FORM HS2/2 Application for approval to IMPORT OR MANUFACTURE HAZARDOUS SUBSTANCE FOR RELEASE by Rapid Assessment

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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
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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
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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
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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.
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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
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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
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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
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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
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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)
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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
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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
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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
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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.
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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.
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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
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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
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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.
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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)
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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.
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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
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