Brodifacoum Pestoff Rodent bait 20R cautionary advisory label and Code of Practice, Public Health and Safety - clarification.
Helen Black made this Official Information request to Environmental Protection Authority
The request was successful.
From: Helen Black
Dear Environmental Protection Authority,
The government's outlet Orillion sell brodifacoum products. My questions concern one of their products: Pestoff Rodent bait 20R, which is normally used for aerial applications.
1. Brodifacoum products sold world-wide states that it is hazardous to aquatic life on their labels/Code of Practices. This is omitted from this 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 Pestoff 20R?
2. "Do not breathe dust" is stated on the NZ brodifacoum cautionary label. What distance does EPA 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. And who would be the reinforcement agency for any immediate breaches?
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."
a) Who are qualified to ensure these standards?
b) What agency enforces that the above regulation are being met?
c) 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 sincerely,
Helen Black
From: Ministerials
Environmental Protection Authority
Good afternoon Helen,
I am emailing to acknowledge receipt of your request for official information received on 18 September 2017 regarding brodificoum, specifically the product Pestoff Rodent Bait 20R. We will endeavour to respond to your request as soon as possible, and in any event no later than 16 October 2017, being 20 working days after the day your request was received.
If you have any queries please do not hesitate to contact me.
Frances Charlett-Green
Official Correspondence Advisor, Regulation
Ext 5533 ••DDI +64 4 474 5533 • Tel +64 4 916 2426
-----Original Message-----
From: Helen Black [mailto:[FOI #6561 email]]
Sent: Sunday, 17 September 2017 12:46 p.m.
To: Information Mailbox <[email address]>
Subject: Official Information request - Brodifacoum Pestoff Rodent bait 20R cautionary advisory label and Code of Practice, Public Health and Safety - clarification.
Dear Environmental Protection Authority,
The government's outlet Orillion sell brodifacoum products. My questions concern one of their products: Pestoff Rodent bait 20R, which is normally used for aerial applications.
1. Brodifacoum products sold world-wide states that it is hazardous to aquatic life on their labels/Code of Practices. This is omitted from this 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 Pestoff 20R?
2. "Do not breathe dust" is stated on the NZ brodifacoum cautionary label. What distance does EPA 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. And who would be the reinforcement agency for any immediate breaches?
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."
a) Who are qualified to ensure these standards?
b) What agency enforces that the above regulation are being met?
c) 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 sincerely,
Helen Black
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From: Frances Charlett-Green
Environmental Protection Authority
Good afternoon Helen,
Please find attached the response to your request for information regarding brodifacoum, specifically the product Pestoff Rodent Bait 20R.
If you have any further queries please do not hesitate to contact me.
Thank you,
Frances Charlett-Green
Official Correspondence Advisor, Regulation
Ext 5533 ••DDI +64 4 474 5533 • Tel +64 4 916 2426
-----Original Message-----
From: Ministerials
Sent: Wednesday, 4 October 2017 5:29 PM
To: '[FOI #6561 email]'
Subject: Official Information request - Brodifacoum Pestoff Rodent bait 20R cautionary advisory label and Code of Practice, Public Health and Safety - clarification.
Good afternoon Helen,
I am emailing to acknowledge receipt of your request for official information received on 18 September 2017 regarding brodificoum, specifically the product Pestoff Rodent Bait 20R. We will endeavour to respond to your request as soon as possible, and in any event no later than 16 October 2017, being 20 working days after the day your request was received.
If you have any queries please do not hesitate to contact me.
Frances Charlett-Green
Official Correspondence Advisor, Regulation Ext 5533 ••DDI +64 4 474 5533 • Tel +64 4 916 2426
-----Original Message-----
From: Helen Black [mailto:[FOI #6561 email]]
Sent: Sunday, 17 September 2017 12:46 p.m.
To: Information Mailbox <[email address]>
Subject: Official Information request - Brodifacoum Pestoff Rodent bait 20R cautionary advisory label and Code of Practice, Public Health and Safety - clarification.
Dear Environmental Protection Authority,
The government's outlet Orillion sell brodifacoum products. My questions concern one of their products: Pestoff Rodent bait 20R, which is normally used for aerial applications.
1. Brodifacoum products sold world-wide states that it is hazardous to aquatic life on their labels/Code of Practices. This is omitted from this 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 Pestoff 20R?
2. "Do not breathe dust" is stated on the NZ brodifacoum cautionary label. What distance does EPA 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. And who would be the reinforcement agency for any immediate breaches?
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."
a) Who are qualified to ensure these standards?
b) What agency enforces that the above regulation are being met?
c) 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 sincerely,
Helen Black
-------------------------------------------------------------------
This is an Official Information request made via the FYI website.
Please use this email address for all replies to this request:
[FOI #6561 email]
Is [EPA request email] the wrong address for Official Information requests to Environmental Protection Authority? If so, please contact us using this form:
https://fyi.org.nz/change_request/new?bo...
Disclaimer: This message and any reply that you make will be published on the internet. Our privacy and copyright policies:
https://fyi.org.nz/help/officers
If you find this service useful as an Official Information officer, please ask your web manager to link to us from your organisation's OIA or LGOIMA page.
-------------------------------------------------------------------
hide quoted sections
From: Helen Black
File Ref: ENQ-32428-Z4Q8P1 Dr Fiona Thomson-Carter
Thank you for your reply. I would appreciate some further clarifications.
1. "The label for Pestoff Rodent Bait 20R includes its hazard classification ‘9.1D’, meaning that the substance is slightly harmful to the aquatic environment. As Pestoff is a vertebrate toxic agent, the Transfer Notice and controls focused the labeling requirements on the harm to vertebrates."
The New Zealand hazard classification differs vastly from the hazard classifications in the US, Canada, Europe and the World Health Organisation (comments and links supplied below). Are potential risks to waterways minimised in New Zealand? What scientific studies does EPA base its classification '9.1D' on? Does it help the environment as a whole to focus the label requirements on what one wants to get rid off?
2. The majority of dust particles in the atmosphere are not visible to the eye. A moving helicopter dropping toxic baits close to a housing area (approximately 30 meters) cannot be compared to a sheltered workshop or a fenced off loading area. Are potential risks to public health minimised in New Zealand? What scientific studies has been done and what is the rational behind to exclude people who live close to areas that are aerially applied with brodifaocum baits from 'Do not breath in dust'?
US/Canada: Brodifacoum: Hazard Identification:
Highly toxic by inhalation; Potential Health Effects: Inhalation: May be fatal if inhaled. May cause respiratory tract irritation.
Acute aquatic toxicity (Category 1)
Other adverse effects: An environmental hazard cannot be excluded in the event of unprofessional handling or disposal. Very toxic to aquatic life. Hazardous to the aquatic environment, long-term hazard.
http://datasheets.scbt.com/sc-239414.pdf
Point 12: https://pubchem.ncbi.nlm.nih.gov/compoun...
Europe:
Hazard statement codes: Very toxic to aquatic life with long lasting effects.
With regards to Environment: Aquatic acute; Aquatic chronic.
https://circabc.europa.eu/sd/a/d88b968d-...
WHO: Brodifacoum is of high acute toxicity to birds, fish, aquatic invertebrates and algae.
http://who.int/whopes/quality/en/Brodifa...
I am looking forward to have this clarified.
Yours sincerely,
Helen Black
From: Ministerials
Environmental Protection Authority
Good evening Helen,
Please find attached the response to your request for information regarding brodifacoum. If you have any further queries, please do not hesitate to contact me.
Thank you,
Frances Charlett-Green
Official Correspondence Advisor, Regulation
Ext 5533 ••DDI +64 4 474 5533 • Tel +64 4 916 2426
-----Original Message-----
From: Helen Black [mailto:[FOI #6561 email]]
Sent: Tuesday, 17 October 2017 1:18 AM
To: Frances Charlett-Green
Subject: Re: FW: Official Information request - Brodifacoum Pestoff Rodent bait 20R cautionary advisory label and Code of Practice, Public Health and Safety - clarification.
File Ref: ENQ-32428-Z4Q8P1 Dr Fiona Thomson-Carter
Thank you for your reply. I would appreciate some further clarifications.
1. "The label for Pestoff Rodent Bait 20R includes its hazard classification ‘9.1D’, meaning that the substance is slightly harmful to the aquatic environment. As Pestoff is a vertebrate toxic agent, the Transfer Notice and controls focused the labeling requirements on the harm to vertebrates."
The New Zealand hazard classification differs vastly from the hazard classifications in the US, Canada, Europe and the World Health Organisation (comments and links supplied below). Are potential risks to waterways minimised in New Zealand? What scientific studies does EPA base its classification '9.1D' on? Does it help the environment as a whole to focus the label requirements on what one wants to get rid off?
2. The majority of dust particles in the atmosphere are not visible to the eye. A moving helicopter dropping toxic baits close to a housing area (approximately 30 meters) cannot be compared to a sheltered workshop or a fenced off loading area. Are potential risks to public health minimised in New Zealand? What scientific studies has been done and what is the rational behind to exclude people who live close to areas that are aerially applied with brodifaocum baits from 'Do not breath in dust'?
US/Canada: Brodifacoum: Hazard Identification:
Highly toxic by inhalation; Potential Health Effects: Inhalation: May be fatal if inhaled. May cause respiratory tract irritation.
Acute aquatic toxicity (Category 1)
Other adverse effects: An environmental hazard cannot be excluded in the event of unprofessional handling or disposal. Very toxic to aquatic life. Hazardous to the aquatic environment, long-term hazard.
http://datasheets.scbt.com/sc-239414.pdf
Point 12: https://pubchem.ncbi.nlm.nih.gov/compoun...
Europe:
Hazard statement codes: Very toxic to aquatic life with long lasting effects.
With regards to Environment: Aquatic acute; Aquatic chronic.
https://circabc.europa.eu/sd/a/d88b968d-...
WHO: Brodifacoum is of high acute toxicity to birds, fish, aquatic invertebrates and algae.
http://who.int/whopes/quality/en/Brodifa...
I am looking forward to have this clarified.
Yours sincerely,
Helen Black
-----Original Message-----
Good afternoon Helen,
Please find attached the response to your request for information regarding brodifacoum, specifically the product Pestoff Rodent Bait 20R.
If you have any further queries please do not hesitate to contact me.
Thank you,
Frances Charlett-Green
Official Correspondence Advisor, Regulation Ext 5533 ••DDI +64 4 474 5533 • Tel +64 4 916 2426
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #6561 email]
Disclaimer: This message and any reply that you make will be published on the internet. Our privacy and copyright policies:
https://fyi.org.nz/help/officers
If you find this service useful as an Official Information officer, please ask your web manager to link to us from your organisation's OIA or LGOIMA page.
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Helen Black left an annotation ()
I'm not very happy with their answer. Have sent Dr Fiona Thomson-Carter a question to clarify her statement
"The label for Pestoff Rodent Bait 20R includes its hazard classification ‘9.1D’, meaning that the substance is slightly harmful to the aquatic environment. As Pestoff is a vertebrate toxic agent, the Transfer Notice and controls focussed the labelling requirements on the harm to vertebrates."
Link to this