epa.govt.nz · Web viewCall for Information – hydrogen cyanamide Call for Information –...

Call for Information on use of hydrogen cyanamide substances30 January 2020

Please submit your comments to [email protected] on this form in Word document format

Response to Call for Information on hydrogen cyanamide substances

Name

Organisation name (optional)

Postal address (optional)

Telephone Number (optional)

Email

Information we are looking for

The EPA is calling for information on the use of hydrogen cyanamide in New Zealand.

This is an opportunity for you, as interested parties and/or stakeholders, to provide information on hydrogen

cyanamide-containing substances that are available in New Zealand, and how those substances are used.

We are looking to receive any relevant information industry, users, other interested parties or the public can

provide to us relating to the current use, practices, and benefits of hydrogen cyanamide substances. This

includes any information relating to the effects of the substances, positive or adverse; toxicology;

ecotoxicology; environmental fate studies; or monitoring results.

We particularly request information that relates to use and application of hydrogen cyanamide in the different

production sectors in which it is used.

As the current risk management framework is driven to a large extent by industry requirements, we are keen

to get a better understanding of current industry requirements, such as:

of 18

Please submit your comments to [email protected] in Word document format no later than 30 April 2020.

mailto:[email protected]


Call for Information – hydrogen cyanamide

the identification and nature of the risks being managed;

what measures are implemented to manage risks;

the effectiveness of the current requirements in managing risks to human health and the environment;

how the industry requirements align with other regulatory requirements under different pieces of legislation (eg Hazardous Substances and New Organisms Act 1996, Health and Safety at Work Act 2015 and Resource Management Act 1991).

Important date

Please complete and return your feedback form to [email protected] by 30 April 2020.

Feedback form

We have produced this feedback form in order to assist you to provide information to inform our analysis of

hydrogen cyanamide use. When providing information, please provide your comments under the relevant

headings below, and attach any evidence or supporting information as applicable. As this is an opportunity to

provide us with your relevant information, please focus on the areas that are of relevance to you. We

encourage you to submit additional information such as product labels, study data, scientific literature, or

technical reports as separate documents. If you choose to submit separate documents, please briefly identify

these in the relevant section of the feedback form.

It would be helpful if you can complete the questions as comprehensively as possible and provide additional

comments where appropriate. This information will be useful to ensure use scenarios are accurate and

applicable to the substances in the reassessment.

Responding is voluntary

Responding to this call for information is voluntary.

You are entitled to respond to whichever questions you feel able to contribute. For each topic, we have

indicated which parties may have information to provide. However, please do not feel restricted by this, as

these indications are provided as guidance only.

of 18





Important information when providing feedback

How we will use this information

This information is intended to be used to prepare an application for reassessment, to determine whether the

EPA should undertake a modified or full reassessment of hydrogen cyanamide, and to inform that

reassessment process. Interested parties will have an opportunity to make formal submissions on our

assessment and proposal once a reassessment application has been lodged.

The EPA may use the information in order to undertake its regulatory role, including by sharing the

information with other agencies.

Feedback may be made publicly availableThe Environmental Protection Authority (EPA) may publish all or part of your feedback on its website at

www.epa.govt.nz. Providing feedback implies that you consent to such publication, unless you clearly specify

otherwise in your feedback.

The EPA will take into account requests for information to be kept confidential and will not proactively

disclose that information, except with your prior consent. However, the EPA is subject to the Official

Information Act 1982 and may be required to disclose information, including confidential information,

provided by you as part of this feedback in accordance with that Act (see Official Information section

below).

Privacy

The Privacy Act 1993 establishes certain principles with respect to the collection, use, and disclosure of

information about individuals by various agencies, including the EPA.

Any personal information you supply when providing feedback will be used only in relation to the matters

covered by this document. We may also use your contact details for the purpose of requesting your

participation in customer surveys.

You have a right to access and correct any personal information held by us, by contacting the EPA (contact

details available here).

You may request that your personal information (such as your name, your address) be withheld from publicly

available information.

of 18



https://www.epa.govt.nz/contact-information/

http://www.epa.govt.nz/


Official Information

The Official Information Act 1982 (OIA) establishes principles with respect to the disclosure of information

held by government agencies, including the EPA. Any information you supply in the course of providing

feedback will be subject to the OIA and may be disclosed, upon request, to members of the public.

Please advise if you consider that the information provided by you would fall within the grounds for

withholding information under the OIA.

If the EPA receives an OIA request that involves information marked confidential or commercially-sensitive,

we make every effort to contact you to advise you that we have received an OIA request and to give you an

opportunity to let us know if you consider that there are grounds under the OIA to withhold the information.

of 18




Part 1: Manufacture and import volumes

Suggested responders: importers, manufacturers, suppliers, retailers

1a) Do you have any information on the quantities of hydrogen cyanamide-containing substances that are manufactured or imported into New Zealand annually?

☐ Yes ☐ No

1b) If your answer is yes, please provide information relating to the quantities of hydrogen cyanamide-containing substances imported and/or manufactured annually in the space below or as a separate attachment. Information may include data on the quantities of hydrogen cyanamide-containing substances being formulated here or imported into the country.

1c) Do you hold any New Zealand sales data for any of the hydrogen cyanamide-containing substances?

☐ Yes ☐ No

1d) If your answer is yes, please provide the sales information in the space below or as a separate attachment.

of 18




1e) Do you hold any New Zealand use data for any of the hydrogen cyanamide-containing substances?

☐ Yes ☐ No

1f) If your answer is yes, please provide the sales information in the space below or as a separate attachment.

of 18




Part 2: Packaging and trade name information

Suggested responders: importers, manufacturers, suppliers, retailers

2a) Do you have any information on the trade name substances containing hydrogen cyanamide, and their corresponding HSNO approval numbers?

☐ Yes ☐ No

2b) If your answer is yes, please provide this information in the space below. We also recommend using Table 2 on the following page to assist in answering Part 2 questions.

2c) Do you have any information on how these hydrogen cyanamide-containing substances are packaged?

☐ Yes ☐ No

2d) If your answer is yes, please provide information relating to how the substances are packaged for sale / distribution (for example, into ready to use containers), the available pack sizes of the product, and the type of packaging used.

We also recommend using Table 2 on the following page to assist in answering Part 2 questions.

of 18




Table 2: Trade name and packaging information (add additional lines to table if necessary)

of 18


Product identifier

HSNO approval #

Trade name(s) of product using this approval number

Active ingredient Concentration of active ingredient(s)

Pack sizes Packaging type Any additional information relating to packaging

eg HSR000XXX eg Bud Breakdance

eg hydrogen cyanamide

eg 50 % eg 500 ml, 1 L, 5 L, 20 L

eg HDPE container



Part 3: Use and application information

Suggested responders: importers, manufacturers, suppliers, applicators, users, growers

We are seeking information on how hydrogen cyanamide-containing substances are used in the agricultural sector in New Zealand. We are seeking information on the use patterns for different crops, the prevalence of use for each crop type, and whether this use corresponds with a particular product label or is an off-label use.

3a) Do you have any information on how hydrogen cyanamide-containing substances are used in the agriculture sector in New Zealand?

☐ Yes ☐ No

3b) If your answer is yes, please provide this information in the space below. We also recommend filling in the GAP table (Table 3) to assist in answering this question. Please include any known off-label uses and note this as part of the remarks section. Please feel free to also attach any product labels.

It is really important that the details included here on use are accurate (for example accurate maximum application rates) as this information will inform our assessment.

of 18




Table 3: GAP table (add additional lines to table if necessary)

Product identifier

Trade name Crop and/or situation

(a)

FGorI

(b)

Purpose of application

(c)

Formulation Application Application rate per treatment PHI

(days)

(l)

Remarks:

(m)

Product

name;

HSNO

approval #

Trade name

of the

substance

Type

(d-f)

Active

ingredient

Conc.

of as

(i)

method

kind

(f-h)

growth

stage & season

(j)

number

min max

(k)

interval

between

applications

(min)

kg as/hL

min max

water L/ha

min max

kg as/ha

min max

Remarks (a) For crops, the EU and Codex classifications (both) should be used; where relevant, the use situation should be described (eg fumigation of a structure)

(b) Outdoor or field use (F), glasshouse application (G) or indoor application (I) (c) Description of purpose of application (eg bud break promoter, thinning agent, insecticide,

herbicide). Include information of target pests if appropriate.(d) eg wettable powder (WP), emulsifiable concentrate (EC), granule (GR)(e) GCPF Codes - GIFAP Technical Monograph No 2, 1989(f) All abbreviations used must be explained(g) Method, eg high volume spraying, low volume spraying, spreading, dusting, drench(h) Kind, eg overall, broadcast, aerial spraying, row, individual plant, between the plants - type

of equipment used must be indicated, spray droplet spectrum, particular application equipment (such as nozzle types)

(i) g/kg or g/l(j) Growth stage at last treatment (BBCH Monograph, Growth Stages of Plants, 1997,

Blackwell, ISBN 3-8263-3152-4), including where relevant, information on season at time of application

(k) The minimum and maximum number of application possible under practical conditions of use must be provided

(l) PHI - minimum pre-harvest interval(m) Remarks may include: Extent of use/economic importance/restrictions

of 18




Part 4: Exposure mitigation measures

Suggested responders: importers, manufacturers, suppliers, applicators, users, growers (including industry groups), other affected parties

We are seeking information on any exposure mitigation measures that are currently being used to limit environmental or human exposure for substances containing hydrogen cyanamide.

This should include details of industry practices that are required to be followed as part of an industry-led approach to risk management. We would like to know whether any measures additional to the requirements are currently being prescribed to minimise environmental or human health exposure (such as adherence to the Management of Agrichemicals New Zealand Standard NZS8409:2004, or requirements arising from other legislation (for example: Health and Safety at Work Act 2015, Resource Management Act 1991)).

4a) Do you have information on how exposure risks associated with hydrogen cyanamide substances are managed/ mitigated?

☐ Yes ☐ No

4b) If your answer is yes, please provide examples of exposure mitigation measures that are implemented for safe application of these substances. You can use the space below to describe these measures, or attach copies of labels or guidance documents that contain this additional information.

4c) Do you have information that indicates how effective the exposure mitigation measures are in regards to management of adverse effects arising from use of hydrogen cyanamide substances?

☐ Yes ☐ No

of 18




4d) If your answer is yes, please provide this information in the space below. Please feel free to also attach any product labels.

of 18




Part 5: Scientific and technical information

Suggested responders: importers, manufacturers, suppliers, industry groups, other affected parties

5a) Do you have any studies or technical reports on the toxicology of hydrogen cyanamide or its formulations (either published or unpublished reports)?

☐ Yes ☐ No

5b) If your answer is yes, please provide these as attachments.

5c) Do you have any studies or technical reports on the ecotoxicology of hydrogen cyanamide or its formulations (either published or unpublished reports)?

☐ Yes ☐ No

5d) If your answer is yes, please provide these as attachments.

5e) Do you have studies or technical information on the environmental fate of hydrogen cyanamide or its formulations (either published or unpublished reports)?

☐ Yes ☐ No

5f) If your answer is yes, please provide these as attachments

of 18




5g) Do you have any environmental monitoring data on the presence of hydrogen cyanamide in the New Zealand environment?

☐ Yes ☐ No

5h) If your answer is yes, please provide these as attachments

of 18




Part 6: Impacts on Māori associated with use of hydrogen cyanamide

Suggested responders: kaitiaki, iwi, hapū, importers, manufacturers, suppliers, applicators, users, growers (including industry groups), other affected parties

We are seeking information on the positive or adverse impacts on the relationship of Māori and Māori culture to the environment associated with use of hydrogen cyanamide-containing substances.

6a) Do you have any information regarding the impacts of hydrogen cyanamide-containing substances on the environmental, economic, social and cultural well-being of Māori? This includes any impacts on taonga such as culturally significant species and resources, and the Māori values, practices, uses, and beliefs associated with these taonga.

☐ Yes ☐ No

6b) If you answered yes, please provide information regarding impacts on Māori in the space below or as a separate attachment.

of 18




Part 7: Benefits and alternatives information


We are seeking information on the benefits associated with use of hydrogen cyanamide-containing substances, and what the possible effects of these substances becoming unavailable or significantly restricted would be.

7a) Do you have any information on the benefits of these hydrogen cyanamide-containing substances?

☐ Yes ☐ No

7b) If you answered yes, please use the space below to detail these benefits.

7c) Do you have any information on the possible effects of these substances becoming unavailable?

☐ Yes ☐ No

d) If you answered yes, please use the space below to detail these possible effects.

of 18




7e) Do you have any information on the availability, relative cost, effectiveness, and safety of any alternative substances that could be used if these hydrogen cyanamide-containing substances became unavailable?

☐ Yes ☐ No

7f) If you answered yes, please use the space below to provide this detail.

of 18




Part 8: Any other pertinent information


8a) Do you have any other pertinent information, not covered by the questions above, related to hydrogen cyanamide or the hydrogen cyanamide-containing substances?

☐ Yes ☐ No

8b) If you answered yes, please use the space below to detail these. Feel free to include any further pertinent information as additional attachments.

of 18



epa.govt.nz · Web viewCall for Information – hydrogen cyanamide Call for Information –...

Documents

Transcript of epa.govt.nz · Web viewCall for Information – hydrogen cyanamide Call for Information –...