Tnl 2650
APPLICATION FORM
Form HS1 Import or Manufacture
any Hazardous Substance for Release
under section 28 of the Hazardous Substances and New Organisms Act 1996
Send by post to: Environmental Protection Authority, PO Box 131, Wellington 6140 OR email to: info@epa.govt.nz
Payment must accompany application; see our fees and charges schedule for details.
Name of Substance(s)
Tnl 2650
Applicant
Zelam Ltd
Date
27 June 2012
APPLICANT CHECKLIST
Mandatory sections filled out
yes
Appendicies enclosed
yes
Fees Enclosed
Approved creditor – please invoice
Signed and dated
27 June 2012
OFFICE USE ONLY
Application Code
Date received
EPA Contact
Initial Fees Paid $
Application Version No
www.epa.govt.nz
Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
Important
1. The level of information that you need to provide in this application is dependent upon the scale and the
significance of the risks and/or whether these risks are well understood and controlled.
2. You can talk to an applications officer at the EPA who can help you scope and prepare your application. We
need all relevant information early on in the application process. Quality information up front will speed up the
process.
3. This application form may be used to seek approvals for more than one hazardous substance where the
substances are related, for example a concentrated compound (active ingredient) and its related formulations
or the two parts of an epoxy glue.
4. Any extra material that does not fit in the application form must be clearly labelled, cross-referenced, and
included in an Appendix to the application form.
5. Commercially sensitive information must be collated in a separate Appendix.
6. Applicants must sign the form and enclose the correct application fee. The initial application fee can be found
in our published Schedule of Fees and Charges. Make sure that you have an up to date copy of the Schedule.
Please check with EPA staff. We are unable to process applications that do not contain the correct fee.
7. Unless otherwise indicated, all sections of this form must be completed for the application to be progressed.
Where an applicant is unable to complete the sections marked optional, this information may be derived by the
EPA and the costs of doing so will be recovered from the applicant as part of the processing costs.
8. You can get more information at any time by contacting us. One of our staff members will be able to help you.
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
1. Applicant Details
1.1. Name and postal address in New Zealand of the organisation making the application:
Name:
Zelam Ltd
Address:
P O Box 7142, NEW PLYMOUTH 4341
Phone:
06 755 9234
Fax:
06 755 1174
1.2. The applicant’s location address in New Zealand (if different from above):
Address:
Hudson Road, NEW PLYMOUTH
1.3. Name of the contact person for the application:
This person should have sufficient knowledge to respond to queries and either have the authority to make decisions on behalf of the
applicant that relate to processing the application, or have the ability to go to the appropriate authority.
Name:
Chris Hayward
Position:
Regulatory Affairs
Address:
P O Box 7142, NEW PLYMOUTH 4341
Phone:
06 755 9234
Fax:
06 755 1174
Email:
chayward@zelam.com
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
2. Application Type and Related Approvals Required
This form is only to be used for an application to import and/or manufacture a hazardous substance for ‘release’ and if it does not meet the
requirements for rapid assessment. Please note that it is the substance(s) which is approved, and thus the approval covers both import and
manufacture.
If you are making the application for some other reason, you will need a different form.
2.1. Is the information in this application relevant to import, manufacture or both:
Import only?
Manufacture only?
Import and manufacture? YES
If import only, indicate whether or not manufacture is likely in New Zealand
2.2. If the information in the application relates to manufacture in New Zealand, provide information on
the proposed manufacturing process and any alternatives.
This application is for an agricultural compound containing 2 actives. Both actives are currently approved by EPA.
The Agricultural compound will be manufactured in New Zealand from ingredients sourced from New Zealand and
overseas. Full details of the manufacturing process are included in appendix i.
2.3. If you have reasons for not providing detailed information in this application, explain what they are
and provide some justification.
An example of a reason for not giving detailed information is where an approval has been given by another jurisdiction and information that
led to that approval can be referenced or the substance will be used in low risk situations or ways.
Detailed information provided in appendix i
2.4. If this substance(s) needs an approval under any other legislation, has an application for this
approval been made?
(Optional)
ACVM registration pending
3. Information on the Substance(s)
Note all information that is commercially sensitive must be attached as an Appendix. The application form should be cross-referenced to the
Appendix but should be able to be read as a stand-alone document which will be publicly available.
You will need to provide a brief description of where the information in the application has been sourced from, eg from; inhouse data,
research, technical literature, etc.
If approval is being sought for more than one hazardous substance, this section must be completed separately for each hazardous
substance.
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
3.1. State the unequivocal identification of the substance(s).
This section should include all information necessary to unequivocally identify the substance(s) and may include:

Chemical Name (Chemical Abstracts Preferred Index name or IUPAC name)

Common Name

Synonyms

Trade Names

CAS Registry Number

Molecular Formula

Structural Formula

Significant impurities
For mixtures, in addition to the above information being provided on the actual mixture, information is also required on the composition of the
mixture i.e. the chemical name, CAS number, function (eg active ingredient, emulsifier, surfactant, filler) and percentages of ALL
components of the mixture (including non-hazardous components and impurities) should be provided. This information may be best
expressed in tabular form. If the composition is variable, please ensure to state the limits.
If there are commercial reasons for not providing full information in the main part of the form, alternative approaches must be discussed with
and agreed by the EPA. These must include the provision of a unique identifier of some kind.
TNL 2650
3.2. Provide information on the chemical and physical properties of the substance(s).
Provide as much information as possible on the chemical and physical properties of the substance(s) [at 20C and 1 atmosphere unless
otherwise stated] eg
1. Appearance (colour, odour, physical state or form)
2. pH
3. Density
4. Vapour pressure
5. Boiling/melting point
6. Solubility in water
7. Water/octanol partitioning co-efficient
For mixtures, information is required on the chemical and physical properties of the mixture itself. However, if this information is not
available, you should provide information on the chemical and physical properties of EACH hazardous component of the mixture
Appearance (colour, odour, physical state or form)
Clear pale yellow liquid
pH
3.5 – 4.5
Density _ S.G.
0.965
Solubility in water
Very soluble
3.3. Provide information on the hazardous properties of the substance(s).
Information should be provided on the hazardous properties of the substance(s) known to the applicant. You must consider each of the six
hazardous properties below and provide information on those hazardous properties that trigger any threshold level. If you wish, you may
assign the relevant HSNO classification category to each hazardous property that exceeds these threshold levels.

explosiveness

flammability
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release




oxidising properties
corrosiveness
toxicity
ecotoxicity
If your substance is a mixture and you cannot provide direct information on its hazardous properties, you can apply mixture rules to the
hazardous components of the mixture. If you do this, then you will need to provide information on the hazardous properties of each
hazardous component of the mixture, and show your workings.


explosiveness
n/a

flammability
n/a

oxidising properties

corrosiveness

toxicity

ecotoxicity
n/a
8.3A
as per SOS 1001731
6.3A, 6.8A, 6.9B as per SOS 1001731
9.1A, 9.2B as per SOS 1001731
3.4. Identification of the default Controls on the substance(s).
A range of default controls are triggered by the hazardous property classification(s) attached to the substance. If you wish, you can list what
these default controls are. If you don’t provide this information, the EPA will do it for you. Regardless, you need to be aware of what the
default controls are so that you can take them into account when assessing risks – see Section 4.
(Optional)
These are undertood by the applicant but not listed here.
3.5. Provide information on what will happen to the substance throughout its whole life from its
introduction into New Zealand, its uses, through to disposal.
This information is used in the development of exposure scenarios and the assessment of risks, costs and benefits and should therefore be
as expansive as possible.
Purpose of Use:
Manufacture:
Tnl 2650 is a coded agricultural compound designed to be diluted prior to use. Target
crops are food and fodder cereal, clover and grass seed crops.
Tnl 2650 will be manufactured at Zelam Ltd’s site in New Plymouth. This facility has ISO 9001
accreditation for the manufacturing and handling of chemicals. Quality control systems in place for
the control of dust, spillage and wash-waters.
No waste substance is allowed to leave the site but is treated on-site, as per the waste
management system.
Staff have received the appropriate training for handling of the raw materials and all MSDS,
production techniques and safety controls are available at all times.
Full details of the production of the tnl 2903 is enclosed in appendix 1.
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
Storage:
Transport:
End-use and
Disposal:
Storage on-site is within the confines of Zelam Ltd’s fully bunded area where any inadvertent
spillage is prevented from entering the city’s storm-water system or the environment via the soil or
any runoff.
Containers are UN Approved HDPE jerry cans with tamper evident lids, sizes ranging for 1 - 20
Litres: HDPE Spec UN3HI/Y/1-4/100 or 110, 200, 1000 litre bulk containers: HDPE UN Spec
1H1/Y/1.4/100; AUS 20244.
These are shrink-wrapped onto pallets for easy of movement and storage.
Storage at retailer / agricultural distributor stores will be on standardised racking, placcarded and
controlled within the requirements of the HSNO Act.
Where possible tnl 2650 will be shipped on pallets. To ship individual 20 litre containers they are
covered with a plastic sleeve - leaving the handle exposed- to protect the label and safety
instructions.
1,5and 10 litre containers are packed in cardboard outers and accompanied with the required
transport documents.
Transport is by approved carriers with the correct placcarding for the hazard class of this product
and accompanied by product MSDS and ESG see appendix iii
Tnl 2650 is designed as a herbicide and as such will be used in the approved manner
according to the label and there will be no requirement to dispose of any material. If the enduser has a requirement to dispose of diluted spray solution it is recommended that he use the
product in the manner in which it was intended or if it is large volumes contact his local council
for options to send to an approved land fill.. Empty containers will be triple rinsed, with rinsate
used as part of the spray mix, and preferably returned to an agrecovery depot for recycling.
Failing that they should be either burnt, weather permitting or crushed and buried in an
approved landfill.
4. Risks, Costs and Benefits
These are the positive and adverse effects referred to in the HSNO Act. It is easier to regard risks and costs as being adverse (or negative)
and benefits as being positive. In considering risks, cost and benefits, it is important to look at both the likelihood of occurrence (probability)
and the potential magnitude of the consequences, and to look at distribution effects (who bears the costs, benefits and risks).
You will need to consider the effects on the environment and human health and welfare, including any social effects.
In each section set out below, it might be easier for you, and most useful for the EPA, if the information is set out under the following three
sub sections:

Costs and benefits which can be stated in monetary (dollar) terms

Non-monetary risks and costs

Non-monetary benefits.
Complete this section as far as you can. If the analysis provided is incomplete, then it will be completed by the EPA. However, the costs of
doing this will be chargeable.
You will need to provide a brief description of where the information in the application has been sourced from, eg from; inhouse research,
independent research, technical literature, community or other consultation.
4.1. Identify all of the potential risks, costs and benefits of the substance(s)
Identification is the first step in assessing risks, costs and benefits. It is important to think about the source of the risk, i.e. the way in which
the risk is created (the exposure pathway), and then the consequences and likelihood of exposure.
You should try to think as widely as possible about every potential risk, cost and benefit and give a brief description. You must also decide
how significant that risk, cost or benefit is likely to be. If the risk, cost, or benefit is obviously not significant (and you can give reasons), then
there is no need to further assess that risk, cost, or benefit.
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
The actives difflufenican and flumetsulam are both currently registered under the ACVM Act 1996 for use on
agricultural food crops in New Zealand. MRLs have been set for difflufenican at 0.01 mg/Kg for barley and wheat .
The Actives will be imported and used in controlled conditions to manufacture an emulsifible concentrate coded
tnl 2650. Liquid formulations offer the end-user a safer product to handle with dust when compared to other
formulation types .
This analysis must be taken in context with the fact that the components of this substance that could promote a risk
are all currently used in the agricultural and horticultural markets of New Zealand. This substance has taken the
actives and combined them with adjuvants commonly used in this industry. Therefore we believe that are no
additional risks to the environment.
Risk Identified
Significant
Reason
Providing suitable transport
delivery facilities
No
Transport controls already in place for
moving similar products
Providing containment for
storage
No
Sites using and storing agricultural
compounds will already have storage controls
in place.
The consequences of a spillage
(with associated environmental
damage potential)
No
With controls in place, accidental spillage or
non-compliance could create risk, however
the monetary risk is considered low since the
hazard classifications mollerate the risks.
Therefore environmental damage will be
minimal.
Adverse health effect on
workers or users.
No
Handling the actives could cause health risks
but this is not likely to be permanent and
protective clothing is supplied to adequately
protect workers.
Inappropriate use of the product
Yes
Even with controls in place, inappropriate use
or non-compliance could create risk
Disposal of unused substance
No
When used within label directions, tnl2650
will not pose a risk to the environment. Off label application to other crops could result
in compromising the food safety standards
with regard to MRLs resulting in the nonsaleability of these crops.
Disposal of packaging
No
Any unused product can be safely stored in
its original container until required for the next
application or for the following season. If
product did require disposal then it should be
used in accordance with the label directions
ie. sprayed out over an orchard or returned to
the manufacturer fro reblending if
appropriate.
Spillage or handling incident at
manufacturing stage
No
Damage to aquatic organisms
YES
November 2010 HSAF106-11
Zelam Ltd’s manufacturing site is a purpose
built facility with full bunding to contain
spillage and double concentric pipework to
reduce potential impact of earthquake. Site
procedures are covered by ISO9001.
EPA have assessed tnl 2650 as triggering
9.1A.
8
Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
Inappropriate use of the product
Yes
Off -label application to other crops could
result in compromising the food safety
standards with regard to MRLs.
Public exposure.
No
Tnl 2650 will be used in controlled
environments with limited public access.
Risk of environmental damage
no
Non-compliance with controls
No
The components of tnl 2650 are currently in
use as agricultural compounds, the risks are
no greater.
.
This could apply to spillage in transport,
container leakage, inappropriate use or
labelling. The range of controls applied
under the HSNO Act should minimise the
risks associated with non-compliance.
Natural hazard (earthquake,
flood, volcanic activity), or
deliberate sabotage
No
Benefit Identified
Significant
Containment during manufacture, appropriate
packaging and low likelihood of bulk storage
reduce the risk associated with natural
disaster. Deliberate sabotage is
unquantifiable, though unlikely, and effect
would be short term.
Reason
A more cost-effective, easier to
handle product.
Yes
This new coded product tnl 2650 is an
unique blend of 2 actives both important in
the control of weeds in agricultural crops.
By combining the 2 at the correct ratio a
more cost effective product has been
produced.
A reduction in the adverse
reaction of workers to the
chemicals
A reduction in the risk to the
environment in the event of a
spillage
Yes
Use of safer chemicals reduces risk of long
term health issues
Yes
In cases of control non-compliance, cost of
remedial work may be lower than
competing products because of benign
nature of ingredients.
Reduced risk of over-use.
Yes
By formulating these 2 very effective
actives into 1 compound the end user can
more accurately apply the correct amount
of active to control disease.
User friendly nature of the
product,
Yes
liquid formulations are easier to measure,
pour and mix therefore minimise the risk of
wastage and over application. No dust
hazard.
Reduction in the number of
containers to be disposed
Yes
The number of plastic containers used
over the season is considerable, by offering
1 compound with 2 actives to control
disease we are reducing the number
needed and ultimately requiring disposal.
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
4.2. Provide an assessment of those risks, costs, and benefits identified in Section 4.1 which might be
significant.
This section excludes risks, costs, and benefits which relate specifically to Māori taonga or to international agreements. See Sections 4.3 and
4.4 below for those aspects.
Assessments only need to be done for those risks, costs and benefits which Section 4.1 shows might be significant. Remember that
assessments can be qualitative i.e. based on judgements, if there is no analytical information available. But it is essential that a firm conclusion
is drawn about the size and likelihood of the risks, costs or benefits, and also about the certainty of the assessment.
In assessing risks especially, it is important to take account of the extent to which risks will be reduced by the default or other controls (see
Section 3.4 above and 4.5 below).
Calculated levels of risk associated with the formulated product tnl 2650
Risk identified
1. The consequences of a
spillage or unsafe disposal of the
substance:
Contamination of waterways
Contamination of soil
Damage to aquatic organisms
2. The consequences of
inappropriate use of the product:
Contamination of off-label crops
Likelihood
Magnitude of effect1
Environment Human
Level of
risk1
Unlikely
Unlikely
Unlikely
Moderate
Minimal
Moderate
n/a
n/a
n/a
Low
Low
Low
unlikely
minimal
minimal
insignificant
50% likelihood
unlikely
not applicable
not applicable
Minimal
Minimal
Insignificant
Insignificant
oral
a) users
b) public
Very unlikely
Very unlikely
not applicable
not applicable
Minimal
Minimal
Insignificant
Insignificant
inhalation
a) users
b) public
Very unlikely
Very unlikely
not applicable
not applicable
Minimal
Minimal
Insignificant
Insignificant
3. Adverse effects on humans:
Human exposure
- dermal
a) users
b) public
1
‘Level of risk’ is calculated using the more serious of the two scores under ‘Magnitude of effect’
4.3. Provide an assessment of any particular risks, costs and benefits which arise from the relationship
of Māori and their culture and traditions with their taonga, or which are, for other reasons, of
particular relevance to Māori.
We have asked for a separate response in this area because these requirements are different to other risks, costs and benefits. Please note
that if there are potentially significant risks in this area, it will almost certainly be necessary to consult with Māori in preparing an assessment.
This formulated product is being introduced to assist the agricultural and horticultural industry in weed control in
crops. The risks costs and benefits associated with it in relation to the Maori culture and traditions are not
November 2010 HSAF106-11
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
expected to be any greater than other agricultural chemicals in the marketplace and no greater effect to Maori
culture than any other culture of New Zealand peoples.
4.4. Provide an assessment of any risks, costs or benefits to New Zealand’s international obligations.
This is a specialist area which the EPA will handle. However, any information you are able to provide on relevant international agreements
would help us and save time and cost.
(Optional)
Both actives are currently registered in New Zealand and overseas for use on food and fodder crops.
4.5. Provide information on the proposed management of the substance.
This section should provide information on managing the effects identified and assessed in Sections 4.1 - 4.4 above. The starting point for
this is the range of default controls triggered by the hazardous property classification(s) attached to the substance (see Section 3.4). You
should describe how these controls would be implemented and indicate other mean of managing risks. The information provided must be
specific to the substance(s) and cover all areas of intended use. Reference should be made to Codes of Practice or standard operating
procedures that will be followed. If changes to the default controls triggered by the substance classification are proposed, the reasons for
these changes should be provided.
Please note that you will find it easiest to complete this section in conjunction with section 4.2. That is because the management of risks will
influence their residual level.
The following regulations will be adhered to in the management of the formulated product tnl
2650.
Hazardous Substances and Noxious Organisms (HSNO) Act 1996. Relevant Controls specified in the Act and
identified in this submission will be implemented.
Resource Management Act 1991 (RMA)
New Zealand Standard NZS5433:1999, Transport of Dangerous Goods on Land.
Transport of the product will be managed under the requirements of this standard. It includes appropriate controls
to be applied to packaging, storage and labelling.
Transport of the chemical will be with approved operators who will be issued with appropriate Emergency Safety
Guides (ESG) and Material Safety Data Sheets (MSDS).
Health & Safety in Employment (H&SE) Act (1992)
Employee safety and well-being will be maintained by compliance with the general requirements of this Act.
Zelam Ltd offers a 24 hour Emergency Response freephone number.
A summary of the controls in place to mitigate the risks identified.
Risk Identified
Management thereof
Providing suitable transport
delivery facilities
Using only approved transport carriers with the correct documentation and
licences
Providing containment for
Ensuring that sites using and storing agricultural compounds have storage
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
storage
controls and adequate space in place.
The consequences of a
spillage (with associated
environmental damage
potential)
With the correct procedures and documentation supplied with the product any
spill could be easily contained and prevented from damaging the environment.
At the manufacturing site this entails bunding, and vaccuming up spill to be
reformulated or disposed into the ‘on-site’ waste system. Spills during use
would most likely be minor and could be adsorbed onto clay granules and
disposed of in the correct manner.
Adverse health effect on
workers or users.
Protective clothing is supplied to adequately protect workers and it is
mandatory that it is worn. Spray contractors will have completed the Growsafe
spray programme and will be aware of the associated dangers and the means
of preventing harm to themselves of others.
Inappropriate use of the
product
Even with controls in place, inappropriate use or non-compliance could create
risk. Off -label application to other crops could result in compromising the food
safety standards with regard to MRLs resulting in the non-saleability of these
crops.
Disposal of unused substance
When used within label directions, tnl2650 will not pose a risk to the
environment.
Any unused product can be safely stored in its original container
until required for the next application or for the following season. If product did
require disposal then it should be used in accordance with the label directions
or returned to the manufacturer for reblending if appropriate.
Zelam belong to the Agrecovery programme and as such all triple rinsed
packaging can be returned to designated depots for recycling.
Disposal of packaging
Spillage or handling incident at
manufacturing stage
Damage to aquatic organisms
Public exposure.
Zelam Ltd’s manufacturing site is a purpose built facility with full bunding to
contain spillage and double concentric pipework to reduce potential impact of
earthquake. Site procedures are covered by ISO9001.
Dilution immediately upon coming in contact with an aquatic situation would
significantly reduce the damage.
Controls in place for the use of such chemicals limit the public access.
Non-compliance with controls
The range of controls applied under the HSNO Act and th e ACVM Act should
minimise the risks associated with non-compliance.
Natural hazard (earthquake,
flood, volcanic activity), or
deliberate sabotage
The controls in place and adhering to the regulations listed above should
assist in the management of any of these occurrences.
4.6. Provide an overall evaluation of the combined impact of all of the risks, costs and benefits set out in
sections 4.2, 4.3 and 4.4.
Doing this overall evaluation is the main task of the Authority. However, you may wish to express a view on the relative importance of the
different risks, costs and benefits and how they should be brought together in making a decision.
(Optional)
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
5. International Considerations
5.1. The EPA 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)
Both actives are approved for use by ACVM NZ for use in agriculture and horticulture. The formulated coded
product tnl 2650 is a new mixture and has not been registered in any other country, however the actives
individually have been registered in NZ mixed with other compounds. Both actives are registered for agricultural
use in Australia where MRLs hav been set in a wide range of crops.
6. 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.
7.
Summary of Public Information
The information provided in this section may be used in the Authority’s public register of substances required under Section 20 of the HSNO
Act.
This summary information will be used to provide information for those people and agencies (eg Ministry for the Environment, Department of
Conservation, Regional Councils, etc), who will be notified of the application, and for potential submitters who request information. This
information will also be used to prepare the public notice of the application.
For these reasons, applicants should ensure that this summary information does not contain any commercially sensitive material.
7.1. Name of the substance(s) for the public register:
Please use a maximum of 80 characters.
TNL 2650
7.2. Purpose of the application for the public register:
This should include (in a maximum of 255 characters) an abstract giving information on the intended use of the substance and why an
application is needed based on its hazardous properties.
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Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
To manufacture or import the coded substance tnl 2650 containing difflufenican and flumetsulam , as a
herbicide for weed control in cereals, grasses and clovers for food, seed and fodder.
7.3. Use Categories of the substance(s):
The EPA has adopted the system of use categories developed by the European Union, which identify various functional uses of substances.
This information is pertinent to the assessment of exposure scenarios and the determination of risk and is also useful for building up a profile
of the substance. There are three sets of use categories. Within each of these, applicants should state which use categories are relevant to
all intended uses of the substance(s).
Main category: There are four main categories
Industry category: There are 16 industry categories
Function/Use category: There are 55 function/use categories (Optional)
Main category:
Industry category:
Function/use category:
4
1
38
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
an assessment of the risks, costs and benefits
the methods implemented to manage the risks, particularly in relation to emergency management and disposal.
To import or manufacture tnl 2650 containing containing difflufenican and flumetsulam, as a herbicide
giving selective weed control in a range of food and fodder crops. Application use rate will be 1 - 2 litres
/ha.
Tnl 2650 will be manufactured on-site at Zelam Ltd’s New Plymouth premises. These premises have
in place totally bunded factories and yards where any waste or spillage is reticulated into the ‘Waste
Management System’. This system together with the air extraction and scrubber ensure that no
unwanted substances escape to the environment as dust or leachate. Staff are trained in the
management of these systems.
The substance will be packed in UN approved HDPE jerry cans , UN approved HDPE drums or bulk
1000litre shuttles designed for the purpose and transported by approved carriers, with the correct
documentation.
Tnl2650 is designed as a herbicide and as such will be used in the approved manner according to the
label and there will be no requirement to dispose of any material. If the end-user has a requirement to
dispose of diluted spray solution it is recommended that he use the product in the manner in which it was
intended or if it is large volumes contact his local council for options to send to an approved land fill..
Empty containers will be triple rinsed, with rinsate used as part of the spray mix, and containers returned
to agrecovery™ depot for collection. If this is impractical then either burnt, weather permitting or crushed
and buried in a approved landfill.
November 2010 HSAF106-11
14
Tnl 2650
Form HS1 Import or Manufacture any Hazardous Substance for Release
The greatest environmental risk would arise from an accident during transport to the distributors depot.
This can be lessened by using the approved UN containers that are rated for transport and storage of
chemicals.
Zelam Ltd subscribe to 0800chemcall a 24hr emergency response service available in the unlikely case
of an accidental spill. Qualified transport carriers trained in the transport of toxic and ecotoxic materials
and ensuring the carrier has the correct documentation giving clear directions as to the management of
an accidental spill.
Zelam Ltd have been ‘Approved Manufacturers of Agricultural Compounds’ since1989 and believe that
when handled correctly, following the Growsafe Agricultural Chemicals Handlers Manual tnl 2650
poses not greater risk to community health, safety or the environment than other substances currently in
use.
The benefits identified from the use of this product are; greater product choice for the industry, fewer
containers used due to 2 actives being combined in 1 formulation, employment opportunities, increase
portfolio of products, financial return, increased profits to shareholders, weed control and availability of
choice.
November 2010 HSAF106-11
15