ENVIRONMENTAL RISK MANAGEMENT AUTHORITY
DECISION
Application Number
NOC98009
Consideration Date
22 March 1998
Considered by
Special Committee of the
Authority
Date 14 April 1999
Application Details
Applicant
Category
Purpose
Date Application Received
Landcare Research New Zealand Ltd.
New Organism Importation into Containment under section
40(1)(a) of the Hazardous Substances and New Organisms Act
1996 (the Act).
To import into containment eight species of Indonesian alpine
mosses to conduct ecological studies, specifically plant responses
to physical parameters, to determine the best method and species
for use in revegetation trials at a mine site in Irian Jaya.
19 February 1999
Decision
The application was Approved with Controls.
The organisms approved are:
1.
2.
3.
4.
5.
6.
7.
8.
Anomobryum julaceum
Barbula wisselii
Breutelia arundinifolia
Bryum c.f. rugicollum
Bryum sclerodictyon
Philonotis secunda
Racomitrium subsecundum
Splachnobryum c.f. novae-guineae
Application Process
The application was formally received on 19 February 1999. The application was verified on 26
February 1999.
The application was not required under the Act to be publicly notified.
The documents available for the evaluation and review of the application by ERMA New
Zealand included the application, (including references and further information) comment from
government agencies (Ministry of Agriculture and Forestry, and Department of Conservation),
and external scientific review of the application undertaken by Dr Ray Tangney, University of
Otago.
In accordance with section 19(2)(b) of the Hazardous Substances and New Organisms Act 1996,
the Authority appointed a Special Committee to determine the application. The Committee
comprised: Dr Lindie Nelson (Chair), Mr Bill Falconer and Dr Patrick Brownsey (External
Expert in Bryology).
Relevant Legislative Criteria
The application was lodged pursuant to section 40 of the Hazardous Substances and New
Organisms Act 1996, and determined in accordance with section 45 and the additional matters
contained in sections 37 and 44. The relevant items in Part II of the Act of particular significance
were: Safeguarding the life supporting capacity of air, water, soil, and ecosystems, section 5(a); The
sustainability of all native and valued introduced flora and fauna, section 6(a); The intrinsic value of ecosystems,
section 6(b).
Consideration of the application followed the relevant provisions of the Hazardous Substances
and New Organisms (Methodology) Order 1998, (“the Methodology”), but with particular regard
to clauses 8 (dealing with the scale and significance of the risks, costs and benefits) and 26 (dealing
with applications where the risks are negligible).
Reasons for the Decision
Purpose
In accordance with section 45(1)(a)(i) of the Act, the Committee was satisfied that the application
was for one of the purposes specified in section 39(1) of the Act. The Committee concluded that
importation into containment of the alpine mosses to conduct ecological studies is an
appropriate purpose under section 39(1)(h) of the Act being such other purposes as the Authority sees fit.
Ability to Escape Containment
In accordance with section 44(b) the Committee considered the ability of the mosses to escape
from containment. The applicants proposed to contain the mosses in accordance with MAF
Regulatory Authority Standard 155.04.0 - Specification for the Registration of a Plant Quarantine
or Containment Facility, and Operator. The Committee considered that it was the Ministry of
Agriculture and Forestry’s role to apply any quarantine containment to the importation, but that
the mosses should be subject to the MAF Regulatory Authority Standard 154.03.02 Containment Facilities for Microorganisms. This standard requires the Authority to determine
the physical containment level as defined in Australia/New Zealand Standard, Safety in
Laboratories Part 3: Microbiology AS/NZS 2243.3:1995. The Committee determined that
Physical Containment Level 2 (PC2) was appropriate for the containment of the mosses.
Due to the variety of methods that mosses can use to establish new plants, and the small size of
their propagative structures, the Committee also considered it was essential that all waste water
be collected and treated, and that the immediate vicinity outside the National Climate Laboratory
be regularly monitored.
Taking into account the containment regime the Committee was satisfied that the mosses could
be adequately contained.
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Self sustaining populations, eradication and adverse effects
In reaching its decision the Committee considered the ability of the mosses to establish
undesirable self-sustaining populations and the ease with which any such populations could be
eradicated [section 37(a) and (b)]. The Committee considered that, should any of the mosses
escape, there is a reasonable chance they could form self sustaining populations. If a self
sustaining population should develop, eradication is unlikely.
However, mosses generally establish in disturbed habitats and are unlikely to spread into
undisturbed native vegetation or displace native flora. In addition, the Committee accepted the
expert advice, as detailed in the ERMA New Zealand Evaluation and Review Report, that
hybridisation is very unlikely and has not been demonstrated to occur in New Zealand mosses.
Therefore the Committee considered that the probability of an adverse impact on the
environment was very low, should any mosses escape.
Inseparable Organisms
In accordance with section 45(a)(ii) the Committee considered the effects of any inseparable
organisms. The mosses will be imported free from soil and inspected to establish that they are
free from insects. However, as the applicant explained, mosses act as a trap for sediments and it
is possible soil microorganisms could be present in the samples. The Committee considered that
the containment regime, the use of only clean vegetative fragments to establish the experimental
plants, and the treatment of all waste water would ensure that any associated organisms would be
contained. As a further safety measure the controls require the Ministry of Agriculture and
Forestry and Environmental Risk Management Authority to be notified of any signs of pests or
disease.
Negligible Risk
Based on the consideration and analysis of adverse effects to the environment and public health,
taking into account the containment proposals, the Committee considered that the risks
associated with the importation into containment are negligible.
Benefits
The Committee considered the benefits of the importation into containment as identified by the
applicant and agreed that Landcare Research Ltd and the National Climate Laboratory would
benefit commercially from the importation.
Scientific benefits to New Zealand are unlikely to be substantial due to the well-established
experimental methodology and the uncertainty associated with the applicability of the test results
to restoration of degraded sites in New Zealand.
It was also considered that there are intangible benefits to New Zealand associated with the
involvement and support for international environmental remediation programmes.
Conclusion
The Committee concluded that, taking account of the ability of the mosses to escape from
containment as in section 44(b), the beneficial effects of having the mosses in containment
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outweighed the likely adverse effects of the mosses and any inseparable organisms, should they
escape.
Having considered the possible effects of the mosses in accordance with sections 45(1)(a)(ii) and
(iii) of the Act, the Committee was satisfied that the proposed containment regime and additional
controls could adequately contain the mosses.
Controls
In order to satisfactorily address the matters detailed in Part II of the Third Schedule to the HSNO
Act - Containment Controls for New Organisms other than Genetically Modified Organisms this application
is approved subject to the following controls:
For the purpose of the controls the “containment facility” shall be Controlled Climate Room 2,
or equivalent, at the National Climate Laboratory, HortResearch, Palmerston North.
1.
To limit the likelihood of any accidental release of any organism or any viable
genetic material1
1.1
To collect moss fragments, plant trolley drain outlets shall be screened with gauze
mesh of a maximum gauge size of 2 mm.
1.2
Prior to disposal, all waste water from the containment facility shall be collected and
treated with Biosan™ or similar product, to kill any moss fragments, reproductive
structures and soil microorganisms.
1.3
All solid waste material, including plant material and growing medium, shall be
autoclaved and incinerated.
1.4
The applicant shall notify the Ministry of Agriculture and Forestry (Chief Plants
Officer, MAF Regulatory Authority) and the Environmental Risk Management
Authority of any evidence of pest or disease associated with the mosses.
1.5
The operation and management of the containment facility shall comply with:
1.5.1
MAF Regulatory Authority Standard 154.03.02 - Containment Facilities for
Microorganisms; and
1.5.2
Physical Containment Level 2 (PC2) of Australia/New Zealand Standard Safety
in Laboratories Part 3: Microbiology AS/NZS 2243.3:1995.
1.6
While the experiment is in progress, the containment facility shall not be used to house
plants other than the mosses involved in the proposed experiment.
1.7
The mosses shall be transported to the containment facility in sealed leak proof
containers, packed into a second container of strong non-crushable material.
Bold headings refer to Matters to be Addressed by Containment Controls for New Organisms excluding Genetically Modified
Organisms, specified in the Third Schedule of the HSNO Act 1996.
1
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1.8
The imported vegetative material shall be imported without soil and shall be free from
any invertebrate infestation.
1.9
Only the vegetative fragments of the upper most portions of the imported mosses shall
be used to propagate mosses for this experiment. The remaining original samples shall
be destroyed by autoclaving followed by incineration. The transport containers shall be
sterilised.
1.10 The plants shall be inspected twice weekly for signs of sporophyte development. Any
sporophytes observed shall be removed immediately, autoclaved, and incinerated.
1.11 At the completion of the experiment all plants, plant fragments and growing medium
shall be autoclaved and incinerated. All growing containers used shall be sterilised.
2. To exclude unauthorised people from the facility:
2.1
The containment facility shall be kept locked and only persons authorised by the
applicant shall have access to the containment facility.
2.2
The applicant shall comply with the requirements contained in the standards listed in
control 1.5 relating to exclusion of unauthorised people from the facility.
3.
To control the effects of any accidental release or escape of an organism:
3.1
The mosses shall be held in containment at the National Climate Laboratory,
HortResearch Palmerston North.
3.2
The applicant shall monitor the immediate vicinity outside the National Climate
Laboratory, Palmerston North, and destroy any detected escaped moss.
3.3
Prior to importation the applicant shall submit to ERMA New Zealand a plan identifying
procedure, locations and frequency for monitoring the immediate vicinity of the National
Climate Laboratory.
3.4
The applicant shall inform ERMA New Zealand and MAF immediately, on detection of
any escaped moss.
3.5
The applicant shall comply with the requirements contained in the standards listed in
control 1.5 relating to controlling the effects of any accidental release or escape of an
organism.
4. Inspection and monitoring requirements for containment facilities:
4.1
Prior to the importation the applicant shall submit to ERMA New Zealand evidence of
inspection and approval of the containment facility by MAF Regulatory Authority.
4.2
The Authority or its authorised agent or properly authorised enforcement officers, may
inspect the facility at any reasonable time.
4.3
The applicant shall maintain, and provide for inspection on request, a logbook recording
the actions taken to manage the experiment and the containment facility in relation to the
controls imposed.
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4.4
The applicant shall report to ERMA New Zealand and MAF Regulatory Authority any
accidents or incidents, involving the mosses or the containment facility, immediately after
the event first comes to the applicant’s notice.
4.5
The applicant shall provide interim reports to ERMA New Zealand every 3 months
during the research period and shall submit a final report within one month of the
completion of the research. Reports shall describe the experimental activities and the
compliance with controls.
4.6
The applicant shall comply with the requirements contained in the standards listed in
control 1.5 relating to inspection and monitoring requirements for containment facilities.
5. Qualifications required of the persons responsible for implementing those controls:
5.1
The person in charge of the experiment and for the operation of the containment facility
shall ensure that all personnel involved in the experiment are made familiar with the
requirements to maintain the mosses in containment and to prevent their unintended or
accidental release.
5.2
The applicant shall comply with the requirements contained in the standards listed in
control 1.5 relating to qualifications required of the persons responsible for
implementing those controls.
Signed on behalf of the Authority
_____________________
Chair
__________________
Date
_____________________
Name
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