19 March 2002
The Environmental Risk Management Authority has decided that there are grounds for reassessment of 1080. This decision was made on 12 March 2002. The Animal Health Board asked the Authority to decide whether grounds for reassessment exist under the Hazardous Substances and New Organisms (HSNO) Act. There are legislated criteria for grounds for reassessment and in this case the criteria are that there is significant new information available relating to the effects of 1080 since it was first registered under the Pesticides Act in 1964, and that there is information relating to a significant change in the quantity of the substance used.
The reassessment process under the HSNO Act is a two-step process. First, the Authority must agree that there are grounds for reassessment and secondly, once grounds have been established, an application for the reassessment of the substance can be prepared and is processed like any normal application under the HSNO Act. The 'grounds' process simply clears the way for a full application to possibly be made. It is a very simple process which is mainly intended to ensure that a full application is justified. Grounds applications are zero priced.
The subsequent application for reassessment will be notified to the public and open for submission for six weeks. At this stage there is no timeframe for receiving the reassessment application itself. The Animal Health Board, in conjunction with the Department of Conservation, intends to prepare this application and it is expected to take several months to gather the necessary information.
The provision for reassessment is one of the most interesting and powerful provisions of the HSNO Act. It provides a mechanism to re-examine the risks, costs and benefits of any hazardous substance or new organism and to review the controls which regulate the substance or organism. It also means that our ability to manage the risks of hazardous substances and new organisms in containment will be able to reflect changing circumstances and knowledge. It also provides an avenue for the community rather than the supplier of a substance, to take the initiative in raising concerns and having them dealt with. However, a reassessment will not necessarily lead to changes in controls. There could be instances where the conclusion is that the existing controls are still the most appropriate.
Sodium fluoroacetate (1080) was initially registered as a pesticide for vertebrate pest control under the now repealed Pesticides Act in 1964. While its acute human toxicity has been well recognised and controlled (it is a controlled pesticide only available to licensed operators), its environmental toxicity and chronic human toxicity has not been formally assessed since that time. Further, since about 80 per cent of the annual world production of 1080 is used in New Zealand, it is unlikely that any other jurisdiction will undertake an extensive review of 1080. Recently, the Animal Health Board has commissioned environmental and chronic toxicity data on 1080 (through Landcare Research). There is also considerable public interest in the risks that may arise from the use of 1080, particularly from aerial application.
All hazardous substances existing in New Zealand prior to the HSNO Act, and this includes 1080, are currently covered by the transitional provisions of the HSNO Act. ERMA New Zealand proposes to transfer them from requirements under old regimes to the new HSNO regime.
This process is called 'transfer of substances'. 1080 is part of a group of controlled vertebrate pesticides due to be transferred into the HSNO regime in November 2002. The Transfer Process is not the same as the reassessment process. The transfer process involves classifying a substance using the HSNO classification system and assigning default controls from the relevant HSNO regulations.
These controls are then compared to the existing pre-HSNO controls through a process of consultation, but may be varied only to the extent of continuing the level of compliance that was required under the old legislation. There is no provision in the transfer process for the Authority to impose controls that are more strict than those which are prescribed by the HSNO Regulations.
In simple terms the difference between 'transfer' and 'reassessment' is that reassessment can be seen as reviewing from scratch. Transfer is just about getting existing substances into the new framework.
For further information see Reassessment of 1080 or contact:
Julie Watson,
Manager, Communications,
ERMA New Zealand
Tel: 04 918 4824
Mobile: 021 674 954
Email: julie.watson@ermanz.govt.nz
The Environmental Risk Management Authority controls the introduction to New Zealand of new plants, animals and microorganisms (including genetically modified organisms GMOs), and hazardous substances by managing their adverse effects.