Summary of HS application APP203301 and submission guidance
Date Submissions Open: 28 February 2019 Date Submissions Close: 12 April 2019
Application number: APP203301
Purpose: To reassess seven approvals for paraquat and paraquat-containing substances
Applicant: Environmental Protection Authority Application Lead: Daniel Phipps and Matthew Allen
Purpose of this document
On 25 February 2019, the Environmental Protection Authority (EPA) received an application seeking to reassess seven approvals for paraquat and paraquat-containing substances. This application is being publicly notified to enable the public to comment and to put all relevant information before the decision- makers.
The purpose of this document is to summarise the application and to provide guidance on the submission process.
Application summary
This document is a summary of the information provided in the application only. The EPA risk assessment, as described in Appendix D of the application may be revised at a later date using information provided through submissions.
Submission process
This document also provides guidance on the submission process. The EPA encourages all submissions.
The submission period for this application will start on 28 February 2019 and will end on 12 April 2019 at 5pm.
In a submission you can provide information, make comments, raise issues or indicate support. In this way, you contribute to the EPA decision making process on specific applications. W e are particularly interested in hearing from you on the following matters.
The reliance on paraquat for kūmara crop production;
Further information on alternatives and their effectiveness;
Assessments of risks to birds associated with multiple applications of paraquat within a growing season;
Provision of refined risk or benefits assessments, or other supported justifications for adopting a different position on risk and/or benefit;
Information on the relevance of the identified risks to birds, such as bird feeding and habitation behaviour in agricultural settings.
Adverse effects, especially adverse effects not identified in the application1. Positive effects, especially positive effects not identified in the application2.
Further information on the purpose of submissions is available from the EPA website using the link below:
https://www.epa.govt.nz/public-consultations/open-consultations/
If you have any questions, you can contact:
The EPA for any question on the application and/or submission process. The Application Lead, Daniel Phipps, can be contacted by e-mail (daniel.phipps@epa.govt.nz) or by phone (+64 4 474 5436).
1 Adverse effects can include any risks and costs associated with release of the substance.
Application summary
1. The EPA has made an application to reassess seven existing approvals for paraquat and paraquat- containing formulations.
2. Grounds to reassess paraquat were established in July 2017 (application reference APP202788).
Grounds were established based on significant new information obtained in the assessment of an application for a paraquat-containing substance (APP202697) that resulted in the application being declined. The risk assessment generated for this application showed that risks to human health and the environment were unacceptable, and unable to be mitigated.
The risk assessment presented in this application is a refinement on that from APP202697, and incorporates data obtained through the call for information (July – September 2017)
3. The application and associated documents are available from the EPA website using the link below:
https://www.epa.govt.nz/database-search/hsno-application-register/view/APP203301
4. The EPA is requesting information in the key areas mentioned above (see report for details).
5. On the basis of the current information available, the EPA identified some control options which could effectively mitigate a number of risk areas across the different use patterns, including the revocation of some approvals which do not offer any benefit or present unnecessary risk, restrictions on the application of paraquat, and new requirements for manufacturers and users of paraquat.
6. If any approvals for paraquat-containing substances are retained, WorkSafe are considering the implementation of risk mitigation measures including further requirements for users.
7. For full detail of the proposals, please see the application form.
Adverse effects assessment
8. Our adverse effects assessment was based on the evidence obtained in the call for information, as well as other readily available sources and information gathered in the compilation of this application.
9. The EPA have identified potential risks to birds which are unable to be mitigated.
10. The cultural risk assessment has identified concerns to Māori, notably the persistence of paraquat in soil.
Please let us know whether you consider that there are additional adverse effects that we should be aware of or additional information related to the described effects.
When identifying adverse effects it is important that you provide us with reasons as to:
What other adverse effects are associated with paraquat-containing substances?
How likely these adverse effects are and their potential scale?
How you think the adverse effects could happen (ie the series of events that would have to happen for the adverse effects to occur)?
Options and proposals for managing the adverse effects.
Any uncertainty you have on the scope of the information we will use to assess the adverse effects.
Positive effects assessment
11.Our positive effects, or benefits, assessment (presented in Appendix B of the application form) was produced by Sapere Research Group, and is based on the evidence obtained in the call for information, interviews with users, as well as other readily available sources and information gathered in the
compilation of this application.
12.The benefits assessment has identified the advantages of paraquat use, and estimates the value that paraquat use contributes to New Zealand’s GDP.
Please let us know whether you consider that there are additional positive/beneficial effects that we should be aware of or additional information related to the described effects.
When identifying positive/beneficial effects, it is important that you provide us with information on:
Other positive effects associated with paraquat-containing substances?
How likely these positive/beneficial effects are and their potential scale?
How you think the positive/beneficial effects could happen (ie the series of events that would have to happen for the positive/beneficial effects to occur)?
Options and proposals for ensuring the positive/beneficial effects occur.
Any uncertainty you have on the scope of the information used to assess the positive/beneficial effects.
Other information
If there is other information you wish us to be aware of, please also include this in your submission.
Making a submission
What is a submission?
We encourage anyone to make a submission, regardless of how much detail you are able to put in to it. In your submission, you can also request a hearing if you would like to strengthen your views in person before the Decision-making Committee. Further information on submissions for a hazardous substance application is available from the EPA website using the link below:
https://www.epa.govt.nz/public-consultations/how-to-make-a-submission/
Submissions are publicly available and will be displayed on the application web page after submissions close. If you have confidential information you wish to provide, please contact the Application Lead, Daniel Phipps, by e-mail (daniel.phipps@epa.govt.nz) or by phone (+64 4 474 5436).
How to make a submission?
The EPA website provides guidance on how to make a submission. This is preferably done via an online submission but alternatively may be sent using the EPA submission form or as a letter or email to the EPA.
This information and the submission form can be accessed from the EPA website using the link below:
https://www.epa.govt.nz/assets/Uploads/Documents/New-Organisms/Forms/Submission-form-for-HSNO- applications.doc
What happens after you make a submission?
When the submission period closes, all submissions will be summarised and made available to the Decision-making Committee together with the EPA Staff Assessment Report.
A date will be set for the Decision-making Committee to consider the application in a public hearing.
You are entitled to bring witnesses who may speak to your submission at a hearing. If you choose this option, you should provide the EPA with a list of the witnesses, their areas of expertise, and the elements of the submission or application they will talk to.
You are also entitled to speak at the hearing in one of the three official languages of New Zealand: English, Māori or New Zealand Sign Language. Please advise the Application Lead at least two weeks prior the hearing in order for the EPA to organise for an interpreter. The Application Lead, Daniel Phipps, can be contacted by e-mail (daniel.phipps@epa.govt.nz) or by phone (+64 4 474 5436).
At least two weeks prior to the hearing, both the applicant and submitter(s) need to provide the EPA with copies of any information they intend to present at the hearing.
A decision will be made by the Decision-making Committee at the end of the consideration period. This will be made public on the EPA website.
