Brodifacoum Pestoff Rodent bait 20R cautionary advisory label and Code of Practice - clarification.
Helen Black made this Official Information request to Ministry for Primary Industries
The request was partially successful.
From: Helen Black
Dear Ministry for Primary Industries,
This is a Local Government Act request.
The government's outlet Orillion, fifty per cent owned by MPI sell brodifacoum products. My questions concern the product Orrillion sell: Pestoff Rodent bait 20R, its warning/user label and Code of Practice.
1. Brodifacoum products sold world-wide states that it is hazardous to aquatic life on their labels/Code of Practices. This is omitted from the New Zealand cautionary warning label and Code of Practice. Why is that?
a) Please provide relevant documentation that explains the decision to allow Pestoff 20R being placed into New Zealand waterways/riverbeds and why this is omitted from the NZ label.
b) Please provide documents that highlights the public health and safety issues of brodifacoum under OP 63.
c) MPI signs off on exemptions to aerial application. Should not the same general public health and safety issues apply as under OP 63? Please provide documents that explain the reasons that the OP 63 guidelines of public health and safety are viewed as irrelevant under the government's new amendment as it exempts OP 63 guidelines for exactly the same product, brodifaocum?
2. "Do not breathe dust" is stated on the NZ brodifacoum cautionary label. What distance does MPI think is sufficient during an aerial application to ensure public safety? For example 5-100 meters from a housing area? Please provide documentation that clarifies/justifies this warning statement.
3. Code of Practice: "Pest proof fences must be of a design and construction which has been tested and proven to be fully effective in preventing access to the Specified Area by all farm livestock and target pests present. Such fences must be able to be maintained in a pest proof state."
Who are qualified to ensure these standards? What agency enforces that the above regulation are being met? Please provide your guidelines/documentation as of who these people/agencies are?
Photos of old and more current slips and slumps can be provided provided of the Nelson Mainland fenced in area as per Code of Practice. One example is from an Nelson Mail article 24/02/2016 (http://www.stuff.co.nz/nelson-mail/news/...).
I am looking forward to your reply.
Yours faithfully,
Helen Black
From: Ministerials
Ministry for Primary Industries
Tēnā koe Helen
Thank you for your official information request as below.
Your request will be considered and an answer provided in accordance with the requirements of the Official Information Act 1982.
If you have any questions regarding this request, please email [email address].
Ngā mihi,
Gabrielle Mackintosh | Ministerial Support Officer
Ministerials & Business Support | Office of the Director-General
Ministry for Primary Industries - Manatū Ahu Matua
Telephone: 0800 00 83 33 | Web: www.mpi.govt.nz
-----Original Message-----
From: Helen Black [mailto:[FOI #6560 email]]
Sent: Sunday, 17 September 2017 12:01 p.m.
To: Ministerials <[email address]>
Subject: Official Information request - Brodifacoum Pestoff Rodent bait 20R cautionary advisory label and Code of Practice - clarification.
Dear Ministry for Primary Industries,
This is a Local Government Act request.
The government's outlet Orillion, fifty per cent owned by MPI sell brodifacoum products. My questions concern the product Orrillion sell: Pestoff Rodent bait 20R, its warning/user label and Code of Practice.
1. Brodifacoum products sold world-wide states that it is hazardous to aquatic life on their labels/Code of Practices. This is omitted from the New Zealand cautionary warning label and Code of Practice. Why is that?
a) Please provide relevant documentation that explains the decision to allow Pestoff 20R being placed into New Zealand waterways/riverbeds and why this is omitted from the NZ label.
b) Please provide documents that highlights the public health and safety issues of brodifacoum under OP 63.
c) MPI signs off on exemptions to aerial application. Should not the same general public health and safety issues apply as under OP 63? Please provide documents that explain the reasons that the OP 63 guidelines of public health and safety are viewed as irrelevant under the government's new amendment as it exempts OP 63 guidelines for exactly the same product, brodifaocum?
2. "Do not breathe dust" is stated on the NZ brodifacoum cautionary label. What distance does MPI think is sufficient during an aerial application to ensure public safety? For example 5-100 meters from a housing area? Please provide documentation that clarifies/justifies this warning statement.
3. Code of Practice: "Pest proof fences must be of a design and construction which has been tested and proven to be fully effective in preventing access to the Specified Area by all farm livestock and target pests present. Such fences must be able to be maintained in a pest proof state."
Who are qualified to ensure these standards? What agency enforces that the above regulation are being met? Please provide your guidelines/documentation as of who these people/agencies are?
Photos of old and more current slips and slumps can be provided provided of the Nelson Mainland fenced in area as per Code of Practice. One example is from an Nelson Mail article 24/02/2016 (http://www.stuff.co.nz/nelson-mail/news/...).
I am looking forward to your reply.
Yours faithfully,
Helen Black
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From: Official Information Act
Ministry for Primary Industries
Dear Helen Black,
On behalf of Allan Kinsella, Director, Systems Audit, Assurance and
Monitoring, I enclose our response to your Official Information Act
request.
Kind Regards,
Samantha Rickard | Adviser – Official Information Act
Officer of the Director-General | Ministerial and Business Support
Ministry for Primary Industries - Manatû Ahu Matua | Pastoral House 25 The
Terrace | PO Box 2526 | Wellington 6140 | New Zealand
Web: [1]www.mpi.govt.nz
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may be unlawful. If you have received this message by mistake please call
the
sender immediately on 64 4 8940100 or notify us by return email and erase
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The Ministry for Primary Industries accepts no responsibility for changes
made to this email or to any attachments after transmission from the
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From: Official Information Act
Ministry for Primary Industries
Dear Helen Black,
On behalf of Allan Kinsella, Director, Systems Audit, Assurance and
Monitoring, I enclose our response to your Official Information Act
request.
Kind Regards,
Samantha Rickard | Adviser – Official Information Act
Officer of the Director-General | Ministerial and Business Support
Ministry for Primary Industries - Manatû Ahu Matua | Pastoral House 25 The
Terrace | PO Box 2526 | Wellington 6140 | New Zealand
Web: [1]www.mpi.govt.nz
--------------------------------------------------------------------------
This email message and any attachment(s) is intended solely for the
addressee(s)
named above. The information it contains may be classified and may be
legally
privileged. Unauthorised use of the message, or the information it
contains,
may be unlawful. If you have received this message by mistake please call
the
sender immediately on 64 4 8940100 or notify us by return email and erase
the
original message and attachments. Thank you.
The Ministry for Primary Industries accepts no responsibility for changes
made to this email or to any attachments after transmission from the
office.
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References
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1. http://www.mpi.govt.nz/
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Helen Black left an annotation ()
I believe MPI skirted around the issue and did not fully address their role as a provider for granting exemptions that bypass health and safety regulations in regards to aerial brodifacoum applications. However, I've been told MPI staff came down to Nelson to inspect the 3rd Brodifacoum application.
I will address this issue again with the new government once the portfolios been settled afresh with a new OIA.
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Helen Black left an annotation ()
Phoned MPI when I realised that I had made a mistake in my OIA request. They suggested I email them which I've done info@mpi.govt.nz. "I made a mistake in my OIA request, see below. Please delete "This is a Local Government Act request." MPI acknowledged this via email.
Link to this