ENVIRONMENTAL RISK MANAGEMENT
AUTHORITY DECISION
21 March 2007
Application code:
HSR06104
Application Type
To import or manufacture any hazardous substance under
Section 28A(2)(b) of the Hazardous Substances and New
Organisms Act 1996 (the Act) [rapid assessment (low hazard)]
Applicant:
Primaxa Ltd
Purpose of the Application
Checkmate CM-F capsule suspension formulation: approval
to import or manufacture as an insect mating disruption
pheromone. (low hazard)
Date application received:
18 January 2007
Consideration Date
21 March 2007
Considered by
Rob Forlong (Chief Executive, ERMA New Zealand)
1 Summary of decision
1.1
The application to import or manufacture Checkmate CM-F for release is approved with
the controls as set out in Appendix 1. This approval has been given in accordance with
the relevant provisions of the Act, the relevant HSNO Regulations, and the HSNO
(Methodology) Order 1998 (the Methodology), based on Checkmate CM-F being
formulated so that the substance has one or more hazardous properties and each
hazardous property has the least degree of hazard for that property.
1.2
The substance has been given the following unique identifier for the ERMA
New Zealand Hazardous Substances Register:
Checkmate CM-F
2 Legislative criteria for the application
2.1
The application was lodged pursuant to section 28. The decision was determined in
accordance with section 28A(2)(b), taking into account the requirements of that section
and matters specified under Part II of the Act. Unless otherwise stated, references to
section numbers in this decision refer to sections of the Act.
2.2
Consideration of the application followed the relevant provisions of the Methodology.
Unless otherwise stated, references to clauses in this decision refer to clauses of the
Methodology.
3 Application process
3.1
The purpose of this application is to gain approval to import or manufacture Checkmate
CM-F as an insect mating disruption pheromone.
3.2
The application was formally received on 18 January 2007.
3.2.1
3.3
The Agricultural Compounds & Veterinary Medicines Group (ACVMG) of the
New Zealand Food Safety Authority (NZFSA) and the Department of Labour Workplace
Group were advised of the application (clause 2(2)(e)).
3.3.1
3.4
3.5
The application timeframe was extended by 29 working days as the result of a
request for further information under section 58.
No responses were received.
Evaluation of the application was undertaken by the ERMA New Zealand project team
which comprised the following staff members:
Margaret Keane
Advisor (Hazardous Substances)
Tania van Maanen
Advisor (Hazardous Substances)
Zack Bishara
Advisor (Maori Unit)
Beth Dye
Applications Manager (Hazardous Substances)
The application was considered by the Chief Executive of ERMA New Zealand as
provided for by a delegation from the Authority under section 19(2)(d).
4 Consideration
Sequence of the consideration
4.1
Primaxa Ltd seeks approval, under section 28, to import or manufacture Checkmate
CM-F for release in New Zealand.
4.2
An application can be assessed by rapid assessment procedures, under section 28A(2)(b),
if it can be shown that Checkmate CM-F has been formulated so that the substance has
one or more hazardous properties and each hazardous property has the least degree of
hazard for that property.
4.3
The approach adopted when considering this application was:
 to identify the composition and hazardous properties of the proposed substance,
Checkmate CM-F;
 to determine whether Checkmate CM-F has been formulated so that it has one or
more hazardous properties and each hazardous property has the least degree of hazard
for that property.
4.4
And then:
 to consider whether there are any other effects that mean Checkmate CM-F should
not be rapidly assessed; and
 to consider whether the controls that apply under the Act will prevent or manage the
adverse effects of the substance.
Environmental Risk Management Authority Decision: Application HSR06104
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Information review
4.5
The project team has reviewed the information supplied by Primaxa Ltd, and considers
that the information constitutes an adequate and appropriate basis for assessing the
application (clause 8). They also consider that there are no significant uncertainties (ie
sufficient to influence decision making) in the scientific and technical information relating
to the risks of Checkmate CM-F (clauses 29 and 30).
Composition of Checkmate CM-F
4.6
Checkmate CM-F is a capsule suspension formulation containing the active component
8,10-dodecadien-1-ol, a synthetic copy of the natural sex pheromone, codlemone,
produced by the Codling moth Cydia pomonella. Codlemone is found naturally in the
environment, in places such as pip fruit orchards (apples and pears), where it is released
by the female codling moth to attract the male moth for mating purposes.
Hazardous properties of Checkmate CM-F
4.7
The project team has determined the hazard profile of Checkmate CM-F based on the
information provided by the applicant and other available information. The hazard
classifications for Checkmate CM-F are set out in Table 4.1.
Table 4.1: Hazard classifications
Hazard Endpoint
Checkmate CM-F
Skin Irritation/Corrosion
Aquatic Ecotoxicity
4.8
6.3B
9.1D
Checkmate CM-F is classified as 6.3B (mild skin irritant) and 9.1D (slightly harmful to the
aquatic environment).
Meeting the criteria for rapid assessment under section 28A(2)(b)
4.9
Based on the above information, the project team considers that the criteria for rapid
assessment under section 28A(2)(b) have been met through Checkmate CM-F being
formulated so that it has two hazardous properties and each hazardous property has the
least degree of hazard for that property.
4.10 The project team considers that there are no other matters which would prevent this
application for Checkmate CM-F from being rapidly assessed.
Use of Checkmate CM-F
4.11 Checkmate CM-F is intended to be applied to apple and pear trees to disrupt mating of
the codling moth by confusing the males and preventing them from detecting the
pheromone of mating females. The product will only affect adult male moths and will
have no effect on female moths, eggs or larvae.
4.12 The applicant notes that the synthetic sex pheromone codlemone is currently used in
New Zealand orchards but it is contained in plastic dispensers which are hung in the
apple or pear orchards, releasing the codlemone slowly into the air over a period of
months.
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4.13 Checkmate CM-F is formulated as a capsule suspension in water and is diluted with water
prior to spraying. The precise methods and rates of application are detailed in
Confidential Appendix 4.
4.14 Checkmate CM-F is added to water in a spraying rig and applied to the target crop as and
when required.
5 Controls
Default controls
5.1
Based on the hazard classifications determined for the proposed substance, a set of
associated default controls has been identified by the project team as being applicable to
Checkmate CM-F. These default controls, expressed as control codes1, are listed in Table
5.1.
5.2
Additional controls under section 77A are available to manage the risks associated with
Checkmate CM-F, which are not addressed by the default controls. These are considered
in Paragraph 5.4 below.
Table 5.1: List of default controls for Checkmate CM-F
Toxicity Controls
T1
Limiting exposure to toxic substances through the setting of TELs
T2
Controlling exposure in places of work through the setting of WESs.
T4
Requirements for equipment used to handle substances
T7
Restrictions on the carriage of toxic or corrosive substances on passenger service
vehicles
Ecotoxicity Controls
E1
Limiting exposure to ecotoxic substances through the setting of EELs
E2
Restrictions on use of substances in application areas
E6
Requirements for equipment used to handle substances
Identification Controls
I1
Identification requirements, duties of persons in charge, accessibility,
comprehensibility, clarity and durability
I9
Secondary identifiers for all hazardous substances
I11
Secondary identifiers for ecotoxic substances
I16
Secondary identifiers for toxic substances
I19
Additional information requirements, including situations where substances are in
multiple packaging
I21
General documentation requirements
I28
Specific documentation requirements for toxic substances
I29
Signage requirements
Packaging Controls
P1
General packaging requirements
P3
Criteria that allow substances to be packaged to a standard not meeting Packing
Group I, II or III criteria
P13
Packaging requirements for toxic substances
PS4
Packaging requirements as specified in Schedule 4 (packaging regulations)
Disposal Controls
Control codes are those assigned by ERMA NZ to enable easy cross reference with the regulations. A detailed list of
these codes is contained in the ERMA New Zealand User Guide to the Controls Regulations.
1
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D4
D5
D6
D7
Disposal requirements for toxic and corrosive substances
Disposal requirements for ecotoxic substances
Disposal requirements for packages
Information requirements for manufacturers, importers and suppliers, and persons
in charge
D8
Documentation requirements for manufacturers, importers and suppliers, and
persons in charge
Emergency Management Controls
EM1
Level 1 information requirements for suppliers and persons in charge
EM6
Information requirements for toxic substances
EM7
Information requirements for ecotoxic substances
EM8
Level 2 information requirements for suppliers and persons in charge
EM11 Level 3 emergency management requirements: duties of person in charge,
emergency response plans
EM12 Level 3 emergency management requirements: secondary containment
EM13 Level 3 emergency management requirements: signage
Tank Wagon and Transportable Containers Controls
The Hazardous Substance (Tank Wagons and Transportable Containers) Regulations 2004
prescribe a number of controls relating to tank wagons and transportable containers.
Additional controls under section 77A
5.3
Under section 77A, the Authority may impose as controls any obligations and restrictions
that the Authority thinks fit. Before imposing a control under this section, the Authority
must be satisfied that, against any other specified controls applying to Checkmate CM-F:
(a) the proposed control is more effective in terms of its effect on the management, use
and risks of hazardous substances; or
(b) the proposed control is more cost-effective in terms of its effect on the management,
use and risks of hazardous substances; or
(c) the proposed control is more likely to achieve its purpose.
5.4
The following control additions have been proposed for Checkmate CM-F by the Project
Team:
5.4.1
The project team notes that, unless specifically allowed for, pesticides should not
be applied into or onto water. As the default controls do not prohibit such use,
the project team considers that the following control should be applied to
Checkmate CM-F as being more effective in terms of its effect on the use of the
substance than the default controls:
Checkmate CM-F shall not be applied directly onto or into water.
5.4.2
The project team notes that the default controls do not address risks associated
with stationary container systems nor do they allow for dispensation where it is
unnecessary for any associated pipework to have secondary containment.
Accordingly, the project team considers that the application of controls
addressing these risks will be more effective than the default controls in terms of
their effect on the management, use and risks of the substance. Such controls
were applied to pesticides on transfer to the HSNO regime. The project team
considers that these controls are similarly appropriate for the management of the
risks associated with Checkmate CM-F and proposes that the following controls
should be applied to the substance:
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The controls relating to stationary container systems, as set out in Schedule 8 of the Hazardous
Substances (Dangerous Goods and Scheduled Toxic Substances) Transfer Notice 2004
(Supplement to the New Zealand Gazette, 26 March 2004, No. 35, page 767), as amended,
shall apply to this substance, notwithstanding clause 1(1) of Schedule 8.
5.4.3
The project team considers that the following subclauses should be added after
subclause (3) of regulation 36 of the Hazardous Substances (Emergency
Management) Regulations 2001:
(4) For the purposes of this regulation, and regulations 37 to 40, where this substance is
contained in pipework that is installed and operated so as to manage any loss of
containment in the pipework it—
(a) is not to be taken into account in determining whether a place is required to have a
secondary containment system; and
(b) is not required to be located in a secondary containment system.
(5) In this clause, pipework—
(a) means piping that—
(i) is connected to a stationary container; and
(ii) is used to transfer a hazardous substance into or out of the stationary
container; and
(b) includes a process pipeline or a transfer line.
Variation of controls under section 77
5.5
Under section 77, the default controls triggered for the substance may be varied.
Under section 77(3), controls may be substituted or added, under section 77(4),
controls may be substituted or deleted; and under section 77(5), where a substance
triggers more than one hazard classification, controls may be combined.
5.6
The following variations have been proposed for Checkmate CM-F by the project
team:
5.6.1
Control T1 relates to limiting exposure to toxic substances through the
setting of Tolerable Exposure Limits (TELs). Following the passing of the
Hazardous Substances and New Organisms (Approvals and Enforcement)
Act 2005, the Agency is intending to review the setting of ADEs, PDEs and
TELs under section 77B. Until this review is complete, the project team
proposes that ADEs, PDEs or TELs are not set for any components of
Checkmate CM-F.
5.6.2
Control T2 relates to the requirement to set Workplace Exposure Standards
(WESs). The project team notes that no Department of Labour values have
been set for any of the components of Checkmate CM-F. It is further noted
that the conditions of Regulation 29(1)(c) are not met as there is insufficient
industrial hygiene data available to enable a WES to be set for any constituent
components. It is therefore considered that this control should not be
applied to the substance.
5.6.3
Control E1 relates to limiting exposure to toxic substances through the
setting of Environmental Exposure Limits (EELs). Following the
implementation of the Hazardous Substances and New Organisms
(Approvals and Enforcement) Act 2005, the Agency is intending to review
Environmental Risk Management Authority Decision: Application HSR06104
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the setting of EELs under section 77B. Until this review is complete, the
project team proposes that EELs are not set for any components of
Checkmate CM-F at this time. It is also proposed that the default EELwater
value be deleted.
5.7
5.6.4
Control E2 relates to restrictions on use within an application area when an
EEL has been set. As no EELs have been set, no application rates are
proposed by the project team at this time.
5.6.5
The project team considers that controls T4 and E6 may be combined
under section 77(5) as they both relate to requirements for equipment used to
handle Checkmate CM-F.
5.6.6
The project team considers that controls P3 and P13 may be combined
under section 77(5) as they both relate to packaging requirements for
Checkmate CM-F.
5.6.7
The project team considers that controls D4 and D5 may be combined
under section 77(5) as they both relate to disposal requirements for
Checkmate CM-F.
The modifications to controls, as above, have been incorporated into the list of
controls for Checkmate CM-F detailed in Appendix 1.
6 Assessment of the adverse effects
6.1
The project team has evaluated the potential of Checkmate CM-F to cause adverse effects
to human health and the environment (non-target organisms) during all stages of the
substance’s lifecycle. A qualitative risk assessment was carried out to assess the risks to
human health (refer Appendix 2 for qualitative descriptors of risk) and both a qualitative
and quantitative assessment was carried out to assess risks to the environment.
Assessment of risks to human health
6.2
The project team considers the risks to human health arising from the mild skin irritancy
hazard (6.3B) presented by Checkmate CM-F to be insignificant. This assessment is
based on the following considerations:
6.2.1
The project team considers it is highly improbable, given adherence to HSNO
controls (e.g. packaging, identification, emergency management and disposal),
transport regulations and the Resource Management Act 1991 (the RMA), that a
spillage of Checkmate CM-F will occur and result in adverse effects on people
when the substance is being transported, stored or disposed of.
6.2.2
The project team considers it is improbable, given adherence to HSNO controls
(e.g. packaging, identification and emergency management) and the Health and
Safety in Employment Act 1992 (the HSE Act) requirements, that workers will
be adversely affected by Checkmate CM-F during its manufacture.
6.2.3
The project team considers it is improbable, given adherence to HSNO controls
(e.g. equipment, packaging, identification and emergency management),
adherence to the Code of Practice for the Management of Agrichemicals NZS:
8409:2004, and the requirements of the RMA and the HSE Act, that users of
Checkmate CM-F will be adversely affected by the substance when applying it.
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6.2.4
The project team considers it is improbable, taking into consideration adherence
to the Code of Practice for the Management of Agrichemicals NZS: 8409:2004,
and the requirements of the RMA, that bystanders will be adversely affected
through spray drift.
6.2.5
The project team considers that if exposure were to occur, the magnitude of any
adverse effect will be minimal as the effect would be limited to the exposed
individuals and be of a relatively short term and mild in nature.
Assessment of risks to the environment
6.3
Quantitative modelling of risks to the environment arising from the use of Checkmate
CM-F has been carried out and is presented in Appendix 3. The acute risk quotients
derived from this assessment are significantly below the level of concern for fish,
crustacean and algae, suggesting that the use of Checkmate CM-F will not pose a high
acute aquatic risk. As no chronic ecotoxicity data was available for 8,10-dodecadien-1-ol,
no estimation was able to be made of chronic risk. However, it is noted that the available
data on 8,10-dodecadien-1-ol suggests it will be readily degradable in the environment,
and will not bioaccumulate. Consequently, the project team consider it highly improbable
that the use of Checkmate CM-F will pose a risk to the environment.
6.4
A qualitative risk assessment was carried out by the project team to consider the risks to
the environment during life-cycle stages other than use. These risks are considered to be
insignificant based on the following considerations:
6.4.1
The project team considers that it is highly improbable given adherence to HSNO
controls (e.g. packaging, identification and emergency management), transport
regulations and the RMA, that the aquatic environment will be exposed to
Checkmate CM-F during manufacture, transport, storage or disposal in such a
manner so as to cause any adverse effects.
6.4.2
If exposure were to occur, the project team considers that the magnitude of any
adverse effect will be minimal to minor as the effect would be localised with no
discernible ecosystem impact.
Assessment of issues and concerns to Māori
6.5
After careful consideration of the information provided by the applicant and the project
team’s scientific evaluation, Kaupapa Kura Taiao is not aware of any likely impact that
Checkmate CM-F could have on Māori culture or traditional relationships with ancestral
lands, water, sites, wāhi tapu, valued flora and fauna or other taonga.
6.6
This assessment is made on the condition that the substance is handled, blended, stored,
transported, used and disposed of, in accordance with the explicitly stated HSNO
controls, and any controls stipulated in other applicable Acts. However, should
inappropriate use, or an accident, result in the contamination of waterways or the
environment, it is encouraged that the appropriate authorities including the relevant iwi
authorities in that region be informed. This action should include advising them of the
contamination and the measures taken to contain and remedy it.
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7 Environmental user charges
7.1
The project team considers that use of controls on Checkmate CM-F is an effective
means of managing risks associated with this substance. At this time, no consideration
has been given to whether or not environmental charges should be applied to this
substance as an alternative or additional means of achieving effective risk management.
Accordingly, no report has been made to the Minister for the Environment.
8 Decision
8.1
Pursuant to section 28A, I have considered this application to import or manufacture a
hazardous substance for release made under section 28.
8.2
Having considered the composition, hazardous properties, and use for Checkmate CM-F,
I am satisfied that the proposed substance meets the criteria for rapid assessment under
section 28A(2)(b) in that it has been formulated so that the substance has one or more
hazardous properties and each hazardous property has the least degree of hazard for that
property.
8.3
Because the risks posed by the Checkmate CM-F are insignificant, I consider that
applying the HSNO default controls to Checkmate CM-F, with the additions and
amendments proposed under paragraphs 5.4 to 5.6.7 (inclusive), will ensure adequate
management of any adverse effects of Checkmate CM-F.
8.4
In this consideration, I have also applied the following criteria in the Methodology:
 clause 9 – equivalent of sections 5, 6 and 8;
 clause 12 – risk assessment;
 clause 21 – the decision accords with the requirements of the Act and regulations;
 clause 24 – the use of recognised risk identification, assessment, evaluation and
management techniques;
 clause 25 – the evaluation of risks; and
 clause 35 – the costs and benefits of varying the default controls.
8.5
The application for importation and manufacture of the hazardous substance, Checkmate
CM-F for release is thus approved with controls as detailed in Appendix 1.
Rob Forlong
Chief Executive, ERMA New Zealand
Date: 21 March 2007
Checkmate CM-F
ERMA New Zealand Approval Code:
Environmental Risk Management Authority Decision: Application HSR06104
HSR007766
Page 9 of 25
Appendix 1: Controls applying to Checkmate CM-F
The controls imposed on Checkmate CM-F are as follows. The regulations cited should be referred
to for definitions and exemptions. The ERMA New Zealand publication “User Guide to Control
Regulations” provides useful guidance on the controls.
Table A1.1: Controls applying to Checkmate CM-F
Control
Code1
Regulation2
Explanation3
Hazardous Substances (Classes 6, 8 and 9 Controls) Regulations 2001 -Toxic Property Controls
T1
11-27
Limiting exposure to toxic substances
This control relates to limiting public exposure to toxic substances through the
setting of tolerable exposure limits (TELs).
No TELs are set for Checkmate CM-F at this time.
T4, E6
7
Requirements for equipment used to handle hazardous substances
Any equipment used to handle Checkmate CM-F (e.g. spray equipment) must
retain and/or dispense the substance in the manner intended, i.e. without
leakage, and must be accompanied by sufficient information so that this can be
achieved.
T7
10
Restrictions on the carriage of hazardous substances on passenger
service vehicles
The maximum quantity per package of Checkmate CM-F permitted to be
carried on passenger service vehicles is 10 L.
Hazardous Substances (Classes 6, 8 and 9 Controls) Regulations 2001 - Ecotoxic Property
Controls
E1
32-45
Limiting exposure to ecotoxic substances
This control relates to the setting of environmental exposure limits (EELs).
No EELs are set for Checkmate CM-F at this time.
E2
46-48
Restrictions on use within application area
These Regulations relate to controls on application areas. An application
(target) area is an area that the person using the substance either has control
over or is otherwise authorised to apply the substance to. For ecotoxic
substances that are intentionally released into the environment (e.g. pesticides),
any EEL controls will not apply within the application (target) area providing
the substance is applied at a rate that does not exceed the allowed application
rate. In addition, any approved handler controls (T6/E7, Regulation 9) do not
apply once the substance has been applied or laid.
No application rates are set for Checkmate CM-F at this time.
Note: The numbering system used in this column relates to the coding system used in the ERMA New Zealand Controls Matrix. This links the
hazard classification categories to the regulatory controls triggered by each category. It is available from the ERMA New Zealand website
www.ermanz.govt.nz/resources and is also contained in the ERMA New Zealand User Guide to the HSNO Control Regulations.
2 These Regulations form the controls applicable to this substance. Refer to the cited Regulations for the formal specification, and for definitions and
exemptions. The accompanying explanation is intended for guidance only.
3 These explanations are for guidance only. Refer to the cited Regulations for the formal specification, and for definitions and exemptions.
1
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Control
Code1
Regulation2
Explanation3
Hazardous Substances (Identification) Regulations 2001
The Identification Regulations prescribe requirements with regard to
identification of Checkmate CM-F in terms of:
 information that must be “immediately available” with the substance
(priority and secondary identifiers). This information is generally provided
by way of the product label;
 documentation that must be available in the workplace, generally provided
by way of SDS;
 signage at a place where there is a large quantity of the substance.
I1
6, 7, 32-35, 36 General identification requirements
(1)-(7)
These controls relate to the duties of suppliers and persons in charge of
Checkmate CM-F with respect to identification (essentially labelling)
(Regulations 6 and 7), accessibility of the required information (Regulations 32
and 33) and presentation of the required information with respect to
comprehensibility, clarity and durability (Regulations 34, 35, 36(1)-(7))
Regulation 6 – Identification duties of suppliers
Suppliers of Checkmate CM-F must ensure it is labelled with all relevant
priority identifier information (as required by Regulations 8-17) and secondary
identifier information (as required by Regulations 18-30) before supplying it to
any other person. This includes ensuring that the priority identifier information
is available to any person handling Checkmate CM-F within two seconds
(Regulation 32), and the secondary identifier information available within 10
seconds (Regulation 33).
Suppliers must also ensure that no information is supplied with Checkmate
CM-F (or its packaging) that suggests it belongs to a class or subclass that it
does not in fact belong to.
Regulation 7 – Identification duties of persons in charge
Persons in charge of Checkmate CM-F must ensure it is labelled with all
relevant priority identifier information (as required by Regulations 8 to 17) and
secondary identifier information (as required by Regulations 18 to 30) before
supplying it to any other person. This includes ensuring that the priority
identifier information is available to any person handling Checkmate CM-F
within two seconds (Regulation 32), and the secondary identifier information
is available within 10 seconds (Regulation 33).
Persons in charge must also ensure that no information is supplied with the
substance (or its packaging) that suggests it belongs to a class or subclass that it
does not in fact belong to.
Regulations 32 and 33 – Accessibility of information
All priority identifier Information (as required by Regulations 8 to 17) must be
available within two seconds, e.g. on the label.
All secondary identifier Information (as required by Regulations 18 to 30) must
be available within 10 seconds, e.g. on the label.
Regulations 34, 35, 36(1)-(7) – Comprehensibility, Clarity and Durability of
information
All required priority and secondary identifiers must be presented in a way that
meets the performance standards in these Regulations. In summary:
 any information provided (either written or oral) must be readily
understandable and in English;
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Control
Code1
Regulation2
I9
18
I11
20
I16
25
I19
29-31
Explanation3
 any information provided in written or pictorial form must be able to be
easily read or perceived by a person with average eyesight under normal
lighting conditions;
 any information provided in an audible form must be able to be easily
heard by a person with average hearing;
 any information provided must be in a durable format i.e. the information
requirements with respect to clarity must be able to be met throughout the
lifetime of the (packaged) substance under the normal conditions of
storage, handling and use.
Secondary identifiers for all hazardous substances
This control relates to detail required for Checkmate CM-F on the product
label. This information must be accessible within 10 seconds (Regulation 33)
and could be provided on secondary panels on the product label. The
following information is required:
 an indication (which may include its common name, chemical name, or
registered trade name) that unequivocally identifies it; and
 enough information to enable its New Zealand importer, supplier, or
manufacturer to be contacted, either in person or by telephone; and
 in the case of a substance which, when in a closed container, is likely to
become more hazardous over time or develop additional hazardous
properties, or become a hazardous substance of a different class or
subclass, a description of each likely change and the date by which it is
likely to occur.
Secondary identifiers for ecotoxic substances
This control relates to the additional label detail required for Checkmate
CM-F. This information must be accessible within 10 seconds (Regulation 33)
and could be provided on secondary panels on the product label. The
following information must be provided:
 an indication of the circumstances in which it may harm living organisms;
 an indication of the kind and extent of the harm it is likely to cause to
living organisms;
 an indication of the steps to be taken to prevent harm to living organisms;
 an indication of its general type and degree of hazard (ie ecotoxic in the
aquatic environment).
Secondary identifiers for toxic substances
This control relates to the additional label detail required for Checkmate
CM-F. This information must be accessible within 10 seconds (Regulation 33)
and could be provided on secondary panels on the product label. The
following information must be provided:
 an indication of its general type and degree of toxic hazard (ie skin
irritancy);
 an indication of the circumstances in which it may harm human beings;
 an indication of the kinds of harm it may cause to human beings, and the
likely extent of each kind of harm;
 an indication of the steps to be taken to prevent harm to human beings.
Alternative information in certain cases
Regulation 29 – Substances in fixed bulk containers or bulk transport
containers
This Regulation relates to alternative ways of presenting the priority and
secondary identifier information required by Regulations 8 to 25 when
Checkmate CM-F is contained in fixed bulk containers or bulk transport
containers.
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Control
Code1
Regulation2
Explanation3
Regulation 29(1) specifies that for fixed bulk containers, it is sufficient
compliance if there is available at all times to people near the container,
information that identifies the type and general degree of hazard of the
substance.
Regulation 29(2) specifies that for bulk transport containers, it is sufficient
compliance if the substance is labelled or marked in compliance with the
requirements of the Land Transport Rule 45001, Civil Aviation Act 1990 or
Maritime Transport Act 1994.
Regulation 30 – Substances in multiple packaging
This Regulation relates to situations when Checkmate CM-F is in multiple
packaging and the outer packaging obscures some or all of the required
substance information. In such cases, the outer packaging must:
 be clearly labelled with all relevant priority identifier information i.e. the
hazardous properties of the substance must be identified; or
 be labelled or marked in compliance with either the Land Transport Rule
45001, Civil Aviation Act 1990 or the Maritime Safety Act 1994 as
relevant; or
 in the case of an ecotoxic substance, it must bear the EU pictogram
“Dangerous to the Environment” (‘dead fish and tree’ on orange
background); or
 bear the relevant class or subclass label assigned by the UN Model
Regulations.
I21
37-39, 47-50
Regulation 31 – Alternative information when substances are imported
This Regulation relates to alternative information requirements for Checkmate
CM-F that is imported into New Zealand in a closed package or in a freight
container and will be transported to its destination without being removed
from that package or container. In these situations, it is sufficient compliance
with HSNO if the package or container is labelled or marked in compliance
with the requirements of the Land Transport Rule 45001.
Documentation required in places of work
These controls relate to the duties of suppliers and persons in charge of places
of work with respect to provision of documentation (essentially Safety Data
Sheets) (Regulations 37, 38 and 50); the general content requirements of the
documentation (Regulation 39 and 47); the accessibility and presentation of the
required documentation with respect to comprehensibility and clarity
(Regulation 48).
These controls are triggered when Checkmate CM-F is held in the workplace
in quantities equal to or greater than 50 L.
Regulation 37 – Documentation duties of suppliers
A supplier must provide documentation containing all relevant information
required by Regulations 39 to 48 when selling or supplying to another person a
quantity of Checkmate CM-F equal to or greater than 50 L, if the substance is
to be used in a place of work and the supplier has not previously provided the
documentation to that person.
Regulation 38 – Documentation duties of persons in charge of places of work
The person in charge of any place of work where Checkmate CM-F is present
in quantities equal to or greater than those specified in Regulation 38 (and with
reference to Schedule 2 of the Identification Regulations), must ensure that
every person handling the substance has access to the documentation required
for each hazardous substance concerned. The person in charge must also
Environmental Risk Management Authority Decision: Application HSR06104
Page 13 of 25
Control
Code1
Regulation2
Explanation3
ensure that the documentation does not contain any information that suggests
that the substance belongs to a class or subclass it does not in fact belong to.
Regulation 39 – General content requirements for documentation
The documentation provided with a hazardous substance must include the
following information:
 the unequivocal identity of the substance (e.g. the CAS number, chemical
name, common name, UN number, registered trade name(s));
 a description of the physical state, colour and odour of the substance;
 if the Checkmate CM-F’s physical state may alter over the expected range
of workplace temperatures, the documentation must include a description
of the temperatures at which the changes in physical state may occur and
the nature of those changes;
 in the case of a substance that, when in a closed container, is likely to
become more hazardous over time or develop additional hazardous
properties, or become a hazardous substance of a different class, the
documentation must include a description of each likely change and the
date by which it is likely to occur;
 contact details for the New Zealand supplier / manufacturer /importer;
 all emergency management and disposal information required for the
substance;
 the date on which the documentation was prepared.
Regulation 47 – Information not included in approval
This Regulation relates to the provision of specific documentation information
(e.g. as provided on an SDS). If information required by Regulations 39 to 46
was not included in the information used for the approval of the substance by
the Authority, it is sufficient compliance with those Regulations if reference is
made to that information requirement along with a comment indicating that
such information is not applicable to that substance.
Regulation 48 – Location and presentation requirements for documentation
All required documentation must be available to a person handling Checkmate
CM-F in a place of work within 10 minutes. The documentation must be
readily understandable by any fully-trained worker required to have access to it
and must be easily read, under normal lighting conditions, at a distance of not
less than 0.3 m.
Regulation 49 – Documentation requirements for vehicles
This Regulation provides for the option of complying with documentation
requirements as specified in the various Land, Sea and Air transport rules
when the substance is being transported.
I28
46
Regulation 50 – Documentation to be supplied on request
Notwithstanding Regulation 37 above, a supplier must provide the required
documentation to any person in charge of a place of work (where Checkmate
CM-F is present) if asked to do so by that person.
Specific documentation requirements for toxic substances
The documentation provided with Checkmate CM-F must include the
following information:
 its general degree and type of toxic hazard (ie skin irritancy);
 a full description of the circumstances in which it may harm human
beings;
 the kinds of harm it may cause to human beings;
Environmental Risk Management Authority Decision: Application HSR06104
Page 14 of 25
Control
Code1
Regulation2
I29
51-52
Explanation3
 a full description of the steps to be taken to prevent harm to human
beings;
 the percentage of volatile substance in the liquid formulation, and the
temperature at which the percentages were measured;
 a summary of the available acute and chronic (toxicity) data used to define
the (toxic) subclass or subclasses in which it is classified;
 the symptoms or signs of injury or ill health associated with each likely
route of exposure;
 the dose, concentration, or conditions of exposure likely to cause injury or
ill health;
 any TELs or WESs set by the Authority.
Duties of persons in charge of places with respect to signage
These controls specify the requirements for signage, in terms of content,
presentation and positioning at places where Checkmate CM-F is held in
quantities exceeding 10,000 L.
Signs are required:
 at every entrance to the building and/or location (vehicular and
pedestrian) where Checkmate CM-F is present
 at each entrance to rooms or compartments where Checkmate CM-F is
present;
 immediately adjacent to the area where Checkmate CM-F is located in an
outdoor area.
The information provided in the signage needs to be understandable over a
distance of 10 metres and be sufficient to:
 advise that the location contains hazardous substances;
 describe the general type of hazard of each substance (ie skin irritancy,
ecotoxic in the aquatic environment);
 where the signage is immediately adjacent to Checkmate CM-F storage
areas, describe the precautions needed to safely manage the substance.
Hazardous Substances (Packaging) Regulations 2001
P1
5, 6, 7 (1), 8
General packaging requirements
These controls relate to the ability of the packaging to retain its contents,
allowable packaging markings with respect to design approvals, factors
affecting choice of suitable packaging, and compatibility of the substance with
any previous contents of the packaging.
Regulation 5 – Ability to retain contents
Packaging for Checkmate CM-F must ensure that, when the package is closed,
there is no visible release of the substance, and that it maintains its ability to
retain its contents in temperatures from –10oC to +50oC. The packaging must
also maintain its ability to retain its remaining contents if part of the contents is
removed from the package and the packaging is then re-closed. The packaging
in direct contact with Checkmate CM-F must not be significantly affected or
weakened by contact with the substance such that the foregoing requirements
cannot be met.
Regulation 6 – Packaging markings
Packages containing hazardous substances must not be marked in accordance
with the UN Model Regulations unless:
 the markings comply with the relevant provisions of that document; and
 the design of the packaging has been test certified as complying with those
Environmental Risk Management Authority Decision: Application HSR06104
Page 15 of 25
Control
Code1
Regulation2
Explanation3
tests.
Regulation 7(1) – Requirements when packing hazardous substance
When packing Checkmate CM-F, account must be taken of its physical state
and properties, and packaging must be selected that complies with the
requirements of Regulation 5, and Regulations 9 to 21.
Regulation 8 – Compatibility
Checkmate CM-F must not be packed in packaging that has been previously
packed with substances with which it is incompatible unless all traces of the
previous substance have been removed.
Regulation 9A and 9B – Large Packaging
Large packaging may be used to contain hazardous substances in New Zealand
if it has been constructed, marked and tested as a large package as provided in
Chapter 6.6 of the 13th revised edition of the UNRTDG, 2003.
P3, P13
9, 19
“Large Packaging” does not include:
 a tank, tank wagon or transportable container (as defined in the Hazardous
Substances (Tank Wagons and Transportable Containers) Regulations
2004; or
 a stationary container system, a stationary tank or a tank (as defined in the
Hazardous substances (Dangerous Goods and Scheduled Toxic
Substances) Transfer Notice 2004.
Packaging requirements for Checkmate CM-F
Checkmate CM-F must be packaged in packaging that complies with Schedule
4 of the Packaging Regulations.
However, there is provision that packages containing less than 0.5 L of
Checkmate CM-F do not have to comply with the drop test performance
standard contained in Schedule 4 provided the packaging complies with the
requirements of regulations 5(1) (a), (b) and (e), and there is a warning
statement on the outside of the package that the package may not withstand a
drop of 0.5 m [Regulation 9 (3), (4), and (5)].
PS4
Schedule 4
Checkmate CM-F offered for sale in a package of less than 2.5L must be in
child resistant packaging (i.e. toxic substances liable to be in homes). However,
if the substance is for use in a place of work to which children do not have
access, this requirement is not mandatory.
This schedule describes the minimum packaging requirements that must be
complied with for Checkmate CM-F.
Environmental Risk Management Authority Decision: Application HSR06104
Page 16 of 25
Hazardous Substances (Disposal) Regulations 2001
D4, D5 8, 9
Disposal requirements for toxic and corrosive substances
Checkmate CM-F must be disposed of by:
 treating it so that it is no longer a hazardous substance, including
depositing the substance in a landfill, incinerator or sewage facility.
However, this does not include dilution of the substance with any other
substance prior to discharge to the environment; or
 discharging it to the environment provided that after reasonable mixing,
the concentration of the substance in any part of the environment outside
the mixing zone does not exceed any TEL (tolerable exposure limit) or any
EEL (environmental exposure limit) set by the Authority for that
substance; or
 exporting it from New Zealand as a hazardous waste.
D6
10
Disposal requirements for packages
This control gives the disposal requirements for packages that contained
Checkmate CM-F and are no longer to be used for that purpose. Such
packages must be either decontaminated/treated or rendered incapable of
containing any substance (hazardous or otherwise) and then disposed of in a
manner that is consistent with the disposal requirements for the substance. In
addition, the manner of disposal must take into account the material that the
package is manufactured from.
D7
11, 12
Disposal information requirements
These controls relate to the provision of information concerning disposal
(essentially on the label) that must be provided when selling or supplying a
quantity of Checkmate CM-F that exceeds 1.0 L.
D8
13, 14
Information must be provided on appropriate methods of disposal and
information may be supplied warning of methods of disposal that should be
avoided, i.e. which would not comply with the Disposal Regulations. Such
information must be accessible to a person handling Checkmate CM-F within
10 seconds and must comply with the requirements for comprehensibility,
clarity and durability as described in Regulations 34-36 of the Identification
Regulations (code I1).
Disposal documentation requirements
These controls relate to the provision of documentation concerning disposal
(essentially in an SDS) that must be provided when selling or supplying a
quantity of Checkmate CM-F that exceeds 50 L.
The documentation must describe one or more methods of disposal (that
comply with the Disposal Regulations) and describe any precautions that must
be taken. Such documentation must be accessible to a person handling
Checkmate CM-F at a place of work within 10 minutes and must comply with
the requirements for comprehensibility and clarity as described in Regulations
48(2), (3) and (4) of the Identification Regulations (code I21).
Hazardous Substances (Emergency Management) Regulations 2001
EM1
6, 7, 9-11
Level 1 emergency management information: General requirements
These controls relate to the provision of emergency management information
(essentially on the label) that must be provided with Checkmate CM-F when
present in quantities equal to or greater than 1.0 L.
Regulation 6 describes the duties of suppliers, Regulation 7 describes the duties
of persons in charge of places, Regulation 9 describes the requirement for the
availability of the information (10 seconds) and Regulation 10 gives the
requirements relating to the presentation of the information with respect to
comprehensibility, clarity and durability. These requirements correspond with
Environmental Risk Management Authority Decision: Application HSR06104
Page 17 of 25
those relating to secondary identifiers required by the Identification
Regulations (code I1, Regulations 6, 7, 32–35, 36(1)-(7)).
EM6
8(e)
EM7
8(f)
EM8
12-16, 18-20
Regulation 11 provides for the option of complying with the information
requirements of the transport rules when the substance is being transported.
Information requirements for toxic substances
The following information must be provided when Checkmate CM-F is
present in quantities equal to or greater than 1.0 L:
 a description of the first aid to be given;
 a 24-hour emergency service telephone number.
Information requirements for ecotoxic substances
The following information must be provided with Checkmate CM-F when
present in quantities equal to or greater than 1.0 L:
 a description of the parts of the environment likely to be immediately
affected by it;
 a description of its typical effects on those parts of the environment;
 a statement of any immediate actions that may be taken to prevent
Checkmate CM-F from entering or affecting those parts of the
environment.
Level 2 emergency management documentation requirements
These controls relate to the duties of suppliers and persons in charge of places
of work with respect to the provision of emergency management
documentation (essentially Safety Data Sheets). This documentation must be
provided where Checkmate CM-F is sold or supplied, or held in a workplace,
in quantities equal to or greater than 50 L.
Regulations 12 and 13 describe the duties of suppliers, regulation 14 describes
the duties of persons in charge of places of work, regulation 15 provides for
the option of complying with documentation requirements of the transport
rules when the substance is being transported, and regulation 16 specifies
requirements for general contents of the documentation.
EM11
EM12
25-34
35-41
Regulation 18 prescribes location and presentation requirements for the
documentation, i.e. it must be available within 10 minutes, be readily
understandable, comprehensible and clear. These requirements correspond
with those relating to documentation required by the Identification regulations
(code I21).
Level 3 emergency management requirements – emergency response
plans
These Regulations relate to the requirement for an emergency response plan to
be available at any place (excluding aircraft or ships) where Checkmate CM-F
is held (or reasonably likely to be held on occasion) in quantities greater than
10,000 L.
The emergency response plan must describe all of the likely emergencies that
may arise from the breach or failure of controls. The type of information that
is required to be included in the plan is specified in Regulations 29 to 30.
Requirements relating to the availability of equipment, materials and people are
provided in Regulation 31, requirements regarding the availability of the plan
are provided in Regulation 32 and requirements for testing the plan are
described in Regulation 33.
Level 3 emergency management requirements – secondary containment
These Regulations relate to the requirement for a secondary containment
system to be installed at any fixed location where Checkmate CM-F is held in
quantities equal to or greater than 10,000 L.
Environmental Risk Management Authority Decision: Application HSR06104
Page 18 of 25
Regulation 36 prescribes requirements for secondary containment systems for
pooling substances. Regulation 37 prescribes requirements for places where
hazardous substances are held above ground in containers each holding up to
60 L or less. Regulation 38 prescribes requirements for places where hazardous
substances are held above ground in containers each holding between 60 L and
450 L. Regulation 39 prescribes requirements for places where hazardous
substances are held above ground in containers each holding more than 450 L.
Regulation 40 prescribes requirements for places where hazardous substances
are held underground. Regulation 41 prescribes requirements for secondary
containment systems that contain substances of specific hazard classifications.
The following subclauses shall be added after subclause (3) of
regulation 36:
(4) For the purposes of this regulation, and regulations 37 to 40, where
this substance is contained in pipework that is installed and
operated so as to manage any loss of containment in the pipework
it—
(a) is not to be taken into account in determining whether a place
is required to have a secondary containment system; and
(b) is not required to be located in a secondary containment
system.
(5) In this clause, pipework—
(a) means piping that—
(i) is connected to a stationary container; and
(ii) is used to transfer a hazardous substance into or out of the
stationary container; and
(b) includes a process pipeline or a transfer line.
EM13
42
Level 3 emergency management requirements – signage
This control relates to the provision of emergency management information
on signage at places where Checkmate CM-F is held at quantities equal to or
greater than 10,000 L.
The signage must advise of the action to be taken in an emergency and must
meet the requirements for comprehensibility and clarity as defined in
Regulations 34 and 35 of the Identification Regulations.
Hazardous Substances (Tank Wagons and Transportable Containers) Regulations 2004
Regulations 4 to 43
The Hazardous Substances (Tank Wagons and Transportable Containers)
where applicable
Regulations 2004 prescribe a number of controls relating to tank wagons and
transportable containers and must be complied with as relevant.
Additional controls set under s77A
Checkmate CM-F shall not be applied directly onto or into water.
The controls relating to stationary container systems, as set out in Schedule 8 of the Hazardous Substances
(Dangerous Goods and Scheduled Toxic Substances) Transfer Notice 2004 (Supplement to the
New Zealand Gazette, 26 March 2004, No. 35, page 767), as amended, shall apply to this substance,
notwithstanding clause 1(1) of that schedule.
EM12: see the control explanation for additional subclauses.
Environmental Risk Management Authority Decision: Application HSR06104
Page 19 of 25
Appendix 2: Qualitative scales for describing effects
Qualitative descriptors
Qualitative descriptors are indicative only and they are primarily intended to be used to rank risks
and benefits for the purposes of balancing risks and costs against benefits, and so that risks can be
prioritised for management. The ‘descriptor’ words should not be seen in any absolute senses – they
are simply a means of differentiating levels of significance.
Table A2.1: Likelihood (adverse effect)
Descriptor
Description
1 Highly improbable
Almost certainly not occurring but cannot be totally ruled out
2 Improbable (remote)
Only occurring in very exceptional circumstances.
3 Very unlikely
Considered only to occur in very unusual circumstances
4 Unlikely (occasional)
Could occur, but is not expected to occur under normal operating conditions.
5 Likely
A good chance that it may occur under normal operating conditions.
6 Very likely
Expected to occur if all conditions met
7 Extremely likely
Almost certain
Table A2.2: Magnitude of adverse effect (risks and costs)
Descriptor
Examples of descriptions
I Minimal
Mild reversible short term adverse health effects to individuals in highly
localised area
Highly localised and contained environmental impact, affecting a few (less
than ten) individuals members of communities of flora or fauna, no
discernible ecosystem impact
Low dollar cost of containment/cleanup/repair (<$5,000)
No social disruption1
II Minor
Mild reversible short term adverse health effects to identified and isolated
groups2 Localised and contained reversible environmental impact, some local
plant or animal communities temporarily damaged, no discernible ecosystem
impact or species damage
Dollar cost of containment/cleanup/repair in order of $5,000-$50,000
Potential social disruption (community placed on alert)
III Moderate
Minor irreversible health effects to individuals and/or reversible medium
term adverse health effects to larger (but surrounding) community (requiring
hospitalisation)
Measurable long term damage to local plant and animal communities, but no
obvious spread beyond defined boundaries, medium term individual
ecosystem damage, no species damage
Dollar cost of containment/cleanup/repair in order of $50,000-$500,000,
Some social disruption (e.g. people delayed)
IV Major
Significant irreversible adverse health effects affecting individuals and
requiring hospitalisation and/or reversible adverse health effects reaching
beyond the immediate community
Long term/irreversible damage to localised ecosystem but no species loss
Dollar cost of containment/cleanup/repair in order of $500,000-$5,000,000
Social disruption to surrounding community, including some evacuations
V Massive
Significant irreversible adverse health effects reaching beyond the immediate
community and/or deaths
1
2
The concept of social disruption includes both physical disruption, and perceptions leading to psychological
disruption. For example, some chemicals may have nuisance effects (through odour) that result in communities
feeling threatened.
Note that the reference to ‘groups’ and ‘communities’ in the context of human health effects includes the notion of
groups defined by health status.
Environmental Risk Management Authority Decision: Application HSR06104
Page 20 of 25
Extensive irreversible ecosystem damage, including species loss
Dollar cost of containment/cleanup/repair greater than $5,000,000
Major social disruption with entire surrounding area evacuated and impacts
on wider community
Table A2.3: Magnitude of beneficial effect (benefits)
Descriptor
Examples of descriptions
I Minimal
Mild short term positive health effects to individuals in highly localised area
Highly localised and contained environmental impact, affecting a few (less
than ten) individuals members of communities of flora or fauna, no
discernible ecosystem impact
Low dollar benefit (<$5,000)
No social effect
II Minor
Mild short term beneficial health effects to identified and isolated groups
Localised and contained beneficial environmental impact, no discernible
ecosystem impact or species damage
Dollar benefit in order of $5,000-$50,000
Minor localised community benefit
III Moderate
Minor health benefits to individuals and/or medium term health impacts on
larger (but surrounding) community and health status groups
Measurable benefit to localised plant and animal communities expected to
pertain to medium term.
Dollar benefit in order of $50,000-$500,000,
Local community and some individuals beyond immediate community
receive social benefit.
IV Major
Significant beneficial health effects to localised community and specific
groups in wider community
Long term benefit to localised ecosystem(s)
Dollar benefit in order of $500,000-$5,000,000
Substantial social benefit to surrounding community, and individuals in wider
community.
V Massive
Significant long term beneficial health effects to the wider community
Long term, wide spread benefits to species and/or ecosystems
Dollar benefit greater than $5,000,000
Major social benefit affecting wider community
Table A2.4: Calculating the level of risk
Likelihood
Highly Improbable
Improbable
Very unlikely
Unlikely
Likely
Very likely
Extremely likely
1
2
3
4
5
6
7
Minimal
I
A
A
B
C
D
E
E
Magnitude of effect
Minor
Moderate
Major
II
III
IV
A
B
C
B
C
D
C
D
E
D
E
E
E
E
F
E
F
F
F
F
F
Massive
V
D
E
E
F
F
F
F
The Agency considers that, for this substance, the level of risk can be assigned as follows:
A Insignificant
B Very low
C Low
D Medium
E High
F Extreme
Environmental Risk Management Authority Decision: Application HSR06104
Page 21 of 25
Appendix 3: Environmental exposure risk assessment
For Class 9 substances, the ecological risk can be assessed for a substance or its components by
calculating a risk quotient based on an estimated exposure concentration. Such calculations
incorporate toxicity values, exposure scenarios (including spray drift, application rates and
frequencies), and the half-lives of the component(s) in soil and water. The calculations provide an
Estimated Environmental Concentration (EEC) which, when divided by the LC50 or EC50, gives a
risk quotient (RQ).
RQ = EEC
LC50 or EC50
If the RQ exceeds a predefined level of concern, this suggests that it may be appropriate to refine
the risk assessment or apply/retain the AH control and/or other controls to ensure that appropriate
matters are taken into account to minimise off-site movement of the substance. Conversely, if a
worst-case scenario is used, and the level of concern is not exceeded, then in terms of the
environment, there is a presumption of low risk which is able to be adequately managed by such
things as label statements (warnings, disposal). The approved handler control can then be removed
on a selective basis.
Levels of concern (LOC) as proposed by the USEPA and adopted by ERMA New Zealand, to
determine whether a substance poses an environmental risk are provided in Table A3.1 below.
Table A3.1. Levels of Concern
Endpoint
Aquatic (fish, invertebrates)
Acute RQ≥
Acute RQ
Acute RQ<
Chronic RQ≥
Plants (aquatic and terrestrial)
Acute RQ≥
Mammal and birds
Acute dietary RQ≥
Acute oral dose [granular products] RQ≥
Chronic RQ≥
Acute RQ = EEC/LC50
Chronic RQ = EEC/NOEC
LOC
Presumption
0.5
0.1-0.5
0.1
1
High acute risk
Risk can be mitigated through restricted use
Low risk
High chronic risk
1
High acute risk
0.5
0.5
1
High acute risk
High acute risk
High chronic risk
Assessment of Expected Environmental Concentration (EEC) – GENEEC2
The Agency has used the GENEEC2 surface water exposure model (USEPA, 2001) to estimate the
EEC of 8,10-dodecadien-1-ol in surface waters which may potentially arise as a result of spray drift
and surface runoff from the proposed New Zealand use pattern.
The proposed maximum application rate for Checkmate CM-F is 0.183 L/ha, equivalent to 0.0257
kg ai/ha. The parameters used in the GENEEC2 modelling are listed in Table A3.2 and represent
the recommended use on apples and pears which was used as a conservative estimate.
Environmental Risk Management Authority Decision: Application HSR06104
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Table A3.2: GENEEC2 input parameters
Application rate
Application frequency
Application interval
Koc
Aerobic soil DT50
Pesticide wetted in?
Methods of application
‘No spray’ zone
Water solubility
Aerobic aquatic DT50
Aqueous photolysis DT50
Checkmate CM-F
0.0257 kg ai/ha
5 times per season
30 days
0.35 * kow
0.35 * 21,878 = 7,657
Not available
No
Air blast spray
None
34.15 ppm (est)
Not available
14 days
Table A3.3: GENEEC2 output
RUN No1 for 8,10-Dodecadien-1-ol on apples/pears
* INPUT VALUES
-------------------------------------------------------------------RATE (#/AC)
No.APPS &
SOIL SOLUBIL
APPL TYPE NO-SPRAY INCORP
ONE(MULT)
INTERVAL
Koc
(PPM )
(%DRIFT)
(FT)
(IN)
-------------------------------------------------------------------.023(
.114)
5 30
7657.0
34.2
ORCHAR( 9.7)
.0
.0
FIELD AND STANDARD POND HALFLIFE VALUES (DAYS)
-------------------------------------------------------------------METABOLIC DAYS UNTIL HYDROLYSIS
PHOTOLYSIS
METABOLIC COMBINED
(FIELD)
RAIN/RUNOFF
(POND)
(POND-EFF)
(POND)
(POND)
-------------------------------------------------------------------.00
2
N/A
14.00- 1736.00
.00
1736.00
GENERIC EECs (IN NANOGRAMS/LITER (PPTr))
Version 2.0 Aug 1, 2001
-------------------------------------------------------------------PEAK
MAX 4 DAY
MAX 21 DAY
MAX 60 DAY
MAX 90 DAY
GEEC
AVG GEEC
AVG GEEC
AVG GEEC
AVG GEEC
-------------------------------------------------------------------953.44
932.38
808.19
601.64
494.74
The estimated environmental concentration (EEC) of 8,10-dodecadien-1-ol as estimated by
GENEEC2 = 953.44 ng/L = 0.000953 mg/L
RQ = EEC
LC50 or EC50
Table A3.4: Calculation of RQ
Fish
Crustacea
Algae (Acute)
EEC from GENEEC2
(mg/L)
0.000953
LC50 or EC50
(mg/L)
5.87
8.6
0.148
Environmental Risk Management Authority Decision: Application HSR06104
RQ (Acute)
0.00016
0.00011
0.0064
Page 23 of 25
When compared against the relevant risk quotients as shown in Table A3.1 the RQs derived from
the GENEEC 2 modelling for 8,10-dodecadien-1-ol are all below the level of concern (LOC) for
fish, crustacean and algae. These results suggest that the use of Checkmate CM-F will not pose a
high acute aquatic risk based on the most sensitive tested aquatic species.
As no chronic ecotoxicity data was available for 8,10-dodecadien-1-ol, no estimation was able to be
made of chronic risk. However, it is noted that the available data on 8,10-dodecadien-1-ol suggests
it will be readily degradable in the environment, and will not bioaccumulate.
Environmental Risk Management Authority Decision: Application HSR06104
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Appendix 4: Confidential
Environmental Risk Management Authority Decision: Application HSR06104
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