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

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value that can be attributed to dichlorvos is unknown. ERMA New Zealand notesthat dichlorvos has specific benefits associated with its volatility, and that <strong>the</strong>re arelimited alternatives available at <strong>the</strong> present time, particularly <strong>for</strong> <strong>the</strong> minor cropssuch as persimmons, tamarillos and passionfruit. ERMA New Zealand cannotdetermine <strong>the</strong> amount <strong>of</strong> <strong>the</strong> value <strong>of</strong> <strong>the</strong> crops that can be attributed specifically to<strong>the</strong> use <strong>of</strong> dichlorvos, but accepts <strong>the</strong> view presented by Horticulture New Zealandand Plant & Food Research that it is potentially significant.4.7.24 It is interesting to note that Japan is moving towards not allowing import <strong>of</strong> freshasparagus that has been treated with dichlorvos (Plant & Food Research). Japan isNew Zealand‘s major market <strong>for</strong> vegetable products taking 34% by value <strong>of</strong>vegetable exports in 2009. Australia is <strong>the</strong> second biggest market at 23% (<strong>the</strong> UnitedStates <strong>of</strong> America is 3%). For fruit and vegetables <strong>the</strong> respective figures are 19%,14% (6%), with <strong>the</strong> EU taking 16%. If Japan were to extend this requirement too<strong>the</strong>r produce <strong>the</strong>n alternatives would need to be found quickly.4.7.25 Based on <strong>the</strong> in<strong>for</strong>mation provided by Horticulture New Zealand and Plant & FoodResearch, and noting <strong>the</strong> specific benefits provided by dichlorvos (e.g. rapiddissipation), ERMA New Zealand considers that a minimal benefit is at least likely,resulting in a low level <strong>of</strong> positive effect.Benefits from use in <strong>the</strong> cymbidium growing industry and cut flowerindustry4.7.26 In<strong>for</strong>mation provided by <strong>the</strong> Northland Cymbidium Growers Association based on anational survey <strong>of</strong> cymbidium growers suggests that dichlorvos is used in <strong>the</strong>cymbidium industry mainly in <strong>the</strong> Northland and Auckland regions. Some growersuse it regularly while o<strong>the</strong>rs use it as a chemical <strong>of</strong> last resort. Its volatility isvaluable here as well with relatively short restricted entry periods.4.7.27 The survey looked at <strong>the</strong> availability <strong>of</strong> alternatives, and growers were generally notaware <strong>of</strong> any product that would fill <strong>the</strong> particular function <strong>for</strong> which <strong>the</strong>y useddichlorvos. Respondents that considered alternatives showed preference <strong>for</strong> o<strong>the</strong>rorganophosphates in general, though no specific substances were identified.4.7.28 Cymbidiums have been consistent per<strong>for</strong>mers <strong>for</strong> a number <strong>of</strong> years. In 2003 <strong>the</strong>total value <strong>for</strong> exported cut flowers and foliage was just <strong>under</strong> $40m ($NZ38.5m <strong>for</strong><strong>the</strong> 2004-5 season). Plant & Food Research indicate that in 2009 this had risen toapproximately $NZ60m. In 2004-5 cymbidiums accounted <strong>for</strong> approximately half <strong>of</strong>this value, dropping to about one third ($NZ22m) in 2009. In 2005/6 Japan took51% <strong>of</strong> New Zealand flower exports and <strong>the</strong> United States 29%.4.7.29 Cymbidiums are <strong>the</strong>re<strong>for</strong>e a significant export crop. Currently dichlorvos is used <strong>for</strong>scale insect and mite control with its main value being that it can be used within oneday <strong>of</strong> harvesting or packing. Based on <strong>the</strong> in<strong>for</strong>mation provided about <strong>the</strong> use andvalue <strong>of</strong> dichlorvos to <strong>the</strong> cymbidium industry, ERMA New Zealand considers that aminimal benefit to <strong>the</strong> cut flower industry is unlikely thus leading to a negligiblebenefit. This does not mean that <strong>the</strong> export crop is not significant, but ra<strong>the</strong>r that <strong>the</strong>contribution <strong>of</strong> dichlorvos to cymbidium production in terms <strong>of</strong> a national benefit isnot significant.Economic benefit associated with public health use4.7.30 Dichlorvos is considered to be particularly important <strong>for</strong> insect pest control in <strong>the</strong>dairy industry where control <strong>of</strong> products is difficult because <strong>of</strong> large, structures andyear round operations with short periods available <strong>for</strong> insect control. ReportedlyDichlorvos reassessment – application Page 61 <strong>of</strong> 436

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