Reassessment of chlorpyrifos

[b][u]Overview[/u][/b] The EPA has initiated a full reassessment of chlorpyrifos because information about its human health and environmental risks suggests the risks from its use outweigh the benefits. The approvals for chlorpyrifos and chlorpyrifos-containing substances will be reassessed under section 63 of the Hazardous Substances and New Organisms Act 1996 (HSNO Act). Chlorpyrifos is an insecticide from the organophosphate group. In New Zealand, it’s used to control a broad range of insect pests on plants. It can only be used by professionals.  We propose to ban the use of chlorpyrifos by revoking its approvals. The ban would mean chlorpyrifos can no longer be imported, manufactured or used in New Zealand.  We now assess that the risks outweigh the benefits. That’s because:  - the levels of exposure considered to pose risks for human health are now 10 times lower - as a result, most uses now have human health risks that can’t be mitigated - all uses have environment risks.  Risks we’ve identified include: - human health risks for spray operators and workers re-entering sprayed sites for most use patterns, and for bystanders for some use patterns - environmental risks, particularly to birds, bees and the aquatic environment.  We also propose that the benefits of using chlorpyrifos are decreasing because other international regulators are reviewing and restricting its use or have already done so.  [b]Risk and benefits assessments[/b] The assessment of risks and benefits are described in the staff assessment document: [url=https://www.epa.govt.nz/assets/FileAPI/hsno-ar/APP204694/APP204694-Chlorpyrifos-staff-assessment-report.pdf]Staff assessment report – the application to reassess chlorpyrifos (PDF, 1007KB)[/url]. A quantitative assessment of human health risks has also been undertaken. This can be found in the document: [url=https://www.epa.govt.nz/assets/FileAPI/hsno-ar/APP204694/APP204694_Science_memo_-chlorpyrifos.pdf]Science memo: APP204694 chlorpyrifos (PDF, 1.7MB)[/url]. The full set of application documents can be found here: [url=https://www.epa.govt.nz/database-search/hsno-application-register/view/APP204694]https://www.epa.govt.nz/database-search/hsno-application-register/view/APP204694[/url] It may also be useful for submitters to be familiar with the previous assessment of chlorpyrifos which occurred as part of the 2013 Reassessment of Organophosphates and Carbamate Plant Protection Substances (APP201045). These documents can be found here: [url=https://www.epa.govt.nz/database-search/hsno-application-register/view/APP201045]https://www.epa.govt.nz/database-search/hsno-application-register/view/APP201045 [/url] [b]Feedback we’re seeking[/b] We’d like to get your feedback on our proposal to ban chlorpyrifos. To help prompt your responses we have asked questions for you to consider. We also welcome any general feedback on the reassessment. While we will consider all information provided in submissions, we would like to encourage the submission of quantitative data on:  - the risks of chlorpyrifos - mitigations for these risks - benefits of chlorpyrifos (where possible, the specific benefit due to chlorpyrifos, including economic benefits) - costs if chlorpyrifos can’t be used, including the costs of replacing chlorpyrifos with alternatives. [b]Attach any supporting documents at the end of this form [/b]Please upload any documents for your submission at the end of this form. You do this on the next page, after clicking 'Continue'. Please also reference these documents in your responses.   [b]Submissions close at 5.00 pm on 12 February 2025. [/b] [b]Publishing submissions[/b] All submissions (including submitter names) will be published on our website at [url=http://www.epa.govt.nz/]www.epa.govt.nz[/url]. We will not publish any personal contact details. [b]Confidential information[/b] If you think your submission contains confidential information, please make this clear in your submission. Reasons may include, for example, that the information discloses commercially sensitive information. If you would like more information about how we treat confidential information, see the section [url=https://www.epa.govt.nz/industry-areas/hazardous-substances/making-an-application/supplying-confidential-or-commercially-sensitive-information-under-the-hsno-act/]Supplying confidential or commercially sensitive information under the HSNO Act[/url] on our website. [b]Privacy statement[/b] The EPA is collecting your personal information for the purpose of considering feedback on the proposals in this document. We will store your personal information securely. We may use your contact details to contact you about your submission if necessary. You have the right to access the personal information we hold about you and to ask for it to be corrected if it is wrong. If you would like to access your personal information, or have it corrected, please contact us at [url=mailto:info@epa.govt.nz]info@epa.govt.nz[/url].  [b]Official information[/b] The Official Information Act 1982 (OIA) applies to all information held by the EPA (subject to section 55 of the Hazardous Substances and New Organisms Act 1996), and information may be released under the OIA unless there are grounds to withhold it. Further information on the OIA is at [url=http://www.ombudsman.parliament.nz/]www.ombudsman.parliament.nz[/url] Please fill in the form below, then click Continue to review your submission. At any time you may click Save and Exit so that you can return later.

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Part 1: Submitter information
Please indicate whether you intend to present on behalf of your submission if a hearing is held for this application
Are the views expressed on behalf of an individual or an organisation?
Part 2: Questions about the reassessment of chlorpyrifos
Do you agree with the EPA's proposal to revoke the approvals for chlorpyrifos?
What are your comments on the risks of chlorpyrifos? Please provide information in support of your assessment or comments on the risks associated with chlorpyrifos. Where possible provide quantitative risk assessment and/or quantitative information which supports and/or is evidence of your consideration of these risks.
What are your comments on the estimated benefits of chlorpyrifos containing substances? Please provide information on any benefits you have identified. Where available please provide quantitative information and where possible provide information which indicates the specific contribution to these benefits that is attributable to the use of chlorpyrifos.
What are your comments on the assessed impacts of chlorpyrifos approvals, and the proposal to revoke these approvals, on Māori? Please provide information on any impacts you have identified. Where possible provide information which indicates the specific contribution to these impacts which is attributable to the use of chlorpyrifos and/or the impact of these substances becoming unavailable.
What are your comments on the estimated costs of the proposed revocation of chlorpyrifos approvals? Please provide information on any costs you have identified. Where possible provide information which indicates the specific contribution of chlorpyrifos being unavailable to these costs, or the specific costs of replacing the use of chlorpyrifos with any available alternative.
What are your comments on the estimated costs of retaining chlorpyrifos approvals and ongoing use of substances which contain this active ingredient? Please provide information on any costs you have identified. Where possible provide information which indicates the specific contribution of chlorpyrifos to these costs.
What are your comments on the overall assessment of risks, benefits, impact to Māori, costs, and any other effects of chlorpyrifos substances over their lifecycle. If not already provided in evidence for a previous question, please provide evidence to support your comments.
Do you have any comments on the proposed revocation timeframe? If yes, please explain.
What are your comments on the additional controls proposed to be applied to the approval before the revocation is proposed to take effect? Please provide details, including suggestions on any controls that should be added or removed, the change in risk mitigation that these controls would have and any comments on potential barriers to compliance.
If chlorpyrifos approvals were retained, would your comments on the controls which should be applied to these approvals change? Please provide details including suggestions on any controls that should be added or removed, the change in risk mitigation that these controls would have and any comments on potential barriers to compliance.
General feedback
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