1. Staff Presentation – Grizly Max
APP202093
Hearing 19 July 2016

2. Outline Introduction to application Submissions
Classifications, Risks, Controls
Benefits
Recommendation
Supplementary information

3. Introduction Insecticide Thrips on onions
Tomato Potato Psyllid (TPP) and aphids on potatoes
Suspension concentrate containing 3 active ingredients
Imidacloprid
Novaluron
Bifenthrin

4. Proposed use pattern
Ground boom application - 2 applications every season with a 7 day interval
Imidacloprid max application rate
210 g/ha for potatoes
156 g/ha for onions
Bifenthrin max application rate
24 g/ha for potatoes
18 g/ha for onions
Novaluron max application rate
36 g/ha for potatoes
27 g/ha for onions

5. Risk assessment
Imidaclopird application rate significantly higher than existing approvals for ground boom application (78 g/ha) hence a risk assessment was carried out
Bifenthrin application rate lower than existing approvals – no risk assessment carried out
Novaluron application method different, hence need for a risk assessment

6. Submissions 3 submissions were received Carolyn O Fallon
National Beekeepers Association
Te Rūnanga o Ngāi Tahu

7. Key issues raised by submitters
Concerns about risks to bees
Risks to the environment
Risks to Māori values including concerns about taonga species
Level of information in the application

8. Classification Hazard endpoint Grizly Max 6.5 Contact sensitisation
6.5B
6.9 Target organ systemic toxicity
6.9B (oral)
9.1 Aquatic ecotoxicity
9.1A
9.2 Soil ecotoxicity
9.2B
9.3 Terrestrial vertebrate ecotoxicity
9.3B
9.4 Terrestrial invertebrate ecotoxicity
9.4A

9. Risks to human health
For the proposed use patterns risks to human health were less than the level of concern
Operators (specific PPE required)
Re-entry workers (wait until spray has dried)
Bystanders

10. Risks to the environment
Risks were less than the level of concern
Groundwater
Non target plants
Birds

11. Risks to the environment
Aquatic risk assessment – risks driven by novaluron
Downwind buffer zones needed to manage risks 24 m for potatoes and 12 m for onions
Low boom application only (<50 cm from the ground)
Application only in wind speeds > 3 km/hr and < 20 km/hr
Application must only occur using coarse droplets (applicant has informed us that product efficacy will not be affected)
No application into or onto water
Control information should be on the product label

12. Risks to soil organisms
Acute risk assessment
Risks less than the level of concern
Chronic risk assessment (risks driven by imidacloprid)
Risk assessment indicated risks above level of concern both in and off field
Risks driven by the fact that the application rate is significantly higher than alternative products
Chronic No Observed Effect Concentration (NOEC) for earthworms is greater than mg/kg soil
Chronic NOEC for the soil-dwelling predatory mite Hypoaspis aculeifer > 120 g/ha

13. Risks to soil organisms
Applicant has provided an argument that earthworms are already under pressure due to cultivation practices and that therefore the risks from the use of Grizly Max are not significant
EPA staff do not accept this argument- Grizly Max could pose a chronic risk to earthworms and other soil organisms

14. Risks to soil organisms
Lack of data on the chronic risks of the principal metabolite of novaluron
Uncertainties about the environmental fate of imidacloprid at the higher application rate

15. Risks to bees
Risk assessment identified risks above the level of concern
Controls were identified to manage these risks to honey bees
No application when bees are foraging or in the 10 day period pre flowering
No application to any crops grown for seed production
We cannot exclude the possibility of risks to bumblebees

16. Risks to Māori Largest area of concern related to risks to earthworms
Indigenous species are less likely where soil disturbance is highest
Benefits to vegetable growers and their employees some of whom are Māori
With controls the risk could be minimised, hence use would be unlikely to breach the principles of the Treaty of Waitangi

17. Benefits
In the application form the applicant has identified benefits related to the control of thrips on onion and TPP on potatoes
EPA staff agree that these pests are a significant problem for important sectors

18. Benefits
Applicant has provided us with an efficacy report which demonstrates that the substance does work at the application rates suggested by the applicant – need at least 900 ml product/ha
All three active ingredients are already approved in separately products
Unsure about the rationale for combining these three active ingredients

19. Benefits
Approving the substance would provide a benefit to growers in terms of convenience and increased grower choice
From the application form we were unsure about why the applicant requested such high application rates

20. Overall recommendation
Based on the information provided by the applicant in their application form and subsequent reports we recommend a decline

21. Subsequent information provided by the applicant
Applicant proposed to reduce the application rates for potatoes from 1200ml/ha to 900ml/ha
Revised risk assessment has not been completed
Applicant has agreed to controls suggested in the Evaluation and Review report and additional label statements

22. Thank you for listening