Grower Submission Guide

The Environmental Protection Authority (EPA) has recommended that Hydrogen Cyanamide (hicane) be banned and phased out over a five-year period. During the five-year phase-out period, the EPA are recommending the following controls:

  • Introduction of buffer zones
    • Between 4-8m bystander (this means the distance from your boundary)
    • Between 5-10m for spray entering waterways
    • Up to 25m for spray settling on land that slopes more than 10% to waterways
    • Between 0-10m non-kiwifruit plants
  • Restrict application rate to a maximum rate of 25kg ai/ha.
  • Maximum wind speed of between 3 km/h and 20 km/h. (Not to be applied when wind speeds are less than 3 km/hr or more than 20 km/hr as measured at the application site)

There are other recommendations like updating labelling requirements and hazard classifications.

The EPA human and environment health risk assessment found:

  • Hydrogen cyanamide is toxic to the reproductive system and thyroid if people are exposed to it over time. It is a suspected carcinogen and is corrosive to skin and eyes
  • There is a risk of exposure to applicators
  • There are risks to the aquatic environment, non-target plants, pollinators, non-target arthropods, and birds

To find out more about what the EPA have recommended, visit the NZKGI hicane page here (scroll down until you reach the EPA reassessment section)

Consultation is open until 20 December 2021 although NZKGI has requested a further extension to 6 April 2022. The EPA is yet to make a decision on this request.

To provide guidance to growers on how to complete a submission to the EPA, a submission guidance template has been developed. The intent is to help you with your submission and set out what type of information the EPA is wanting to know. The template provides headings to guide you but the information is your own. You can access the template here.

Submissions can be posted, emailed or you can fill in the online form on the EPA website:


Environmental Protection Authority
Private Bag 63002
Waterloo Quay
Wellington 6140

Complete the online response form

If you want to set out your own submission, see below for the type of information the EPA is looking for submitters to provide and your own personal information.

1.Provide a short summary of your growing operation – do you grow green/gold/red? How many hectares? What region?

2.Describe your hicane use and what systems are used to keep you/workers safe.

3.If hicane is banned describe what the financial impact would be. Include mental health implications.

4.Do you want to speak at the hearing?

5.Information on your use of closed cab application, closed systems for mixing and loading and/or any other technological developments that you have implemented.

6.If you have any data on occupational exposure monitoring.

  • how do you monitor possible exposure of yourself or your workers

7.Information on bird behaviour in New Zealand orchards.

  • What type of birds are on your orchards during hicane spraying season
  • What type of food sources are available to birds on your orchard during hicane season

8.Effectiveness and cost of alternatives to hydrogen cyanamide.

  • Have you tried any alternatives
  • What were they
  • Were they effective. If not, provide tray production difference data

9.Positive effects, especially positive effects not identified in the reassessment application.

10.The value of hicane to your orchard.

  • The financial impacts if hicane banned
  • Tray production

11.Your spray practices.

  • How you meet GAP safe spraying standards and health & safety requirements
  • How you protect neighbours
  • What shelter do you have on your orchard/s and what do you do to keep it in good condition?