Reporting to the Rotterdam Convention
Ursula Edgington made this Official Information request to Ministry for the Environment
Ministry for the Environment did not have the information requested.
From: Ursula Edgington
Dear Ministry for the Environment,
Please forward any documentation from the last 10 years regarding the required reporting responsibilities to the above international legally-binding agreement.
In particular, I would like to see any reports and correspondence between the New Zealand representative for the Rotterdam Convention (RC) and the RC Secretariat relating to the chemical(s) defined as Fluoroacetamide and similar toxic chemicals (e.g Sodium Fluoroacetate) used as a pesticide and included in Annex 3 of the RC Prior Informed Consent (PIC) procedures - as defined by the RC and United Nations in the official Decision Guidance Documents (DGD).
I confirm that I am a NZ resident for the purposes of acquiring this OIA which will be communicated via FYI.
Yours faithfully,
Dr Edgington
From: Ministerials
Ministry for the Environment
Tēnā koe Ursula Edgington,
On behalf of the Ministry for the Environment, I acknowledge receipt of
your email of 21 July 2017, requesting the following information:
Please forward any documentation from the last 10 years regarding the
required reporting responsibilities to the above international
legally-binding agreement.
In particular, I would like to see any reports and correspondence between
the New Zealand representative for the Rotterdam Convention (RC) and the
RC Secretariat relating to the chemical(s) defined as Fluoroacetamide and
similar toxic chemicals (e.g Sodium Fluoroacetate) used as a pesticide and
included in Annex 3 of the RC Prior Informed Consent (PIC) procedures - as
defined by the RC and United Nations in the official Decision Guidance
Documents (DGD).
Your request will be considered according to the provisions of the
Official Information Act 1982 (OIA). You will receive a response as soon
as is reasonably practicable.
Nāku noa nā,
Ministerials
Ministry for the Environment
[1]cid:image001.png@01D2F705.36EF8650
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From: Ministerials
Ministry for the Environment
Dear Ursula
I refer to your official information request dated 21 July found below.
After consultation with the Environmental Protection Authority (EPA) we
are refusing your request under section 18(e) of the OIA, as the material
requested does not exist.
I can confirm that the Ministry for the Environment does not have material
generated in the past 10 years which would be captured by your request.
While, the EPA holds documentation from the last 10 years regarding the
required reporting responsibilities to the Rotterdam Convention, it holds
nothing in relation to “Fluoroacetamide and similar toxic chemicals (e.g
Sodium Fluoroacetate) used as a pesticide and included in Annex III of the
Rotterdam Convention Prior Informed Consent (PIC) procedures” as per your
request.
New Zealand issued a ‘no consent to import’ for fluoroacetamide in 1993,
which is listed in the Rotterdam Convention database here:
[1]http://www.pic.int/Procedures/ImportResp...
Sodium fluoroacetate (1080) is not included in Annex III of the Rotterdam
Convention. Nor are there any other ‘similar toxic chemicals’ to
fluoroacetamide (or sodium fluoroacetate) listed in Annex III. The EPA
does hold information on 1080 for the purposes of the Hazardous Substances
and New Organisms Act 1996. If you would like to see this information,
please contact the EPA on 0800 429 7827.
There is no formal reporting obligation under the Rotterdam Convention,
with the exception of a country informing the Secretariat when it places a
restriction on the import/export of a substance listed under Annex III of
the Convention, as stated in Articles 10-12 of the Rotterdam Convention.
This is communicated to the Secretariat by adding the listing to its
online database.
You have the right to seek an investigation and review by the Ombudsman of
this decision. Information about how to make a complaint is available at
[2]www.ombudsman.parliament.nz or by freephone 0800 802 602.
Yours sincerely
Executive Relations
Ministry for the Environment
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From: Ursula Edgington
Dear Ministerials,
Sorry, but I am confused by your response. Can you please check the clarity of your text? You say in the above that "fluoroacetamide is not listed in Annex III" when clearly it is.
My question was, because the Rotterdam Convention Annex III chemicals does indeed include fluoroacetamide (1081) and Sodium Fluoroacetate is very similar in structure (and even more toxic, because it is without antidote), what reports have NZ supplied about the widespread and long-term use of this chemical to the secretariat? If no reports have been filed, then please supply the documented rationale for this, as it seem logical and in line with the objectives of the Rotterdam Convention agreement - to share all knowledge about highly hazardous chemicals, i.e. that as fluoroacetamide IS included, then any findings about the use of the more toxic Sodium Fluoroacetate should indeed be reported to member partners..
Yours sincerely,
UE
From: Ministerials
Ministry for the Environment
Dear Ursula
In regards to your request for clarification about "fluoroacetamide not being listed in Annex III" and it being similar to Sodium fluoroacetate.
In our previous statement we noted that the Ministry does not hold any reports to the Rotterdam Secretariat on sodium fluoroacetate. Furthermore, that the rationale for not having produced reports, is that we do not have to under the Rotterdam Convention. This is because sodium fluoroacetate is not listed in Annex III. This statement is accurate, sodium fluoroacetate is not on the annex. We did not state that fluoroacetamide is not in the Rotterdam annex.
Whilst it is true that fluoroacetamide has a similar structure to sodium fluoroacetate, they are in fact two separate chemicals. Simply because sodium fluoroacetate is similar to fluoroacetamide does not make it part of the Rotterdam Convention Annex III.
In summary, only fluoroacetamide is on the annex, not sodium fluoroacetate.
Kind regards
Executive Relations
Ministry for the Environment – Manatū Mō Te Taiao
Website: www.mfe.govt.nz
23 Kate Sheppard Place, PO Box 10362, Wellington 6143
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