ENVIRONMENTAL RISK MANAGEMENT
AUTHORITY DECISION
1 December 2006
Application Code
HSE06004
Application Type
To import or manufacture and use a hazardous substance in a
special emergency under Section 49D of the Hazardous
Substances and New Organisms Act 1996 (the Act)
Applicant
Ministry of Agriculture and Forestry, Biosecurity New Zealand
(the applicant)
Purpose of the Application
To import or manufacture and use Imidacloprid 175
suspension, containing 0.000175% imidacloprid as the active
ingredient to kill feral bees in an area of the South Island of
New Zealand known to be infested with the Unwanted
Organism, Varroa destructor.
Date Application Received
20 November 2006
Consideration Date
29 November 2006
Considered by
Hearings Committee of the Authority
SUMMARY OF DECISION
1
1.1
The application to manufacture and use Imidacloprid 175 suspension in a special
emergency declared under section 49B is approved with controls in accordance with
the relevant provisions of the Act and the HSNO (Methodology) Order 1998 (the
Methodology).
1.2
The substance has been given the following unique identifier for the ERMA New
Zealand Hazardous Substances Register:
Imidacloprid 175 suspension
HSE000006
LEGISLATIVE CRITERIA FOR APPLICATION
2
2.1
On 18 September 2006, and pursuant to Section 49B of the Act, the Minister for
Biosecurity declared an adverse event, the incursion of the varroa bee mite Varroa
destructor into the South Island, to be a special emergency until 30 June 2007.
2.2
On 20 November 2006, the applicant lodged an application pursuant to section 49D to
manufacture and use Imidacloprid 175 suspension in the special emergency. The
decision was determined in accordance with section 49F taking into account additional
matters to be considered in that section, the matters specified in Part II of the Act
(Purpose of Act) and the relevant provisions of the Methodology. Unless otherwise
stated, references to section numbers in this decision refer to sections of the Act and
clauses to clauses of the Methodology.
2.3
In accordance with section 49F, the approach adopted when considering this
application was to consider all the information having regard to the particular
circumstances of the special emergency that the applicant provided under section 49E
and determine whether:
 the hazardous substance is necessary for use in the special emergency; and
 the proposed plan adequately controls the adverse effects of the substance.
APPLICATION PROCESS
3
3.1
The application was formally received on 20 November 2006.
3.2
Project Team:
Bella Whittle
Advisor (Hazardous Substances)
Chris Geering
Advisor (Hazardous Substances)
Zack Bishara
Advisor (Maori Unit)
3.3
The applicant supplied the following documents:
 the application; including the following documents as appendices
o Appendix 1: Management Plan for “Imidacloprid 175 suspension” (the
Management Plan),
o Appendix 2: the Nelson Varroa Elimination Plan.
 two research papers commissioned by the applicant on field tests conducted by
HortResearch:
o Taylor, M.A. (2003). Field Testing Proposed Methods for Destroying Feral Bee Colonies.
HortResearch Client Report No: 10541.
o Taylor, M.A. and Goodwin, Dr R.M. (2001). Destruction of managed and feral honey
bee (Apis mellifera) Colonies. HortResearch Client Report No: 2001/392.
3.4
Pursuant to sections 49F(2)(a) and 49F(2)(b), the Agency consulted with Department
of Conservation, the Ministry of Health, the Department of Labour, the Ministry for
the Environment and the Agricultural Compounds and Veterinary Medicines (ACVM)
Group of the New Zealand Food Safety Authority (NZFSA) on the proposal.
3.5
The Committee had particular regard to the views of the Department of Conservation
(DoC) when considering whether the applicant’s plan will adequately control the
adverse effects of the substance.
3.6
DoC outlined concerns regarding risks to non-target species, specifically birds, bats
and native invertebrates; potential contamination of waterways; and the risk to human
health if the substance were to enter the food chain. DoC included recommendations
regarding measures the applicant should take to manage such risks. DoC made
recommendations relating to signage, reporting on feeding behaviour of non-target
species, and ongoing consultation with DoC. This submission has been forwarded to
the applicant.
3.7
One of DoC’s recommendations is that signage equivalent to that required for
vertebrate poisoning should be required, particularly on land administered by DoC.
The Committee considers that due to the low concentration of imidacloprid, and
hence the low hazard of the substance, that the risks of the substance entering the
food chain as a result of interference by animals such as feral pigs will be very low. In
addition, bait stations are to be checked twice daily during baiting. Further, the
ERMA New Zealand Decision: Application HSE06004
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Committee notes that risks relating to residues will be considered by the ACVM, rather
than ERMA New Zealand.
3.8
The Department of Labour (DoL) recommended that “the people handling the
product will need to be trained in, or have knowledge of, the use of appropriate PPE
[Personal Protective Equipment] as well as the field workers may also need to use
appropriate gloves and have suitable first aid training as well as wearing overalls”. The
Committee notes that the applicant has been forwarded the advice provided by DoL
with regard to PPE requirements and first aid training.
3.9
The Committee also considered the comment made by the Agricultural ACVM
regarding the relationship between HSNO and the ACVM registration.
CONSIDERATION
4
Sequence of the Consideration
4.1
This application was considered by the following members of the Authority’s Hearings
Committee (acting under a delegation under section 19(2)(b)): Mr Tony Haggerty
(Chair), Professor George Clark, Dr Manuka Henare on 29 November 2006.
4.2
In accordance with section 49F and clause 24, the approach adopted when
determining the application was to:




consider whether the applicant had provided sufficient information to determine
whether the substance should be used in a special emergency;
consider the purpose of the application and determine whether the substance is
necessary for use in the special emergency;
consider the lifecycle of the substance and determine the hazardous properties
and adverse effects of the substance; and
consider whether the Management Plan provided by the applicant adequately
controls the adverse effects of the substance.
Information review
4.3
The Committee has reviewed the applicant’s information and additional information
available to it and considers that there is sufficient information to determine whether
Imidacloprid 175 suspension should be manufactured and used in the special
emergency.
Purpose of the application
4.4
The purpose of this application is to obtain approval under the Act to manufacture
and use a substance containing the active ingredient imidacloprid to kill feral bees in an
area of the South Island of New Zealand known to be infested with the Unwanted
Organism, Varroa destructor. The active ingredient imidacloprid has been demonstrated
in field trials conducted by HortResearch to be an effective poison for this purpose. A
poison to kill feral bees is needed in defined geographical areas of the South Island to
eliminate bees carrying the Varroa destructor mite from the infested areas.
4.5
As the purpose amounts to “manufacture an agricultural compound”; and the “use of
an agricultural compound in a manner that would contravene the Act”, the Committee
ERMA New Zealand Decision: Application HSE06004
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considers that the application qualifies for consideration under sections and 49D(2)(b)
and 49D(2)(d).
Criteria for declining the application
4.6
Under section 49F(3) the Authority may decline the application only if it is satisfied
that –
(a) the hazardous substance is not necessary for use in the special emergency; or
(b) the proposed plan does not adequately control the adverse effects of the
hazardous substance.
The necessity to use the hazardous substance to deal with the special emergency.
4.7
The applicant advises that removal of all bees (Apis mellifera) is a key step in the
elimination of the obligate parasite Varroa destructor. Removal of managed bee hives in
the infested region is complete. Elimination of the remaining feral bees in the infested
region is now necessary if the Varroa elimination attempt is to succeed. The details of
the plan to remove bees from the infested region are outlined in the Nelson Varroa
Elimination Plan (Appendix Two of the application form).
4.8
The applicant claims that a compound that is effective to kill bees following delayed
contact is necessary to poison bees in feral hives. Use of compounds such as
insecticides containing permethrins that are immediately effective, killing bees at a bait
station, preclude carriage of the toxin back to the feral bee colony and killing the entire
bee colony. There are no agricultural compounds containing imidacloprid registered
for use on bees in New Zealand.
4.9
The Committee has reviewed the information provided by the applicant and is satisfied
that the application to manufacture and use Imidacloprid 175 suspension is necessary
for the special emergency.
Controlling the adverse effects of the substance
Hazardous properties
4.10
The Committee notes that the hazard classifications supplied on the application form
(Page 8) are for the approved substance “Suspension concentrate containing 350
g/litre imidacloprid” – (Approval Code HSR000687; Trade name – Kohinor 350). To
formulate Imidacloprid 175 solution, to a field strength of 1.75 mg imidacloprid/litre,
this requires the addition of 5 L of Kohinor 350 to one litre of sucrose and water.
Lifecycle
4.11
In assessing the adverse effects of the substance, the Committee reviewed the lifecycle
of the substance as described in the applicant’s Management Plan, as summarised
below.
The plan for dealing with the use of the substance in the special emergency
4.12
The applicant notes that HortResearch has developed and field tested a method of
destroying feral colonies through baiting, which is intended to be used to manage
Imidacloprid 175 suspension. This method involves placing bait stations on a 1km x
1km grid in the eradication zone. Each bait station is an open-topped container,
secured against stock and other vertebrates. Bait stations are filled with 65% sucrose
ERMA New Zealand Decision: Application HSE06004
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solution, and a diluted honey mixture sprayed in a one-metre radius around the bait
station to attract bees. Individual bees detect the bait station while foraging, and recruit
other bees from their hive to switch to this food source. When the number of bees
feeding is sufficient (more than 300 simultaneously), the pre-bait is removed and
approximately 2 litres of sugar solution containing the final dilution of imidacloprid is
substituted. When feeding ceases, any remaining Imidacloprid 175 suspension is
removed and stored for disposal as hazardous waste. Bait stations are closely
monitored while containing imidacloprid, and all bait stations in areas accessible to the
public will be continuously supervised.
4.13
The attached Management Plan (Appendix 1) provides additional details on the
proposed management of the substance, including details on risk management to
prevent spillage and exposure to non-target species.
Identification and evaluation of the adverse effects of the substance for use in the
special emergency
4.14
In the application, the applicant identified and assessed potential adverse effects, and
detailed proposals for, and impacts of risk management. The Committee has reviewed
the applicant’s assessment of adverse effects and agrees that that it is suitable for the
consideration.
Adverse effects to the environment
4.15
The Committee considers that adverse effects to the environment may arise from:
 spillage of Imidacloprid 175 suspension during manufacture;
 spillage of Imidacloprid 175 suspension in transit;
 leakage or spillage of Imidacloprid 175 suspension during storage;
 spillage of Imidacloprid 175 suspension at the Field Operations Response Centre;
 exposure to non-target species during use;
 breach of packaging or bait stations;
 residual risk of diluted Imidacloprid 175 suspension remaining in feral bee hives.
4.16
The application and accompanying Management Plan contain measures that must be
taken to avoid, remedy or mitigate the adverse effects arising from the manufacture
and use of Imidacloprid 175 suspension.
4.17
The Committee has reviewed these proposals and is satisfied that they are adequate to
control the adverse effects of the substance in the environment.
Adverse effects on human health and welfare
4.18
The applicant has identified that adverse effects to the human health and welfare may
arise from:
 spillage of Imidacloprid 175 suspension in transit or during manufacture;
 spillage of Imidacloprid 175 suspension in transit;
 leakage of Imidacloprid 175 suspension during storage;
 spillage of Imidacloprid 175 suspension at the Field Operations Response Centre;
 operator or bystander contact with the bait stations;
 consumption of honey from feral colonies inside eradication zone;
 consumption of honey from feral colonies outside eradication zone; and
ERMA New Zealand Decision: Application HSE06004
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
consumption of honey from managed hives re-introduced to eradication zone
after completion of baiting.
4.19
The application and the accompanying Management Plan contain measures that must
be taken to avoid, remedy or mitigate the adverse effects arising from the manufacture
and use of Imidacloprid 175 suspension.
4.20
The Committee has reviewed these proposals and is satisfied that they are adequate to
control the adverse effects of the substance to human health and welfare.
Māori issues and concerns
4.21
The Committee is aware of the potential impacts that Imidacloprid 175 suspension
may have on the environment, the mauri of taonga flora and fauna and well being of
Māori communities. The applicant has outlined the hazardous classifications of the
substance and assessed the potential risks against the Management Plan, controls and
conditions and regulations governing the intended use of this substance.
4.22
The Committee notes the concern local iwi have from potential threat of the Varroa
destructor parasite to bee welfare and wider ecological well being. There is no evidence
to suggest that the strategically controlled use of the substance will breach the
principles of the Treaty of Waitangi given the strict conditions, regulations and
management strategy associated with this substance. In light of the emergency status of
the potential Varroa destructor threat the Committee sees no requirement for the
applicant to consult with Māori regarding this application.
4.23
This assessment is made on the condition that the substance is manufactured, handled,
stored, transported, used and disposed of, in accordance with the explicitly stated
controls, and any controls stipulated in other applicable Acts. However, should
inappropriate use, or an accident, result in the contamination of waterways or the
environment, it is recommended that the appropriate authorities be notified including
the relevant iwi authorities in that region. This action should include advising them of
the contamination and the measures taken to contain and remedy it.
Economic and related effects of the use of the substance
4.24
Removal of Varroa destructor from the South Island is expected to save an estimated
$41-$54 Million over 20 years, increasing to between $564 and $660 million over 35
years because of delayed pastoral impacts. The principle impacts of the parasite relate
to the increased cost of pollination and honey production.
4.25
The cost of Imidacloprid estimated to be required is less than $400. The cost of bait
stations and application to the grid is estimated to be $83 500, however this cost is
largely the labour cost, which is being provided by volunteers from the bee keeping
industry. The cost of waste disposal for any unused compound is approximately $200.
4.26
The Committee is satisfied that the proposed use of the substance will not have
adverse effects on New Zealand’s market economy.
Effects related to New Zealand’s international obligations
4.27
The applicant states that New Zealand has international obligations pertaining to any
bee products, honey and wax exported. The applicant notes that the expected residue
ERMA New Zealand Decision: Application HSE06004
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of this poisoning program is very low with less than 0.1 gram of imidacloprid applied
per square kilometre. In the short term all products from infested bee hives, and bee
equipment may not be moved from the Controlled Area, and feral bee products found
will be removed and destroyed where practical within the infested zone. The issue of
residues within managed hives moved in to the infested zone, post elimination, is to be
considered by the ACVM. It is anticipated that no honey or wax from beehives
reintroduced to the infested zone will be sold until January 2008.
4.28
The Committee is satisfied that the proposed use of the substance will not have
adverse effects on New Zealand’s international obligations.
CONTROLS
5
5.1
The Committee has evaluated the adequacy of the arrangements proposed by the
applicant in the management plan and consider that these are adequate to control the
adverse effects of Imidacloprid 175 suspension.
DECISION
6
6.1
The Committee has considered this application made under section 49D, and pursuant
to section 49F, the Committee is satisfied that the substance is necessary for use in the
special emergency.
6.2
Having considered the risks associated with the lifecycle of Imidacloprid 175
suspension, the Committee is satisfied that the Management Plan and the controls
imposed, including those in place under other legislation, will result in the substance
being adequately managed in accordance with the Act.
6.3
The Committee has also applied the following criteria in the Methodology:
 clause 9 – equivalent of sections 5, 6 and 8;
 clause 11 – characteristics of substance;
 clause 21 – the decision accords with the requirements of the Act and regulations;
 clause 22 – the evaluation of risks – relevant considerations;
 clause 24 – the use of recognised risk identification, assessment, evaluation and
management techniques.
6.4
The application manufacture and use Imidacloprid 175 suspension in a special
emergency is thus approved pursuant to section 49F, with the following controls:
6.4.1
The substance may only be used if the special emergency is managed in
accordance with the plan specified by the applicant as set out in Appendix 1.
6.4.2
The approval takes effect on the date of this decision and expires on 30 June
2007.
6.4.3
On expiry of this approval the Imidacloprid 175 suspension must be
disposed of unless, before the expiry of the approval, the applicant has, under
any other provision of the Act, been granted an approval.
ERMA New Zealand Decision: Application HSE06004
Page 7 of 17
Tony Haggerty
1 December 2006
Date
Chair
ERMA New Zealand Decision: Application HSE06004
Approval Codes:
Imidacloprid 175
suspension
HSE000006
Page 8 of 17
APPENDIX 1: MANAGEMENT PLAN FOR “IMIDACLOPRID
175 SUSPENSION” (PREPARED BY APPLICANT)
Background
On Thursday 15th June 2006 an incursion of Varroa bee mite was found in bee hives in the
Nelson city area. A measured response was declared under the Biosecurity Act 1993 on Friday
16th June. A Controlled Area was declared on the 16th June and movement restrictions on bees,
bee keeping equipment and bee products were imposed within the Buller, Tasman, Nelson city
and Marlborough districts. Initial delimiting surveillance determined the extent of Varroa
destructor infestation to be confined to bee hives within a ten kilometre radius around Nelson
city, a one kilometre radius around a point near Pelorus Bridge, and a one kilometre radius at two
sites in Tapawera.
Options for control and elimination were submitted to Cabinet, and a decision to manage the
incursion was agreed on 2 August 2006. Subsequent to this decision a beekeeper group, the
South Island Varroa Control Group has presented a plan to eliminate varroa from the infested
area. In late August 2006, Cabinet directed Biosecurity New Zealand to work with the
beekeeping industry on a limited bee elimination program in Nelson, including implementing a
government-led feral baiting program.
The elimination program involves removal of managed hives from the infested areas, followed
by poisoning of feral bees to remove all bees from these areas. In the absence of a suitable host
the parasitic mite Varroa destructor will be eliminated. The managed hives have been removed
to the North Island of New Zealand, and the placing of bait stations containing non-toxic bait in
grids within the infested area has begun. This will be followed by placing of toxic baits
containing imidacloprid to poison the feral bees in the area.
On Monday 18 September 2006, the Honourable Jim Anderton, Minister for Biosecurity,
declared the incursion of the varroa bee mite Varroa destructor into the South Island, to be a
special emergency (under section 49D of the Hazardous Substances and New Organisms
(HSNO) Act 1996) until Saturday 30 June 2007. An application for approval to import,
manufacture and use substance containing imidacloprid in a special emergency was made to the
Environmental Risk Management Authority (ERMA New Zealand) on 17 November 2006.
In accordance with the requirements of the application for approval, this report describes the
proposed management plan for dealing with the import, manufacture and use of substances
containing imidacloprid for the elimination of feral bees from the Nelson region.
Elimination Areas
In the Nelson region Varroa destructor has been found in Nelson city, Tapawera and Pelorus.
Each of the three areas is surrounded by two zones called the elimination zone and the buffer
zone. Within the Nelson city elimination zone there are 117 registered apiaries and 653 hives
belonging to 61 beekeepers. The elimination zones around the Nelson and Pelorus infested
places extend 10 km from the centre and the elimination zone around the Tapawera incursion
ERMA New Zealand Decision: Application HSE06004
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extends 5 km. The buffer zone in all three areas extends 5 km from the outside edge of the
elimination zone (Figure 1).
Figure 1 Map of 10km elimination zone for Nelson and Pelorus incursions
and 5 km for Tapawera. The buffer zone is a 5km radius surrounding the
elimination zones.
Feral Baiting Program
Timing for the Feral Baiting Program
It is proposed that there be up to two rounds of elimination of feral bees.
1.
A round of feral elimination may take place as soon the chemical is registered. This
would be conducted within the Pelorus and Nelson infested areas. At the time the chemical
becomes available an assessment will be made to the feasibility of conducting elimination. Items
to consider included:
Weather conditions and forecasts
Competing floral sources
Pollination activity
Availability of resources
ERMA New Zealand Decision: Application HSE06004
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Specific areas that should be targeted.
2.
A full round, in all infested areas, of feral elimination would be conducted during late
summer or early autumn. The best time to complete this will be determined taking the following
factors into account:
Weather conditions and forecasts
Competing floral sources
Availability of resources
Leaving time for any mop up poisoning to be completed
Weather conditions
To enable sufficient bee foraging activity to take place to conduct an elimination program a
period of at least 4 consecutive days of settled weather, with a temperature of at least 15ºC1 is
required. Depending on the conditions, the elimination program will be attempted at the earliest
opportunity.
Competing floral sources
Attracting foraging bees to the bait station is most successful when there are little or no other
nectar sources available. The timing of the nectar flow in the Nelson region is variable and it
may not be possible to successfully bait for feral colonies during November, December, and
January.
Pollination Activity
It is intended that feral baiting will occur over the three elimination zones:
•
Nelson city 10 km radius
•
Pelorus 10 km radius
•
Tapawera 5 km radius
Pelorus Zone
There do not appear to be any crops requiring pollination in the Pelorus Zone so feral baiting can
start as soon as the managed hives have been removed and the weather is suitable.
Tapawera Zone
There is cropping within the Tapawera zone. Feral baiting will not be able to begin until after
the hives used for pollination have been removed. Because the nectar flow might begin soon
after pollination, feral baiting in this area may not be able to start before February. Due to the
delay in the commencement of the baiting programme a decision was made to begin elimination
of known or locatable feral colonies by the best available means.
Nelson City Zone
Within the Nelson city elimination and buffer zone there is approximately 4 hectares (ha) of
citrus, 74 ha of kiwifruit (type unknown), 9 ha of nuts, 1023 ha of pipfruit, 25 ha of stonefruit,
225 ha of vegetables and 100 ha of berries. Approximately 2000 hives are needed for pipfruit
pollination (assuming 2 hives per ha) and 568 hives for kiwifruit pollination.
1
Johansen, C.A., Mayer, D.F. (1987). Observation on honey bee foraging behaviour. American Bee Journal,
127 (3): 194-196.
ERMA New Zealand Decision: Application HSE06004
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Figure 2 Location of orchards within the zone that need bees for
pollination
Pipfruit flower in the middle of September and through to the end of October. The kiwifruit
(Hayward) flower in November and blackberries flower at the end of December. Feral bee
baiting can begin as soon as possible in the north eastern end of the Zone but no closer than 5 km
from crops in the south western end of the Zone where pollination has to happen before feral
baiting can be conducted. As with the Tapawera Zone, due to the delay in the commencement of
the baiting programme, a decision was made to begin elimination of known or locatable feral
colonies by the best available means to reduce the risk of varroa spreading outside the area
before the feral baiting program can start.
The baiting in the Nelson area will be split into two sections – the Nelson city section and the
Western pollination section. The feral bee baiting program within five km of crops requiring
pollination on the Waimere plains will not occur until after flowering has finished and the hives
used for pollination have been removed. The area of the zone where pollination hives are being
placed will be searched for feral colonies which will be destroyed. Feral baiting in each area will
occur as soon as possible.
The feral baiting program will be rolled out in several stages. This will enable pollination within
the elimination and buffer zones to be accomplished with limited disruption to pollination. As
soon as the weather conditions become stable the feral baiting program will be conducted first in
areas where pollination does not occur. Once pollination has been completed the baiting
program will be conducted in other areas.
Availability of resources
ERMA New Zealand Decision: Application HSE06004
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Each round of elimination activities is envisaged to take up to 6 days. Activities requiring
management resources will include:
 Public notification
 Landowner communication and liaison.
 Beekeeper notification
 Control of sugar syrup, honey solutions and baits.
 Establishment of bait station or checking of bait station already deployed. Bait stations are to
be deployed on a 1km grid throughout the infested area.
 Pre baiting of stations with 50% sugar syrup
 Spray of attractant (dilute honey solution) around bait stations. Care must be taken to ensure
the honey is not contaminated with American Foul Brood spores.
 Monitoring of bait stations to determine when poisoning should occur
 Switching from pre-baiting to baiting
 Monitoring of bait stations that contain poison baits
 Disposal of poison baits and contaminated material
 Collection and disposal of contaminated soil. If poison is spilt soil to a depth of 10cm over
the contaminated area must be removed and incinerated.
Bee Free Period and Follow-up Baiting
Once poisoning, has been completed the effectiveness needs to be assessed. It is important that
the area is bee free.
Determining Bee Freedom
It is important that strong efforts are made to determine if the infested areas are bee free. It is
expected that there will be some bee activity at the periphery of the previous infested areas. It is
proposed that the following methods are employed to determine bee freedom. These activities
should commence no sooner than 2 weeks after poisoning.
1. Examination of known feral colonies to see if they have been killed.
2. A field survey will be undertaken looking at flowers for bee activity. This will be
completed by experienced persons that can recognise bees and when weather conditions
are suitable for bee foraging. The location of any bee finds will be documented including
a grid reference.
3. Use selected bait stations, pre-bait with sugar solution and monitor for bee activity.
4. Bee lining; where bees are observed in the field they may be followed to determine where
their nests are.
5. Follow up public reports.
When bees are found other than at the edge of the previous known infested areas, further limited
baiting will be undertaken. The bee free status should be maintained until repopulation.
Length of Bee Freedom
The area should remain free of bees and not be repopulated until August 2007 when bees are
required for the 2007 pollination. Ongoing surveys will be undertaken to ensure the bee free
status is maintained.
ERMA New Zealand Decision: Application HSE06004
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Proposed Management of the Substance
Import/Transport
The approved chemical Kohinor 350 (ERMA Approval: HSR000687) will be transported
directly into a secure environment at the field operations response team (FORT) headquarters in
Nelson where it will be stored on site in its original container with the correct labelling. The
amount imported will be one litre of Kohinor 350. Any surplus remaining after the 30th June
2007 will be stored in a secure environment that meets the requirements of the HSNO
regulations.
Manufacture
Laboratory staff will be exposed to Kohinor 350 during the manufacture of the stock bait
solution “Imidacloprid 175 suspension” (1.75 mg imidacloprid/litre). The secure facilities where
“Imidacloprid 175 suspension” is formulated will have standard operating procedures for the
handling of hazardous substances. The material safety data sheets and an emergency response
plan is kept in the secure facilities and staff are familiar with their contents. The process of
manufacturing “Imidacloprid 175 suspension” will be undertaken by trained staff that meet the
requirements specified in the HSNO regulations.
The “Imidacloprid 175 suspension” will be formulated to field strength of 1.75 mg
imidacloprid/litre by the addition of 5 microlitres of Kohinor 350 to one litre of sucrose and
water in the FORT headquarters.
Use
The field strength solution (“Imidacloprid 175 suspension”) will be stored briefly at the FORT
for use within two days by field staff. The transport of “Imidacloprid 175 suspension” from the
FORT headquarters to the use sites will be in labelled secure plastic screw top containers. At the
previously established bait stations “Imidacloprid 175 suspension” will be used to replace the
sucrose solution in bait stations where bee foraging has been established. Two litres of
“Imidacloprid 175 suspension” will be placed in each bait station.
Bait stations have the following features
 Are covered by netting with 2cm hexagonal pattern to exclude birds
 Are clearly labelled as containing toxic bait (poison).
 Are additionally covered by a plastic crate in areas where larger animals (e.g.
dogs) may come in to contact with them.
 Placement of stations is such that they are at least three metres away from
waterways, may be placed on low roofs to reduce exposure to people and dogs.
 Are individually numbered, and will be accounted for by the operations manager
 Consultation with landowners has been done, any landowners that objected, did
not have a bait station placed on their property.
 Prior to feral poisoning there were approximately 300 bait stations laid in the
infested zone.
Due to the delay in the commencement of the baiting programme a decision was made to begin
elimination of known or locatable feral colonies by the best available means. The progress of this
programme means that there are significantly fewer bait stations than previously. During the first
round of poisoning approximately 40 bait stations will be used. If two litres of “Imidacloprid 175
ERMA New Zealand Decision: Application HSE06004
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suspension” are required at each bait station, as planned, this means that a total of up to 0.4
millilitres of Kohinor 350 will be used.
Field staff will be briefed on the use and safety precautions each morning by the Cleaning and
Disinfection Officer, Paul Newing AgriQuality.
The bait stations will be checked at least twice daily, with those in areas accessible to the public
actively supervised throughout the day. At the end of the day the residual bait is collected in to
waste containers, and the empty bait stations are placed in marked bags and returned to the
FORT. The waste bait will be incinerated as medical waste. The bait stations will be cleaned and
storage for re-use or disposal.
It is intended that poisoning will last for one day for a given bait station. Following poisoning
some sentinel bait stations containing sucrose solution will remain. If there is significant bee
foraging at the sentinel stations in the week following poisoning, then either a search and destroy
effort by bee-lining (following the flight path of bees) or if there is a large number (>350) of bees
foraging at once, a repeat poisoning day will be done.
The toxic bait will not be left out in bait stations overnight.
Any spillage of the “Imidacloprid 175 suspension” solution will be mopped up using shredded
paper where possible, followed by removal of 10cm of the underlying soil to remove any
residues from the site. The shredded paper and soil will be double bagged and transported back
to the FORT for disposal by incineration.
If bait stations are placed on roofs, any gutters or down pipes will be blocked for the day of
poisoning to prevent waterway contamination. A spill on a roof will be absorbed in to waste
paper, double bagged and removed to the FORT for incineration. The responsibility for all
operations at the FORT is with the FORT controller, either Peter Wilkins, or Richard Calvert
AgriQuality.
Tracking
The containers for the field strength toxic bait, the waste containers and individual bait stations
are numbered and tracked by the FORT controller to ensure that all equipment is accounted for
and disposed of safely.
Disposal
As noted above, any spills on a hard surface will be treated by absorption and incineration. Any
laboratory waste will not enter waterways. Used bait stations will be returned to the
HortResearch laboratory for cleaning and storage for re-use within the Varroa Nelson program.
At the conclusion of the program in autumn 2007, they will be destroyed by incineration. Waste
toxic syrup and containers, and any contaminated soil will be incinerated. Used gloves and
disposable overalls will be incinerated, any contaminated clothing will be laundered. Boots will
be detergent washed at the FORT. Waste water from the FORT enters the Nelson city municipal
waste.
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Public notification
A public website has been created for public information about varroa and its impact.
http://www.biosecurity.govt.nz/pests-diseases/animals/varroa
The MAF contact phone number for enquiries and reports of bees is 0800 80 99 66.
MAF will notify the Ministry of Health of the operation to manage public health enquiries. The
National Poisons Centre will also be contacted to by MAF to advise of the operation in case they
get calls.
The address of the FORT is the AgriQuality office in Nelson at 25 Vickerman St, Nelson.
Labelling
“IMIDACLOPRID 175 SUSPENSION”
NOT FOR SALE
Insecticide for the control of Apis mellifera within the Controlled Area, Nelson
Varroa Incursion, declared on Friday 16th July 2006.
Active Ingredient: Contains 1.75 mg imidacloprid/litre in the form of a suspension.
Provisional Registration pursuant to the ACVM Act 1997, No XXXX
Approved for emergency use under section 49D, HSNO Act 1996
Net Contents 5 Litres
Distributed by
Biosecurity New Zealand
25 The Terrace
P.O. Box 2526
Wellington
Phone 04 894 0100
Fax
04 894 0736
Directions – must only be used by approved personnel.
Spills- clean up immediately, treat as hazardous waste.
DO NOT CONTAMINATE ANY WATER BODY OR DRAIN.
Label on sticky tape that is currently applied to bait stations
Warning Feral Bee Poison Bait Station
Imidacloprid in sugar syrup, handle with waterproof gloves. If accidentally ingested
call
NATIONAL POISONS INFORMATION CENTRE 0800 764 766. If splashed in eyes flush
immediately with copious amounts of water
ERMA New Zealand Decision: Application HSE06004
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Varroa Bee Mite Bait Station – Please do not remove
All enquiries to 0800 80 99 66 or 027 249 7771
“Imidacloprid 175
suspension” Solution
WARNING
This substance is harmful if
swallowed, inhaled or absorbed
through the skin.
PRECAUTIONS
Store in original container, tightly
closed. Store in a dry, ventilated
room. When using wear waterproof
gloves. Wash splashes of concentrate
from the skin immediately. Do not eat
drink or smoke while using. Wash
hands and face before meals and after
work. Return empty container to the
FORT in Nelson.
Insecticide for the control of
Apis mellifera within the
Controlled Area, Nelson Varroa
Incursion, declared on Friday
16th July 2006.
Active Ingredient: Contains 1.75 mg
imidacloprid/litre in the form of a
suspension
Wear gloves and protective clothing
when handling.
For use on approved bait stations
only
Number
TOXIC to Insects and Aquatic life.
Avoid contamination of any water
body or drain with the chemical or
empty container.
12
Date of manufacture
First Aid
If swallowed do not induce vomiting.
For advice contact the National
Poisons Centre 0800 POISON (0800
764 766) or a doctor immediately. If
skin or hair contact occurs, remove
contaminated clothing and flush skin
and hair with running water. If
inhaled move the victim to fresh air
immediately.
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