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

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humidity conditions. The higher residual concentration in <strong>the</strong> strip being replacedmeans that greater care is needed in handling <strong>the</strong> strip during replacement in <strong>the</strong>trap and with <strong>the</strong> disposal <strong>of</strong> <strong>the</strong> used strips.Potential exposure <strong>of</strong> contractors carrying opened sachets might arise in a vehicle(confined space). However contractors are trained to roll over <strong>the</strong> torn opening toreseal <strong>the</strong> sachet. This not only protects from potential exposure by inhalation butalso helps ensure unused strips do not become prematurely depleted <strong>of</strong> <strong>the</strong> activecomponent.“3.8.5 On <strong>the</strong> basis <strong>of</strong> this in<strong>for</strong>mation a Use Scenario <strong>for</strong> operator exposure was developedas follows. The operator will service 90 traps in a day, spending 2 minutes at eachtrap, giving an exposure <strong>of</strong> 3 hours per day. 41% <strong>of</strong> <strong>the</strong> 520 mg dichlorvos on a stripwill be emitted continuously over <strong>the</strong> 6 week (1008 hours) service life <strong>of</strong> a strip in atrap, giving an emission rate <strong>of</strong> 0.21 mg dichlorvos / hour. There will be no build-up<strong>of</strong> dichlorvos within a trap and an operator will inhale all <strong>the</strong> dichlorvos beingemitted from a trap as <strong>the</strong>y bend over it to service it, but will not be exposed to anydichlorvos while travelling between traps, i.e. operators will be exposed to 0.21 mgdichlorvos / hour <strong>for</strong> 3 hours per day. The risks posed to operators based on <strong>the</strong>sefigures are detailed in paragraph 4.4.4.1.3.9 Existing Controls3.9.1 The lifecycle and hazardous properties <strong>of</strong> dichlorvos and its <strong>for</strong>mulations aremanaged through a variety <strong>of</strong> controls. These controls are prescribed as part <strong>of</strong> <strong>the</strong>approval <strong>of</strong> <strong>the</strong>se substances <strong>under</strong> <strong>the</strong> Act and <strong>the</strong> Agricultural Compounds andVeterinary Medicines Act 1997 (ACVM Act), and through requirements <strong>for</strong> resourceconsents <strong>under</strong> <strong>the</strong> Resource Management Act 1991.3.9.2 The HSNO Act controls applicable to dichlorvos and its <strong>for</strong>mulations are given inAppendix J. A summary <strong>of</strong> conditions <strong>under</strong> <strong>the</strong> ACVM Act is also given inAppendix J.3.9.3 In Section 4, <strong>the</strong> risks, costs and benefits <strong>of</strong> dichlorvos are identified and assessed.This assessment is made <strong>under</strong> <strong>the</strong> assumption that <strong>the</strong>re is compliance with <strong>the</strong>existing controls.Dichlorvos reassessment – application Page 39 <strong>of</strong> 436

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