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

water is present or to intertidal areas below the mean high watermark.6.1.5 Controls and variations to protect operators and workers6.1.5.1 ERMA New Zealand proposes that Use Scenarios 1 to 8 are prohibitedon the basis of the unmanageable levels of risk posed to the environment.6.1.5.2 ERMA New Zealand notes that, while it might potentially be possible tomanage the non-negligible risks to operators and workers (e.g. throughuse of PPE, maximum application rates, use of engineeringtechnology),—the proposal arising from the environmental assessment means thatfurther consideration is not required; andERMA New Zealand does not have the information available to itto determine whether effective risk mitigation measures could beimplemented to protect human health.Use Scenarios 9 – 25: Indoor use (industrial)6.1.6 Controls to protect workers – greenhouse, mushroom house, warehouses6.1.6.1 Specified PPE/RPE:A minimum level of PPE is required to ensure the level of risk isnegligible. ERMA New Zealand considers that the risks to humanhealth from exposure to dichlorvos are sufficient that the level ofPPE required to ensure negligible risk should be prescribed.6.1.6.2 Remotely activated automated fogging/misting equipment:Use of automated equipment can reduce the exposure of operatorsthrough use, by removing pathway of risk to operators.The equipment should be capable of being activated remotely toensure that no operators are required to be present in the treatmentarea to initiate application.6.1.6.3 Operational controls to restrict number of cylinder changes:For use of dichlorvos-containing gases, the number of cylinderchanges is a key factor in determining operator exposure;The assessment carried out has indicated that the number ofcylinder changes should be restricted to 1 cylinder change peroperator per day. ERMA New Zealand notes that a reduction inallowable cylinder changes could result in larger volume cylindersbeing used.Additionally, appropriate levels of PPE/RPE are required to ensurethat the operator exposure risks are negligible.6.1.6.4 Restriction of maximum application rates, mixing quantities and treatedareas:Dichlorvos reassessment – application Page 77 of 436