FORM HS2/2 Application for approval to IMPORT OR MANUFACTURE HAZARDOUS SUBSTANCE FOR RELEASE by Rapid Assessment under section 28A of the Hazardous Substances and New Organisms Act 1996 Under the Criterion that is Similar to a Substance with an Existing HSNO Approval Name of Substance(s): Kop-Coat LOSP Option 1 Kop-Coat LOSP Option 2 Applicant: Kop-Coat New Zealand Ltd Office use only Application Code: Date received:____/____/____ ERMA NZ Contact: Application Version No: Initial Fees Paid: $ . Contents Page Section One - Applicant Details 1.1. Name and postal address 1.2 Location 1.3 Contact person Section Two ………………………………………………….……..4 ………………………………………………………………………….4 ………………………………………………………................4 - Application Type and Related Approvals Required 2.1 Rapid Assessment …………………………………………………………………5 2.2 Reference substance …………………………………………………………………5 2.3 Relevance to import or manufacture 2.4 Manufacture 2.5 Approvals needed under other legislation ………………………………………6 …………………………………………………….................................6 …………...………………………….6 Section Three - Information on the Substance(s) ………………………………………….……………..7 3.1 Identification of substance 3.2 Information on chemical and physical properties of substance(s) 3.3 Information on the hazardous properties 3.4 Identification of the default controls for the substance(s) ...………………….10 3.5 Information on what will happen to substance through its life ….………………...13 ………..…...7 …………………………………...….8 Section Four - Identification & Assessment of any Significant Variations in Risk Section Five - International Considerations Section Six - Miscellaneous 6.1 Glossary of terms 6.2 Other information considered relevant …..15 ……………………………..........................17 ...…………………………………….............17 …………………………….............17 HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 2 of 24 Section Seven - Summary or Public Information 7.1 Name of substance for public register .…………………….........................18 7.2 Purpose of application for public register ………………………...……...........18 7.3 Use categories 7.4 Executive Summary …………………………………………………….....18 …………………………………….……………………………18 Checklist .…………………………………………………………………19 Statutory Declaration .…………………………………………………………………20 HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 3 of 24 Section One – Applicant Details 1.1 Name and postal address of the organisation making the application: Name: Kop-Coat New Zealand Ltd Address: PO Box 3878 Auckland Phone: Fax: (9) – 920 1080 (9) – 920 1081 1.2 The applicant’s location address in New Zealand (if different from above): Address: Kop-Coat House No. 2 Te Papa Tipu Innovation Park 49 Sala Street Rotorua 3010 Phone: Fax: (7) 343 6304 (7) 343 6305 1.3 Name of the contact person for the application: Name: Position: Robert Wong Accountant Phone: Fax: Email: (9) 920 1080 (9) 920 1081 robert@rwca.co.nz HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 4 of 24 HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 5 of 24 Section Two – Application Type and Related Approvals Required 2.1 The Authority may make a “rapid assessment” of applications to import or manufacture a hazardous substance for release if certain criteria apply. You need to confirm that the following criterion applies and provide reasons in support of this. (See comments under “Section 2.1 of Form” in the User Guide) The application is for a substance(s) that has a similar composition and similar hazardous properties to an approved, existing substance Yes/No This application is for an oil miscible liquid (hydrocarbon carrier) containing tebuconazole, propiconazole and permethrin (each with a concentration range) and with the option of adding iodocarb as an additional mouldicide. The reference substance, HSR000007, is an oil miscible timber preservative that contains tebuconazole, propiconazole and permethrin. The oil miscible formulations in this application have the same hazardous classifications when compared to the reference substance and would also be used as timber preservatives in industrial plants. The basis for this conclusion is summarised in Sections 3.1 to 3.5 of this application. HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 6 of 24 2.2 Identify the substance with an existing approval for which you wish to use as the reference substance(s). Note you will need to supply an approval number. Applicants will probably find it convenient to cross-reference their response to the details in later sections of the application. (See comments under “Section 2.2 of Form” in the User Guide) The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations contain tebuconazole, propiconazole and permethrin, and may also contain iodocarb (Confidential Appendix A, Section 2). These new substances are referenced to HSR000007, a ready-to-use timber preservative that is also an oil miscible liquid and contains tebuconazole, propiconazole and permethrin as the active ingredients. The reference substance does not contain iodocarb however subsequent HS2/2 applications for similar substances with iodocarb included have been accepted as the overall risk and hazardous classifications have not changed. Another similar substance to the Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations is HSR000132, AZUS, and this substance does contain all the same actives; tebuconazole, propiconazole, permethrin, iodocarb. The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations do not exactly match to existing substances on the ERMA Register because of the concentration range and hydrocarbon solvent carrier system. 2.3 Is the information in this application relevant to import, manufacture or both? Import only Yes/ No Manufacture only Yes/No Import and manufacture Yes/No If import only, indicate whether or not manufacture is likely in New Zealand 2.4 n/a If the application in the application relates to manufacture in New Zealand, provide information on the proposed manufacturing process and any alternatives. Manufacture of the Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations would be at manufacturing facilities approved for flammable, toxic products. Manufacture is by a batch process. Confidential Appendix A, Section 2 HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 7 of 24 2.5 If this substance(s) needs an approval under any other legislation, has an application for this approval been made? Name of Approval Application made Agricultural Compounds and Veterinary Medicines Act 1997 Food Act 1981 Medicines Act 1981 Chemical Weapons (Prohibition) Act 1996 Radiation Protection Act 1965 Biosecurity Act 1993 Resource Management Act 1991 Other (please specify): Yes/No/NA Yes/No/NA Yes/No/NA Yes/No/NA Yes/No/NA Yes/No/NA Yes/No/NA Yes/No HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 8 of 24 Section Three – Comparative Information on the Substance(s) 3.1 State the unequivocal identification of the substance(s). The active ingredients (3 fungicides and an insecticide) are listed on the ERMA Register (see Table 1 below) and the sources of supply are already used in similar timber preservative formulations in New Zealand. The active ingredients are solubilised in hydrocarbon solvent carriers and the formulations include other non-hazardous additives. The difference between the Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations, is in the hydrocarbon solvent carrier system. Table 1: List of active ingredients in the Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations Active Ingredient Tebuconazole CAS No 107534-96-3 ERMA Register HSR002879 Propiconazole 60207-90-1 HSR003109 Iodocarb 55406-53-6 HSR002733 Permethrin 52645-53-1 HSR003111 3.2 Provide information on the chemical and physical properties of the substance(s). The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations have the same chemical and physical property specification (Confidential Appendix A, Section 2). Table 2: Chemical and physical properties Characteristic Appearance Odour Density Flashpoint Description Clear to light yellow liquid Hydrocarbon 0.79 – 0.80 Option 1 : 38 0C HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 9 of 24 Option 2 : 51 0C Immiscible Not applicable Solubility in water pH 3.3 Provide information on the hazardous properties of the substance. The hazardous properties of the Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations have been determined using mixture classification rules based on the data points from the ERMA classification database (www.ermanz.govt.nz) and taking account of the concentration cut-off limits (Confidential Appendix A, Sections 3 & 4). It is noted that the reference substance (HSR000007) did not originally have 6.5A and 6.5B classifications as the concentration threshold was 1% w/w at the time but is now 0.1% w/w. The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations do not trigger a 6.9B classification. While there are components that are identified with a 6.9B classification (Confidential Appendix A, Section 3), none of these components are present at > 1% w/w. Otherwise all the hazardous classifications are the same as the reference substance (Table 3). Table 3: Hazardous classification Class 1 Explosive Summary of Hazardous Property Classifications Reference substance [HSR000007] Not triggered Kop-Coat LOSP Option 1 Kop-Coat LOSP Option 2 Not triggered Not triggered 3.1C 3.1C (FP 380C) 3.1C (FP 510C) Class 5 Oxidiser Not triggered Not triggered Not triggered Class 8 Corrosive Not triggered Not triggered Not triggered 6.1E aspiration, inhalation 6.1E aspiration, inhalation (hydrocarbon solvent) 6.1E aspiration, inhalation (hydrocarbon solvent) Class 3 Flammable Class 6.1 Acute toxicity HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 10 of 24 Hazardous classification Class 6.3 Skin irritancy Class 6.4 Eye irritancy Reference substance [HSR000007] 6.3B Kop-Coat LOSP Option 1 Kop-Coat LOSP Option 2 6.3B 6.3B Not triggered Not triggered Not triggered Class 6.5 Sensitisation 6.5A, 6.5B* 6.5A, 6.5B (permethrin) 6.5A, 6.5B (permethrin) Class 6.6 Mutagen Not triggered Not triggered Not triggered Class 6.7 Carcinogen Not triggered Not triggered Not triggered Class 6.8 Reproductive, development toxicant Class 6.9 Target organs, systems Not triggered Not triggered Not triggered 6.9B Not triggered Not triggered Class 9.1 Aquatic ecotoxicity 9.1A 9.1A (propiconazole, iodocarb, permethrin) Not triggered 9.1A (propiconazole, iodocarb, permethrin) Not triggered Class 9.2 Soil ecotoxicity Not triggered Class 9.3 Terrestrial vertebrates Not triggered Not triggered Not triggered 9.4B 9.4B (permethrin) 9.4B (permethrin) Class 9.4 Terrestrial invertebrates * not originally identified as 6.5A and 6.5B because of cut-off concentration at that time (which is now lower at 0.1% w/w) HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 11 of 24 3.4 Identification of the default Controls on the substance(s). The Default Controls for the reference substance are summarised in Table 4. The Approved Handler (AH1) and Tracking (TR1) Controls are listed. These are triggered by the 9.1A aquatic toxicity classification. Subsequent to the reference substance being approved, ERMA have waivered the AH1 and TR1 Controls for timber preservatives when triggered by a 9.1A classification. The applicant requests ERMA to consider a waiver also for the Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations. Table 4: Control Code Default controls for reference substance, HSR 000007 Regulation Explanation Hazardous Substances (Classes 1 to 5 Controls) Regulations 2001 F1 Reg 7 General test certification requirements for all class 1 to 5 substances F2 Reg 8 General public transportation restrictions and requirements for all class 1 to 5 substances F3 Reg 55 General limits on all flammable substances F5 Regs 58, 59 Requirements regarding hazardous atmosphere zones for class 2.1.1, 2.1.2 and 3.1 substances F6 Regs 60-70 Requirements to prevent unintended ignition of class 2.1.1, 2.1.2 and 3.1 substances F11 Reg 76 Segregation of incompatible substances F12 Regs 77, 78 General requirement for all for hazardous substance locations for flammable substances F14 Reg 81 Test certification requirements for facilities where class 2.1.1, 2.1.2 or 3.1 substances are present F16 Reg 83 Controls on transit depots where flammable substances are present F17 Regs 84, 85 Requirements to control adverse effects of intended ignition of flammable substances, including requirements for protective equipment and clothing Hazardous Substances (Classes 6, 8 and 9 Controls) Regulations 2001 – Toxic Property Controls T1 Regs 11 – 27 Limiting exposure to toxic substances; setting values for acceptable daily intake (ADE)/reference dose (RfD), potential daily exposure (PDE), tolerable exposure limit (TEL); prohibition on use of substances in excess of TEL T2 Regs 29, 30 Controlling exposure in places of work and other ‘use’ situations; setting of workplace exposure standards (WES) T4/E6 Reg 7 Requirements for equipment used to handle substances T7/E8 Reg 10 Restrictions on carriage of toxic substances on passenger service vehicles HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 12 of 24 Control Code Regulation Explanation T8 Reg 28 Controls for vertebrate poisons Hazardous Substances (Classes 6, 8 and 9 Controls) Regulations 2001 – Ecotoxic Property Controls E1 Regs 32 – 45 Limiting exposure to ecotoxic substances, the environmental exposure limit (EEL) approach E2 Regs 46 – 48 Restrictions on use of substances in application areas E3 Reg 49 Controls relating to protection of terrestrial invertebrates eg beneficial insects E5/T3 Regs 5, 6 Requirements for keeping records of use E7/T6 Reg 9 Quantities of class 6, 8 and 9 substances that require an approved handler E8 Reg 10 Restrictions on carriage of ecotoxic substances on passenger service vehicles Hazardous Substances (Identification) Regulations 2001 I1 Regs 6, 7, Identification requirements, duties of persons in charge, accessibility, 32-35, 36 comprehensibility, clarity and durability (1)-(7) I3 Reg 9 Priority identifiers for ecotoxic substances I5 Reg 11 Priority identifiers for flammable substances I8 Reg 14 Priority identifiers for toxic substances I9 Reg 18 Secondary identifiers for all hazardous substances I11 Reg 20 Secondary identifiers for ecotoxic substances I13 Reg 22 Secondary identifiers for flammable substances I16 Reg 25 Secondary identifiers for toxic substances I17 Reg 26 Use of generic names I18 Reg 27 Requirements for using concentration ranges I19 Regs 29 – 31 Additional information requirements, including situations where substances are in multiple packaging I21 Regs 37-39, General documentation requirements 47-50 I23 Reg 41 Specific documentation requirements for ecotoxic substances I28 Reg 46 Specific documentation requirements for toxic substances I29 Regs 51, 52 Signage requirements I30 Reg 53 Advertising corrosive and toxic substances Hazardous Substances (Packaging) Regulations 2001 P1 P3 Regs 5, 6, 7 (1), 8 Reg 9 General packaging requirements Criteria that allow substances to be packaged to a standard not meeting Packing HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 13 of 24 Control Code Regulation Explanation Group I, II or III criteria P5 Reg 11 P13 P15 PG3 Reg 19 Reg 21 Schedule 3 Pacakaging requirements for flammable liquids (subclass 3.1) Packaging requirements for toxic substances (class 6) Packaging requirements for ecotoxic substances (class 9) Packaging requirements equivalent to UN Packing Group III Hazardous Substances (Disposal) Regulations 2001 D2 D4 D5 D6 D7 Reg 6 Reg 8 Reg 9 Reg 10 Regs 11, 12 D8 Regs 13, 14 Disposal requirements for class 2,3,4 substances (flammables) Disposal requirements for class 6 and 8 substances (toxics and corrosives) Disposal requirements for class 9 substances (ecotoxics) Disposal requirements for packages Information requirements for manufacturers, importers and suppliers, and persons in charge Documentation requirements for manufacturers, importers and suppliers, and persons in charge Hazardous Substances (Emergency Management) Regulations 2001 EM1 EM9 Regs 6, 7, 911 Reg 8(c) Reg 8(e) Reg 8(f) Regs 12–16, 18–20 Reg 17 EM10 EM11 Regs 21-24 Regs 25 – 34 EM12 EM13 Regs 35 – 41 Reg 42 EM4 EM6 EM7 EM8 Level 1 information requirements for suppliers and persons in charge Information requirements for flammable substances Information requirements for toxic substances Information requirements for ecotoxic substances Level 2 information requirements for suppliers and persons in charge Additional information requirements for flammable and oxidising substances and organic peroxides Fire extinguisher requirements Level 3 emergency management requirements: duties of person in charge, emergency response plans Level 3 emergency management requirements: secondary containment Level 3 emergency management requirements: signage Hazardous Substances (Tracking) Regulations 2001 TR1 Regs 4(1), 5, 6 General tracking requirements Hazardous Substances (Personnel Qualifications) Regulations 2001 AH1 Regs 4 – 6 Approved Handler requirements (including test certificate and qualification HS2/2 Page 14 of 24 s.28A Rapid Assessment under Similar to Existing Substance Criteria Control Code Regulation Explanation requirements) Hazardous Substances (Tank Wagon and Transportable Containers) Regulations 2004 Controls for Stationary Container Systems These controls are set out in Schedule 8 of the Hazardous Substances (Hazardous Substances (Dangerous Goods and Schedule Toxic Substances) Transfer Notice 2004. The requirements of this schedule are detailed in the Compilation of Hazardous Substances Regulations and Controls (http://www.ermanz.govt.nz/hs/hs-regulations.html). Controls Relating to the adverse effects of unintended ignition Code Schedule 10 Schedule 10 of Gazette Notice Issue 35 - Hazardous Substances GN35A* (Dangerous Goods and Scheduled Toxic Substances) Transfer Notice 2004 prescribes additional requirements relating to controlling the adverse effects of unintended ignition of class 2 and 3.1 flammable substances 3.5 Provide comparative information on what will happen to the substance throughout its whole life from its introduction into New Zealand, its uses, through to disposal. Manufacture It is the intention to manufacture the Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations in New Zealand using existing manufacturing facilities. The facility used will need to have the necessary approvals, e.g. a Location Certificate, consent from local Councils. Packaging Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations are ready-to-use (RTU) timber preservative solutions. In other words the formulations do not require further dilution after delivery to the treatment plant and prior to impregnation into timber at the industrial treatment facility. HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 15 of 24 The preferred formulation would be despatched to the timber treatment plant in a chemical tanker (capacity 5,000 to as much as 20,000L) designed to carry flammable liquids. There may be occasions where product needs to be stored or shipped in 200L drums (mild steel) or 1000 L bulki bins but this is very unlikely. A Safety Data Sheet would be available ((Confidential Appendix A, Section 5). Transport & storage The formulation could be transported by road or rail within New Zealand. This might include shipments across Cook Strait. The formulation would be transported and stored in accordance with the requirements of NZS 5433:2007, marine transport regulations (IMDG) and the HSNO regulations. A suitable Dangerous Goods category us UN 1306, WOOD PRESERVATIVES, LIQUID, Class 3, PG III, Hazchem 3Y. Application The formulations would only be available for industrial purposes for application to timber in vacuum impregnation plants. These treatment plants have been previously required to meet or exceed the Best Practice Guideline for Timber Treatment [www.nztpc.co.nz]. Use The wood treatment facilities are purpose designed and located on industrial sites with limited access to the public. The Kop-Coat LOSP formulations would be used to treat dry timber products to hazard classes as specified in the New Zealand Standard NZS3640:2003 Chemical Preservation of Round and Sawn timber, and including subsequent amendments to that standard. For sawn timber for export to Australia, and other types of wood products, the reference preservative standard is AS/NZ 1604, Parts 1 – 5 inclusive. If exporting to other countries, e.g. USA, then the specification/standard for that country would apply. The preservative Standards or specifications describe the penetration requirements and concentration (retention) for the preservative actives. The general rule is that 100% penetration of the sapwood is required and in some instances a degree of penetration of the heartwood. The proposed timber application (treatment plant, application/impregnation schedules) would be the same/similar to the reference product (HSR000007) . Generally the nett uptake of solution will be in the range of 25 – 40 L /m3. The concentration of active components in the treatment solution covers the solution strengths required to achieve the minimum concentration of the specified active ingredient (tebuconazole, propiconazole, iodocarb, permethrin) in the timber. Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations are ready-to-use treating solutions but cover a concentration range that will allow optimisation for specific plant configurations/treatments processes and for the wood product type/market specification. HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 16 of 24 Disposal Specific warnings can be provided on the label, Safety Data Sheets and product documentation, not to dispose of the product (or used packaging whenever applicable) into waterways or drains because of the aquatic and soil toxicity of the active ingredients. Section Four: Identification and Assessment of any Significant Variations in Risk between the Proposed Substance(s) and the Reference Substance(s) The lifecycle of the Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations has been considered to assess potential risk events and consequences (Table 5). No risks specific to Maori concerns have been identified that would not also apply to the reference substance . The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations have the same or less hazardous classifications for each category when compared to the reference substance. Impregnation (treatment schedules) into timber at industrial timber treatment facilities for the treated timber would be similar. The safe operation of these plants as required under the Best Practice Guideline for Timber Treatment. The minimum concentrations of active ingredients required in timber is in the New Zealand treatment standard, NZS3640:2003. Transport will be of dilute product(ready-to-use timber treatment solutions). Delivery of dilute LOSP type preservatives is preferred as this avoids the handling of concentrates at the treatment site and dilution with hydrocarbon solvent at the treatment site. The manufacture/supplier can also check the concentration of all active components more easily, than the treatment plant operator Tanker delivery also avoids the potential risk of disposal of packaging containing flammable/toxic/ecotoxic residues. The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations do not present any increase in risk to that of the reference substance HSR000007. Table 4: Summary of Potential Risk Events during the Lifecycle of the formulations Life cycle step Potential risk event HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Possible consequence Page 17 of 24 Life cycle step Manufacture Potential risk event Containers/packaging damaged or leaking (raw material components, finished product) Labels damaged, missing or illegible Mixed with incompatible substances Spillage from mixing &/or failure of bunding Fire Natural disaster , e.g. earthquake Containers (tanks) damaged or leaking Spillage from transport accident Fire Containers (tanker valves) opened (unauthorised people) Stored where children have access to product Release into environment (water, soil) Contact with people, animals Release into environment (water, soil) Contact with people, animals, foodstuffs Release into environment (water, soil) Skin, eye or inhalation contact with people, specifically children, also pets, birds, beneficial invertebrates Contact with skin, eyes Inhalation from aerosol mists (treatment vessel door) or solvent vapours (treated timber) Product swallowed Used where there is contact with foodstuffs, pets, children Contamination of waterways Over treatment of timber (high residual solvent levels) Releasing timber too soon after treatment Off label use Cleaning of delivery tanks Treated timber Release into environment (water, soil) Product swallowed (contaminated containers used for drinks or foodstuffs) Transport & Storage Treated timber Disposal Possible consequence HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 18 of 24 Life cycle step Potential risk event Possible consequence Skin or eye contact with product Section Five – International Considerations 5.1 ERMA New Zealand is interested in whether this substance (or any of its components) has been considered by any other regulatory authority in New Zealand or by any other country. If you are aware of this, please provide details of the results of such consideration. (Optional). - Section Six – Miscellaneous 6.1 Provide a glossary of scientific and technical terms used in the application. - 6.2 Provide here any other information you consider relevant to this application not already included. HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 19 of 24 Section Seven – Summary of Public Information 7.1 Name of the substance(s) for the public register: Kop-Coat LOSP Option 1 Kop-Coat LOSP Option 2 7.2 Purpose of the application for the public register: To manufacture Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations as ready-to-use timber preservative solutions. 7.3 Use Categories of the substance(s): Main category: Industry category: Function/Use category: 3 (Non- dispersive use) 0 (Other) 39 (Pesticides, non-agricultural) HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 20 of 24 7.4 Executive Summary: In this section, the applicant should provide a summary of information contained in this application, including: the identification of the substance, its hazardous properties and intended uses and disposal; and any information provided on the significant risks (adverse effects) of the substance (See comments under “Section 7.4 of Form” in the User Guide) The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations contain tebuconazole, propiconazole and permethrin and may contain iodocarb. The difference between the formulation options is the hydrocarbon solvent carrier. Both formulations trigger the same hazardous classifications; 3.1C, 6.1E (aspiration, inhalation), 6.3B , 6.5A, 6.5B, 9.1A and 9.4B . The reference substance (HSR000007) has the equivalent hazardous classifications but also a 6.9B classification. The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations would be used for the same purpose and in the same manner as the reference substance. No additional risks have been identified. The Kop-Coat LOSP Option 1 and Kop-Coat LOSP Option 2 formulations would be manufactured as ready-to-use (R-T-U) timber preservative solutions that would be delivered by chemical tanker to industrial timber treatment facilities. The timber treatment plants have been required to meet or exceed the requirements of a Best Practice Guideline for Timber Treatment. The proposed timber treatment equipment and application methods for the treated timber are identical to the reference substance. The concentration of active components required in the timber is as specified in the New Zealand Standard for Timber Preservation, NZS3640:2003, or applicable overseas equivalent. Product to be disposed of from a treatment facility can be recycled by re-use through another treatment plant, or the solvent recovered or solution re-worked (for re-use as a timber preservative). Any residues (from rinsed containers) can be recycled. Waste that cannot be recycled/reworked (residues or liquid) would be disposed of through an approved waste management company. Treated timber disposal options may be by recycling, incineration (where approved by local authority) or to landfill. HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 21 of 24 CHECKLIST Mandatory sections filled out Yes Appendices enclosed Yes/ NA Initial fee enclosed Application signed and dated Yes Yes Electronic copy of application e-mailed to ERMA NZ Yes HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 22 of 24 Signature and Statutory Declaration I, _______________________________________[full name], of ___________________________________________________ [Address], __________________________________________ [Occupation/position] being the applicant or authorised to do so on behalf of the applicant, verify that the information contained in this application is true and correct. I make this solemn declaration conscientiously believing the same to be true and by virtue of the Oaths and Declarations Act 1957. __________________________________ Signature Declared at _________________on this ______day of ____________, 200____ before me: __________________________________ Signature __________________________________ [Name] Barrister or Solicitor of the High Court of New Zealand [or Justice of the Peace, Notary Public, or other person authorised to take a statutory declaration] HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 23 of 24 Appendix A : Commercially Sensitive Information HS2/2 s.28A Rapid Assessment under Similar to Existing Substance Criteria Page 24 of 24