ENVIRONMENTAL AND POLICY

NZKGI Hicane submission

NZKGI has provided a response to the EPA proposal to ban hicane with a phase out period of five years which you can read here. Due to the EPA not approving NZKGI time extension request, we have been unable to provide expert evidence relating to toxicology and operator exposure however this will be provided to the EPA in March 2022. The Decision-Making Committee of the EPA has allowed further information to be provided if submitters notify the EPA what this is and what timeframe it will be provided by 31 January 2022.

Response to HiCane reassessment

To help streamline NZKGI response to the Hicane reassessment, workstreams have been developed with work well underway to research and gather information to form our response. Below provides a timeline of each workstream and further details:

Interested Parties

This is our advocacy and collaboration work. We are working with Hort NZ, in discussions with hicane suppliers and working with Zespri – we want to be aligned as much as possible with other submitters therefore this work is critical.

Lead: NZKGI CE Colin Bond and Senior Policy Analyst Sarah Cameron.

Toxicology

To provide a strengthened position with our response to human/environment health risks, we are in the process of engaging two toxicologists – one to focus solely on the possible carcinogen link and the other who will provide a complete response.

Lead: Sarah Cameron.

Applicator Exposure

Concerns have been raised by the EPA about applicator exposure. We are working with Worksafe on resolving what these risks are but also investigating what actual risks there are to applicators if correct procedures are used.

Lead: NZKGI Te Puke rep Simon Cook.

Economics

We are delving into the impacts for growers at an individual level – not just industry – and we will provide three or four case studies from East Coast, Bay of Plenty and Northland that show not only what the financial impacts are (if the product is banned) but also the mental health implications for growers.

Lead: NZKGI deputy chair Whetu Rolleston and NZKGI Gisborne rep Tim Tietjen.

Alternatives

If HiCane is banned what alternatives are there. Is there a new variety that can produce the same or higher yields without hicane – these are key questions that we will work alongside Zespri on.

Lead: Hicane grower group members Braden Hungerford and Whetu Rolleston.

Communications

It’s simple really – this is a crucial part of our response. What we strive for is the best outcome for growers and we can’t do that if we don’t talk to you. Your opinions will help drive our response and you will see more information about this soon.

EPA Reassessment

The EPA is  reassessing the use of hydrogen cyanamide (HiCane) and has provided a number of recommendations:

  • Current approvals for hydrogen cyanamide be declined, and the substance banned
  • Hicane to be phased out over five years with tighter controls taking immediate effect after the final decision.
  • Introduction of buffer zones
  • Update hazard classifications to:
    • Classify the soluble concentrate as skin and eye corrosive, rather than an irritant
    • Include a carcinogenicity classification
    • Change the specific target organ toxicity classification (from Category 1 to 2)
    • Classify as hazardous to soil organisms
    • Lowest possible application rates (HiCane application rate is not restricted in New Zealand. The EPA is proposing that a maximum application rate of 25 kg ai/ha is set)
    • 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). If spraying under 3km, then drift can travel for a lot further
    • Update labelling and packaging requirements

The EPA reassessment can be found here and is supported by a number of documents:

To mitigate drift, the EPA has recommended the following buffer zones:

Proposed bystander buffer zones

Note: ai means active ingredient

Note: The EPA are proposing the introduction of a maximum application rate of 25kg of ai per hectare. This means at 6% you can safely spray up to a volume of around 750L per hectare. Growers wishing to apply at 7% will be restricted to around 650L per hectare.

 

Proposed buffer zones to protect the aquatic environment (waterways)

Aquatic environment

In the risk assessment, the term aquatic environment is used to encompass any area of water that contains any of the aquatic species assessed (fish, aquatic invertebrates, aquatic plants/algae).

In terms of the proposed buffer zones, while the draft controls mention the aquatic environment, the tables set out particular distances to a downwind or downslope water body.

The EPA definition of a water body:

Water body – Includes all-natural and modified/artificial watercourses such as reservoirs, irrigation canals, water-supply races, canals for the supply of water for electricity generation or farm drainage, ditches, streams, rivers, ponds and lakes. For clarity, it excludes fully covered pipes, tanks or other enclosed structures, puddles or groundwater.

Watercourse or Waterway – Includes every river, stream, passage, and channel on or under the ground, whether natural or not, through which water flows, whether continuously or intermittently.

Proposed downwind buffer zones to protect non-target plants

In the risk assessment, the term “non-target plants” means plants that are not the intended pesticide target.

In terms of the proposed buffer zone distances for non-target plants, these are set in conjunction with clause 51 of the Hazardous Property Controls Notice 2017.

The EPA has stressed that the recommendations are initial proposals and subject to change based on submissions. NZKGI will provide a grower submission to the EPA, working alongside Maori Kiwifruit Growers Inc.

Growers can make their own submission. The EPA has asked that submitters (as much as possible) address the following points:

  • Feedback on the input values we used for the risk assessment on human health.
  • Feedback on the proposed maximum application rate restrictions, and information on the effectiveness of lower application rates.
  • Information on advances in closed cab application, closed systems for mixing and loading, and other technological developments
  • Occupational exposure monitoring data
  • Crop-specific spray drift curve information with full supporting data, or refined risk assessments
  • Information on birds, for example, foraging habits and behaviour in New Zealand orchards
  • Information on alternatives to hydrogen cyanamide, their relative cost and effectiveness, and any recent developments.

Before drafting your submission it is recommended that you read the application and summary guide here. You can either complete an online submission here or via word here

Email

reassessments@epa.govt.nz

Post

Reassessments
Environmental Protection Authority
Private Bag 63002
Waterloo Quay
Wellington 6140

Submissions close Friday 20 December at 5 pm.

If you have any feedback on the recommendations, please email NZKGI Senior Policy Analyst, Sarah Cameron sarah.cameron@nzkgi.org.nz