APP202349 Submission123443
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SUBMISSION 123443 ENVIRONMENTAL PROTECTION AUTHORITY Application for the Reassessment of Hazardous Substances under Section 63 and Section 63A of the Hazardous Substances and New Organisms Act 1996 [www.epa.govt.nz] Applicant: Dr. Allan Freeth, Chief Executive, Environmental Protection Authority Name of substance: Non-professional use of chlorothalonil formulations Application number: APP202349 Substances for Reassessment HSNO Approval Number Suspension concentrate containing 500 gm/L chlorothalonil (Substance B) : HSR000480 Suspension concentrate containing 102 gm/L chlorothalonil and 125 g/L thiophanate methyl: HSR000147 Suspension concentrate containing 62.5 gm/L chlorothalonil, 9.6 g/L tau -fluvalinate and 62.5 g/L thiophanate methyl: HSR000586 Suspension concentrate containing 250 g/L chlorothalonil and 250 gm/L thiophanate methyl: HSR000618 Tui Disease Eliminator (ready to use) HSR100 Submitter: Anthony R. Bellvé, wishes to be heard on behalf of ‘Waikato Domestic Beekeepers’ Association’ Contact: T: 07 957 0300; M: 022 60 71217; F: 07 260 0300; E: [email protected] President: Cameron Blackbourn Contact: T: 07 846 7864, M: 021 766 123, E: [email protected] Submitted: Friday, 16th December 2016 A. Recommendations The Waikato Domestic Beekeepers’ Association (WDBA), having reviewed recent evidence relating to the deleterious effects of Chlorothalonil, and related chemicals, on honey bees, Apis melliflora and A. carnica*, New Zealand’s two major and distinct bee species, strongly recommends rescinding the fungicide/pesticide’s current approval status and thereby discontinuing all retail distribution and domestic applications of Chlorothalonil, country-wide. B. Executive Summary The WDBA has reviewed contemporary scientific evidence on the effects of: i) Chlorothalonil alone; ii) Chlorothalonil in two-way combination with Tau-fluvalinate or Methyl-thiophanate; and iii) Chlorothalonil in three-way combination with Tau-fluvalinate and Methyl-thiophanate, at the specified concentrations, when applied to flowering plants in various domestic usages, and assorted professional agricultural and horticultural applications. *Apis carnica is represented by ‘Southern Cross Carniolans’ hybrids (Refer: Daykel Apiaries, Taipa, Northland, New Zealand). 1 SUBMISSION 123443 Chlorothalonil, and derivatives listed by the ‘European Chemicals Agency’ (ECHA, https://echa.europa.- eu/), are highly potent acaricides, bactericides, fungicides, miticides and pesticides. Chlorothalonil used on domestic plants and trees and professional applications on agricultural and horticultural crops, has proven to be: a) Incorporated preferentially into crop nectar and pollen during flowering; b) Harvested by pollinating honey bees (and bumble bees); c) Transferred inadvertently by adult bee foragers to in-hive brood; and d) Killed larval and pupal stages during early development of domestic bees. Chlorothalonil and related chemicals now are deemed to be foremost causes of the recent ‘World-wide’ collapse of honey bee populations, an event now generally termed ‘Colony Collapse Disorder’ (CCD)18,19. C. Bees’ Wax and Wane 1. The Industrious Pollinators Pollinating vectors World-wide, comprising wind, water, insects (beetles, bees, bumble bees, butterflies, flies, moths, thrips and wasps) and a variety of vertebrates (bats, birds, lizards, capuchins, snakes), contribute toward enhancing the diversity and survival of native plants, increasing propagation and production of agricultural and horticultural crops, and augmenting food efficiency and security. Among these pollinators, there are over 20,000 species of bees specialized for pollination, of which 50 species are managed and of the latter 12 are deployed primarily to pollinate agricultural and horticultural crops. Apis mellifera and A. cerana are the most abundant contributors to pollination of flowering plants (Fig. 2). Indeed, honey bees pollinate 71% to 75% of 107 agricultural crops collectively contributing 90% of food consumed by today’s World-wide population. Honey bees pollinate and thereby ensure propagation of more than 4,000 of the planet’s crop species, together with ensuring diversity and survival of native plants among innumerable ecosystems. Globally, honey bees earn more than US$200 billion per year. Recently, the Food and Agriculture Organisation (FAO), United Nations, published estimates of pollinators relative, fiscal contribution to World-wide food production, expressed as presumed losses incurred in the absence of api-cultural, flower pollination. These data enable global and country-wide comparisons between 1961 and 2012 (Figs.1A &1B). During the ~50-year period, there was a marked >2-fold increase in food production dependent on pollinators19. This trend reflected changes in cultural and societal demands for pollinator-dependent consumable foods, and, in some case, particular increases for high-value products destined for international markets (e.g. coffee beans). Thus, greater global harvest and consumption of horticultural crops, increased dependence on faunal pollination19. Similarly, New Zealand’s increasing production and export of horticultural products, mirrored by recent increases in the sector’s gross national product (GNP), confers more reliance on pollination by honey bees. FAO’s estimates indicate New Zealand could have lost 5% to 7% of its productivity, in 1961, through loss of pollinators; but, that drop would have extended to 15% to 25% less in 2012 (Fig. 1). The country has become 3-fold to 5-fold more reliant on api-culture for pollinating agricultural (clovers, lucerne, rape) and horticultural crops (fruits, grapes, vegetables (Figs. 1Aa & 1Bb)19. Thus, New Zealand’s rapidly expanding horticultural export markets will necessitate propagating and sustaining healthy populations of managed honey bees. Further, honey bees will become increasingly important as food supplies are subject to greater demand globally. The Planet’s population, based on recent re-assessments, is expected to increase by ~83 million peoples annually, attaining a total of 9.7 billion by 2050 and 11.2 billion by 2100 (‘World Population Prospects – a Revision’, Department of Economic and Social Affairs, Population Division, Programme for Development, United Nations, 2015). Likewise, New Zealand’s population will continue to increase exponentially. The population-driven demand for greater intensity in agricultural and horticultural production, will necessitate more abundant and efficient pollination services over coming decades. Honey bees, in addition to producing honey, propolis and wax, make substantial contributions through flower pollination toward World-wide food production. Indeed, there will be greater prerequisites for New Zealand to nurture and sustain native and managed populations of viable and efficient honey bees, to ensure optimal security of crop pollination for the future well-being of our children and grandchildren. 2 SUBMISSION 123443 A 1961 Aa 1961 2012 B Bb 2012 FIG. 1: World-wide agriculture losses were estimated, in the absence of flower pollination by faunal vectors, for 1961 [A, Aa] to 2012 [B, Bb]. Greater fiscal exposure occurs as the World’s population harvests more horticultural crops [Potts et al., Nature, 2016, 19 based on data from FAO, United Nations (See: http://www.fao.org/faostat/en/#home)]. 2. Pressures on Waning Bee Populations Bee populations, both native and managed, are subject to substantial pressures from direct and indirect anthropogenic drivers. The present brief is based on the excellent and highly recommended reviews by Potts et al.’s (2016) ‘Assessment Report of the Intergovernmental Science - Policy Platform on Biodiversity and Ecosystem Services on Pollinators, Pollination and Food Production’, pp. 1-888, together with other recent reviews and pertinent scientific reports. In this context, there are five main classes of drivers threatening the effectiveness and survival of existing bee populations18,19. These include: a) Changes in type and intensity of land management, b) Applications of pesticides - acaricides, fungicides. insecticides, herbicides, molluscicides – directly or indirectly (plant GMOs - herbicides) affecting flowering plants in urban and rural settings, c) Parasitic loads of pathogens (bacteria, fungi & viruses) and parasites (protozoa & vertebrates); e.g. Varroa mites (Varroa destructor) parasitizing A. Cerana and later spreading to A. mellifera. d) Invasions of parasitic alien pests compromising pollinator health through dysfunction to death; e.g.: Western Yellow Jacket (Vespula pensylvanica), a wasp killing native bees on Hawaii, USA. e) Spatial and temporal global-warming shifts of pollinators- versus flowering-crop eco-systems. 3 SUBMISSION 123443 These five drivers summarize 74 possible causes promulgating rapid ‘Colony Collapse Disorder’, a syndrome fundamental to recent losses of native and domestic bees, especially throughout Europe and the Americas (See: IPBES-4/1)18,23,26. Recent evidence is consistent with these parameters having interactive effects with negative synergistic impacts on the health of managed bee populations and thereby threatening future propagation and production of pollinated crops important for human well-being10,19. 3. Genetics of Native and Domesticated Bee Species Bees have been ‘domesticated’ for the past 7,000 years and managed with gradually increasing sophistication, particularly upon the relatively recent transition from clay pots through the Langstroth hive10. During this period,