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

SECTION 2 - THE RISK MANAGEMENT CONTEXT2.1 Risk management context2.1.1 The Authority decides whether to approve or decline hazardous substances based onthe requirements of the HSNO Act and the Methodology 1 . The purpose of the Act isto ―protect the environment and the health and safety of people and communities, bypreventing or managing the adverse effects of hazardous substances and neworganisms‖. The Act and the Methodology therefore provide the foundation for therisk management context for the evaluation and review of this application whichmust be undertaken in accordance with the purpose of the Act.2.1.2 Section 29 of the Act requires the Authority to consider adverse and positive effectsof the substance(s) and to make a decision based on whether or not the positiveeffects of releasing the substance outweigh the adverse effects of the substance. Therelevant adverse and positive effects are those that are associated with the substance.2.1.3 In particular, in accordance with section 6 of the Act, the following matters havebeen taken into account in assessing the risks, costs and benefits associated with theuse of dichlorvos in New Zealand:The sustainability of native and valued introduced flora and fauna;The intrinsic value of ecosystems;Public health;The relationship of Māori and their culture and traditions with their ancestrallands, water, sites, wāhi tapu, valued flora and fauna, and other taonga;The economic and related benefits to be derived from the use of dichlorvos;New Zealand‘s international obligations.2.1.4 ERMA New Zealand notes that comparison of risks or benefits, for example a risk ofchronic human toxic effects compared to a risk of aquatic toxic effects, and thecomparison of risks and benefits, for example an environmental or human health riskcompared to a societal or economic benefit, requires value judgement. This is takeninto account in making recommendations (Section 7) and the Authority will take thisinto account in reaching an overall assessment of the risks and benefits.2.2 Consideration of Outcome Scenarios2.2.1 Risk-benefit analysis is used to assess the adverse and positive effects. Risk-benefitanalysis is a comparative tool; thus the results of the assessment of risks and benefitsfor one option need to be compared against one or more alternative options.2.2.2 In the HSNO context there are two basic options in terms of the resultant riskmanagement regimes to be applied to the approvals for substances containingdichlorvos: the baseline Outcome Scenario linked to the status quo and one or morealternative Outcome Scenarios. In this instance the baseline scenario is based on thecurrent use of the substance.2.2.3 Dichlorvos is used in a range of sectors. The sectors evaluated in this applicationare: dispersive use, greenhouse use, use on industrial premises, use in domestic and1Hazardous Substances and New Organisms (Methodology) Order 1998 (SR 1998/217).Dichlorvos reassessment – application Page 18 of 436