Application for the Reassessment of a Hazardous Substance under ...

This evaluation takes into account that ERMA New Zealand‘s assessment is based on theinformation that is available to it. Additional information is welcomed. ERMA New Zealandinvites submitters to provide additional information that they might have, and notes thefollowing as areas where additional information may be particularly useful:the level of benefit offered by dichlorvos substances, especially regarding socialeffects from the use of dichlorvos (e.g. effect on local employment opportunities,direct/indirect local community impact arising from dichlorvos use);the level of ecomonic benefit provided to the public health sector by dichlorvos;the financial implications of overseas restrictions on crops treated with dichlorvos;identification of the use and availability of alternative substances, with particularregard to dichlorvos use in non-agricultural enclosed space use;identification of use patterns that have not been included in the assessment;provision of data to determine when unrestricted entry into treated glasshouses ormushroom houses can occur;identification of minimum effective application rates, which may be used to refinethe exposure assessment;feasibility of proposed risk management measures, and the implications of themodified control regime (such as financial implications of installing or upgradingapplication equipment).ERMA New Zealand considers that:the non-negligible risks to the environment (Use Scenarios 1 to 8) cannot bereduced to negligible by the application of practicable controls to the existingapprovals, and that these adverse effects are not outweighed by the positiveeffects;the non-negligible risks to human health can be reduced to negligible for the UseScenarios 9 to 29, and 31 by the application of practicable controls;the non-negligible risks to human health cannot be reduced to negligible for UseScenario 30 by the application of practicable controls, and that these adverseeffects are not outweighed by the positive effects.ERMA New Zealand considers that the Outcome Scenarios in Table ES. 5 are appropriate forcontinued safe use of dichlorvos in New Zealand.Table ES. 5Summary of proposed Outcome Scenarios for use of dichlorvos.Use Scenarios Continue Use Restrict Use /Additional ControlsOutdoor agricultural usage1 - 8Enclosed space, agricultural usage9 - 16Enclosed space, industrial usage17 - 25Enclosed space, domestic usageOutcomeScenario (a)OutcomeScenario (b)DiscontinueUseOutcomeScenario (c)Dichlorvos reassessment – application Page 10 of 436