Dear Ministry for Primary Industries,

The government's outlet Orillion, fifty per cent owned by MPI sell brodifacoum products. My questions concern the product Orillion 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 is 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