regulations;
 clause 22 – the evaluation of risks – relevant considerations;
 clause 24 – the use of recognised risk identification, assessment, evaluation and
management techniques.
7.4
The application import for release and use Hexaflumuron (Sentricon Termite Bait)
in a special emergency is thus approved pursuant to section 49F, with the following
controls:
ERMA New Zealand Decision: Application HSE07002
Page 9 of 14
7.4.1
The substance may only be used if the special emergency is managed in
accordance with the plan specified by the applicant as set out in Appendix
1.
7.4.2
The approval takes effect on the date of this decision and expires on the
earlier of:
 two years after the date on which this approval is granted; or
 the date an approval is granted for the substance under section 28 of
the Act.
7.4.3
On expiry of this approval the Hexaflumuron (Sentricon Termite Bait)
must be disposed of or stored in an Exempt Laboratory under the
Hazardous Substances (Exempt Laboratories) Regulations 2001, unless,
before the expiry of the approval, the applicant has, under any other
provision of the Act, been granted an approval.
signed
George Clark
Date
19 December 2007
Chair
Approval Code:
Hexaflumuron (Sentricon Termite
Bait):
ERMA New Zealand Decision: Application HSE07002
HSE000010
Page 10 of 14
APPENDIX 1: MANAGEMENT PLAN
PLAN FOR DEALING WITH THE AGRICULTURAL COMPOUND OR MEDICINE IN
THE SPECIAL EMERGENCY
(A) The Measures That Be Taken To Avoid, Remedy, Or Mitigate Any Actual Or Potential
Adverse Effects From The Use Of The Agricultural Compound Or Medicine
There are only a few very low risks associated with the use of hexaflumuron as described in this
application. In order to comply with the matters listed in Section 49G of the HSNO Act, MAF
will have a number of Management actions in place.

The product will be used on a termite infested property in Auckland and any newly detected
site in the Auckland Region. It will be installed in-ground around the perimeter, as advised
by the specialists on the property. When installed in-ground, it initially only contains
wooden monitoring devices (no pesticide). These stations are inspected periodically and only
when termites are detected within the station that the monitoring devices are replaced with
the bait tube (containing hexaflumuron embedded in cellulose matrix). This minimises
identified risks to flora and fauna or any other environmental exposure.

The baits shall only be applied by way of the inclusion in Sentricon IG Bait stations or
Sentricon AG Bait stations, as appropriate.

The above-ground bait station consists of a secure plastic box containing hexaflumuron in
cellulose matrix and is installed only in those locations above ground where active termite
feeding is detected. This would restrict the exposure to non-target organisms and to humans.
In addition, the bait station is secured with a silicon sealant to maintain humidity levels and
minimise disturbance.

The location of bait stations at the response sites shall be chosen so as to prevent the
substance entering any surface water or groundwater system.

The Sentricon manual is provided which outlines the detailed management procedures that
will be adhered to at the actual sites. The main details are summarised as follows:
Summary of on-site management procedures:

After conducting a survey at each site, the in-ground stations will be installed around the
perimeter of the infested property building(s) at intervals of 3 - 5 metres. When installed,
these stations will not contain the bait matrix (hexaflumuron). The stations will only contain
two pieces of wooden monitoring devices. The stations will be monitored at intervals of 2-4
weeks.

If any station has termite activity, the wooden monitoring devices will be replaced with the
bait matrix (please refer to the attached manual for detailed procedures of installing this bait
matrix – Page 4-7 of the attached manual).

All baiting stations will be numbered, listed and a site map with actual locations at the
infestation site will be produced. This will facilitate that all baiting stations are accounted
ERMA New Zealand Decision: Application HSE07002
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for, will be maintained during the course of the response programme and will be removed on
completion.

During routine monitoring, if termites are detected above ground, the Above Ground stations
will be safely installed (please refer to pages 9-12 of the attached manual).

The In Ground bait stations are secured with a child proof and the Above Ground bait boxes
have a secure cover to prevent non-target exposure. Once the termite feeding has ceased the
bait tubes will be replaced with the monitoring devices and the bait boxes will be removed.
On-site management procedures relevant for a private property

The infested site(s) is (will) be declared Restricted Places under Section 130 of the
Biosecurity Act, thereby restricting movement of the chemical and all other associated
materials from the site. Any movement of chemicals from the site will need to be directed by
a MAF approved Inspector or Authorised person.

Residents of properties neighbouring the treatment site shall be advised in writing of the
response and the need to restrict access to the baits by pets and children.

Residents of the properties to be treated shall be advised in writing of the response and the
need to restrict access to the baits by pets and children.

Access to the treatment site(s) shall be by permission of the BNZ Investigations and
Diagnostics Centres (IDC) operations controller or owner of the property on which it is
located.

Ideally, the treatment site boundaries shall be clearly marked and distinctly visible from
outside the site throughout the life of the treatment. The site(s) shall be signed indicating
that unauthorized access is not allowed, that the site is subject to an eradication treatment,
and that the bait stations should not be removed or disturbed. However, the concern is that
signage will lead media et al to the property to the detriment of the homeowners, neighbours
and the treatment. A potential solution is to use smaller discrete signs that could be placed so
that they are not visible from the road. BNZ would discuss this matter with the homeowner
to ensure the conditions meet both the homeowners and the regulatory requirements.
On-site management procedures relevant for a public land

The infested site(s) is (will) be declared Restricted Places under Section 130 of the
Biosecurity Act, thereby restricting movement of the chemical and all other associated
materials from the site. Any movement of chemicals from the site will need to be directed by
a MAF approved Inspector or Authorised person.

Residents of properties neighbouring the treatment site shall be advised in writing of the
treatment and the need to restrict access to the baits by pets and children.

The treatment site boundaries shall be clearly marked and distinctly visible from outside the
site throughout the life of the treatment. The site(s) shall be signed indicating that
unauthorized access is not allowed, that the site is subject to an eradication treatment, and
that the bait stations should not be removed or disturbed.
ERMA New Zealand Decision: Application HSE07002
Page 12 of 14

Bait stations will be placed in positions where disturbance is minimised or preferably
excluded. Any unauthorised interference with the bait station may result in reduced bait
uptake, bait station abandonment or the retreat of termite activity from the area altogether,
severely impacting on the program effectiveness.
(B) The Requirements For The Disposal Of The Agricultural Compound Or Medicine:

Lifecycle of the chemical in New Zealand:
o
The product has no specific transport requirements hence can be safely transported to
Auckland by air/ road.
o
Containment plan for our facility in Auckland (Plants and Environment Laboratory –
Investigation and Diagnostic Centre, 231 Morrin Road, St. Johns, Auckland) is in
Appendix II. Once imported the product will be stored in the above mentioned location
for a short duration.
o
The active ingredient (hexaflumuron) is embedded in a paper based bait matrix. Thus
spillage of the active ingredient is not expected to be an issue. Should any spillage of the
baits occur it shall be contained, prevented from entering waterways, and recovered.
These recovered baits shall be used in the response or disposed of through local landfills,
subject to the facility’s waste acceptance policy.
o
Used bait tubes and bait boxes will be double bagged and disposed of by deep burial at a
local authority landfill (as specified in the MSDS).
o
Surplus substance remaining at the end of the response operations shall be stored in IDC
laboratory, or alternatively exported or adequately disposed.
o
A record shall be kept of all use of the substance.
o
Information on appropriate safety precautions necessary to provide safeguards against
the substance’s toxic and ecotoxic properties shall accompany the substance at all stages
of its lifecycle.
o
Personal protective equipment shall be worn when handling Sentricon Baits or
components of the bait stations. The application, inspection and monitoring of the bait
stations will be carried out by authorised Dow AgroScience agents from Pestforce Pty
Ltd, Australia. The operator has been used in recent termite responses and is expected to
be acquainted with current New Zealand regulations regarding pesticide use,
Occupational Health and Safety, etc.
Address:
Pestforce Pty Ltd
20 Kenthurst Rd
Round Corner NSW 2158
Postal Address- PO Box 116 Round Corner NSW 2158
ABN (Australian Business Number) 91 002 777 264
ERMA New Zealand Decision: Application HSE07002
Page 13 of 14
(C) The Requirements For The Eradication Or Control Of Any New Organism.
The bait system (e.g. Sentricon bait stations baited with hexaflumuron) was highlighted as the
only possible mechanism available to respond and potentially eradicate the subterranean
infestation in the recent past in New Zealand (e.g. Otorohanga response). The same applies for
the newly identified South Rodney site. Scientific evidence indicates that a response action
based on the bait system is the main response tool with high probability of success. This tool has
previously been used for eradication of an extensive termite infestation at Otorohanga site in
1999/2000 (declared successful in 2005) and is currently been used in the Nelson area
As of mid-January 2007 Biosecurity New Zealand is aware of only one infested property in
South Rodney. The possibility that during the course of investigation more infested
properties/locations are located cannot be excluded. Should there be newly detected infested
properties/locations in the Greater Auckland Region, the Sentricon baiting stations will
have to be used on those locations under the umbrella of this response.
The precise number of Sentricon IG and AG baiting stations and quantities of the bait that might
be required are unknown at this stage. It is important that Biosecurity New Zealand has a
permission to import and use as many stations and baits as it finds appropriate for
eradication of subterranean termites from the Auckland Region.
ERMA New Zealand Decision: Application HSE07002
Page 14 of 14