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

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ERMA New Zealand was not able to quantitatively assess <strong>the</strong> risk<strong>of</strong> exposure to operators arising from <strong>the</strong> use <strong>of</strong> dichlorvosimpregnatedinsecticide strips (Use Scenario 31). Given <strong>the</strong> usepattern described <strong>for</strong> DDVP Insecticide strips, <strong>the</strong> criteria used todevelop <strong>the</strong> Use Scenario, ERMA New Zealand has <strong>under</strong>takensemi-quantitative assessment. ERMA New Zealand estimates thatoperators will be exposed to 0.21 mg / hour <strong>of</strong> operations involvingDDVP strips associated with traps (which includes placing andreplacing strips in traps, and also routine inspection <strong>of</strong> traps).ERMA New Zealand estimates that operators will be exposed <strong>for</strong> aduration <strong>of</strong> 3 hours per day (0.63 mg dichlorvos per day). It hasbeen assumed that exposure will only occur via inhalation, as PPE(i.e. gloves) will be used when handling DDVP strips. Comparing<strong>the</strong> quantity <strong>of</strong> exposure to <strong>the</strong> AOEL (0.0014 mg/kg bw / day), <strong>for</strong>a 75 kg operator <strong>the</strong> daily AOEL equates to 0.105 mg dichlorvos.ERMA New Zealand considers that, whilst <strong>the</strong> estimations arelikely to be conservative in nature, <strong>the</strong> magnitude <strong>of</strong> adverse effectposed to operators is minor to major. ERMA New Zealandconsiders that <strong>the</strong> likelihood <strong>of</strong> minor to major adverse effectsoccurring is very unlikely. The level <strong>of</strong> risk to <strong>the</strong> health <strong>of</strong>operators is <strong>the</strong>re<strong>for</strong>e negligible to low.4.4.4.2 Restricted entry exposure to operators:Only a few scenarios <strong>for</strong> existing uses <strong>of</strong> dichlorvos gaveacceptable risks <strong>for</strong> restricted entry workers. Acceptable restrictedentry generally requires <strong>the</strong> use <strong>of</strong> PPE and/or RPE plus in mostcases a time period called <strong>the</strong> Restricted Entry Interval (REI) 6 isalso needed. The level <strong>of</strong> risk <strong>of</strong> exposure associated with each UseScenario is detailed in Table 11, arising from restricted entry intotreated areas.ERMA New Zealand considers that <strong>the</strong> unrestricted entry timeperiods proposed <strong>for</strong> industrial buildings treated with dichlorvos,indicate that inhalation exposure to dichlorvos is acceptable withoutuse <strong>of</strong> RPE after such a time. ERMA New Zealand considers that<strong>the</strong> such time periods, with respect to inhalation exposure risk, canalso be imposed on glasshouse and mushroom house use.However,, given that ERMA New Zealand is not able to establish atime period after which dermal exposure has reduced to acceptablelevels, ERMA New Zealand considers that contact with treatedglasshouse and mushroom house crops after treatment require use<strong>of</strong> PPE to prevent dermal exposure.ERMA New Zealand considers that <strong>the</strong> semi-quantitativeassessments carried out <strong>for</strong> operator exposure <strong>for</strong> Use Scenario 31is appropriate to use <strong>for</strong> <strong>the</strong> restricted entry operator exposure6A Restricted Entry Interval (REI) is a time period within which specific restrictions must be met. Examples<strong>of</strong> <strong>the</strong> types <strong>of</strong> restrictions that may be imposed include use <strong>of</strong> PPE and RPE, entry is only allowed <strong>for</strong> certaintasks and <strong>for</strong> specified durations.Dichlorvos reassessment – application Page 50 <strong>of</strong> 436

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