SECTOR ASSESSMENT FEEDBACK FORM
Organophosphate and carbamate use in kiwifruit
production
Introduction
In this assessment the EPA has documented what it understands is the current state of the kiwifruit
industry in New Zealand (your sector), based on publicly available information and feedback from the
sector. When complete, this sector assessment will form part of the EPA’s formal application for
reassessment of organophosphate and carbamate insecticides.
To help complete the assessment, we need your input.
This document contains:
 A profile of your sector
 Some information on your sector’s use of organophosphates and carbamates and alternatives you
may use
 A preliminary assessment of the risks
 Possible options for managing risks
We acknowledge this document is not complete. Where there are gaps in our data please
include information to help us fully understand the current situation. We have put some
specific questions in grey boxes throughout the document for you to answer.
We need you to:
 Correct inaccuracies and provide us with additional information about your sector by editing this
document using “tracked changes” or printing the document out and writing onto it.
 Change or add information about yield, sales values, employment figures, major pests, and
insecticide use patterns, in the tables that we have started to populate.
 Answer the questions about your research, pest management programmes, proposed controls,
and the impacts the loss of organophosphates and carbamates would have on your sector.
 Suggest additional or alternative management options (controls) that would be practical and
effective.
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APP201045 Kiwifruit Sector Assessment
Sector profile
We need to know the size and characteristics of your sector to help us understand the extent of the
impact if organophosphate and carbamate insecticides were restricted or removed. The tables below
contain the information we already have. Please add anything that you feel is missing or incorrect.
Size of the sector
Table 1: Sector statistics1
Year
2007
2008
2009
2010
Hectares planted
11,967
12,168
12,337
12,525
Yield (tonnes)
7,514
8,371
8,866
8,546
Main growing region/s
Bay of Plenty (77%), Northland (6%), Nelson (5%), Auckland (4%)
Zespri Group (formerly the New Zealand Kiwifruit Marketing Board) is owned by kiwifruit growers and
is responsible for marketing almost all the export kiwifruit from New Zealand to over 60 countries.
ZESPRI International Limited is a corporatised cooperative. Kiwifruit Growers is a representative body
for New Zealand Kiwifruit Growers.
Europe and Japan have been the main export markets for the last two decades, with Taiwan, China
and South-East Asia growing significantly in recent years 2.
Table 2: Crop sales value ($ millions)1
Year
2007
2008
2009
2010
Exports (FOB)
765.1
870.7
1,071.7
995.7
Domestic sales
Total sales
Kiwifruit production is export focussed, with 93% exported. The kiwifruit sector through ZESPRI and
collaborative exporters sells in over 60 countries with export earnings (offshore revenue less offshore
costs) 2010/11 of $NZ1.0B. In addition Class 2/3 fruit is sold on the local markets (New Zealand and
Australia) by a number of companies3.
Sector demographics
Table 3: Sector demographics1
Year
Number of growers
May 2012
2002
2007
2008
2009
2010
2,754
2,727
2,710
2,711
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APP201045 Kiwifruit Sector Assessment
Number of employees
(directly employed )
Number of employees in
supporting businesses (e.g.
packhouses , rural
contractors)
Approach to pest management
Pest management systems
It is important to understand how the sector manages insecticide use.
1. Describe the management systems you have in place to regulate insecticide use.
Comment on any sector-wide programmes or private standards used by growers, and
estimate what percentage of your sector follows these practices. Please reference or
attach your sources.
Since 1997, kiwifruit grown for export has been grown organically or in accordance with an IPM
programme called KiwiGreen®, resulting in a reduction in insecticide use4.
The Crop Protection Programme (CPP) is based on KiwiGreen®, an Integrated Pest Management (IPM)
programme, developed in the early to mid-1990’s specifically for the kiwifruit industry. The CPP takes into
account targeted spraying across a range of pest species using softer chemicals or cultural practices to
maintain control of the key pests3. ZESPRI indicates that the reliance on organophosphates in the CPP
has been progressively reduced.
To be accepted for export, all kiwifruit must be grown in accordance with the CPP
Organophosphate and carbamate use
We are interested in the pests for which organophosphate and/or carbamate use is critical to your
sector. Table 4 lists the active ingredients registered for use in your sector, as well as other uses you
have told us about. Please indicate which of these active ingredients you are and are not using, and
add rows to include information for other organophosphates and carbamates that are being used but
are not captured in the table.
Do you use any organophosphates/carbamates on your crop post harvest? If so, please add
this information into Table 4 below, and provide use information by updating Table 6.
We also need you to tell us for which pests the use of organophosphates and carbamates is critical,
and which are able to be managed using alternatives.
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APP201045 Kiwifruit Sector Assessment
Please highlight the pests that are of most concern to your sector. We have already highlighted some
where we have information to suggest they are significant pests to your industry.
Table 4: Organophosphates and carbamates used on kiwifruit5
Insect pests
Chemical
group
Active
ingredient
Examples of products
Greedy scale
OP
*Chlorpyrifos
Chlorpyrifos EC, Lorsban
750 WG, Rampage
*Diazinon
Dew 600, Diazinon EC,
Diazol
*Pirimiphosmethyl
Attack
Latania scale
OP
*Pirimiphosmethyl
Attack
Leafroller
caterpillars
OP
*Diazinon
Hortcare Diazinon 500EW
Leafrollers
OP
*Chlorpyrifos
Chlorpyrifos EC, Lorsban
750 WG, Rampage
*Diazinon
Dew 600, Diazinon EC,
Diazol
*Pirimiphosmethyl
Attack
*Chlorpyrifos
Chlorpyrifos EC, Lorsban
750 WG, Rampage
*Pirimiphosmethyl
Attack
Passion vine
hopper
OP
Root knot
nematode
OP
*Fenamiphos
Canyon, Nemacur,
Nematak 400EC
Scale insects
OP
*Diazinon
Hortcare Diazinon 500EW
Active in
use (Y/N)
Critical
(Y/N)
*Registered for use on this crop
Non organophosphate and carbamate use
Table 5 lists the non-organophosphate/carbamate insecticides used on kiwifruit against the same
pests as the organophosphates and carbamates listed in Table 4. These substances are considered
to be possible alternatives. Please indicate which active ingredients you are and are not using, and
add information for those that are being used but are not captured in the table.
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APP201045 Kiwifruit Sector Assessment
Table 5: Non-organophosphates/carbamates used on kiwifruit against identified pests5
Insect pests
Chemical
group
Active ingredient
Examples of products
Greedy scale
Mineral oil
*Mineral oil
Excel Oil, Excel Organic
Spraying Oil, Excel Spring
Oil, Organic JMS Stylet Oil
Thiadiazine
*Buprofezin
Buprofezin
Latania scale
Mineral oil
*Mineral oil
Excel Oil, Excel Organic
Spraying Oil, Excel Spring
Oil, Organic JMS Stylet Oil
Leafroller
caterpillars
Biopesticide
*Bacillus
thuringiensis
BAactur, Dipel DF, Organic
Caterpillar
Oxadiazine
*Indoxacarb
Steward 150 SC
Avermectin
*Abamectin
Abamectin
*Emamectin
benzoate
Proclaim
Ecdysteroid
agonist
*Tebufenozide
Approve 240 SC, Approve
70 WP, Comic, Prolan
240SC
Macrocyclic
lactone
*Spinosad
Success Naturalyte Insect
Control
Other
*Methoxyfenozide
Prodigy
*Neem
Neem 600WP
*Pheromone
Desire Sex Pheromone
Traps
*Silicon dioxide
Insecta-Kill
Spinosyns
*Spinosad
Entrust Naturalyte Insect
Control, Spinosad
Synthetic
pyrethroid
*Bifenthrin
Disect 100EC, Talstar 100
EC, Venom
*Taufluvalinate
Mavrik Aquaflo
Neonicotinoid
*Thiamethoxam
Actara
Other
*Silicon dioxide
Insecta-Kill
Pyrethrins
*Piperonyl
butoxide
Key Pyrethrum, Pyganic,
Pyradym
Biopesticide
*Lime sulphur
BioBlast, Gro-Chem Lime
Leafrollers
Passion vine
hopper
Scale insects
May 2012
Active being
used (Y/N)
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APP201045 Kiwifruit Sector Assessment
Insect pests
Chemical
group
Active ingredient
Examples of products
Active being
used (Y/N)
Sulphur, Orion Lime
Sulphur
*Registered for use on this crop
Organic pest management techniques for kiwifruit pests include the following6:
Scale:
 Control of scale depends on how much there was last year. If there was a high loading or if the
fruit was rejected for scale then the approach is altered. This would involve waterblasting the
trunks, followed by a handgun mineral oil application on trunks and leaders, with a pre-blossom oil
spray as well. Scale numbers are monitored. With correct nutrition, and if the vines are healthy,
then less scale is found. E.g. in pre-drought conditions down to one oil-spray, but post-drought
waterblasting required.
 Treatment of surrounding areas to control scale is not necessary – they provide a friendly habitat
for birds, including welcome swallows, fantails. Small birds also help keep insect populations in
check, however the nests of larger birds are removed.
Bird deterrence:
 Some growers have issues with birds. Techniques to keep birds off vines include the laying of
roadkill, which attracts hawks and keeps birds off the vines. Also the shelterbelt used makes a
difference: thin cover such as pittosporum tends to attract (pest) birds, while stouter cover, such as
banksias, are useful as they attract tuis.
Leafroller
 2 post blossom sprays of Bt (Bacillus thuringiensis) are used – these are generally sprayed in late
afternoon as the bacteria in BT is sensitive to sunlight, and leafroller tend to feed at dusk and dawn
(late afternoon tends to extend the lifespan into the following days). Clean water, not chlorinated is
used. Most orchards require two sprays. Clusters are then monitored. This is generally found to be
effective and re-spray is generally not needed.
2. What is the basis of your choice of active ingredients to manage your critical pests?
Be specific about the efficacy and cost differences between options.
The kiwifruit industry has identified diazinon as, until recently, a key insecticide for the control of armoured
scale on kiwifruit 5. In a 2004 crop-based diazinon use estimate, the kiwifruit sector used a total of 29.66
tonnes a.i./year7. Due to an MRL reduction in the EU, diazinon was removed from the ZESPRI CPP.
Diazinon can no longer be used on kiwifruit vines but can be used on shelterbelts, which are a host for
armoured scale. Several alternatives are identified 5.
The kiwifruit industry support the continued availability of OPs, submitting that with the removal of broad
spectrum chemicals in the last few seasons the general ‘contaminant’ pest population has gradually
increased. The effective control options for mites, thrips and some mealybug species has diminished
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APP201045 Kiwifruit Sector Assessment
meaning an increasing incidence of a number of pests is found at harvest.
3. Tell us about pest control research undertaken by your sector, and any trials
underway or completed that would reduce your reliance on organophosphates and
carbamates. This could include a description of cultural or chemical control methods
that have been tried in the past and met with mixed success, or that are being
investigated currently. If you have identified alternatives please give us a timeline for
when they will be available for use (Reference or attach sources).
Example: Collectively New Zealand growers spend $x each year on research of which $y is spent
researching pest control. Currently projects are underway to establish the potential for...
4. List pests that are likely to pose a future threat to your sector, and comment on what is being
used to combat them elsewhere. This could include existing and potential pests.
Although the kiwifruit sector is not a high volume user of OPs it does support the continued availability for
other sectors to ensure there is continuity of supply to New Zealand if a strategic use is needed by the
sector in the future.
With regard to biosecurity use: although OP options would be highly desirable during the incursion phase,
availability of broad spectrum control options for growers after the incursion has wound down will also be
desirable3.
Modelling risks on current use
Table 6 summarises our understanding of your sector’s use patterns for organophosphates and
carbamates. These use patterns are the basis for our preliminary risk assessment. Use patterns were
drawn from label statements as well as from industry feedback.
The EPA has only assessed the risks for the use patterns it has information about. Uses will
be restricted to those described in Table 6 unless we receive further information.
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APP201045 Kiwifruit Sector Assessment
If your use patterns are different to those shown in Table 6, please amend the table. Please indicate
which rows are incorrect or not relevant to your sector. If rows in Table 6 are incomplete, please
complete them. If you have use patterns not covered by any of the rows in the table, please add extra
rows to describe the additional use pattern.
You have indicated that your use of organophosphates and carbamates is reducing. Are there any of
these substances that you would want to retain the option to use? If so, include these substances in
Table 6 and indicate at what rate you would use them.
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APP201045 Kiwifruit Sector Assessment
Table 6: Organophosphate and carbamate use data in kiwifruit production
In the final column please indicate whether the scenario is relevant in your sector.
Key: Indicate Relevant , Not relevant X, Relevant as modified ().
You may modify a scenario using tracked changes so that we can see how it differs from the original, or add a row into the table.
Use
scenario
number
Pest
Active
ingredient
Application
method
Source of use
information
Formulation
type
Application
rate
(g/ha)
Application
frequency
(per
season)
Application
interval
(days)
Application
area
(ha/day)
Kiwifruit1
Greedy
scale
Chlorpyrifos
Airblast
Label
Liquid
500
2
21
8
Kiwifruit2
Greedy
scale
Chlorpyrifos
Airblast
Label
WSG
500
2
21
8
Kiwifruit3
Greedy
scale
Chlorpyrifos
Airblast
Label
WSB
500
2
21
8
Kiwifruit4
Greedy
scale
Chlorpyrifos
Airblast
Label
WSB
660
4
30
8
Kiwifruit5
Greedy
scale
Diazinon
Airblast
Label
Liquid
480
4
7
8
Kiwifruit6
Greedy
scale
Diazinon
Airblast
Label
Liquid
500
4
7
8
Kiwifruit7
Greedy
scale
Diazinon
Airblast
Plant and Food
Report
Liquid
1440
2
7
8
Kiwifruit8
Greedy
scale
Pirimiphosmethyl
Airblast
Label
Liquid
950
4
21
8
Kiwifruit9
Latania
Pirimiphos-
Airblast
Label
Liquid
950
4
21
8
May 2012
Relevance
to sector
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APP201045 Kiwifruit Sector Assessment
Use
scenario
number
Application
method
Source of use
information
Formulation
type
Application
rate
(g/ha)
Application
frequency
(per
season)
Application
interval
(days)
Application
area
(ha/day)
Pest
Active
ingredient
scale
methyl
Kiwifruit10
Leafrollers
Chlorpyrifos
Airblast
Label
Liquid
500
2
21
8
Kiwifruit11
Leafrollers
Chlorpyrifos
Airblast
Label
WSG
500
2
21
8
Kiwifruit12
Leafrollers
Chlorpyrifos
Airblast
Label
WSB
500
2
21
8
Kiwifruit13
Leafrollers
Chlorpyrifos
Airblast
Label
WSB
660
4
30
8
Kiwifruit14
Leafrollers
Diazinon
Airblast
Label
Liquid
480
4
7
8
Kiwifruit15
Leafrollers
Diazinon
Airblast
Label
Liquid
500
4
7
8
Kiwifruit16
Leafrollers
Diazinon
Airblast
Plant and Food
Report
Liquid
1440
2
7
8
Kiwifruit17
Leafrollers
Pirimiphosmethyl
Airblast
Label
Liquid
950
4
21
8
Kiwifruit18
Passion
vine
hoppers
Chlorpyrifos
Airblast
Label
Liquid
500
2
21
8
Kiwifruit19
Passion
vine
hoppers
Chlorpyrifos
Airblast
Label
WSG
500
2
21
8
Kiwifruit20
Passion
vine
hoppers
Chlorpyrifos
Airblast
Label
WSB
500
4
14
8
May 2012
Relevance
to sector
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APP201045 Kiwifruit Sector Assessment
Use
scenario
number
Pest
Active
ingredient
Application
method
Source of use
information
Formulation
type
Application
rate
(g/ha)
Application
frequency
(per
season)
Application
interval
(days)
Application
area
(ha/day)
Kiwifruit21
Passion
vine
hoppers
Chlorpyrifos
Airblast
Label
WSB
660
4
30
8
Kiwifruit22
Passion
vine
hoppers
Pirimiphosmethyl
Airblast
Label
Liquid
950
4
21
8
Kiwifruit23
Root knot
nematode
Fenamiphos
Dipping
Label
Liquid
1.6 g/l
EC emulsifiable concentrate
EW emulsion, oil in water
WSG water soluble granule
WSB water soluble bag
May 2012
300
litres/day
handled
Relevance
to sector
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APP201045 Kiwifruit Sector Assessment
Risks
Overview
The EPA has evaluated the risks to operators, re-entry workers, bystanders, the aquatic environment,
birds and bees from using these substances. All risk assessment results in this document should be
considered preliminary as they may change with additional feedback. The final risk assessment
results will be presented in the reassessment application.
Results are described as risk quotients (RQs) which compare predicted exposures and maximum
concentrations that will not cause adverse effects. All risk quotients have been normalised so that
RQs above 1 exceed the EPA’s Level of Concern where effects are likely to be seen.
Data gaps
Fenamiphos is registered for used on kiwifruit against Root Knot nematode. There are significant data
gaps that affect our understanding of the risks that fenamiphos pose to both human health and the
environment. Our risk assessment for fenamiphos could be refined if additional data about its dermal
absorption was provided. In the absence of information the EPA has assumed that 50% of the
fenamiphos in both the product and the spray would be absorbed through skin.
5. Please provide information about the dermal absorption of fenamiphos, and reference or
attach your sources.
The EPA could not find any information about the toxicity of fenamiphos to bees. Given its status as
an insecticide, the EPA is assuming that fenamiphos will pose a high risk to bees.
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APP201045 Kiwifruit Sector Assessment
Risk modelling
This section summarises our understanding of the risks of organophosphates and carbamates based
on modelling of the risks to human health and the environment.
Figures 1 and 2 show the maximum and minimum risk quotients for your sector’s use of each active
ingredient. Both figures depict risks assuming that operators wear full PPE (chemical resistant gloves,
coveralls, sturdy footwear, a hood and visor), that re-entry workers do not enter the crop for 24 hours
after spraying and that Good Agricultural Practice is followed.
Figure 1: Maximum Risk Quotients (the black line indicates the level of concern)
10000
1000
Max of Operator (Full PPE)
100
10
1
0.1
Max of Re-entry worker (no
gloves)
Max of Bystander
Max of Aquatic
Max of Birds
Max of Bees
Figure 2: Minimum Risk Quotients (the black line indicates the level of concern)
10000
1000
Min of Operator (Full PPE)
100
10
Min of Re-entry worker (no
gloves)
Min of Bystander
1
Min of Aquatic
0.1
Min of Birds
Min of Bees
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APP201045 Kiwifruit Sector Assessment
Quantitative estimates of risk to operators, re-entry workers, bystanders, the aquatic environment,
birds and bees have been made for all use scenarios except for dipping roots (fenamiphos) for which
risks to re-entry workers, bystanders and environmental risks are assumed to be negligible.
Maximum RQ values across your sector’s range of use scenarios are shown in Figure 1. These are
worst-case scenarios generally indicating high application rates and frequency. If the maximum RQ is
less than one, no additional risk management is needed, but if the RQ is greater than one, risk
management will be needed for at least some uses.
The minimum RQs depicted in Figure 2 indicate the best-case scenarios across your sector’s use of
these substances i.e. the lowest rates and safest formulations. Substances for which the minimum
RQ is greater than one for one or more endpoints require risk management.
Information and assumptions used for modelling risks can be found in the accompanying Background
Document.
Possible risk management options
It is possible that additional controls could help to manage the risks posed by organophosphates and
carbamates. The EPA has evaluated some possible controls to help reduce risks for each of the usescenarios. This could mean that for some substances uses with low risks would be retained while
others may require additional risk management.
Possible risk management options are listed in Table 7. Appendix A describes the possible options in
more detail and defines terms used in Table 7. .Existing controls will continue to apply to a
substance..
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APP201045 Kiwifruit Sector Assessment
Table 7: Possible options for reducing risks for organophosphate and carbamate use on kiwifruit
General
Operator
Chemical class
identification
RPE (in
addition
to full
PPE)
Substance
Re-entry
worker
Closed
mixing /
loading
system
Closed cab
application
Minimisation
of dust or fine
particles
Bystander
/Aquatic
Concerns still exist
for:
Maximum
application
rates (g
a.i./ha)
Re-entry
interval
Buffer
zone (m)
24 h
Yes
Aquatic Bees
Chlorpyrifos
(airblast, WSB)
Yes
660
Chlorpyrifos
(airblast, liquid)
Yes
500
Yes
Aquatic Bees
Chlorpyrifos
(airblast, WSG)
Yes
500
Yes
Aquatic Bees
Yes
Operator, even with
additional controls
Re-entry Aquatic
Birds Bees
Diazinon (airblast,
liquid)
Yes
Yes
Fenamiphos
(dipping, liquid)
Yes
Yes
Pirimiphos-methyl
(airblast, liquid)
Yes
Yes
Yes
1440
24 h
Operator, even with
additional controls
1.6 g/l
950
24 h
Yes
Aquatic
For your sector our preliminary risk assessment indicates there are substances which are still of concern for human health and the environment even after
additional controls have been considered.
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The risk management options in Table 7 are based on an assessment of the substances’ risks alone. Data you provide on actual use patterns, alternative
risk information and additional controls will help us to re-evaluate this risk assessment.
We know that many of these substances have significant benefits, and the final decision on their future use will consider their risks, costs and benefits.
However, if the benefits are not shown to outweigh the risks phase out may be triggered for some uses.
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APP201045 Kiwifruit Sector Assessment
What is the impact?
We need your input about the practicality of the possible risk management options and, if these
controls are impractical, we are asking you to suggest alternatives to manage the risks.
When answering the questions below please consider what the impact on your sector would be if the
options above were applied. Please supply information to support your assessment.
6. Which of the possible risk management options in Table 7 would be workable if they
were implemented in your sector? Please describe how you could make them work in
the field.
Example: We always apply downwind buffer zones when applying these substances. Or: Wearing
respirators during application could reduce risks in a similar way to closed cab application, and is a
cheaper option for us.
7. If you think that any of the possible risk management options in Table 7 are not
workable please explain why.
Example: The maximum application rate is too low to control XYZ insect populations. Or: We often need
to re-enter fields during the summer within the first 24 hours to apply irrigation.
Be specific
In the questions below we are asking you to indicate what economic impact the possible risk
management options would have e.g. how a lower application rate would affect your costs or, if the
controls are unworkable, what effect the phase out of a substance would have.
Much of the feedback that we have received to date has included generalisations such as, “without
organophosphates our crop would be decimated”, and localised facts like, “without organophosphates
my farm would lose $70,000 per year”. This feedback is useful to give us an idea of the nature and
extent of the problem, but we need more information to help us understand the effect of the changes
on your sector.
Please include the type of information provided in the example below when responding to questions 7
to 10.
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Hypothetical example
If our industry were not able to use diazinon then we estimate that the cost of control would increase
by $200/hectare on an average annual basis. Approximately 80% of the kiwifruit growing area would
be affected, mainly in the North Island (75% affected in Bay of Plenty). As well as the additional cost
of control we believe that the production levels would reduce by 10% and this would mean that there
would be less work for pickers and packers, and the total export value would decrease by 15%. This
would be a long term effect (probably 10 years) while alternative products were developed and
registered for use.
8. How would the loss of any of the substances in Table 7 affect you? We are particularly
interested in those substances that are critical to the profitable production of your crop.
Please provide information separately for each substance.
9. How would the possible risk management options affect your production costs?
10. Please describe how employment in your industry would be affected if the risk
management options were implemented and if high risk uses of some substances
were phased out. If possible indicate changes to on-farm and off-farm employment
separately.
11. How would the possible options affect production/yield, and your income or the value
of your sector? Include information for the possible loss of high risk uses requiring
the substitution of alternatives. Please quote average per annum figures and show
your workings.
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APP201045 Kiwifruit Sector Assessment
12. Comment on how any impacts would change with time. Would the impact on yield
and value of implementing the possible risk management options be short term or
long term, and would the effects increase or decrease over time?
Example: If application rates were reduced we would see little difference in yield short term, but over time
pest pressure would increase along with costs. Yield and value may reduce in the mid-term until effective
alternatives were available.
Alternative options to manage risks
In Table 7 we have outlined a range of possible options for managing the risks of organophosphate
and carbamate use on kiwifruit. We are interested in any alternative measures to manage these risks
which may be more appropriate. You may have existing obligations under product stewardship or
good agricultural practice schemes that you think address the concerns that we have identified. Less
toxic alternatives may have been identified which the sector is planning to adopt. It may also be
possible to reduce the levels of exposure through use of specific technology like recapturing
application equipment which applies less substance within a treatment area. There may also be
alternative management strategies that you might use.
13. Please suggest other control measures to reduce the risks of using organophosphates and
carbamates. Provide us with specific details which will enable us to evaluate the impact of
your proposals. For example include details of reduced exposure that would be achieved by
lowering application rates to a specified amount, reducing applications to an identified
number, or using recapture technology. Explain what mix of management techniques and/or
alternative substances you would prefer to use. Make sure that you explain which
substances the controls would apply to, and if they are stand-alone measures or
implemented as a suite of controls.
Substance
May 2012
Proposed risk management option
How this would reduce risks
20
APP201045 Kiwifruit Sector Assessment
14. How effective would your alternative management strategy be in terms of pest
control?
15. How would your alternative options affect production/yield, costs, employment and
your income or the value of your sector? Please show your workings and use
average per annum figures.
16. Comment on how any impacts of your alternative risk management strategy would
change with time. Would the impact on yield and value of implementing your strategy
be short term or long term, and would the effects increase or decrease over time?
We welcome all feedback.
Please respond by 31 July 2012 either:
 Through your industry body, or
 Directly to the EPA by emailing reassessments@epa.govt.nz or
 faxing to OP Reassessment 04 914 0433
May 2012
21
APP201045 Kiwifruit Sector Assessment
Sources
1
Fresh Facts 2007, 2008, 2009, 2010. Plant and Food Research Institute of New Zealand Ltd.
2 NZ
Horticulture – Barriers to Our Export Trade (November 2010) Prepared by Market Access
Solutionz.
3
Zespri Kiwifruit & New Zealand Kiwifruit Growers. Submission on the Organophosphate and
Carbamate Reassessment.
4 Plant
& Food Research Report commissioned by ERMA New Zealand for diazinon.
5
New Zealand Novachem Agrichemical Manual website www.novachem.co.nz
6
Peter Downard. Organic kiwifruit grower. Personal communication.
7
Manktelow, D., Stevens, P., Walker, J., Gurnsey, S., Park, N., Zabkiewicz, F, Teulon, D. and
Rahman, A. 2005. Trends in Pesticide Use in New Zealand: 2004. Report to the Ministry for the
Environment.
May 2012
22
APP201045 Kiwifruit Sector Assessment
Appendix A
Tables 8 and 9 provide explanations of the possible options and definitions of the terms used.
Table 8: Descriptions of possible options for reducing risks
Description
A restriction on the permitted application methods is applied so that the
substance may only be applied using [application method]. This
requirement must be stated on the label.
Application equipment
Buffer Zone
In circumstances where a particular application method poses high risks,
a restriction may be imposed to prohibit that use. Alternatively, in order
to retain a particular use pattern (such as a critical use), use of a specific
application method may be specified.
Application of the substance is only permitted in conjunction with a buffer
zone as described in NZS 8409:2004 The Management of
Agrichemicals, which is available from Standards New Zealand
(www.standards.co.nz or call 0800 STANDARDS). This requirement
must be stated on the label.
A Buffer Zone is the minimum separation distance downwind of an area
where a substance is applied and a sensitive area.
Application of the substance is only permitted using a vehicle equipped
with a fully enclosed closed operator cab, where the cab air intake is
fitted with chemical filters. This requirement must be stated on the label.
Closed cab application
A reduction in the exposure of a person applying a substance can be
achieved by using application equipment where the operator is within a
fully enclosed cab, fitted with chemical filters to ensure that the airsupply for the operator is not contaminated with chemicals.
The substance must be loaded into the application equipment using a
closed system. This requirement must be stated on the label.
Closed loading systems
Granule application restriction
Closed mixing and loading systems can be used in order to remove the
exposure to operators during this phase of the substance lifecycle.
Liquids may be charged to the spray tank using closed pumping systems
in a spray shed, or by charging mechanisms on the sprayer. For
granules used in aqueous sprays, water soluble packaging can be used.
The substance must be applied below the surface of the soil, or be
covered completely with soil immediately after application. This
requirement must be stated on the label.
This restriction will put an obligation on the applicator to ensure that the
substance does not pose a post application risk to birds.
A maximum application rate is set for this substance. This requirement
must be stated on the label.
Maximum application rates
May 2012
The risk assessment for a given substance has been carried out for
particular use parameters. Use of a substance in excess of the
quantities assessed can give rise to greater levels of risk, and as a
23
APP201045 Kiwifruit Sector Assessment
result, the proposed controls may not adequately manage the risks
posed.
This substance must not contain more than 1.5%(w/w) with a particle
size of less than 150 µm.
Minimisation of dust or fine
particles
This condition is to ensure that fine particles or dust are excluded from
the substance, so that handling of the substance does not result in
exposure to dust or fine particles.
In the case of an organophosphate-containing substance, the main label
must clearly identify the substance as containing an organophosphate
chemical; or
Chemical class identification
In the case of a carbamate-containing substance, the main label must
clearly identify the substance as containing a carbamate chemical.
This additional labelling condition will provide clear identification of the
chemical class of the substance, and is to ensure that the end-user is
aware of the type of substance being handled.
Personal Protective Equipment
(PPE)
Respiratory Protective
Equipment (RPE)
Use of specific RPE is prescribed. This requirement must be stated on
the label.
The additional requirement for RPE details the specific minimum
requirements for RPE and are in addition to the requirement for use of
full PPE when handling the substance or entering a treated area within a
REI.
After [date], use of this substance on [crop/sector] is no longer permitted.
Phase-out Period
For substances that have use patterns that are to be phased out, a
period of time is established to provide an opportunity for use or disposal
of the substance. After the Phase-out Period has elapsed, use of that
substance will no longer be permitted for that particular use pattern. For
substances that are used in different sectors, such a restriction may be
imposed for certain uses or application methods in certain sectors, whilst
being retained in others.
Entry into treated areas is not permitted until the Restricted Entry
Interval has elapsed since the end of application of the substance,
unless PPE (and RPE where prescribed for operators) is worn for the
time that the person is within the treated area. This requirement must be
stated on the label.
Restricted Entry Interval (REI)
May 2012
A Restricted Entry Interval (REI) is the period of time which must elapse
after application of a substance before entry into the treated area is
permitted without use of PPE and RPE (as required). Entry into a treated
area before the REI has elapsed is only permitted if full PPE is worn
(and RPE if required for application of the substance). Additionally, the
entry restriction may limit the tasks that may be carried out within the
treated area, and the time per day that a person may spend in the
treated area within the REI.
24
APP201045 Kiwifruit Sector Assessment
Table 9: Definitions of terms used in the possible options
Description
Implementation Period
It is appropriate to allow a period of time in order to implement any
changes of controls applied to a substance. If an Implementation Period
is specified, then the controls that currently apply to a substance are
valid until the end of the implementation period. Once the
Implementation Period has elapsed, any new controls, or changes to the
existing controls, must be followed.
PPE is protective equipment that is specifically designed to prevent nonrespiratory exposure of a person handling chemicals.
Full PPE constitutes the following clothing and equipment:
Personal Protective Equipment
(PPE)
Respiratory Protective
Equipment (RPE)
 Chemical resistant gloves;
 Coveralls;
 Sturdy footwear;
 A hood and visor.
RPE is protective equipment that is specifically designed to prevent
exposure of the respiratory system to chemicals, such as using a
respirator fitted with an appropriate chemical filter.
A sensitive area is a location that may be sensitive to drift of an applied
substance. Sensitive areas include:
 Residential buildings and areas;
Sensitive area (definition)
 Private property;
 Places where public may lawfully be (e.g. schools, parks,
playgrounds, day care facilities, prisons, hospitals, nursing homes);
 Waterways.
Waterway (definition)
May 2012
A waterway includes modified water courses such as reservoirs,
irrigation canals, water supply races, canals for supply of water for
electricity generation or farm drainage canals, as well as natural water
bodies.
25
APP201045 Kiwifruit Sector Assessment
Appendix B
Table 10: Risk quotients from modelling risks of using organophosphates and carbamates on kiwifruit
Re-entry
worker
Max
0.14
0.034
0.018
0.0047
0.13
0.033
0.013
0.0033
0.89
0.44
0.35
3600
1.8
33
170
Kiwifruit2
0.18
0.035
0.06
0.0053
0.13
0.033
0.013
0.0033
0.89
0.44
0.35
3600
1.8
33
170
Kiwifruit3
0.13
0.033
0.013
0.0033
0.13
0.033
0.013
0.0033
0.89
0.44
0.35
3600
1.8
33
170
Kiwifruit4
0.18
0.043
0.018
0.0043
0.18
0.043
0.018
0.0043
1.1
0.54
0.43
6500
2.3
50
220
Kiwifruit5
9.8
4.7
1.3
0.65
9.4
4.5
0.94
0.45
230
120
41
770
13
250
110
Kiwifruit6
10
4.9
1.4
0.68
9.8
4.7
0.98
0.47
240
120
43
800
14
330
110
Kiwifruit7
29
14
3.9
2
28
14
2.8
1.4
500
250
89
1600
30
670
320
Kiwifruit8
0.4
0.29
0.044
0.031
0.39
0.29
0.039
0.029
8.9
4.4
0.89
240
0.63
14
53
Kiwifruit9
0.4
0.29
0.044
0.031
0.39
0.29
0.039
0.029
8.9
4.4
0.89
240
0.63
14
53
Kiwifruit10
0.14
0.034
0.018
0.0047
0.13
0.033
0.013
0.0033
0.89
0.44
0.35
3600
1.8
33
170
Kiwifruit11
0.18
0.035
0.06
0.0053
0.13
0.033
0.013
0.0033
0.89
0.44
0.35
3600
1.8
33
170
Kiwifruit12
0.13
0.033
0.013
0.0033
0.13
0.033
0.013
0.0033
0.89
0.44
0.35
3600
0.39
33
170
Kiwifruit13
0.18
0.043
0.018
0.0043
0.18
0.043
0.018
0.0043
1.1
0.54
0.43
6500
2.3
50
220
May 2012
Full PPE
RPE
Closed cab
Kiwifruit1
Full PPE
Min
Bees
With gloves
Aquatic
No gloves
Full PPE
RPE
Closed cab
No mix/load
Full PPE
Closed cab
No mix/load
Bystander
Full PPE
Closed cab
Full PPE
RPE
No mix/load
Birds
Full PPE
RPE
Use
scenario
number
Full PPE
No mix/load
Operator
26
APP201045 Kiwifruit Sector Assessment
Re-entry
worker
Birds
Aquatic
Bees
9.4
4.5
0.94
0.45
230
120
41
770
13
250
110
Kiwifruit15
10
4.9
1.4
0.68
9.8
4.7
0.98
0.47
240
120
43
800
14
330
110
Kiwifruit16
29
14
3.9
2
28
14
2.8
1.4
500
250
89
1600
30
670
320
Kiwifruit17
0.4
0.29
0.044
0.031
0.39
0.29
0.039
0.029
8.9
4.4
0.89
240
0.63
14
53
Kiwifruit18
0.14
0.034
0.018
0.0047
0.13
0.033
0.013
0.0033
0.89
0.44
0.35
3600
1.8
33
170
Kiwifruit19
0.18
0.035
0.06
0.0053
0.13
0.033
0.013
0.0033
0.89
0.44
0.35
3600
1.8
33
170
Kiwifruit20
0.13
0.033
0.013
0.0033
0.13
0.033
0.013
0.0033
1.1
0.57
0.45
6300
2.1
50
170
Kiwifruit21
0.18
0.043
0.018
0.0043
0.18
0.043
0.018
0.0043
1.1
0.54
0.43
6500
2.3
50
220
Kiwifruit22
0.4
0.29
0.044
0.031
0.39
0.29
0.039
0.029
8.9
4.4
0.89
240
0.63
14
53
Kiwifruit23
28
28
May 2012
Max
0.65
Min
1.3
Full PPE
RPE
Closed cab
4.7
Full PPE
Closed cab
9.8
Full PPE
RPE
Kiwifruit14
Full PPE
With gloves
Bystander
No gloves
Full PPE
RPE
Closed cab
No mix/load
Full PPE
Closed cab
No mix/load
Full PPE
RPE
No mix/load
Use
scenario
number
Full PPE
No mix/load
Operator