Submission on the application to reassess Acephate and
Methamidophos (ERMA200399)
To:
Submissions
ERMA New Zealand
PO Box 131
Wellington 6140
Email: submissions@ermanz.govt.nz
Fax: (04) 914 0433
This submission relates to an application made by the Chief Executive of ERMA New
Zealand to reassess the chemicals acephate and methamidophos and substances containing
them.
If the benefits outweigh the risks and costs, the Authority may approve the continued use of
acephate and methamidophos in New Zealand for some or all of their current uses (possibly
with stricter controls or with further restrictions on use). If the benefits do not outweigh the
risks or costs then the Authority may decide to revoke the approval for substances containing
acephate and methamidophos.
If you have any questions about making a submission please contact ERMA New Zealand
on 0800 376 234 or visit www.ermanz.govt.nz for details.
Closing date for submissions: 16 March 2011
Your details
Your name:
Organisation name:
(if you are submitting
on its behalf)
Email:
Postal address:
Telephone number:
Privacy
Please keep my contact details confidential
ERMA New Zealand will deal with any personal information you supply in your submission in accordance with
the Privacy Act 1993. We will use your contact details for the purposes of processing the application that it
relates to (or in exceptional situations for other reasons permitted under the Privacy Act 1993). Where your
submission is made publicly available, your contact details will be removed only if you have indicated this as
your preference in the tick box above. We may also use your contact details for the purpose of requesting your
participation in customer surveys.
ERMA New Zealand is likely to post your submission on its website at www.ermanz.govt.nz. We also may make
your submission available in response to a request under the Official Information Act 1982.
We recommend that you read the full application before completing
your submission. The application can be downloaded from:
www.ermanz.govt.nz/find/webResults.aspx?search=erma200399
Decision Sought1:
Based on the preliminary recommendation of the staff of ERMA New Zealand (the Agency)
the revocation of the approvals is proposed for all of the acephate-containing substances and
methamidophos-containing substances with a phase-out period to allow disposal through use.
Please select one option
I support the recommendations in this application and would like it approved (i.e the
approval for these substances would be revoked)
OR
I oppose the recommendations in this application and would like it declined (i.e. the approval
for these substances would be retained)
OR
I neither support the recommendations in this application
Hearing
Please select one option
I wish to speak at the hearing in support of my submission
OR
I do not wish to speak at the hearing in support of my submission
1
Further information can be appended to your submission, if you are sending this submission electronically and
attaching a file we accept the following formats – Microsoft Word, Text, PDF, ZIP, JPEG and JPG. The file
must be not more than 8Mb.
Effects on the environment
Information on the following would be particularly useful:

Further information on the precise timing of application of acephate and
methamidophos during the season for all crops would enable refinement of the first-tier
assessment.
What potential adverse effects might the continued use of acephate and/or
methamidophos have on the environment?
What potential beneficial effects might the continued use of acephate and/or
methamidophos have on the environment?
Effects to human health and safety
Information on the following would be particularly useful:

any monitoring of operator dermal and inhalation exposure conducted according to
international best practice;

data to determine when unrestricted entry into treated greenhouses can occur;

the identification of minimum effective application rates, which may be used to refine
the exposure assessment.

Dislodgeable Foliar Residue (DFR) data for crops gathered according to international
best practice. Such data to be used in the re-entry worker exposure assessment;
What potential adverse effects might the continued use of acephate and/or
methamidophos have on human health and safety?
What potential beneficial effects might the continued use of acephate and/or
methamidophos have on human health and safety?
Effects of significance to Māori
What potential adverse effects might the continued use of acephate and/or
methamidophos have on Māori culture and values?
What potential beneficial effects might the continued use of acephate and/or
methamidophos have on Māori culture and values?
Effects on society and communities
Information on the following would be particularly useful:

the level of benefit offered by acephate and methamidophos containing substances,
especially regarding social effects such as the effect on local employment opportunities
and direct/indirect local community impact;
What potential adverse effects might the continued use of acephate and/or
methamidophos have on society and communities?
What potential beneficial effects might the continued use of acephate and/or
methamidophos have on society and communities?
Effects on the market economy
Information on the following would be particularly useful:

the financial implications of overseas restrictions on treating crops with acephate and
methamidophos;

further information about the effects of unavailability of the substances on the market
economy, preferably in the form of numerical data that compare the economic
consequences of using alternative pest control products to the continued use of
acephate/methamidophos
What potential adverse effects might the continued use of acephate and/or
methamidophos have on the market economy?
What potential beneficial effects might the continued use of acephate and/or
methamidophos have on the market economy?
Additional information
Is there any additional information you would like to provide to help us assess the risks, costs
and benefits?
Information on the following would be particularly useful:
If a longer phase-out period is adopted, then the substances may be subject to stricter
controls such as higher standards of PPE, buffer zones to protect human health and the aquatic
environment, REIs and maximum application rates and frequencies to reduce the risks as much as
possible.

Comments are sought regarding the effects of the proposed phase-out period with
interim controls such as Personal Protective Equipment, re-entry intervals and
application rates

identification of use patterns that have not been included in the assessment;

alternatives to the use of acephate and methamidophos for use on New Zealand crops;
their efficacy; and the likely timeframe of their implementation