ENVIRONMENTAL RISK MANAGEMENT AUTHORITY
DECISION
16 August 2002
Application code
HSR02009
Application type
To import or manufacture any hazardous substance under Section 28 the
Hazardous Substances and New Organisms (HSNO) Act 1996
Applicant
Osmose New Zealand
Purpose
To manufacture PROTIM ANTIMOULD, a fungicide treatment for timber
and wood products
Date received
11 March 2002
Consideration date
21 June 2002
Considered by
Hazardous Substance Standing Committee of the Authority.
1. Summary of Decision
1.1
The application to import or manufacture PROTIM ANTIMOULD, is approved with
controls in accordance with the section 28 of the Hazardous Substances and New
Organisms Act 1996 (the HSNO Act), the HSNO Regulations, and the HSNO
(Methodology) Order 1998.
1.2
The substance has been given the following unique identifier, for the ERMA New
Zealand Hazardous Substances Register:
PROTIM ANTIMOULD
1.3
The Committee has adopted a use classification system as the basis for recording the
nature and uses of substances approved. The following use categories are recorded for
this substance:
Main category
Industry category
Function/use category
3
0
39
Non-dispersive use
Other
Pesticides, non-agricultural
Environmental Risk Management Authority Decision: Application HSR02009
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2 Legislative Criteria for Application
2.1
The application was lodged pursuant to section 28 of the HSNO Act. The decision was
determined in accordance with section 29, taking into account additional matters to be
considered in that section and matters relevant to the purpose of the Act, as specified
under Part II of the HSNO Act. Unless otherwise stated, references to section numbers
in this decision refer to sections of the HSNO Act.
2.2
Consideration of the application followed the relevant provisions of the Hazardous
Substances and New Organisms (Methodology) Order 1998 (the Methodology). Unless
otherwise stated, references to clauses in this decision refer to clauses of the
Methodology.
3 Application Process
3.1
The application was formally received on 11 March 2002 and verified on 18 March
2002.
3.2
In accordance with sections 53(1) and 53A of the Act, public notification was made on
20 March 2002. Submissions closed on 6 May 2002.
3.3
The following written submission was received:

Carter Holt Harvey raised issues with regard to environmental and/or health risks
associated with the handling, use, and disposal of PROTIM ANTIMOULD. In
addition, they requested verification of the claim that PROTIM ANTIMOULD offers
a timber treatment alternative with a lower hazardous profile.
3.4
Various government departments (including MAF, OSH and MOH), Crown Entities
and interested parties, which in the opinion of the Authority would be likely to have an
interest in the application, were notified of the receipt of the application (in accordance
with section 53(4) of the HSNO Act and clauses 2(e) and 5 of the Methodology), and
provided with an opportunity to comment or make a public submission on the
application.
3.5
The following three written comments were received:

West Coast Regional Council raised concerns regarding the adequacy of the
Department of Labour Approved Code of Practice for the Safe Use of Timber
Preservatives and anti-sapstain chemicals (June 1993).

Fish & Game New Zealand advised that they wanted it to be stated that PROTIM
ANTIMOULD is not to be used in such a way that it may contact water.

The Ministry of Health wished to draw attention to the fact that iodocarb might be
expected to have attracted scheduling as a toxic substance.
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3.6
No external experts were used in the considering of this application (clause 17).
3.7
The statutory time frames for the consideration of the application were subject to three
waivers – to reduce the 10-day circulation of the E&R Report, to delay the date of the
consideration, and delay the notification of the decision. All three times were waived
with the agreement of the applicant (Section 59(4)).
3.8
Members of the Hazardous Substances Standing Committee of the Authority: Tony
Haggerty (Chairperson), Prof. George Clark, and Jill White considered the application
(section 19(2)(b)).
3.9
The information available to the Committee comprised:
 The application plus confidential information on manufacturing details,
formulation and data of the components.
 References – IUCLID Datasheet for component A.
-– IARC Database: iodocarb and component A.
 Information from resources on the World Wide Web.
 The ERMA NZ Evaluation and Review Report.
 Submission from Carter Holt Harvey (see 3.3 above)
 Comments from agencies (see 3.5 above).
4
Consideration
Purpose of the Application
4.1
The purpose of the application is for the manufacture of PROTIM ANTIMOULD, a
light organic solvent preservative (LOSP) for the protection of timber and wood
products from fungal degrade or disfigurement. The treated wood is intended for use as
framing timber.
4.2
PROTIM ANTIMOULD contains a fungicide (iodocarb 330 g/L) dissolved in a
specific hydrocarbon solvent.
4.3
Following transport to purpose-built wood treatment plants, PROTIM ANTIMOULD is
to be diluted with white spirits (final iodocarb concentration is expected to be 0.020.5% w/v) before being used in a sealed treatment vessel.
4.4
PROTIM ANTIMOULD will be registered as a pesticide by the ACVM Group of New
Zealand Food Safety Authority. In order to be registered it has to be approved by the
Authority (ref. section 21(5) of the Agricultural Compounds and Veterinary Medicines
Act 1997).
4.5
The Committee notes that fifteen other substances containing iodocarb have been
registered under the Pesticides Act 1979 and have been used for various timber
treatments (13) and as pruning pastes in horticulture (2) in New Zealand since 1992
(the year of the first registration).
Environmental Risk Management Authority Decision: Application HSR02009
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4.6
4.7
Sequence of the Consideration and the Approach Adopted
In accordance with clause 24 of the Methodology, the approach adopted by the
Committee was to:
 Establish the hazard classifications for the substance and derive the default
controls.
 Identify potentially non-negligible risks, costs, and benefits.
 Assess potentially non-negligible risks, costs, and benefits in the context of the
default controls and possible variations to those controls. Risks were assessed in
accordance with clause 12, and costs and benefits in accordance with clause 13 of
the Methodology.
 Consider and determine variations to the default controls arising from the
circumstances provided for in sections 77 (3), (4) and (5) of the Act and then
consolidate controls.
 Evaluate overall risks, costs, and benefits to reach a decision. The combined
impact of risks, costs and benefits was evaluated in accordance with clause 34, and
the cost-effectiveness of the application of controls was considered in accordance
with Clause 35.
The approach used and set out above meets the requirements of clause 24 of the
methodology i.e. the need to use recognised risk identification, assessment, evaluation,
and management techniques.
Hazard Classification of the Substance
4.8
In determining the appropriate hazard classifications for the substance, the Committee
considered both the classifications proposed by the applicant, and variations to those
classifications proposed in the E&R Report. The Committee agreed with the analysis
in the E&R Report, (ref: section 6.2 of the E&R Report) and PROTIM ANTIMOULD
is therefore classified as follows:
6.1 D
6.4 A
6.5 B
6.9 B
9.1 A
9.3 C
Acutely toxic (oral)
Eye Irritant
Contact sensitiser
Harmful to human target organs or
systems
Very ecotoxic in the aquatic
environment
Harmful to terrestrial vertebrates
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Default Controls
4.9
The Committee considers that the ERMA New Zealand Project Team correctly
assigned default controls associated with above classifications in the E&R Report (at
section 6.3), and they are not reproduced here. They were used as the reference for
subsequent consideration of the application.
Identification of the Potentially Non-negligible Risks, Costs, and Benefits of the
Substance
4.10 In the following sections, the Committee identifies potentially non-negligible risks,
costs and benefits with reference to clauses 9 and 11 of the Methodology, which
incorporate relevant material from sections 2, 5, 6, and 8 of the Act.
Identification of risks
4.11 The Committee reviewed the identification of risks made by the applicant and
additional risks identified in the E&R Report. From all these risks, the Committee
identified those summarized below as those which were potentially non-negligible and
thus warranted more detailed assessment.
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Human Health and the Environment
Lifecycle
Activity
Associated source of risk
Manufacture
Handling incident leads to
spill/accidental discharge
Potential risks arising
Human Health
Risk to workers and
general public from
ingestion, eye or skin
contact. [Discussed in
section 6.4.3.1.1 of the
E&R Report]
Environment
Risk to aquatic organisms
and terrestrial vertebrates.
[Discussed in section
6.4.3.2.1 of the E&R
Report]
Workers come into
contact with substance
during mixing
Risk to workers from
ingestion, eye or skin
contact. [Discussed in
section 6.4.3.1.1 of the
E&R Report]
Transport of
substance
Vehicle accident between
manufacturing facility and
timber-treatment site
leads to spill
Risk to workers and
general public from
ingestion, eye or skin
contact. [Discussed in
section 6.4.3.1.2 of the
E&R Report]
Risk to aquatic organisms
and terrestrial vertebrates.
[Discussed in section
6.4.3.2.2 of the E&R
Report]
Storage of
substance
Damage to packaging
leads to spill
Risk to workers from
ingestion, eye or skin
contact. [Discussed in
section 6.4.3.1.3 of the
E&R Report]
Risk to aquatic organisms
and terrestrial vertebrates.
[Discussed in section
6.4.3.2.3 of the E&R
Report]
Storage of
diluted
substance
Storage tank failure leads
to spill.
Risk to aquatic organisms
and terrestrial vertebrates.
[Discussed in section
6.4.3.2.3 of the E&R
Report]
Use of
substance
Handling incident leads to
spill/accidental discharge
Risk to workers and
general public from
ingestion, eye or skin
contact. [Discussed in
section 6.4.3.1.3 of the
E&R Report]
Risk to workers from
ingestion, eye or skin
contact. [Discussed in
section 6.4.3.1.4 of the
E&R Report]
Use of treated
timber
Workers come into
contact with substance
during/after dilution with
white spirits
Builders handling/sawing
inadequately dried timber
Risk to builders/general
public from inhalation or
skin contact. [Discussed in
section 6.4.3.1.4 of the
E&R Report]
Exposure to inadequately
dried timber in
buildings/homes
Risk to general public
from inhalation or skin
contact. [Discussed in
section 6.4.3.1.4 of the
E&R Report]
Risk to aquatic organisms
and terrestrial vertebrates.
[Discussed in section
6.4.3.2.4 of the E&R
Report]
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Disposal of
substance
Inappropriate disposal
(e.g. into drains or
waterways).
Disposal of
treated timber
Treated timber is burnt in
domestic fireplace or
landfill incinerator
Risk to aquatic organisms
and terrestrial vertebrates.
[Discussed in section
6.4.3.2.5 of the E&R
Report]
Risk to human health due
to inhalation of vapours.
[Discussed in section
6.4.3.1.5 of the E&R
Report]
Burning of treated
timber/leachate
Other
Sabotage leading to
release or spill
Natural hazard leading to
release or spill
Risk to workers and
general public from
ingestion, eye or skin
contact. [Discussed in
Table 4 of the E&R
Report]
Adverse effects on the
environment. [Discussed
in section 6.4.3.2.5 of the
E&R Report]
Risk to aquatic organisms
and terrestrial vertebrates.
[Discussed in Table 4 of
the E&R Report]
Māori Issues
4.12 Potential risks to Māori culture from possible contamination of waterways arising
from the release of the substance into the environment. Such contamination may
impact on traditional food resources and water supplies.
Social and community
4.13 Potential social and community risks arise from possible traffic disruptions in the
event of a transporter having a road accident and spills of the substance that disrupt
a commercial or recreational fishery.
Economic Risks
4.14 No further potentially adverse economic risks were identified by the Committee.
Identification of Costs
4.15 Costs are defined in the Methodology as the value of an adverse effect expressed in
monetary or non-monetary terms. In relation to the costs of effects identified in the
above table (including health treatment costs associated with any skin or eye
contact with the substance), the Committee considered that the following economic
costs were potentially non-negligible:
 Costs of clean-up after spillage;
 Disposal costs.
4.16 The Committee noted the recent discussion and concerns about the rotting of
untreated timber in new construction in the Auckland region. No data was available
to the ERMA New Zealand review team to consider a cost and benefit study as
other factors such as design, construction methods, and construction quality were
also involved.
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Identification of Benefits
4.17 The benefits identified in the application and the E&R report arise if, and to the
extent that, the substance is used as an alternative to other products. Timbers
susceptible to rot can be treated and used in an environment exposed to more
adverse conditions. Such timbers can be expected to have longer life and to
maintain their strength for the life of the structure. They are part of providing
security and shelter in timber constructed dwellings and buildings.
Assessment of the Potentially Non- negligible Risks and Costs of the Substance
4.18 The risks and costs assessed were those identified above as potentially nonnegligible. Risks were assessed in terms of the requirements of clause 12 of the
Methodology, including consequences and probabilities, the impact of uncertainty
and the impact of risk management. Costs were considered in terms of clause 13 of
the methodology. The qualitative descriptors of risk in this decision are as defined
in Appendix 5 of the E&R Report.
4.19 The evidence available was largely scientific in nature and was considered in terms
of clause 25(1) of the Methodology. This evidence comprised that provided by the
applicant and additional evidence as set out in the E&R Report
Sources of Risk
4.20 In assessing risk the Committee gave particular consideration to risks arising from
the significant hazards of the substances i.e. toxicity and ecotoxicity, and examined
the extent to which exposure to hazard would be mitigated by controls. (Clauses
11 and 12 of the Methodology refer).
4.21 The substance is an acute oral toxicant, eye irritant and skin sensitiser. It is also
harmful to human target organs and systems (clause 12(a)).
4.22 The substance is also very ecotoxic in the aquatic environment and harmful to
terrestrial vertebrates (clause 12(a)).
Assessment of Risks to Human Health from Accident Spillage
4.23 There is the potential for workers (and possibly the general public) to be exposed
to the substance in the event of a spillage at a storage facility or when the substance
is in transit. Though accidents involving spillages are not at all uncommon, the
Committee notes that it is very unlikely that an accident or other event will lead to
the exposure of people to this particular substance, particularly having regard to the
packaging, labelling and other controls for substances having this classification
(clause 12(d)).
4.24 The Committee concluded that the magnitude of the above effects would be minor
as the controls on the substance are such that the effects would be localised and
reversible. (clauses 12 (b) and (d). Accordingly, the Committee considers the risk
to human health from accidental spillage to be insignificant (clause 12 (c)).
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Assessment of Risks to the Environment from Accidental Spillage
4.25 The Committee recognises that, in the event of an accidental spill, there could be
some risk to aquatic life due to the ecotoxic effects of PROTIM ANTIMOULD.
However these effects are considered to be localised and to be short term in effect.
As it is very unlikely that a spillage will occur, and the magnitude of any effects are
considered to be minimal, the Committee is satisfied that the risk to the
environment from accidental spillage to be insignificant (clause 12 (c)).
Assessment of Risks to Human Health from Manufacture of the Substance
4.26 PROTIM ANTIMOULD will be manufactured by dissolving iodocarb in
Component A. Stainless steel vessels will be used within a bunded and wellventilated area. The applicant proposes that batches will not exceed 1000 litre
quantities. A handling incident leading to spillage or release is considered unlikely.
In the event of spillage or release, exposure to the substance could result in acute
toxicity (via inhalation), eye irritation and skin sensitisation. These effects are
considered to be minimal.
4.27 Repeated dermal or oral exposure, however, could result in liver/kidney toxicity
and changes in haematological and clinical chemistry parameters. Chronic
exposure of this kind is considered to be unlikely; however the effects could be
moderate.
4.28 Accordingly, the Committee considers the risk to human health from the
manufacture of PROTIM ANTIMOULD are insignificant-low (clause 12 (c)).
Assessment of Risks to the Environment from Manufacture of the Substance
4.29 A handling incident leading to significant spillage or release during manufacture is
considered unlikely. In the event of spillage or release, exposure of the
environment to the substance could result in minor adverse effects to aquatic
organisms and minimal adverse effects to terrestrial vertebrates. While there is
some uncertainty with respect to soil ecotoxicity, the substance is not thought to be
highly persistent or bioaccumulative. There is also uncertainty regarding terrestrial
invertebrate toxicity, however, it is considered unlikely that the substance would
come into contact with such insects.
4.30 The HSNO controls include requirements for emergency management (including
secondary containment, e.g., bunding). An EELWATER will also be set for the
hazardous components (iodocarb and Component A) of PROTIM ANTIMOULD.
4.31 Accordingly, the Committee considers the risk to the environment from the
manufacture of PROTIM ANTIMOULD are insignificant (clause 12 (c)).
Assessment of Risks to Human Health from Use of the Substance
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4.32 As indicated above, the potential health effects relate primarily to eye irritancy and
to possible target organ toxicity if there is prolonged repeated exposure to the
substance.
4.33 During the course of their work, it is likely that operators may be exposed to raw
materials and to undiluted PROTIM ANTIMOULD. The potential for eye
irritation, skin sensitisation, and inhalation of solvent vapour is of concern,
however, these effects are considered to be minimal. Repeated dermal or oral
exposure could result in liver/kidney toxicity and changes in hematological and
clinical chemistry parameters. Such effects are considered to be moderate and
precautions would need to be taken to prevent personal contamination.
4.34 The Committee accepted the analysis in the E&R Report which demonstrated that
the dermal exposure of operators is not likely to lead to adverse effects from target
organ toxicity, and concluded that this risk was both very unlikely and minimal in
effect, and was hence negligible (clause 12(b)&(c)). The Committee reached this
conclusion having regard to the controls applying to the substance. Similarly, the
risk to other persons from dermal exposure leading to target organ toxicity (within
the application area, or beyond it) was considered by the Committee to be
negligible.
4.35 The residual active ingredient in the treated timber is very low and will be bound in
the wood. In addition, due to the evaporation of white spirits, the treated timber
will not be flammable after drying. In light of this, the magnitude of any toxic
effect to end-use workers (e.g. builders) is considered to be minimal. The treated
wood is intended for use as interior framing timber in buildings/domestic homes. It
is possible that the treated wood may contain a small amount of the solvent;
however, neither the applicant nor ERMA New Zealand is aware of any public
health issues that have arisen as a result of outgassing. If controls and handling
guidelines were not complied with (i.e., the timber drying period was not adhered
to), there would be the potential for the public to be exposed to outgassing solvent.
Such an event, however, is considered unlikely to occur and, in view of the small
amount of substance involved, the magnitude of effect is considered to be minimal.
4.36 Accordingly, the Committee considers the residual risks, with the controls in place,
to be insignificant.
Assessment of Risks to the Environment from Use of the Substance
4.37 PROTIM ANTIMOULD would be diluted with white spirits before use in a timber
preservative system. An incident leading to spillage or release of the
diluted/undiluted PROTIM ANTIMOULD during the dilution procedure is
considered unlikely. The release of concentrated PROTIM ANTIMOULD outside
of the timber treatment plant could result in minor adverse effects to aquatic
organisms and minimal adverse effects to terrestrial vertebrates. The release of the
diluted PROTIM ANTIMOULD outside of the timber treatment plant could result
in minor adverse effects to aquatic organisms (the hazard classification is lowered
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upon dilution; however, the volume of substance is increased) but is no longer
considered a hazard to terrestrial vertebrates.
4.38 The HSNO controls include requirements for equipment used to handle the
substance, along with Emergency Management requirements.
4.39 ERMA New Zealand considers the residual risks, with the controls in place, to be
insignificant.
4.40 The Committee considered Fish & Game submission of the possible use of treated
timber in contact with water and the substance leaching out into the aquatic
environment. It was concluded that the concentration of the active ingredient in the
timber was very small and if there was a risk of significant leaching there would be
significant new grounds for reassessment.
Assessment of Risks to Human Health/Environment from Disposal of the
Substance
4.41 The risks to either human health or to the environment from the disposal of either
the substance, the used containers, or surplus diluted substance relate to the
potential effects discussed above (clause 12(a)). The disposal controls, together
with environmental exposure limits in the controls provide adequate means of
managing the risks and, with these controls in place, it is unlikely that effects
would occur. If effects were to occur, they would be localised and reversible, and
hence minor for the reasons discussed earlier (clause 12(b)). Hence the risk is low
(clause 12c).
4.42 In the event of burning treated timber, decomposition products of PROTIM
ANTIMOULD may include carbon dioxide, carbon monoxide, nitrogen oxides and
iodine vapour. Given the low residual amount of PROTIM ANTIMOULD in the
treated timber, the levels of these by-products would also be low. In addition, no
hazardous residues would be left in the ash. The burning of treated timber is
considered likely; however, adverse effects on the environment from the
decomposition products are considered to be minimal. The residual substance in
the treated timber is very low and is bound to the wood. As such, it is not expected
to leach out into the environment at levels that would cause adverse effects.
Although there is some uncertainty with regard to soil ecotoxicity, the substance is
not thought to be highly persistent or bioaccumulative.
4.43 The HSNO controls include requirements for the disposal of toxic and ecotoxic
substances. In addition, the implementation of an EEL establishes the maximum
concentration of an ecotoxic substance legally allowable in a particular non-target
environmental medium. Incineration of treated timber at a landfill is very unlikely
as the majority of local Councils oppose such practice. In addition, the OSH Code
of Practice stipulates that LOSP-treated timber should not be burnt. RMA and
District Plan controls may also apply.
4.44 The Committee considers the residual risks, with the controls in place, to be
insignificant.
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Assessment of the risks to Māori
4.45 In line with the advice from ERMA New Zealand’s Senior Advisor (Māori Issues),
(see Appendix 3 of E&R Report), the Committee is satisfied that the application
poses no risk to the relationship between Māori culture and their traditions with
their ancestral lands, water, sites, waahi tapu, valued flora and fauna and other
taonga. This is on the condition, that the product PROTIM ANTIMOULD is used
in accordance with the manufactures guidelines for “Light organic solvent
preservatives”. In addition, employers of the timber treatment plants must comply
with the Occupational Safety and Health Service code of practice “The safe use of
timber preservatives and antisapstain chemicals”.
Assessment of the Social and Community risks
4.46 The Committee considers it unlikely that the substance would have a negative
impact on social and community. The magnitude of effects is considered minimal.
Accordingly, the Committee considers the social and community risks to be
insignificant.
Assessment of the Potentially Non-negligible Costs and Benefits
4.47 The Methodology and the Act both call for consideration of monetary and nonmonetary costs (clause 13 and section 9). In addition to the costs arising from the
above risks (primarily non-monetary), the following economic costs are considered
below:
 cost of clean up and disposal after spillage;
 cost of disposal of residual substance.
4.48 The Committee agrees with the E&R report that the identified economic costs
accrue primarily to the user (monetary 13(a)) although they are likely to be passed
on to the wider community through increased prices. Costs to the community more
directly could be incurred if a spillage requires a response from emergency or other
community agencies.
4.49 The benefits of the substance identified in paragraphs 4.17 above are both
monetary and non-monetary (clause 13(a)). The magnitude of the benefits depends
largely on the degree to which such products will be used instead of the more
hazardous alternatives.
4.50 While the Committee was unable to quantify the extent of this substitution, and
hence the magnitude of the benefits (clause 13(b)) it is satisfied that such
substitution and the associated benefits can be expected to occur.
4.51 The applicant stands to benefit economically from product sales. Wider benefits
derived from more widespread use of less hazardous products will accrue to end
users and their families and to the wider community as a result of the reduction in
risks to health and to the environment (clause 13(c)).
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Establishment of the Approach to Risk in the Light of Risk Characteristics
4.52 Clause 33 of the Methodology requires the Authority to have regard for the extent
to which a specified set of risk characteristics exist when considering applications.
The intention of this provision is to provide a route for determining how cautious
or risk averse the Authority should be in weighing up risks and costs against
benefits.





Toxic exposure to the risks of PROTIM ANTIMOULD is involuntary
(clause 33(a)) as it was considered that the release of the substance was most
likely to occur in an accident in handling or transporting the substance. The
adverse effects would occur if the person exposed did not wear the
appropriate personal protective equipment.
The ecotoxic effects of the risk will persist only over a short time until the
substance is diluted.(i.e. short term localised acute adverse effects) (clause
33(b)).
The risk due to an accident or spill would be localised or most likely subject
to controllable spread (i.e. secondary containment) and is unlikely to extend
its effects beyond the immediate location of incident (clause 33(c)).
The potential adverse effects are reversible (clause 33(d)).
Society could be inconvenienced (traffic delay, route change) in the event of
a transport accident involving the substance, but the expectation is that this
inconvenience would be short term. The long term potential adverse effects
are expected to be insignificant (clause 33(e)).
4.53 In the light of these risk characteristics and with reference to clause 33, the
Committee did not adopt an especially risk-adverse approach when considering the
application.
Overall Evaluation of Risks, Costs and Benefits
4.54 The overall evaluation of risks, costs and benefits set out below was carried out
having regard to Clauses 22 and 34 of the Methodology and in accordance with the
tests in clause 26 of the Methodology and section 45 of the Act. Risks were
evaluated taking account of all proposed controls including default controls plus
proposed variations to the controls.
4.55 The risks with controls were determined to be negligible and therefore Section 26
of the methodology was applied by the Committee.
4.56 In accordance with clause 26, where a substance poses negligible risks to the
environment and human health and safety, the Authority may approve a substance
if it is evident that the benefits associated with that substance outweigh the costs.
4.57 The main benefits of PROTIM ANTIMOULD are considered to be its protection
of timber from fungal rot. The major cost would be the cost of the substance and
treatment of that timber versus the use of alternate treatments or no treatment. The
net benefit of introducing PROTIM ANTIMOULD is that it may enhance choice
and invoke competition and lead to lower costs for homeowners. There is a range
Environmental Risk Management Authority Decision: Application (HSR02008)
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of approved wood treatment substances already available in NZ so expected
benefits of adding an additional product to the market maybe very small, except for
the applicant.
4.58 The major costs are those associated with the results of an accident, or the failure
to comply with the controls.
4.59 Benefits to be gained are for timber treatment operations to have an alternative
formulation and or competitive economics of another supplier of the active
ingredient in the market place.
4.60 It is realistic to recognise that the public of New Zealand can benefit from having
available treated timber to provide long-term security and shelter for dwellings and
other timber constructions.
4.61 No data have been provided to allow a quantitative estimation of costs and
benefits. This assessment has been qualitative, but based on the data provided.
4.62 In light of the above, the Committee is satisfied that the benefits of the substance
outweigh the costs.
Variation of Controls
4.63 Under section 77(3), (4) and (5) of the Act the default controls determined by the
hazard classifications of the substance may be varied. Such variations, together
with the setting of exposure limits as provided for in controls are discussed below:
4.64 The Committee accepted the rationale in the E&R report (section 7.1) that an
Acceptable Daily Exposure (ADE) and a Tolerable Exposure Limit (TEL) for the
substances need not be set as it was highly unlikely that members of the general
public would be exposed to either substance, and thus the pre-requisite for setting
these controls is not met.
4.65 Regulation 28 of the Hazardous Substances (Classes 6, 8 and 9 Controls)
Regulations 2001 (control code T8) relates to the use of any class 6.1 substance
that is applied outdoors for vertebrate pest control. This substance is not intended
to be used for vertebrate pest control, and it is highly unlikely that it ever would be.
However, given the limited statutory discretion to delete controls, it remains as a
control on the substances. The Committee expects that it will lie dormant, and not
affect the normal use of the substance.
4.66 The Ecotoxicity classification of 9.1A and 9.3C invokes the default control for
setting an Environmental Exposure Limit (EEL). The Committee concluded that
the default EELwater for PROTIM ANTIMOULD at 0.0001 mg/l should be set.
4.67 No EEL for soil was set as the substance does not trigger the soil ecotoxicity
threshold. The Committee also decided not to set an EEL value for sediment,
surface deposition or secondary poisoning as PROTIM ANTIMOULD will be used
Environmental Risk Management Authority Decision: Application (HSR02008)
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in a contained environment and as it has a rapid degradation profile. Accordingly,
these controls do not apply to the substance.
4.68 The acute oral toxicity of PROTIM ANTIMOULD results in it being classified as a
6.1D acute toxicant. WES values are expressed as concentrations of a substance in
air and are intended for inhalation exposure scenarios. The Committee considers
such a value is not relevant to a substance that is acutely toxic only via ingestion.
On this basis, a WES value has not been set for any of the components of PROTIM
ANTIMOULD.
4.69 As the proposed use of PROTIM ANTIMOULD is not as a pesticide spray but in a
pressure vessel the restrictions on use within an application area (control code E2)
do not apply.
4.70 With respect to the approved handler (E7 and AH1) and tracking controls (TR1),
the Committee notes that both of these controls were triggered by the aquatic
ecotoxicity of PROTIM ANTIMOULD. The beneficial use of the substance is to
prevent fungal degradation of timber. The active ingredient iodocarb has had a
present and past history of use for this purpose in New Zealand with a number of
products registered prior to the commencement of HSNO. During manufacture,
transportation and use of PROTIM ANTIMOULD it is most unlikely the substance
will be significantly exposed to the aquatic environment. The addition of approved
handler and tracking controls will be unlikely to significantly reduce the adverse
effects of the PROTIM ANTIMOULD to the aquatic environment. Accordingly,
these controls are deleted under section 74(4)(b) to retain the benefits of this
substance for wood treatment without significantly increasing any adverse aquatic
ecotoxicity effects to the environment.
4.71 The Committee agreed with the proposals in the E&R report that the following
controls should be combined as provided for by section 77(5) of the Act. The
Committee's view is that the combined controls resulting from these deletions will
control all of the adverse effects identified for the substance.



T7 & E8 - Regulation 10, Hazardous Substances (Classes 6, 8 and 9 Controls)
Regulations 2001. For PROTIM ANTIMOULD, the maximum quantity per
package that can be carried on public transport is 0.1 L
I21- General documentation requirements [Regs 37,38]. This control applies to
quantities of 1L and greater.
P13, P15 - Packaging requirements for toxic/ecotoxic substances [Reg 21].
4.72 The Committee notes that Regulations 8(e) and (f) of the Emergency Management
Regulations refer to these regulations applying to toxic and ecotoxic substances
and makes reference to Schedule 1 of the Emergency Management Regulations.
However, there is no reference in Schedule 1 to toxic or ecotoxic substances. As
indicated in the E&R report this omission is due to an error in printing of the
Regulations and Schedule 1 was intended to apply to toxic and ecotoxic substances
in categories 6.5 B in any amount, 6.4A in quantities above 0.1 litres, and to
ecotoxic substances in categories 9.1A in quantities above 0.1 litres and category
9.3C in quantities from 1 litre
Environmental Risk Management Authority Decision: Application (HSR02008)
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4.73 The relevant control has thus not been set. However, the Committee strongly
recommends that the applicant provide the appropriate emergency management
information on the label or in some other accessible form for any amount of
PROTIM ANTIMOULD.
4.74 Prior to the Committee’s consideration, the E&R Report that proposed the above
variations to controls was provided to the applicant for comment. The provisions
of clause 35(b) are effectively met. The controls are thus varied accordingly.
Environmental User Charges
4.75 In the current absence of comprehensive criteria for undertaking such a
consideration, no consideration has been given to whether or not environmental
user charges should be applied to the substance which is the subject of this
approval.
Environmental Risk Management Authority Decision: Application (HSR02008)
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5 Decision
5.1
Having considered all the possible effects of the hazardous substance in accordance
with section 29 of the Act, pursuant to clause 26 of the Methodology, based on
consideration and analysis of the information provided, and taking into account the
application of default controls specified in this decision, the view of the Committee
is that the adverse effects associated with the importation or manufacture of
PROTIM ANTIMOULD are outweighed by the positive effects associated with
the importation or manufacture of the substance.
5.2
In accordance with clause 36(2)(b) of the Methodology, the Committee records
that, in reaching this conclusion, it has applied the weighing up tests in section 29
of the Act and clause 26 of the Methodology.
5.3
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 12 - evaluation of assessment of risks;
 Clause 13 - evaluation of assessment of costs and benefits;
 Clause 21 - the decision accords with the requirements of the Act and
regulations;
 Clause 22 - the evaluation of risks, costs and benefits - relevant
considerations;
 Clause 24 - the use of recognised risk identification, assessment, evaluation
and management techniques;
 Clause 25 - the evaluation of risks;
 Clause 26 - risks are negligible and costs are outweighed by benefits;
 Clause 33 - risk characteristics;
 Clause 34 - the aggregation and comparison of risks, costs and benefits; and
 Clause 35 - the costs and benefits of varying the default controls.
5.4
The application for the manufacture of the hazardous substance PROTIM
ANTIMOULD is thus approved, with controls, as detailed in Appendix 1.
Mr. Tony Haggerty
Chair Hazardous Substances Committee
Date 16th August 2002
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Appendix: Controls
The controls imposed on PROTIM ANTIMOULD are as follows. The regulations cited should be referred to for definitions and exemptions.
The ERMA New Zealand publication “User Guide to HSNO Control Regulations” provides useful guidance on the controls.
Control
Code1
Regulation2
Explanation3
1
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 ERMA New Zealand and is also contained in the ERMA New Zealand User Guide to
the Controls 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.
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Hazardous Substances (Classes 6, 8 and 9 Controls) Regulations 2001 – Toxic Property Controls
T2
Regulations 29,
30
T4, E6
Regulation 7
T5
Regulation 8
T7, E8
Regulation 10
Controlling exposure in places of work
A workplace exposure standard (WES) is designed to protect persons in the workplace from the adverse effects of toxic substances. A WES is an
airborne concentration of a substance (expressed as mg substance/m3 of air or ppm in air), which must not be exceeded in a workplace.
Requirements for equipment used to handle substances
Any equipment used to handle PROTIM ANTIMOULD 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.
Requirements for protective clothing and equipment
Protective clothing/equipment must be employed when PROTIM ANTIMOULD is being handled. The clothing/equipment must be designed,
constructed and operated to ensure that the person does not come into contact with the substance.
People using protective clothing/equipment must have information specifying how the clothing or equipment may be used, and the requirements
for maintaining the clothing/equipment.
Restrictions on the carriage of hazardous substances on passenger service vehicles
In order to limit the potential for public exposure to PROTIM ANTIMOULD, the following requirements are prescribed for the carriage on public
transport vehicles:

T8
Regulation 28
carriage is restricted to a maximum of 0.1 L per package.
Controls on Vertebrate Poisons
These controls limit the likelihood of a substance laid or applied for vertebrate pest control coming into contact with members of the general public
and non-target species, in places of public access.
A person in charge of PROTIM ANTIMOULD that is laid or applied outdoors for the purpose of controlling vertebrate poisons must

erect warning signs at every normal entry point to the place at least 3 days prior to the bait being applied or laid, and;

ensure exposure to non-target vertebrate species is limited (see also ecotoxic control E4, Regulations 50 and 51).
Hazardous Substances (Classes 6, 8 and 9 Controls) Regulations 2001 – Ecotoxic Property Controls
E1
Regulations 32–
45
Limiting exposure to ecotoxic substances
This control relates to the setting of environmental exposure limits (EELs). An EEL establishes the maximum concentration of an ecotoxic
substance legally allowable in a particular (non target) environmental medium (e.g. soil or sediment or water),

The EEL water for PROTIM ANTIMOULD is 0.0001 mg/L
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E5
Regulations 5, 6
Requirements for keeping records of use
A person using a PROTIM ANTIMOULD must keep a written record of that use if 3kg or more of the substance is applied or discharged within 24
hours in an area where the substance may enter air or water. The record must be kept for a minimum of 3 years and must be made available to an
enforcement officer on request.
Hazardous Substances (Identification) Regulations 2001
I1
Regulations 6,
7, 32-35, 36 (1)(7)
General identification requirements
These controls relate to the duties of suppliers and persons in charge of PROTIM ANTIMOULD with respect to identification (essentially
labelling) (regs 6 and 7), accessibility of the required information (regs 32 and 33) and presentation of the required information with respect to
comprehensibility, clarity and durability (regs 34, 35, 36(1)-(7)).
Regulation 6 – Identification duties of suppliers
Suppliers of any hazardous substance must ensure it is labelled as required by regulations 9 and 14 (priority identifiers for ecotoxic and toxic
substances), and regulations 18, 20 and 25 (secondary identifiers for ecotoxic and toxic substances) of the Identification regulations (see below)
before supplying it to any other person.
Regulation 7 – Identification duties of persons in charge
Persons in charge of hazardous substances must ensure the substances are identified with all relevant priority identifier information (as required by
regs 8 - 17) and secondary identifier information (as required by regs 18 - 30) before supplying it to any other person. This includes ensuring that
the priority identifier information is available to any person handling the substance within 2 seconds (reg 32), and the secondary identifier
information available within 10 seconds (reg 33).
Regulations 32 and 33 – Accessibility of information
All priority identifier Information (as required by regs 8 - 17) must be available within 2 seconds, e.g. on the label.
All secondary identifier Information (as required by regs 18 - 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 and oral) must be readily understandable and in English
 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
 all required information must continue to be met throughout the lifetime of the (packaged) substance under the normal conditions of storage,
handling and use.
I3
Regulation 9
Priority identifiers for ecotoxic substances
This requirement specifies that PROTIM ANTIMOULD must be prominently identified as being ecotoxic.
This information must be available to any person handling the substance within two seconds (reg 32) and can be provided by way of signal
headings or commonly understood pictograms on the label.
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I8
Regulation 14
Priority identifiers for toxic substances
This requirement specifies that PROTIM ANTIMOULD must be prominently identified as being toxic. In addition, information must be provided
on the general degree and type of hazard of the substance (e.g. highly poisonous), and the need to restrict access to children.
This information must be available to any person handling the substance within two seconds (reg 32) and can be provided by way of signal
headings or commonly understood pictograms on the label.
I9
Regulation 18
Secondary identifiers for all hazardous substances
This control relates to detail required for hazardous substances on the product label. This information must be accessible within 10 seconds (reg 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, a description of each likely change and the date by which it is likely to occur.
I11
Regulation 20
Secondary identifiers for ecotoxic substances
This control relates to the additional label detail required PROTIM ANTIMOULD. This information must be accessible within 10 seconds (reg 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 (e.g. very toxic to aquatic life)
These requirements could be addressed by statements on the label with respect to its action against both target and non-target organisms and the
method of application used to avoid exposure to non-target organisms. A statement should be included warning against incorrect disposal in
sensitive environments.
I16
Regulation 25
I17
Regulation 26
Secondary identifiers for toxic substances
This control relates to the additional label detail required for PROTIM ANTIMOULD. This information must be accessible within 10 seconds (reg
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
 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
 the name and concentration of any ingredient that would independently of any other ingredient, cause the substance to be classified as either
a class 61 D, 6.5 or 6.9, namely iodocarb
Use of Generic Names
This control provides the option of using a generic name to identify iodocarb
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I18
Regulation 27
Requirements for using concentration ranges
This control provides the option of providing concentration ranges for those ingredients whose concentrations are required to be stated on the
product label, namely iodocarb.
I19
Regulations 29–
31
Alternative information in certain cases
Regulation 29 relates to alternative ways of presenting the priority and secondary identifier information required by regulations 8–25, when
PROTIM ANTIMOULD is contained in fixed bulk containers or bulk transport containers. The information requirements for fixed bulk containers
are specified in reg 29 (1). The information requirements for bulk transport containers are specified in reg 29 (2), which essentially states that for
HSNO compliance, the substance should be 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 relates to situations when hazardous substances are in multiple packaging and the outer packaging obscures some or all of the
required substance information. 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 label assigned by the UN Model Regulations
Regulation 31 relates to alternative information requirements for hazardous substances that are imported into New Zealand in a closed package or
in a freight container and will be transported to their 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.
I20
Regulation
36(8)
Durability of information for class 6.1 substances
Any packaging in direct contact with PROTIM ANTIMOULD must be permanently identified as having contained a toxic substance, unless the
substance as packaged is restricted to a place of work.
I21
Regulations 37–
39, 47–50
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
Material Safety Data Sheets) (regs 37, 38 and 50); the general content requirements of the documentation (reg 39 and 47); the accessibility and
presentation of the required documentation with respect to comprehensibility and clarity (reg 48).
For PROTIM ANTIMOULD these controls are triggered when the substance is held in the workplace in quantities of 1 L or greater.
Regulation 37 – Documentation duties of suppliers
A supplier must provide documentation containing all relevant information required by regulations 39 – 46 when:
 selling or supplying a quantity 1 L or more of PROTIM ANTIMOULD;
 if PROTIM ANTIMOULD is to be used in a place of work and the supplier has not previously provided the documentation to that person.
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Regulation 38 – Documentation duties of persons in charge of places of work
The person in charge of any place of work where PROTIM ANTIMOULD is present in quantities above 0.5 kg must ensure that every person
handling the substance has access to the documentation containing all relevant information required by regulations 39 – 46.
Regulation 39 – General content requirements for documentation
The documentation provided with PROTIM ANTIMOULD 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 substance’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
 the name and concentration of any ingredients that would independently of any other ingredient, cause the substance to be classified as either
a class 6.5, or 6.9, namely iodocarb.
Regulation 48 – Location and presentation requirements for documentation
All required documentation must be available to a person handling PROTIM ANTIMOULD 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 0.3m.
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.
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 a
PROTIM ANTIMOULD is present) if asked to do so by that person.
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I23
Reg 41
Specific documentation requirements for ecotoxic substances
The documentation provided with PROTIM ANTIMOULD must include the following information:
 its general degree and type of ecotoxic hazard (e.g. very ecotoxic in the aquatic environment)
 a full description of the circumstances in which it may harm living organisms and the extent of that harm
 a full description of the steps to be taken to prevent harm to living organisms
 a summary of the available acute and chronic (ecotoxic) data used to define the (ecotoxic) subclass or subclasses in which it is classified
 its bio-concentration factor or octanol-water partition coefficient
 its expected soil or water degradation rate
 any EELs set by the Authority
I28
Regulation 46
I29
Regulations 51–
52
Specific documentation requirements for toxic substances
The documentation provided with toxic substances must include the following information:
 its general degree and type of toxic hazard
 a full description of the circumstances in which it may harm human beings
 the kinds of harm it may cause to human beings
 a full description of the steps to be taken to prevent harm to human beings
 if it will be a liquid during its use, 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 (toxicity) 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
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 PROTIM ANTIMOULD is
held in quantities exceeding 100 L.
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 and degree of hazard of the substance

where the signage is immediately adjacent to the hazardous substance storage areas, describe the precautions needed to safely manage the
substance
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I30
Regulation 53
Advertising toxic substances
Any advertisements for PROTIM ANTIMOULD must provide information identifying that it is toxic, specifying the degree of toxicity and the
need to restrict access by children.
Hazardous Substances (Packaging) Regulations 2001
P1
Regulations 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 PROTIM ANTIMOULD with any previous contents of the packaging.
Regulation 5 – Ability to retain contents
Packaging for PROTIM ANTIMOULD 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 are removed from the package and the packaging is then re-closed. The packaging in direct contact with the
substance 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 PROTIM ANTIMOULD must not be marked in accordance with the UN Model Regulations unless the markings comply with
the relevant provisions of that document and the packaging complies with the tests set out in Schedule 3 (Packaging Regulations) and the design of
the packaging has been test certified as complying with those tests.
Regulation 7(1) – Requirements when packing hazardous substance
When packing PROTIM ANTIMOULD, 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 – 21.
Regulation 8 – Compatibility
PROTIM ANTIMOULD must not be packed in packaging that has been previously packed with substances with which it is incompatible.
P3
Regulation 9
Requirement for substances packed in limited quantities
PROTIM ANTIMOULD with a may be packaged in packaging that complies with the tests set out in Schedule 4.
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P13, P15
Regulation 19,
21
Packaging requirements for toxic and ecotoxic substances
The packaging requirements for PROTIM ANTIMOULD are as follows:
 Packages containing more than 1 L (per package) of PROTIM ANTIMOULD must comply with the tests set out in Schedule 3 (UN PGIII).
Packages containing less than 1L (per package) may be packaged in packaging that complies with the tests set out in Schedule 4. (i.e. Reg 9
above)
 PROTIM ANTIMOULD that is offered for sale in a package of less than 2.5 L must be in child resistant packaging. However, if the
substance is for use in a place of work to which children to not have access, this requirement is not mandatory.
PG3
Schedule 3
This schedule provides the test methods for packaging that required to be tested in accordance with this schedule. The tests correlate to the
packaging requirements of UN Packing Group III.
Hazardous Substances (Disposal) Regulations 2001
D4, D5
Regulation 8, 9
Disposal requirements for toxic and ecotoxic substances
PROTIM ANTIMOULD must be disposed of by:
 treating the substance 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 the substance 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 set by the Authority for that substance); or
 exporting the substance from New Zealand as hazardous waste
D6
Regulation 10
Disposal requirements for packages
This control gives the disposal requirements for packages that contained PROTIM ANTIMOULD and are no longer to be used for that purpose.
Such packages must be 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.
D7
Regulations 11,
12
Information requirements
These controls relate to the provision of information concerning disposal (essentially on the label) that must be provided when selling or supplying
1 L or more of PROTIM ANTIMOULD. 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. that would not comply with the Disposal Regulations. Such information must be
accessible to a person handling PROTIM ANTIMOULD within 10 seconds and must comply with the requirements for comprehensibility, clarity
and durability as described in Regs 34-36 of the Identification regulations (code I1).
D8
Regulations 13,
14
Documentation requirements
These controls relate to the provision of documentation concerning disposal (essentially in a MSDS) that must be provided when selling or
supplying more than 1 L of PROTIM ANTIMOULD. 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 PROTIM
ANTIMOULD at a place of work within 10 minutes and must comply with the requirements for comprehensibility and clarity as described in Regs
48 (2), (3) and (4) of the Identification regulations (code I21).
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Hazardous Substances (Emergency Management) Regulations 2001
EM1
Regs 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 PROTIM
ANTIMOULD when present in quantities exceeding the trigger levels as listed in Schedule 1 of the Emergency Management Regulations.
Schedule 1 does not cover PROTIM ANTIMOULD due to a printing error in the regulations. Suppliers and persons in charge of places are
recommended to adopt this control
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 those relating to secondary identifiers
(see Identification Regulations, regulations 6, 7, 32–35, 36(1)-(7)).
Regulation 11 provides for the option of complying with the information requirements of the transport rules when the substance is being
transported.
EM6
Regulation 8(e)
Information requirements for toxic substances
The following information must be provided when PROTIM ANTIMOULD is present in quantities exceeding the trigger levels as listed in
Schedule 1 of the Emergency Management Regulations. Schedule 1 does not cover PROTIM ANTIMOULD due to a printing error in the
regulations. Suppliers and persons in charge of places are recommended to adopt this control
 A description of the usual symptoms of exposure
 A description of the first aid to be given
 A 24-hour emergency service telephone number
EM7
Regulation 8(f)
Information requirements for ecotoxic substances
The following information must be provided with PROTIM ANTIMOULD when present in quantities exceeding the trigger levels as listed in
Schedule 1 of the Emergency Management Regulations. Schedule 1 does not cover PROTIM ANTIMOULD due to a printing error in the
regulations. Suppliers and persons in charge of places are recommended to adopt this control
 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 the substance from entering or affecting those parts of the environment
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EM8
Regulations 12–
16, 18–20
Level 2 emergency management information 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 Material Safety Data Sheets). This documentation must be provided where PROTIM ANTIMOULD is sold or supplied,
or where they are held in a workplace in quantities equal to or greater than 1 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 PROTIM ANTIMOULD is being transported,
and regulation 16 specifies requirements for general contents of the documentation.
Regulation 18 provides accessibility requirements (documentation to be available within 5 minutes) and regulation 19 provides requirements for
presentation with respect to comprehensibility and clarity. These requirements correspond with those relating to documentation required by the
Identification regulations (code I21).
EM11
Regulations 25–
34
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
PROTIM ANTIMOULD is held (or reasonably likely to be held on occasion) in quantities equal to or greater than 100 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 29–30. Requirements relating to the availability of equipment,
materials and people are provided in regulation 31. Requirements regarding the availability of the plan is provided in regulation 32 and
requirements for testing the plan are described in regulation 33.
EM12
Regulations 35–
41
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 liquid (or liquefiable)
PROTIM ANTIMOULD is held in quantities above 100 L.
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.
EM13
Regulation 42
Level 3 emergency management requirements – signage
These controls relates to the provision of emergency management information on signage at places where PROTIM ANTIMOULD is held at
quantities equal to or greater than 100 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.
Environmental Risk Management Authority Decision: Application (HSR02008)
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