5.1. The importance of understanding the benefits
Knowing and communicating the benefits of a new hazardous substance is an important part of applying for approval to import or manufacture the substance. It is so important that it is part of New Zealand law and is written into the HSNO Act – the EPA must evaluate the positive effects (the benefits) of a hazardous substance and its adverse effects (the risks). So when assessing and evaluating a new hazardous
substance, the benefits of the substance are considered; when a reassessment of an existing substance is initiated, we seek comments from the public and industry, as part of a call for information, to better
understand the benefits of that substance.
A new hazardous substance can only be approved under the HSNO Act if the benefits outweigh the risks. If there are no stated benefits in an application, or if it is clear that the presented benefits do not outweigh the risks, an application seeking approval for a hazardous substance will be declined. Including a comprehensive benefits assessment with all applications is therefore important.
5.2. Who is responsible for collating this information?
As mentioned earlier, the applicant, or their consultants and advisors, are in the best position to collect and present this information, as they have the best knowledge about the benefits of making their product available in New Zealand.
When making an application for a new hazardous substance, we recommend that the case for the benefits is made separately from that of the risks, as a separate report. While the EPA may look for more information about the risks when evaluating an application, we are unlikely to seek additional information on the benefits of a substance, if it wasn’t already supplied with the application. This may happen in rare cases, if we need to know more about the benefits to inform the final decision about approving the application. This may result in a delay to reach a decision.
If the public has been consulted over an application (publicly notified) and people have asked to share their views, then there will be an opportunity for the applicant or the public to present further benefits at a hearing.
However, not every application will be publicly notified, and not all publicly notified applications result in a hearing. Therefore, it is more efficient for all parties if the benefits are provided at an early stage and with the application.
If we initiate a reassessment of a hazardous substance that is already approved and in use in New Zealand, we will work with interested parties to identify the benefits of the hazardous substance, and the
consequences if the substance is withdrawn or its availability is restricted.
5.3. What to include in a benefits assessment
The HSNO Act 1996 and the related Hazardous Substances and New Organisms (Methodology) Order 1998 both list several areas of impact that need to be considered when evaluating and considering an application, which include the natural environment, human health, economy, people and communities, and Māori. Table 11 summarises some useful questions to ask to help identify benefits. If there are other relevant benefits that are outside of these questions, these should be included with your application also. These same questions could be used in the opposite sense to identify the costs associated with a substance or with its non- availability.
The benefits must be related to the application being considered. While both direct and indirect benefits may be relevant to the consideration, how far indirect benefits will be considered will depend on the nature of the application. With hazardous substances, the benefits may be primarily related to substitution of one product for another with the new (proposed) product expected to be ‘less risky’ than the current product. The realisation of these benefits will depend on the market share that the new product achieves, and it may be useful to consider, compare and substantiate a range of scenarios for evaluating such benefits.
Table 11 Benefits assessment example questions
Benefit type Beneficiary Questions to ask
Environmental
Environmental loss
How could it prevent/reduce environmental loss? How much damage would pests do to our environment without the substance? Are there any
biosecurity concerns?
Environmental enhancement
How might it enhance the environment? Will vegetation be saved, ecosystems enhanced, at-risk species supported? Is it less persistent and/or bioaccumulative than the chemicals currently used for the job?
Ecosystems How might it enhance the environment? Vegetation saved, ecosystems enhanced, at-risk species supported?
Economic
User Is it a unique product, cost effective or efficacious (ie works well enough to perform the intended function)?
Community Will it contribute to jobs or capital investment to a community?
New Zealand Will it enhance our GDP, knowledge or innovative capacity?
International Harmonisation Will approving the substance align New Zealand with international practices?
Māori culture and traditions
Kaitiaki tanga Will it allow for kaitiaki tanga (intergenerational guardianship and stewardship) and enhance their role as kaitiaki (guardians)?
Manaakitanga Will it enhance/protect manaakitanga (care and respect for people and the environment)?
Mahinga kai Will it enhance/protect mahinga kai (food resources and related environments)?
Taonga species Will it enhance/protect culturally taonga (culturally significant) species?
Benefit type Beneficiary Questions to ask
Taha hauora Will it enhance/protect (taha hauora) human health and wellbeing?
Economics Will it provide employment for Māori or profit to Māori enterprises?
Social
Social and cultural
wellbeing Are lifestyle or values enhanced by the use of this substance?
Health Will it keep us safe from the spread of diseases?
Jobs Will it enhance industry or help create/save jobs?
Animal welfare Will it improve the welfare of pets or livestock?
Intrinsic values Will it enhance/save local landscapes/sites of significance?
Safety Will it improve the safety of people? Is it safer for people to use?
Choice What is the benefit to families of being able to live and work in an area of their choosing?
Recreation
Does a pest impede access to or enjoyment of a site? Might an activity be lost altogether? What are the additional costs of alternative recreational activities, because this is the benefit of keeping the current one?
As with the risk assessments, a benefit assessment can be conducted qualitatively or quantitatively (that is, with a monetary value in this case). Examples of qualitative descriptors are presented in Table 2 and discussed in section 3.2. The more detailed quantitative assessment is generally required only if the qualitative benefits assessment, or the balance between benefits and risks, indicate that further work is required by the applicant to confirm that the benefits outweigh the risks.
A detailed assessment of benefits should also show an understanding of how they are distributed across different groups, demographics and geographies, and over different timescales.