Submission on Application to reassess Quintozene (Application Code: ERMA200692) To: Quintozene 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 'water dispersible granule or wettable powder containing 750g/kg quintozene' to take into account that it contains dioxin as a contaminant. ERMA New Zealand proposes the following preliminary recommendation: that the approval for the quintozene-containing substance (HSR000742) shall be revoked. 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 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. Page 1 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=erma200692 Decision sought Please select one option I support the recommendation in this application and would like it approved (i.e. the approval for quintozene would be revoked) OR I oppose the recommendation in this application and would like it declined (i.e. the approval for quintozene would be retained) OR I neither support nor oppose the recommendation in this application Hearing Please select one option I wish to speak at a hearing in support of my submission OR I do not wish to speak at a hearing in support of my submission Revocation of the approval for the substance containing quintozene with its associated dioxin contaminant. ERMA New Zealand is proposing that the approval for the substance containing quintozene that is used to control fungal diseases in seeds, bulbs and recreational turf is revoked. Non-negligible adverse effects on human health and the environment have been identified from the use of quintozene with its dioxin contaminant and alternative fungicidal products that can replace quintozene have been identified. Time limit The application proposes that the use of quintozene be discontinued and that any stocks must be used up within 6 months. Do you have any comments about this proposed duration of time allowed to use up stocks? Do you have any comment about the proposal that no additional controls are applied during that 6 month period? Page 2 Information sought by the applicant (ERMA New Zealand) ERMA New Zealand is seeking further information in the following areas which may help us to assess the risks, costs and benefits. Are there any uses of quintozene not covered in the application? Do you have any information on application rates or methods which differ from those used in the assessment? Effects on society and communities What potential adverse effects might the continued used of quintozene wit its dioxin contaminant have on society and communities? What potential positive effects might the continued used of quintozene with its dioxin contaminant have on society and communities? Effects on the environment What potential adverse effects might the continued used of quintozene with its dioxin contaminant have on the environment? Can you provide any ecotoxicological, persistence, or fate data that should be taken into account in the assessment, particularly in relation the assessment of risks to: - birds and bees; - aquatic and terrestrial plants; - soil organisms; - terrestrial invertebrates (other than bees)? Page 3 Are there other controls that can be applied to address risks to the environment? Effects on human health and safety What potential adverse effects might the continued used of quintozene with its dioxin contaminant have on human health and safety? Do you have any information which can refine the assessment of the risks to human health from the quintozene or its dioxin contaminant? (Such as information on work practice, or use of personal protective equipment which will adequately protect human health). Do you have any comments on whether the assessment of the risks to human health from the dioxin contaminant is appropriate? What potential positive effects might the continued used of quintozene have on human health and safety? Page 4 Effects on the market economy What potential adverse effects might the continued used of quintozene with its dioxin contaminant have on the market economy? What potential positive effects might the continued used of quintozene have on the market economy? In particular, do you have any comments on whether the alternative fungicides that are available can adequately replace all quintozene uses, including costs to growers? Effects on Māori culture and values What potential adverse effects might the continued used of quintozene with its dioxin contaminant have on Māori culture and values? What potential positive effects might the continued used of quintozene have on Māori culture and values? Additional Information Is there any additional information you would like to provide to help us assess the risks, costs and benefits? Page 5