ENVIRONMENTAL RISK MANAGEMENT AUTHORITY
DECISION
Amended under s67A on 6 September 2007
10 August 2005
Application code:
NOC03002
Application category:
Import into Containment any New Organism under
section 40(1)(a) of the Hazardous Substances and New
Organisms (HSNO) Act 1996
Applicant:
Butterfly and Orchid Garden
Applicant contact:
Roger Gass
Purpose:
To import into containment 199 species of tropical
butterfly for public display and breeding
Date application received:
9 December 2004
Consideration date:
17 – 29 June 2005
Considered by:
A Committee of the Authority (the Committee)
1
Summary of Decision
1.1
Application NOC03002 to import into containment 199 species of butterflies
and moths (listed in Appendices 1 and 2) is approved in part, with controls
(as detailed in Appendix 3), and declined in part, having being considered in
accordance with the relevant provisions of the Hazardous Substances and New
Organisms (HSNO) Act 1996 (the Act) and the HSNO (Methodology) Order
1998 (the Methodology). The organisms listed in Appendix 1 are approved
with controls. The organisms listed in Appendix 2 are declined.
2
Legislative Criteria for Application
2.1
The application was lodged pursuant to section 40(1)(a) of the Act and
determined in accordance with section 45, having regard to the matters
specified in section 44 and other matters relevant to the purpose of the Act, as
specified in 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, as specified in more detail below. Unless otherwise stated,
references to clause numbers in this decision refer to clauses of the
Methodology.
3
Application Process
Application receipt
3.1
Application NOC03002 was determined to be in compliance with section
40(2) of the Act and was formally received on 9 December 2004.
Notification
3.2
Under section 53(2) of the Act the Environmental Risk Management Authority
(the Authority) has discretion as to whether to publicly notify an application to
import any new organism into containment. In this case the application was
not publicly notified because it was considered unlikely that there would be
significant public interest in this application. This conclusion was based on the
grounds that there are no novel features of these organisms and no
unprecedented issues are raised by this application. In making this decision, it
was relevant that the applicant had consulted the Entomological Society of
New Zealand.
3.3
In accordance with section 58(1)(c) of the Act and clauses 2(2)(e) and 5 of the
Methodology, the Department of Conservation (DoC) and the Ministry of
Agriculture and Forestry (MAF) Biosecurity New Zealand were notified and
provided with an opportunity to comment on the application. Comments were
included in the Evaluation and Review (E&R) Report prepared by the Agency.
Decision Making Committee
3.4
The application was considered by a sub-committee of the New Organisms
(Non-GMO) Standing Committee of the Authority (the Committee) appointed
in accordance with section 19(2)(b) of the Act and clause 43 of the First
Schedule to the Act. The Committee comprised the following members: Dr
Max Suckling (Chair), Associate Professor Marie Dziadek and Professor
George Clark.
3.5
The Committee considered the application by teleconference on 17 June and in
person on 29 June 2005.
Information Available for Consideration
3.6
The information available for the consideration of the application was:

Application NOC03002 (Form NO2N): To Import into Containment any
New Organism that is not Genetically Modified including the supporting
documents listed at section 1.9 of the E&R Report;

E&R Report prepared by the Agency to assist and support the Committee's
decision-making including comments on the application from DoC and
MAF.
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
Report on Application NOC03002 produced for the Authority by Mr John
Dugdale.

Additional information received after completion of the E&R Report:
o Comment on E&R Report from Applicant;
o Comment on E&R Report from John Dowsett (of Butterfly Creek);
o Comment on E&R Report from DoC;
o Comments on proposed controls from MAF (minutes of discussion
with ERMA staff);
o Draft Butterflies and Moths Enclosure Schedule to Zoo Standard
(MAF);
o IATA Container Requirement 63 for caterpillars and larvae;
o Proposal to amend decision NOC98008 by substituting the original
controls with those in Appendix 3.
3.7
Recognised techniques were used in identifying, assessing, and evaluating the
relevant information, as required under clause 24 of the Methodology.
Techniques for identifying and preparing information on risks, costs and
benefits were based on internal procedures as specified in the ERMA New
Zealand Technical Guide publications.
4
Associated Approvals
4.1
The importation of butterflies and moths into containment is subject to the
requirements of the Biosecurity Act 1993, including the issue of an import
permit by MAF and adherence to the requirements of the MAF Import Health
Standard (IHS) for the Importation into New Zealand of Tropical Butterfly
Pupae from All Countries.
4.2
Two of the approved species (Ornithoptera aesacus and Troganoptera
trojanus) are regulated under the Convention on International Trade in
Endangered Species of Wild Fauna and Flora (CITES) agreement. New
Zealand is a party to this agreement and therefore has obligations pursuant to
it. These obligations are specified in the Trade in Endangered Species Act
1989, which is administered by DoC. Any person importing these two species
will need to apply for a CITES approval.
5
Sequence of the Consideration
5.1
In accordance with clause 24 of the Methodology, the approach to the
consideration adopted by the Committee was to look sequentially at the
identification, assessment and evaluation of risks, costs and benefits.
5.2
Those risks identified as significant were assessed in accordance with clause
12 of the Methodology. Management techniques were considered in relation to
the identified risks. Costs and benefits were assessed in accordance with
clause 13 of the Methodology. Qualitative scales used by the Committee to
measure likelihood and magnitude of risks, costs and benefits were provided
in Appendix 14 of the E&R Report. The approach to the consideration follows
the decision path outlined in Appendix 1 of the E&R Report.
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5.3
In carrying out its consideration the Committee considered the adequacy of
containment in accordance with section 45(1)(a)(iii) of the Act, and the
magnitude and probability of the risks, costs and benefits alongside each other
and in an integrated fashion. This is because the former interact with the latter
and this is recognised in clause 12(d) of the Methodology and in section
45(1)(a)(ii) of the Act.
5.4
The Committee set controls to satisfactorily provide for the matters in the
Third Schedule (Part II) of the Act and additional controls were considered in
relation to residual risks that required further consideration.
5.5
Benefits associated with this application were considered in accordance with
clauses 9, 10, 13 and 14 of the Methodology and section 6(e) of the Act.
5.6
Finally, taking account of the risk characteristics established in accordance
with clause 33 of the Methodology, the combined impact of risks, costs and
benefits was evaluated in accordance with clause 34.
6
The Application
Purpose of the Application
6.1
The purpose of application NOC03002 was “to import into containment 199
species of tropical butterfly for public display and breeding.” The Butterfly
and Orchid Garden (the Applicant) has operated as a public zoological facility
since 1999, following the Authority decision to approve, with controls, the
importation into containment of seventy species of tropical butterfly
(application NOC98008). Other zoological facilities are now using the existing
approvals and further facilities may do so in future. The applicant sought
approval to import into containment a further 199 species of tropical
butterflies and moths in order to increase the quality of the zoological
exhibition by importing a wider range of species.
6.2
The Committee was satisfied that the application is within the scope of the
purpose in section 39(1)(e) of the Act; the public display of any organism
including, but not limited to, display in a circus or zoological garden.
Information Supporting the Application
6.3
In accordance with clause 8 of the Methodology the Committee considered the
adequacy of the information presented. The key information for the
Committee has been the information relating to the ability of the organisms to
establish populations in New Zealand in the event of an escape from
containment. In this regard the abilities of each species to tolerate the climate
and to utilise plants present in New Zealand as host plants is crucial. The
information relating to these factors that has been supplied is largely based on
expert opinion and empirical predictions about the likelihood of the organisms
having those abilities. This information was derived from expert knowledge
and readily accessible information on recorded host plants.
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6.4
It was noted that no specific host range testing information has been presented
and no specific information relating to the abilities (or likelihood) of the
species in this application to utilise alternative (other than known) host plant
species. Also, no specific information on climatic limitations or tolerances for
each species has been presented. As such the information available for making
this decision has an inherent degree of uncertainty attached to it.
6.5
The Committee considers that this level of information has been sufficient to
identify risks but has limited the ability to specify the level of risk. As
discussed below this has resulted in significant uncertainty in the Committee’s
assessment of the probability and magnitude of potential effects and the
consequent decline of part of the application. The Committee advise that
further information, reducing this level of uncertainty, should accompany any
future application for those species that have been declined on this occasion.
Scope of Application
6.6
The 199 species listed in the application include 189 butterfly and 8 moth
species. One species, Euptoieta hegesia, is listed twice (26 and 82). The
information received from Mr Dugdale is that the silk moth, Bombyx mori
(196), was present in New Zealand prior to 29 July 1998. The Committee has
therefore not considered this species as part of this application.
6.7
The Committee have considered the remaining 197 species of butterfly and
moth in the application. In approaching such a large number of species in one
application the Committee first determined the criteria for the decision and then
grouped the species into similar risk groups for measurement against those
criteria. These groups (largely based upon Mr Dugdale’s evidence) are set out in
the E&R Report prepared by the Agency.
Previous Similar Applications and Amendment of NOC98008
6.8
In reflecting on previous decisions where these involve similar issues to those
raised by this application the Committee notes the Authority decision to
approve 70 species of tropical butterfly for importation into containment
(application NOC98008) involved very similar organisms. The Authority must
consider each application on its merits, and is therefore not bound by the
stance taken in previous decisions.
6.9
The containment regime specified in the Authority decision on application
NOC98008 forms the basis for the controls in this decision. Experience in
operating this regime to date (and the subsequent development of an approved
containment standard for zoo animals) has created reasons for considering
amendments to the current controls. Variations (including additional or deleted
controls) to the NOC98008 controls are identified and discussed in the
document “Proposed changes to NOC98008 under s67A minor amendment”
prepared by the Agency.
6.10
The Committee considers that for reasons of consistency it is preferable to
standardise the controls that apply to all tropical butterfly and moth species
approved by the Authority for public display in zoological facilities.
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Therefore, we have reviewed the controls on approval NOC98008 and
determined that these may be amended by deleting the current controls and
substituting the controls described in Appendix 3, below. The Committee is
satisfied that this change is minor in effect on the basis of the project team’s
analysis presented in the above mentioned document.
7
Adequacy of the Containment Regime
7.1
In considering the ability of the organisms to escape from containment, the
Committee considered the:
i.
biological characteristics of the organisms;
ii. containment regime;
iii. potential pathways for escape of the organisms from the containment
facility;
(i) Biological characteristics of the organisms
7.2
The biological characteristics of butterflies and moths relevant to containment
are noted in section 2 of the E&R Report. In summary, butterflies and moths
have a life cycle consisting of four stages. These are egg, caterpillar (larvae),
chrysalis (pupa) and adult. Eggs are not independently mobile and are laid by
female adults often on leaves or other parts of plants. The caterpillar stage
feeds on plant material and may crawl. The chrysalis or pupa stage is spent in
a protective case generally attached to one place. It is in this stage that the
insects are transported.
(ii) Containment regime
7.3
Approved species of butterflies and moths shall be imported into a MAF
registered containment facility in accordance with the MAF Biosecurity
Authority/ ERMA New Zealand Standard 154.03.04: Containment Facilities
for Zoo Animals (the Standard) (see controls 1.1, 1.2 and 1.4 in Appendix 3 of
this decision).
7.4
The Standard requires the containment facility to be constructed and operated
in a manner to ensure that zoo animals are securely contained and that
containment is maintained. These requirements cover, access, staff training,
operational and management procedures, record keeping, contingency plans,
disposal of dead organisms and waste, and transportation of organisms. In
considering all of the matters specified in Schedule 3 (Part II) of the Act, the
Committee are satisfied that these are adequately addressed by the Standard
and the additional controls specified in Appendix 3.
(iii) Potential pathways for escape of organisms from the containment
facility
7.5
The Committee considered the potential pathways of escape of butterflies and
moths described in section 3 of the E&R Report. The Committee considers
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that the Butterfly House type of zoological containment facilities have
inherent pathways for escape of organisms which cannot be easily mitigated.
This is due to the absence of barriers between the visiting public and the
organisms and due to the frequency of visitors entering and leaving the
enclosure. These factors increase the likelihood of escape through both
unintentional and deliberate removal of butterflies or moths by visitors.
Ability of butterflies and moths to escape from containment
7.6
The Committee has considered the ability of butterflies and moths to escape
from this containment regime based on the characteristics of the organisms,
the potential pathways of escape and the available measures for reducing the
likelihood of escape including the operation and management of the facility.
7.7
The Committee have considered measures to reduce the likelihood of an
escape from containment and have imposed controls 6.7 to 6.12 (largely based
on the current practice) for this purpose.
7.8
Taking these considerations into account the Committee concluded that it is
unlikely that butterflies or moths would escape from containment. In the view
of the Committee escape is possible but it is not expected to occur under
normal operating conditions.
7.9
The Committee acknowledges that more stringent measures may be employed
in order to further reduce the likelihood of escape of butterflies and moths
such as those required for invertebrate containment facilities.1 However, in
these circumstances where the purpose of the facility is a zoological display
house in which visiting members of the public will have direct contact with the
organisms, further additional measures are impractical.
7.10
In accordance with the Standard, the Committee requires all containment
facilities holding approved new organisms (butterflies or moths) to have a
contingency plan for use in the event of an escape and to implement this plan
immediately following any breach of containment (Appendix 3, control 3.3).
Approval holders are also required to notify MAF and ERMA New Zealand
following such an occurrence (Appendix 3, control 3.2).
7.11
The Committee also imposed an additional control requiring all users of the
approval to notify ERMA New Zealand and MAF when they first exercise the
approval (see Appendix 3, control 6.1). This is for compliance monitoring
purposes and the need to know who is using the approval in case a
reassessment (section 62 of the Act) or amendment (section 67A of the Act) of
the approval is warranted.
8
Ability of the Organisms to Establish a Self-Sustaining
Population and Ease of Eradication
1
Registered and operated in accordance with the MAF/ERMA New Zealand Standard
154.02.08 Transitional and Containment Facilities for Invertebrates.
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8.1
In accordance with section 37 and clause 10(e) the Committee considered the
ability of butterflies and moths to form self-sustaining populations should they
escape from containment and the ease of eradication of such populations.
8.2
The Committee noted that a number of factors influence the likelihood of a
population establishing including the number of individuals (and of which sex)
successfully escaping, evasion of detection or capture, whether suitable host
plants exist and are in the same location, whether breeding is successful, the
effect of predators or parasites and the ability to survive climatic conditions.
8.3
The Committee identified two key factors influencing the ability of the
butterfly or moth species to establish self-sustaining populations; the presence
of a suitable host plant and tolerance of climatic conditions.
8.4
The information provided to the Committee on potential host plants has come
from expert opinion (from the Applicant, DoC and Mr Dugdale) and is based
on recorded host plants for each species. These records have been used to
identify potential host plants present in New Zealand allowing for the
possibility that organisms may be able to adapt to alternative host plants. An
alternative host plant is a plant species other than a recorded host plant
(usually closely related) that the organism may utilise as a food source. In
some instances the recorded host plants are known to be present (such as
citrus), in others the indications of potential host plant presence in New
Zealand is based on estimates of the abilities of the organisms to utilise
alternative hosts and the identification of plant species sufficiently closely
related to a known host to be potential hosts.
8.5
The Committee recognises that these indications of the presence, or otherwise,
of potential host plants is based on expert assessments of how closely related
to a known host plant other plants are in order to qualify for being indicated as
a potential host plant. Also the basis for determining presence in New Zealand
of the identified potential host plants is based on expert opinion. The
uncertainty inherent in making those assessments is relevant to determining
the likelihood of the butterflies or moths having suitable host plants present in
New Zealand. The Committee accepts this evidence as strongly indicative but
notes that without host range testing data this information has a degree of
uncertainty attached to it.
8.6
The available information relating to the suitability of the climate for
population establishment indicates that it is likely the butterflies or moths will
be unable to tolerate the climatic conditions in New Zealand. However, this
evidence (based on expert opinion) is insufficient to rule out the possibility of
unexpected abilities to survive in temperate climates in parts of New Zealand.
The Committee finds that this information suggests that it is unlikely the
climate will be suitable for any of the species to establish in New Zealand but
notes that, in the absence of recorded data on temperature tolerance ranges for
the individual species, this assessment has a degree of uncertainty attached to
it. The Committee has adopted Mr Dugdale’s categorisation of the species in
the application into tropical (T), subtropical (ST) or warm temperate (WTe) as
a means of identifying the degree of uncertainty about temperature tolerances
that exists for each species. For those indicated as ST or WTe this uncertainty
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is very significant. For those species indicated as T (indicating a likelihood of
being restricted to tropical climates), this uncertainty is less but is still
significant.
8.7
The Committee have considered measures to reduce the likelihood that the
organisms will be able to tolerate temperatures outside of containment and for
this reason have imposed a control to restrict the use of the approval to
containment facilities in geographical locations less favourable to the
formation of self-sustaining populations in the unlikely event of an escape
(control 6.2). Further measures to reduce this likelihood are controls 6.3 and
6.4 which are designed to reduce the likelihood of importing organisms that
have adapted to temperate climates and to reduce the possibility of imported
organisms adapting to lower temperatures in the containment facilities.
8.8
In making its key assessment of the likelihood of the species in this application
to be able to establish self-sustaining populations in New Zealand the
Committee has established the following criteria against which all of the
groups of species in the E&R Report have been measured.
8.9
For those species which the expert opinion has indicated have no potential
host plants present in New Zealand and which have not been categorised as
subtropical or warm temperate species, the Committee considers the likelihood
of establishment of a population in New Zealand ranges from improbable to
unlikely. The residual uncertainty attached to this assessment is not
significant.
8.10
For those species for which no information is available about potential host
plants (Table 1 in the E&R Report) the uncertainty about the ability to
establish populations is significant and does not allow this likelihood to be
stated with sufficient certainty for any of these eight species.
8.11
For those species which have been indicated as having potential host plants
present in New Zealand the likelihood of establishing a self-sustaining
population ranges from unlikely, for those likely to be restricted to tropical
climates, to likely for those which have been categorised as warm temperate
species. The degree of uncertainty in this assessment for these species is
significant.
8.12
As indicated in the risk assessments below, the risks of adverse effects is
strongly dependant upon the ability of the species to establish self-sustaining
populations in New Zealand.
8.13
Ease of Eradication
8.14
The Committee considers that the eradication of populations of butterflies or
moths is possible. The ease with which such an operation may be successfully
carried out will depend on many variables including the size of the population
when detected, the location of the population and how widespread it is. Recent
experience with such operations indicates that they can be very costly and
disruptive to the community. Such programmes may not be cost effective
where the adverse effect of the pest organism is minor.
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9
Identification and assessment of potentially significant
adverse and beneficial effects (risks, costs and benefits)
9.1
The Committee considered the potential risks, costs and benefits relating to the
application, identified in section 5 of the E&R Report. In accordance with
sections 5 and 6 of the Act, and clause 9 of the Methodology, the potential
adverse and beneficial effects of this application were categorised and
considered in terms of their area of impact on the environment, on human
health and safety, and on Māori and their culture and traditions.
9.2
The potential risks and costs assessed here are those identified as significant,
having regard for those matters set out in clauses 9 and 10 of the
Methodology, which reflect sections 5, 6, 8 and 44 of the Act. Risks were
considered in terms of the requirements of section 45(4) of the Act and clause
12 of the Methodology, including the assessment of consequences and
probabilities, the impact of uncertainty and the impact of risk management.
Costs were considered in terms of clause 13 of the Methodology. A “cost” is
defined in clause 2 as “the value of a particular adverse effect expressed in
monetary or non-monetary terms”. Therefore, these have been assessed in an
integrated fashion together with the risks of those adverse effects.
Potential adverse effects on the environment
Potential adverse effects on native or valued plant species
9.3
Some lepidoptera have the potential to become pests of the host plants on
which their larvae feed. This may have an impact on the productivity or
amenity value of horticultural crops or ornamental and native plant species.
The nature of this potential impact will depend on what the affected host plant
is and the significance of that host plant.
9.4
The effect of introduced butterfly or moth species is difficult to predict
without specific host plant range information. At the higher end of the scale is
the example of painted apple moth which is the subject of a significant and
costly eradication programme. The Committee notes that exposure to this
hazard is involuntary, may persist over time and spread beyond the immediate
location of incidence. In the event that this risk materialises, management
options are possible, however, the painted apple moth experience shows that
the measures for control of insect pests can have significant adverse effects on
affected communities.
9.5
The key elements of the risk pathway are; escape from containment,
establishment of a sustainable population that is dependant on a suitable host
plant that is present in New Zealand, and that the effects on that host plant
reduces the value of that plant.
9.6
Escape of any of the species from containment (as discussed above) is
considered to be unlikely. The ability of the species to establish a sustainable
population is dependant on a number of factors. As indicated above, two of the
most important of those factors are the suitability of the climate in New
Zealand and the presence of suitable host plants to enable the larval stage of
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the butterfly or moth life cycle to feed. The information available on climatic
data (as discussed above) indicates that there is significant uncertainty about
those species identified as having natural ranges extending into sub-tropical
and warm temperate regions and relatively less uncertainty for those species
identified as restricted to tropical regions.
9.7
The available information on the presence in New Zealand of potential host
plants (from all sources presented to the Authority) has indicated that the
species of butterfly and moth in this application either have potential host
plants present in New Zealand or they do not (or there was no information
available on this). The likelihood of adverse effects on native or valued plant
species, in the event of an escape and establishment, ranges from improbable
(for those species unlikely to establish) to unlikely for those species for which
the ability to establish is uncertain.
9.8
The magnitude of a potential effect on native or valued plant species would be
influenced by the ability of the butterfly to establish a population dependant on
the plant, the extent of defoliation caused by larvae, the significance of the
particular plant species and the impact of available management options
(including chemical or biological insect pest control measures). The available
information leaves significant uncertainty such that the potential adverse
effects on host plants range from minimal to moderate.
9.9
The Committee considers there is significant uncertainty about the level of risk
posed by those species identified as having potential host plants present in
New Zealand. Taking into account this uncertainty the risk is considered to be
non-negligible.
9.10
For those species not indicated as having potential host plants present there is
some residual uncertainty but the Committee considers this risk is negligible.
Potential for displacement of native or valued invertebrates and
consequent disruption of ecosystems
9.11
The Committee noted the potential for the establishment of a self-sustaining
population of butterfly or moth to result in the displacement of organisms that
were already present in New Zealand. Any such effect would be dependant
upon the imported butterfly or moth species establishing a self-sustaining
population in New Zealand and that population displacing one already present.
The possibility of establishment has been assessed elsewhere in this decision
and is dependant upon the presence of a potential host plant.
9.12
For those species identified as having potential host plants present in New
Zealand this risk ranges from low to high and cannot be stated with greater
accuracy because the uncertainty is high.
9.13
For those species not indicated as having potential host plants present there is
some residual uncertainty but the Committee considers this risk is negligible.
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Potential for parasites or diseases to be inadvertently imported with the
butterflies and affecting native or valued invertebrates
9.14
The potential for imported butterfly or moth pupae to carry parasites or
diseases into New Zealand was considered. The Committee considers that it is
likely diseased pupae (or live parasites) may be imported from time to time.
However, given the management procedures already in place, and required by
the proposed controls (Appendix 3), the likelihood of any such organisms
escaping detection and being unintentionally transferred out of containment is
improbable.
9.15
In order to manage this risk the Committee impose a control requiring all
diseased pupae to be incinerated or securely forwarded to a MAF controlled
facility for testing/diagnosis if required by MAF (Control 6.5). Given this
control, the risk to native or valued invertebrates from the unintended
importation and escape of diseases or parasites is negligible.
Potential adverse effects on human health and safety
Potential for larvae to cause irritation to humans
9.16
The Committee noted that some tropical butterflies and moths have
caterpillars which can cause irritation. Given that this occurrence is unlikely
and exposure to this hazard is voluntary and is limited to those persons in
direct contact with caterpillars, this risk is negligible.
Potential adverse effects on Māori and their culture and traditions
Potential for butterflies and moths to have adverse effects on Māori and
their culture and values
9.17
The Committee considered the potential Māori cultural effects of this
application in accordance with clauses 9(b)(i) and 9(c)(iv) of the Methodology
and sections 6(d) and 8 of the Act, and the assessment framework contained in
the ERMA New Zealand User Guide “Working with Māori under the HSNO
Act 1996”.
9.18
The Committee considers that the escape from containment of some of the
species of tropical butterfly or moth poses a risk of potential adverse effects to
native or valued species and therefore the kaitiakitanga of Māori, including the
protection and enhancement of the mauri of taonga (native and valued) flora
and fauna species and ecosystems.
9.19
From the evidence that has been provided by the applicant, in many instances
it is difficult to fully assess the potential for some of the species to have
adverse effects on taonga species following escape and establishment through
competition or displacement. It is therefore difficult to determine whether any
potential effects would be of significant cultural importance to Māori.
9.20
However, given the containment and quarantine requirements of the
application, and the additional controls, the Committee considers the potential
for adverse effects to the relationship of Māori with their culture and traditions
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and with their ancestral lands, water, sites, waahi tapu, valued flora and fauna
and other taonga, caused by species not likely to have host plants present in
New Zealand, as not significant. For these species any subsequent effect to the
integrity and mauri of native or valued species and ecosystems is highly
improbable with a minimal magnitude of effect.
9.21
For those butterfly or moth species which may have potential host plants
present in New Zealand, and which therefore have been assessed as more
likely to be able to establish, this risk is not negligible.
Potential beneficial effects associated with the import into
containment of the organisms
9.22
The Committee considered the potential beneficial effects associated with the
application, in accordance with sections 5 and 6(e) of the Act and clauses 9,
10, 13, and 14 of the Methodology. The following beneficial effects were
identified:
1. Financial benefits to the zoological gardens that house butterflies and
moths through increased attraction of customers, and to local economies
where the facilities are located through employment opportunities.
2. Increased entertainment, education and satisfaction of visitors.
9.23
The Committee considers that the potential benefits are very likely to be
realised and would be of moderate value, particularly to the users of this
approval. Therefore the Committee considers these benefits to be nonnegligible.
10
Establishment of the Approach to Risk in the Light of
Risk Characteristics
10.1
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. This provision provides a route for determining how cautious or
risk averse the Authority should be in weighing up risks and costs against
benefits. In the present application clause 33 is influenced by the application
being “in containment” however, the Committee considers that the nature of
the Butterfly House display facility limits the ability of the containment to
fully mitigate the risks that may occur in the event of an escape of butterflies
or moths. There will remain a significant, although unlikely, possibility of
escape which must be included in the assessment required by section
45(1)(a)(ii) of the Act.
10.2
It is considered that the potentially significant risks are dependant upon escape
from containment and establishment of an undesirable self sustaining
population. The Committee have taken into account the need for caution due
to the uncertainty in the assessments of the abilities of the organisms to
establish self-sustaining populations in New Zealand and the likelihood of the
adverse effects that may occur consequently. In relation to the environmental
risks considered, the Committee considers that exposure to these risks is
involuntary. The Committee also considers that there are significant risks
Environmental Risk Management Authority Decision: Application NOC03002
Page 13 of 24
which are reversible but which may involve costly and unwanted eradication
measures. The general public have been exposed to such eradication measures
previously (painted apple moth incursion) and therefore have some
understanding of these measures.
10.3
In the circumstances of this application, in particular the nature of the
containment facility, the uncertainty in the information available and these risk
characteristics the Committee considers that a cautious approach is warranted.
11
Overall Evaluation of Risk, Costs and Benefits
11.1
The overall evaluation of risks, costs and benefits set out below was carried
out in accordance with section 45 of the Act and clause 27 of the
Methodology, having regard to clauses 22 and 34 of the Methodology.
11.2
The Committee is satisfied that the application is for the purpose set out in
section 39(1)(e) of the Act.
11.3
The Committee has assessed the potential risks of importing the butterflies and
moths in application NOC03002 into containment including potential adverse
effects on native or valued plant species, displacement of invertebrates already
present, and potential for adverse effects to the mauri of native fauna and
ecosystems and the continued role of Māori as kaitiaki.
11.4
The Committee was unable to find common units of measurement with which
to combine risks, costs, and benefits in accordance with clause 34(a), however,
there is one dominant risk (clause 34(b)) which is the potential for the
organisms to establish undesirable self-sustaining populations causing adverse
effects on native or valued plant species. Because this risk is not negligible the
decision is made in accordance with clause 27 (not clause 26) of the
Methodology.
11.5
The uncertainty resulting from the level of information available (particularly
the absence of host range testing data) for these species meant that the
Committee could only describe the risks in terms of ranges of likelihood and
magnitude.
11.6
In order to weigh these risks in accordance with section 45 of the Act, the
Committee was able to identify one group of species among the total of 197
species in the application for which the risk could be described with greater
precision. This group of species carry a low risk of establishing undesirable
self-sustaining populations because they are unlikely to have suitable host
plants present in New Zealand and are unlikely to tolerate the climatic
conditions. The benefits of importing these species into containment are
considered to be of moderate value and to outweigh the risks. The Committee,
having regard to the matters in Schedule Three (Part II) of the Act, is satisfied
that these species can be adequately contained. These species, listed in
Appendix 1 are approved with controls as detailed in Appendix 3.
11.7
For the remaining species (listed in Appendix 2) the risks have been found to
range from low to high but this assessment has significant uncertainty attached
Environmental Risk Management Authority Decision: Application NOC03002
Page 14 of 24
to it. The uncertainty is largely created by the low level of information about
potential host plants that may be present in New Zealand that has been
presented to the Authority. In the circumstances of the Committee’s approach
to risk, outlined above, and given the level of containment, this level of risk is
not outweighed by the beneficial effects of importing these species into
containment. The application for approval to import the species listed in
Appendix 2 is declined.
12
Decision
12.1
Pursuant to section 45(1)(a)(i) of the Act, the Committee is satisfied that this
application is for one of the purposes specified in section 39(1) of the Act,
being section 39(1)(e): the public display of any organism including, but not
limited to, display in a circus or zoological garden.
12.2
Having considered all the possible effects in accordance with sections
45(1)(a)(ii), 45(4) and 44 and pursuant to clause 27 of the Methodology, and
based on consideration and analysis of the information provided and taking
into account the application of risk management controls specified in this
decision, the view of the Committee is that the risks (or costs) of adverse
effects associated with the importation into containment of the 197 butterflies
and moths considered fall into a range of levels. For each group on this range
(broadly reflecting the risk groups identified in the E&R Report) the level of
risk of adverse effects was weighed against the beneficial effects of having the
organisms in containment. In respect of the species listed in Appendix 1 that
level of risk is outweighed by the benefits. In respect of the species listed in
Appendix 2 the level of risk is not outweighed by the benefits.
12.3
The Committee is satisfied that the containment regime, as determined by the
controls in Appendix 3, will adequately contain the approved organisms,
taking account of the level of risk, as required by section 45(1)(a)(iii) of the
Act.
12.4
In accordance with clause 36(2)(b) of the Methodology the Committee records
that, in reaching this conclusion, it has applied the balancing tests in section 45
of the Act and clause 26 of the Methodology and has relied in particular on the
criteria set out in the following sections of the Act:




12.5
section 44 additional matters to be considered;
section 45 determination of application;
section 37 additional matters to be considered; and
the Third Schedule-Part 2, matters to be addressed by containment
controls for new organisms.
The Committee has also applied the following criteria in the Methodology:
clause 9 - equivalent of sections 5, 6 and 8;
clause 10 - equivalent of sections 36 and 37;
clause 12 – evaluation of assessment of risks;
clause 13 – evaluation of assessment of costs and benefits;
clause 20 – information produced from other bodies;
Environmental Risk Management Authority Decision: Application NOC03002
Page 15 of 24
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 27 - the risks are not negligible;
clause 29 and 32 – considering uncertainty;
clause 33 – the risk characteristics; and
clause 34 – the aggregation and comparison of risks, costs and benefits.
12.6
The application to import into containment the species listed in Appendix 1 is
approved, with controls, in accordance with section 45(1)(a) of the Act. As
required under section 45(2) the approval is subject to the controls listed in
Appendix 3 of this decision.
12.7
The application to import into containment the species listed in Appendix 2 is
declined in accordance with section 45(1)(b) of the Act.
12.8
The Committee have reviewed the controls on approval NOC98008 and
determined that these shall be amended by deleting the current controls and
substituting the controls described in Appendix 3, below (in accordance with
section 67A of the Act). The Committee is satisfied that this change is minor
in effect.
___________________________
10 August 2005
Dr Max Suckling
Date
Chair, New Organisms Standing Committee of the Authority
Approval codes: NOC002394-2453
Amendment: November 2006
Changes to controls:
 Addition of footnotes to the containment facility references and the
Australian/New Zealand containment facility references to “future proof” the
decision
 Standardise the wording of the breach of containment control
 Standardise the wording for the notification of the first time use of this
approval
 Removal of the control regarding inspection of facilities by the Authority, its
agent or enforcement officers
____________________________
Dr Max Suckling
Chair, New Organisms Standing Committee
Environmental Risk Management Authority Decision: Application NOC03002
Date: 6 September 2007
Page 16 of 24
Appendix 1: Species Approved with Controls:
ID. No.
10
14
48
49
59
63
66
67
68
69
70
71
72
74
75
79
85
86
87
88
89
90
92
98
100
103
104
108
110
111
112
113
114
118
119
120
122
124
125
126
127
128
131
132
133
147
153
155
165
Subfamily
Danainae
Danainae
Limenitinae
Limenitinae
Nymphalinae
Limenitinae
Limenitinae
Limenitinae
Limenitinae
Limenitinae
Heliconiinae
Charaxinae
Charaxinae
Nymphalinae
Nymphalinae
Limenitinae
Limenitinae
Limenitinae
Limenitinae
Limenitinae
Limenitinae
Limenitinae
Charaxinae
Nymphalinae
Nymphalinae
Limenitinae
Limenitinae
Limenitinae
Nympalinae
Charaxinae
Nymphalinae
Charaxinae
Nymphalinae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Current or Valid name
(based on Mr Dugdale’s Report)
Anetia thirza
[Danaus] Anosia genutia
Limenitis fessonia
Limenitis iphiclus
Anartia fatima
Parathyma perius
Catonephele godmani
Catonephele mexicana
Catonephele numilia
Catonephele orites
Cethosia hypsea
Charaxes castor
Charaxes polyxena
Chlosyne gaudialis
Chlosyne janais
Dynamine mylitta
Hamadryas arinome
Hamadryas februa
Hamadryas feronia
Hamadryas fornax
Hamadryas chloe
Hamadryas gautemalena
Hypna clytemnestra
Junonia oenone
Kallima paralekta
Myscelia cyaniris
Myscelia ethusa
Kallima sylvia
Junonia hierta
Prepona omphale
Salamis parrhassus
Siderone nemesis
Metamorpha epaphus
Pachliopta annae
Pachliopta mariae
Parides neptunus
Parides semperi
Eurytides epidaus
Eurytides branchus
Eurytides phaon
Graphium angolanus
Graphium antheus
Ornithoptera aesacus
Pachliopta kotzebuae
Pachliopta oreon
Papilio lorquinianus
Papilio oribazus
Papilio peranthus
Parides arcas
Environmental Risk Management Authority Decision: Application NOC03002
Author, date
(Hübner &) Geyer
Cramer, 1779
Hewitson, 1847
Hewitson, 1847
Fabricius, 1793
Linnaeus, 1757
Stichel, 1901
Jenkins & R de la Maza
Cramer, 1779
Stichel, 1898
Doubleday, [1847]
Cramer, 1775/76
Cramer, 1775/76
Bates, 1864
Drury, 1782
Cramer, 1782
Lucas, 1853
Hübner, 1816/24
Linnaeus, 1758
Hübner, 1816/24
Stoll, 1787
Bates, 1864
Cramer, 1777
Fabricius, 1764
Horsfield, 1829
Doubleday, [1848]
Boisduval, 1836
Cramer, 1776
Fabricius, 1798
Hübner, 1819
Drury, 1782
Cramer. 1777
Latreille, 1819
Felder, 1861
Semper, 1878
Guerin-Meneville, 1840
Felder, 1861
Doubleday, [1846]
Doubleday, 1846
Boisduval, 1836
Goeze, 1779
Cramer, 1779
Ney, 1903
Eschscholz, 1821
Doherty, 1891
Felder, 1865
Boisduval, 1836
Fabricius, 1787
Cramer, 1781
Page 17 of 24
166
167
169
171
172
173
174
182
197
198
199
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Pieridae
Uraniidae
Uraniidae
Uraniidae
Parides erithalion
Parides iphidamus
Parides montezumae
Parides photinus
Parides sesostris
Parides vertumnus
Trogonoptera trojanus
Eurema nise
Chrysiridia rhipheus
Urania sloanus
Urania leilus
Environmental Risk Management Authority Decision: Application NOC03002
Kollar, 1850
Fabricius, 1893
Westwood, 1842
Doubleday, 1844
Cramer, 1779
Cramer, 1779
Staudinger, 1889
Cramer, 1775
Drury, 1773
Cramer, 1779
Linnaeus, 1758
Page 18 of 24
Appendix 2: Species Declined:
ID.
No.
1
Subfamily
Morphinae
2
3
4
5
6
7
8
9
Morphinae
Morphinae
Morphinae
Morphinae
Morphinae
Morphinae
Morphinae
Morphinae
11
12
13
15
16
17
18
19
20
21
22
23
24
25
Danainae
Danainae
Danainae
Danainae
Danaiinae
Danainae
Danainae
Danainae
Danainae
Danainae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
50
51
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Heliconiinae
Danainae
Danainae
Danainae
Danainae
Danainae
Danainae
Danainae
Danainae
Heliconiinae
Charaxinae
Charaxinae
Current or Valid name (based on Dugdale
Report)
Caligo atreus
Caligo uranus
Brassolis isthmia
Eryphantis polyxena
Opsiphanes cassina
Morpho achilles
Morpho deiamia
Morpho granadensis
Morpho menelaus
Amauris niavius
?syn A. albimaculata
[Danaus] Anosia affinis
Parantica agleoides
Tellervo hamata
Euploea phaenareta
Idea blanchardii
Idea leuconoe
Idea stolli
Ideopsis juventa
Lycorea cleobaea
Agraulis vanillae
Dione moneta
Dryadula phaetusa
Eueides aliphera
Euptoieta hegesia
see also#82
Heliconius clysonymus
Heliconius ?primularis
Heliconius erato
Heliconius hecale
Heliconius hecalesia
Heliconius hewitsoni
Heliconius hortense
Heliconius ismenius
Heliconius numatus
Heliconius ricini
Heliconius sapho
Heliconius wallacei
Dircenna dero
Ithomia heraldica
Mechanitis isthmia
Mechanitis polymnia
Pteronymia cotytto
Thyridia psidii
Tithorea harmonia
Tithorea tarricina
Acrea issoria
Anaea arginussa
Cymatogramma artacaena
Environmental Risk Management Authority Decision: Application NOC03002
Author, date
Kollar, 1894
Herrich-Schaefer 1850
(1858)
Bates, 1854
Meerberg, 1775
Felder, 1862
Linnaeus, 1758
Hübner, 1816
Felder, 1867
Linnaeus, 1758
Linnaeus, 1758
Bates, 1875
Fabricius 1775
Felder & Felder, 1860
MacLeay, 1827
Schaller, 1785
Marchal, 1845
Erichson, 1834
Moore, 1883
Cramer, 1777
Godart, 1819
Linnaeus, 1758
Hübner, 1819-26
Linnaeus, 1758
Latrielle&Godart,1819
Cramer, 1779
Latreille1817
Butler, 1869
Linnaeus, 1758
Fabricius, 1777
Hewitson, 1853
Staudinger,1875
Guerin[-Meneville] 1829-38
Latreille1817
Cramer, 1780
Linnaeus, 1758
Drury, 1782
Reakirt, 1866
Hübner, 1823
Bates 1866
Bates, 1863
Linnaeus, 1758
Guerin[-Meneville], 1844
Linnaeus, 1758
Cramer, 1777
Hewitson, 1857
Hübner, 1816
Hübner & Geyer,1832
Hewitson, 1869
Page 19 of 24
52
53
54
55
56
57
58
60
61
62
64
65
73
76
77
78
80
81
[82]
83
84
91
93
94
95
96
97
99
101
102
105
106
107
Charaxinae
Charaxinae
Charaxinae
Charaxinae
Charaxinae
Charaxinae
Nymphalinae
Charaxinae
Charaxinae
Limenitinae
Limenitinae
Limenitinae
Charaxinae
Charaxinae
Charaxinae
Limenitinae
Limenitinae
Limenitinae
Heliconiinae
Charaxinae
Limenitinae
Limenitinae
Nymphalinae
Nymphalinae
Nymphalinae
Nymphalinae
Nymphalinae
Nymphalinae
Limenitinae
Limenitinae
Limenitinae
Limenitinae
Limenitinae
109
115
116
117
Heliconiinae
Nymphalinae
Heliconiinae
Heliconiinae
Papilionidae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
121
123
129
130
134
135
136
137
138
139
140
141
142
143
144
145
146
148
149
Anaea chrysophana
Anaea euryple
Anaea glycerium
Anaea pithyusa
Anaea nobilis
Anaea perenna
Anartia amathea
Prepona demophon
Prepona meander
Ariadne ariadne
Biblis hyperia
Catagramma pitheus
Charaxes violetta
Anaea electrica
Consul fabius
Colobura dirce
Euthalia aconthea
Euthalia dirtea
Euptoieta hegesia, repeated, see #26
Godardia wakefieldi
Hamadryas amphinome
Historis odius
Hypolimnas misippus
Hypolimnas monteironis
Hypolimnas usumbara
Junonia evarete
Junonia genoveva
Kallima inachus
Marpesia petreus
Limenitis procris
Nessaea aglaura
Nessaea hewitsoni
Neptis hylas
Phalanta phalantha
[incl Atella exulans]
Metamorpha stelenes
Vindula deione
Vindula erota
Bates, 1866
Felder, 1862
Doubleday, [1849]
Felder, 1869
Bates, 1864
Godman & Salvin, 1884
Linnaeus, 1758
Linnaeus, 1758
Cramer, 1775
Linnaeus, 1763
Cramer, 1779
Latreille, 1811/1823
Grose-Smith, 1885
Westwood, 1850
Cramer, 1779
linnaeus, 1764
Cramer, 1779
Fabricius, 1793
Cramer, 1779
Ward, 1873
Linnaeus, 1767
Fabricius, 1775
Linnaeus, 1758
Druce, 1774
Ward, 1872
Cramer, 1782
Cramer, 1782
Boisduval, 1836
Cramer, 1776
Cramer, 1777
Doubleday, [1848]
Felder, 1859
Linnaeus, 1758
Drury, 1773,
[Hopkins, 1927]
Linnaeus, 1758
Erichson, 1834
Fabricius, 1793
Parides nox
Papilio clytia
Graphium antiphates
Graphium doson
Papilio astyalus
Papilio ascalaphus
Papilio castor
Papilio chaon
Papilio chikae
Papilio constantinus
Papilio cresphontes
Papilio demodocus
Papilio godeffroyi
Papilio gigon
Papilio helenus
Papilio hipponous
Papilio lycophon
Papilio montrouzieri
Papilio nephelus
Swainson, 1822/23
Linnaeus, 1758
Cramer, 1775
Felder, 1864
Godart, 1819
Boisduval, 1836
Westwood, 1842
westwood, 1845
Igarashi, 1965
Ward, 1871
Cramer, 1777
Esper, 1798
Semper, 1866
Felder, 1864
Linnaeus, 1758
Felder, 1862
Hübner, 1818
Boisduval, 1859
Boisduval, 1836
Environmental Risk Management Authority Decision: Application NOC03002
Page 20 of 24
150
151
152
154
156
157
158
159
160
161
162
163
164
168
170
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Papilioninae
Lycaenidae
Papilioninae
175
Papilio nireus
Papilio nobilis
Papilio oenomanus
Papilio palinuris
Papilio pericles
Papilio pilumnus
Papilio phorcas
Papilio schmeltzi
Papilio thoas
Papilio torquatus
Papilio troilus
Motasiona zagreus
Papilio zalmoxus
Parides lysander
Linnaeus, 1758
Rogenhofer, 1891
Godart, 1819
Fabricius, 1787
Wallace, 1865
Bisduval, 1836
Cramer, 1775
Herrich-Schaeffer, 1869
Linnaeus, 1771
Cramer, 1777
Linnaeus, 1758
Doubleday, 1847
Hewitson, 1864
Cramer, 1775
Parides neophilus
Hübner, 1837
GuerinMeneville, 18430
Talicada nyseus
Pieridae
176
177
178
179
180
181
183
184
185
186
187
188
189
190
191
192
193
194
195
Pieridae
Morphinae
Satyrinae
Saturniidae
Anteos maerula
Appias lyncida
Appias nero
Catopsila pyranthe
Catopsila scylla
Eurema hecabe
Eurema proterpia
Hebomoia glaucippe
Phoebis argante
Phoebis philea
Phoebis sennae
Pieris viardi
Amathusia phidippus
Elymnias hypermnestra
Actias dubernardi
Argema maenas
Actias selene
Argema mimosae
Argema mittrei
Environmental Risk Management Authority Decision: Application NOC03002
Fabricius, 1775
Cramer, 1777
Fabricius, 1793
Linnaeus, 1758
Linnaeus, 1763
Linnaeus, 1764
Fabricius, 1775
Linnaeus, 1758+
Fabricius, 1775
Linnaeus, 1763
?Boisduval, 1836?
Linnaeus 1758
Boisduval, 1836
Linnaeus, 1763
Linnaeus, 1763
Oberthür, 1897
Doubleday, 1847
Hübner, 1806
Boisduval, 1847
Guerin-Meneville, 1846
Page 21 of 24
Appendix 3: Controls
In order to satisfactorily address the matters detailed in the Third Schedule Part II:
Containment controls for new organisms excluding genetically modified organisms2of
the Act, and other matters in order to give effect to the purpose of the Act, the
approved organisms are subject to the following controls:
For the purposes of the controls the following definitions apply:
 The “containment facility” includes the following two areas:
o the “Butterfly House “ is the area where the adult butterflies are
housed for public display; and
o the “Quarantine, Rearing and Breeding Facility” is the area where
insects are imported into for rearing, and includes the corridor between
the butterfly house and the quarantine, rearing and breeding facility, as
well as the glass display area containing pupae for public display.
 “incineration” means incineration in a high temperature, regional councilapproved incineration facility that reduces the material to ashes.
1
To limit the likelihood of any accidental release of any organism or
any viable genetic material3:
1.1
The approved organisms shall be imported into, and maintained within a
containment facility which complies with these controls.
1.2
The construction, operation, and management of the containment facility shall
be in accordance with the Ministry of Agriculture and Forestry (MAF)/ERMA
New Zealand Standard 154.03.044: Containment Facilities for Zoo Animals.
1.3
The person responsible for the operation of the containment facility shall inform
all personnel involved in the handling of the organisms of the Authority’s
controls.
1.4
The containment facility shall be approved by Ministry of Agriculture and
Forestry (MAF), in accordance with section 39 of the Biosecurity Act and the
Standard listed in control 1.2.
2
2.1
To exclude unauthorised people from the facility:
The identification of entrances, numbers of and access to entrances, and the
security requirements for the entrances and the facility shall be in compliance
with the Standard specified in control 1.2.
2
Bold headings refer to matters to be addressed by containment controls for new organisms
excluding genetically modified organisms, specified in the Third Schedule (Part II) of the
HSNO Act 1996.
3
Viable Genetic Material is biological material that can be resuscitated to grow into tissues or
organisms. It can be defined to mean biological material capable of growth even though
resuscitation procedures may be required, e.g. when organisms or parts thereof are sub-lethally
damaged by being frozen, dried, heated, or affected by chemical.
4
Any reference to this standard in these controls refers to any subsequent version approved or
endorsed by ERMA New Zealand.
Environmental Risk Management Authority Decision: Application NOC03002
Page 22 of 24
3
To control the effects of any accidental release or escape of an
organism:
3.1
Control of the effect of any accidental release or escape of the organism shall be
in compliance with the Standard specified in control 1.2.
3.2
If a breach of containment occurs, the facility operator must ensure that the
MAF Inspector responsible for supervision of the facility has received
notification of the breach within 24 hours.
3.3
In the event of any breach of containment of the organism, the contingency plan
for the attempted retrieval or destruction of the organism that has escaped shall
be implemented immediately. The contingency plan shall be included in the
containment manual in accordance with the requirements of the Standard
specified in control 1.2.
4
Inspection and monitoring requirements for containment facilities:
4.1
The inspection and monitoring requirements for the containment facility shall
be in compliance with the Standard specified in control 1.2.
4.2
The containment manual shall be updated, as necessary, to address the
implementation of the controls imposed by this approval, in accordance with the
Standard specified in control 1.2.
5
5.1
6
Qualifications required of the persons responsible for implementing
these controls:
The training of personnel working in the facility shall be in compliance with the
Standard specified in control 1.2.
Additional controls:
6.1
Any person using this approval for the first time shall notify ERMA New
Zealand and the MAF Inspector responsible for supervision of the facility of
their intention to do so in writing.
6.2
This approval shall only be used by containment facilities located south of
latitude 34oSouth (Cape Reinga).
6.3
All species to be imported shall be sourced from tropical populations only.
Verification of sources shall be kept and made available to MAF or ERMA on
request.
6.4
The containment facility shall be maintained at temperatures of at least 20˚C.
6.5
All waste (including dead or diseased pupae) associated with the importation of
butterflies and moths shall either be rendered non-viable on-site (via
autoclaving or incineration), or shall be double bagged or placed in a sealed
container in the facility, before being transported to an incineration facility, or
MAF-approved diagnostic facility. Vegetation may be mulched on-site in the
Butterfly House and retained in the containment facility for use as plant mulch.
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6.6
Mounting of dead butterflies for display or sale is an acceptable means of
disposal.
6.7
The Quarantine, Rearing and Breeding Facility component of the containment
facility shall be separated from the Butterfly House by a means of excluding
ready access by visiting public (eg a closed door). Only persons authorised by
the facility Operator (and those parties listed in Control 4.2) shall have access to
the Quarantine, Rearing and Breeding Facility.
6.8
Pupae in the publicly accessible area must be completely contained within a
physical structure (for instance a box composed of transparent material such as
glass), access to which is limited to persons authorised by the facility Operator
(and those parties listed in Control 4.2). Ready access by the visiting public to
the contents of the physical structure should be prevented (eg by installation of
a lock on any access flaps).
6.9
All drains, air vents and other outlets that connect to the outside of the
containment facility shall have a mesh screen securely fitted to them. The size
of the mesh shall be sufficient to prevent escape of any caterpillar or adult held.
6.10 The number of entry/exit doors to the containment facility shall be kept to a
minimum. Entry and exit of the public and staff shall be through at least one
enclosed vestibule fitted with two physical barriers to the movement of
butterflies or moths. These barriers shall include at least one self-closing door.
6.11 Within the vestibule a combination of at least two safeguards must be put in
place to reduce the likelihood that the butterflies can escape. Safeguards may
include, eg low light levels, mirrors within the vestibule so that people can
check for the presence of butterflies, a cold air curtain, or a curtain of flexible
vertical panels covering an area at least as large as the door.
6.12 Daily checks shall be made to remove leaves with eggs, caterpillars or pupae
from the Butterfly House. Any eggs, caterpillars or pupae found during this
search shall be destroyed or transferred to the Quarantine, Rearing and Breeding
Facility. Butterflies or moths that have been bred in the containment facility
may be transferred to other facilities in accordance with the transfer provisions
in the Standard.
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