APPLICATION FORM CONTAINMENT
Application for containment approval for new organisms under the Hazardous Substances and New Organisms Act 1996
Send by post to: Environmental Protection Authority, PO Box 131, Wellington 6140 OR email to: [email protected]
Application number
APP201124
Applicant
The New Zealand Institute for Plant & Food Research Limited
Key contact
Lloyd Stringer
The New Zealand Institute for Plant & Food Research Limited
Postal Address: Plant & Food Research Lincoln PB 4704, Christchurch Mail Centre, Christchurch, 8140, New Zealand Physical Address: Plant & Food Research Lincoln
Gerald Street, Lincoln, 7608, New Zealand
www.epa.govt.nz 2
Application for containment approval for new organisms
Important
This application form should be used if you intend to import, develop or field test any new organism (including genetically modified organisms (GMOs)) in containment. These terms are defined in the HSNO Act. The HSNO Act can be downloaded from: http://www.legislation.govt.nz/act/public/1996/0030/latest/DLM381222.html. If your application is for a project approval of low-risk genetic modification, use application form EPA0062. The HSNO (Low Risk Genetic Modification) Regulations can be downloaded from: http://www.legislation.govt.nz/regulation/public/2003/0152/latest/DLM195215.html. Applications to field test GMOs will be publicly notified. The other application types may or may not be publicly notified. This application form will be made publicly available so any confidential information must be collated in a separate labelled appendix. The fee for this application can be found on our website at www.epa.govt.nz. If you need help to complete this form, please look at our website (www.epa.govt.nz) or email us at [email protected]. This form was approved on 21 September 2011.
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Application for containment approval for new organisms
1. What type(s) of containment activities are you applying for?
Tick where appropriate: Application type Type of new organism
GM Import into containment Non-GM
Develop in containment i.e. regeneration, fermentation or GM genetic modification Non-GM
GM Field test in containment Non-GM
2. Brief application description
Provide a short description (approximately 30 words) of what you are applying to do.
The importation of species of Lepidoptera into containment for research purposes.
3. Summary of application
Provide a plain English, non-technical description of what you are applying to do and why you want to do it.
The order Lepidoptera has a considerable number of species that are of economic importance in horticulture, agriculture and forestry. Consequently, many lepidopteran species are considered to be biosecurity threats to New Zealand, and could cause considerable damage to our economy if they were to establish here. In addition, some Lepidoptera are valuable as weed biological control agents. We wish to import the pupae of multiple species of the insect order Lepidoptera from any country into PC2 invertebrate containment facilities, for the purpose of identifying and developing a synthetic pheromone(s) or other semiochemicals for each of the species. As biologically active semiochemicals can differ for mated and unmated females, for this approval we would like to identify compounds that are biologically active for both mated states.
The use of lepidopteran semiochemicals for monitoring as a first line of defence for detecting alien species at the border is a proven one. This strategy has already been used successfully, for example, to provide early warning of an incursion of gypsy moth (Lymantria dispar) into Hamilton in March, 2003. The specific semiochemicals including pheromones will mainly be used as monitoring tools as part of New Zealand’s biosecurity initiatives, or for other uses in pest management strategies both in New Zealand and overseas. The identification of the pheromones and other semiochemicals of these insects will help to maintain and expand scientific capability in this area, which is important both for New Zealand’s biosecurity and for reducing insecticide usage. Other positive benefits will accrue from international cooperation and successfully helping other nations’ biosecurity and biocontrol interests.
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Application for containment approval for new organisms
4. Describe the background and aims of your application
This section is intended to put the new organism(s) in perspective of the wider activities(s) that they will be used in. You may use more technical language but please make sure that any technical words used are included in a glossary.
Our aim is to identify semiochemicals for use in modifying the behaviour (attraction and/or repellence) of both male and female lepidoptera. We are also interested in other factors from live plants that can affect host range.
We have an approval to bring in Lepidoptera into containment for the purpose of identifying semiochemicals (NOC002488). We would now like to allow mating to occur between males and females of the same species for the purpose of identifying semiochemical odours that attract lepidoptera. Female moths are a particular target as they produce the offspring (larvae are often the most damaging phase of the lepidopteran lifecycle) contributing to future generations. Odour(s) are often food based, coming from foods such as nectar, but can come from other sources such as, but not limited, to host plants signalling suitable and unsuitable egg laying sites. The mating status of the female moths can influence the response to odour(s) (Masante-Roca et al. 2007). Mated moths may respond to different odour stimuli than unmated moths. Mated moths do not need to concentrate on attracting a mate, thus prioritise finding extra nourishment for the production of offspring and suitable oviposition sites using odour cues. We will not mate lepidoptera for the purpose of maintaining a colony. Relatively few odours have been identified for attracting female moths, unlike sex pheromones, that are a powerful tool for the attraction of male moths to population monitoring traps, for mass trapping and mating disruption. Pheromone analysis would continue as it has under approval NOC002488, whereby extracts are taken from glands of females (most often) and tested for detection of male moth antennae by use of an electroantennogram and antennae are stimulated by various compounds that are passed over it. Candidate compounds may then be identified by Gas Chromatography- Mass Spectrometry (GC-MS) and those compounds tested in a flight tunnel for a behavioural response. Testing of final products would likely be field tested overseas where the target species is present.
For the identification of other semiochemicals, odours will be identified using similar methods as above with the main difference being that the same will be done on female as well as male antennae, followed by compound(s) identification, flight tunnel bioassays and field testing as above. As female moths can respond differently to different compounds when mated from when they were not mated, flight tunnel assays will be an important step to prove attraction. This may include responses to live plants.
5. Information about the new organism(s)
For non-GMOs: provide a taxonomic description of the new organism(s). For GMOs: provide a taxonomic description of the host organism(s) and describe the genetic modification (i.e. the experimental procedures and biological material to be used in the genetic modification and where the expression of foreign nucleic acid may occur). Describe the biology and main features of the organism including if it has inseparable organisms.
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Application for containment approval for new organisms
Describe if the organism has affinities (e.g. close taxonomic relationships) with other organisms in New Zealand. Could the organism form an undesirable self-sustaining population? If not, why not? How easily could the new organism be recovered or eradicated if it established an undesirable self-sustaining population?
Taxonomy for non-GMO
Kingdom: Animalia Phylum: Arthropoda Class: Insecta Order: Lepidoptera (moths and butterflies)
Biology
All Lepidoptera have holometabolistic development with four distinct life stages. These are egg, larva (caterpillar), pupa (chrysalis), and adult (usually winged). Pupae (and adults) are usually sexually dimorphic. In general, the adult males are more active than their conspecific females and fly in search of a mate. Typically female adults produce a sex pheromone to attract their conspecific males during the species’ behaviourally- active diurnal period. However, in a few moth species and in some butterflies, it is the male that emits the sex pheromone. The majority of moths are night-flying and most butterflies are daytime fliers
Although not strictly inseparable, insect parasitoids and pathogens could potentially accompany the lepidopteran pupae. For Lepidoptera that are sourced from rearing facility cultures, it is unlikely that any pest or pathogen would accompany the pupae as the colony in culture would likely fail in the presence of a pest or pathogen, thus will be controlled for. However, for field collected insects, these have the potential to have an associated parasitoid or pathogen. Pupae would be transported to the transitional facility in separately sealed containers and pupae would emerge as adults separately to prevent the contamination of the entire shipment should there be an associated pest or pathogen. Any accompanying pest or pathogen found in the shipments would be identified and destroyed.
Taxonomic relationships
Imported Lepidoptera may have close taxonomic relationships with lepidopteran species already present in New Zealand. This will be different with for each species brought into containment; some may be in the same genus as a species already present in New Zealand others may be only as close as being a member of the same taxonomic family.
Ability to form a self-sustaining population
The likelihood of any mated female lepidopteran escaping from the containment facility is very low given that they will be held in MAF approved PC2 invertebrate containment facilities. In the event that this did occur, the ability of the insect to establish a self-sustaining population would depend upon the sex and mating status of
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Application for containment approval for new organisms individuals, its biology (e.g. thermo tolerance) and presence of host(s). The likelihood of species from tropical regions establishing at this latitude (Canterbury, New Zealand) is extremely low, whereas for those species from high altitude tropical regions or more temperate climatic regions with multiple host plants, the likelihood of establishment could be greater.
A sustainable population of any lepidopteran species could only establish if 1) a gravid female (mated with a fertile male) was to escape and encounter a suitable oviposition site and larval host or 2) both male and female insects escaped then mated and the female was able to find a suitable host plant. Because female and male lepidopteran will be separated at all times while in the containment facility except for when mating for trials where mated females are required, it is highly unlikely that any adverse effects will result from an escape.
How easily could the new organism be recovered or eradicated if it established an undesirable self- sustaining population?
There are a number of tools available including the use of a sex pheromone and other semiochemicals for detection and mass trapping for the successful eradication of any species if it escaped and subsequently established.
In the highly unlikely event that a fertile gravid female or multiple individuals escape from containment, mate and form a self-sustaining population there are numerous ways in which organisms could be located, identified and eradicated.
All Lepidoptera life stages can be located by visual searches of hosts. The adult form can be attracted to traps using pheromones, other semiochemicals or lights. Eradication may then be achieved through the use of some or all of the following: host destruction, broad-spectrum and selective (e.g. Bacillus thuringiensis) insecticides, mass trapping, mating disruption and the sterile insect technique (Suckling et al. 2009), many of which were used for the successful eradication of the painted apple moth Teia anartoides from New Zealand (Suckling et al. 2007). The choice of options will be species dependant.
In the unlikely event that an insect or multiple insects escape and form a self-sustaining population, the probability of successful eradication would be high because the population is likely to be small and in a confined area. This is due to the controls already in place under EPA approval NOC002488 (the importation of pupae of species of Lepidoptera into containment for semiochemical identifications) where we account for every individual insect from arrival through to destruction. Should an insect escape we would know immediately.
Voucher specimens are deposited with the New Zealand Arthropod Collection (NZAC) as required for MAF Biosecurity Authority 154.02.08 section 4.8 confirmation of identity;
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“The operator shall confirm through an independent authority the taxonomic identity of the imported invertebrates as soon as practicable after importation. Voucher specimens shall be lodged with the New Zealand Arthropod Collection at this time and again when biosecurity clearance is given.” We currently do this for NOC 002488.
6. For field tests: The nature and method of the field test
Describe the nature and method of the field test and the experimental procedures to be used.
N/A
7. Proposed containment of the new organism(s) (physical and operational)
Describe how you propose to contain the new organism(s) after taking into account its ability to escape from containment (i.e. the possible pathways for escape).
It is proposed to hold all imported pupae from the Order Lepidoptera in the Level PC2 Invertebrate Containment Facility at Lincoln, (MAF registration number 2829) operated to MAF/EPA approved Standard 154.02.08 “Transitional and Containment Facilities for Invertebrates”. Details of the containment facility are presented in a containment manual lodged with MAF.
8. Detail of Māori engagement (if any)
Discuss any engagement or consultation with Māori undertaken and summarise the outcomes.
We passed on a copy of the draft application to the Ngai Tahu HSNO komiti for comment. The following was received by email 9th November 2011 from Edward, Chair for the HSNO komiti, via Tina Woodgate, senior administrator for the Ngai Tahu HSNO committee:
“We had no issue with the containment part of the project, main interest was that it did not have unforeseen consequences for native insects. We have not changed our stance from that of Dyanna Jolly and Fiona Musson of Taumutu Runanga who commented back in 2007 I think it was, that is, we are generally supportive.”
From 2007 While no formal consultation with Māori has taken place as a component of this application. We have spoken informally to representatives from Te Runanga o Ngai Tahu (Dyanna Jolly) and Te Taumutu Runanga (Fiona Musson) for the current approval (NOC002488). Both parties gave a positive response to the proposal, and assessed any risks as being low to negligible, given the containment facility and the associated HSNO controls, and the likely EPA conditions of approval.
9. Identification and assessment of beneficial (positive) and adverse effects of the new organism(s)
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Application for containment approval for new organisms
Adverse effects include risks and costs. Beneficial or positive effects are benefits. Identification involves describing the potential effects that you are aware of (what might happen and how it might happen). Assessment involves considering the magnitude of the effect and the likelihood or probability of the effect being realised.
Consider the adverse or positive effects in the context of this application on the environment (e.g. could the organism cause any significant displacement of any native species within its natural habitat, cause any significant deterioration of natural habitats or cause significant adverse effect to New Zealand’s inherent genetic diversity, or is the organism likely to cause disease, be parasitic, or become a vector for animal or plant disease?), human health and safety, the relationship of Māori to the environment, the principles of the Treaty of Waitangi, society and the community, the market economy and New Zealand’s international obligations.
We do not intend to release any organisms into the environment thus do not believe that there would be any interaction between insects brought into containment and current flora and fauna in New Zealand. The purpose of the importation is to enable research to be carried out to identify insect pheromones/semiochemicals. These have a direct application to biosecurity procedures as they can be used in traps to provide early warning detection systems. The identification of the semiochemicals for these insects will help to maintain and expand scientific capability in this area, which is important both for New Zealand’s biosecurity and for reducing insecticide usage. Other general positive benefits accrue from international cooperation and successfully helping overseas biosecurity, biocontrol and biodiversity interests. Early detection of organisms is key for a high likelihood of a successful eradication when the tools are available. New Zealand is continually at risk of new species coming in and establishing on potentially valuable crops impacting that sector. There is further risk that incidental species may directly or indirectly impact the native flora and fauna of New Zealand. This may lead to increased pesticide application. New Zealand benefits from the development of new tools for the early detection of potential pests and for the eradication of those pests by a potential reduction in the use of pesticides.
The key risks associated with this application are that associated organisms such as a parasitoid may arrive with imported pupae that could affect other Lepidoptera should it escape containment and that a gravid lepidopteron or multiple lepidopterans of both sexes may escape from containment and forma self sustaining population causing damage to susceptible plant species.
Associated organisms are likely to emerge at the egg, larva and pupa stages following importation. As we will only be importing pupae that will be housed individually we will be able to monitor for possible associated organisms while they are still individually housed and destroy any associated organisms. The greatest risk of inadvertent escape of a gravid female or multiple lepidoptera would be in the flight tunnel. However, as these flights are monitored and all individuals are accounted for, this is unlikely. Our standard procedure for if a lepidopteran escapes the flight tunnel is that it must be recaptured in the room before continuing any further flights. The other risk is that mated females may lay eggs inside the flight tunnel that subsequently hatch into larvae. These risks have been minimised by the controls set out in NOC002488, and we have protocols in place whereby we check for eggs visually after flight tests. During a flight, any females that appear to be laying eggs may be removed from the trial. If any eggs are missed and larvae hatch, we have fine mesh through which larvae do not fit attached to the downwind end of the flight tunnel. If larvae balloon (passive flight), they will be trapped on this mesh, should they get beyond this mesh further mesh will also be placed around existing external vents to prevent larvae escaping and finding host material to feed on in order to survive and grow.
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Application for containment approval for new organisms
We have a quarantine room where we store the insects. We would be checking for eggs from mated females. If any eggs were discovered, we would move the female into a new container and would destroy the contaminated container by freezing the container followed by autoclaving as per normal protocol when destroying individuals under EPA approval NOC002488.
Our facility has a good track record with positive feedback from the annual MAF audits and no breaches of containment. Under EPA approval NOC002488 (The importation of pupae of species of Lepidoptera into containment for semiochemical identifications) we have successfully imported the following Lepidoptera into containment without any incidents:
Lymantria obfuscata Indian gypsy moth Conogethes pluto Alpinia stem borer Metisa plana no common name Uraba lugens Gum leaf skeletoniser Epiphyas postvittana Light brown apple moth Eudocima phalonia Fruit piercing moth Citripestis eutraphera no common name Herpetogramma phaeopteralis Tropical sod webworm Lobesia botrana European grapevine moth
10. For developments of GMOs that take place outdoors and field tests of GMOs: Alternative methods and potential effects from the transfer of genetic elements
Discuss if there are alternative methods of achieving the research objective. Discuss whether there could be effects resulting from the transfer of genetic elements to other organisms in or around the site of the development or field test. N/A
11. For imports of GMOs: Could your organism(s) undergo rapid assessment (s42B of the HSNO Act)?
Discuss whether the GMO(s) to be imported fulfil the following criteria: The host organism(s) are Category 1 or 2 host organisms as per the HSNO (Low Risk Genetic Modification) Regulations. The genetic modifications are Category A or B modifications as per the HSNO (Low Risk Genetic Modification) Regulations and the modifications are not listed in the Schedule of these Regulations. The minimum containment of the GMO(s) will be as per the HSNO (Low Risk Genetic Modification) Regulations (PC1 or PC2 as per AS/NZS2243.3:2002). N/A
12. Other information
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Add here any further information you wish to include in this application including if there are any ethical considerations that you are aware of in relation to your application.
13. Appendices(s) and referenced material (if any) and glossary (if applicable)
Glossary
A semiochemical is a chemical substance or mixture that carries a message between organisms. Semiochemicals are used in communications between organisms either within the same species (pheromones) or from different species (allelochemicals including synomones, kairomones, allomones and repellents), and in this approval would include synthetic chemicals which resemble or mimic the action of natural semiochemicals.
References MASANTE-ROCA, I., ANTON, S., DELBAC, L., DUFOUR, M. C., and GADENNE, C. 2007. Attraction of the grapevine moth to host and non-host plant parts in the wind tunnel: effects of plant phenology, sex, and mating status. Entomologia Experimentalis et Applicata 122:239-245. DOI 10.1111/j.1570- 7458.2006.00510.x.
SUCKLING, D. M., BARRINGTON, A. M., CHHAGAN, A., STEPHENS, A. E. A., BURNIP, G. M., CHARLES, J. G., and WEE, S. L. 2007. Eradication of the Australian painted apple moth Teia anartoides in New Zealand: trapping, inherited sterility, and male competitiveness, pp. 603-615, in M. J. B. Vreysen, A. S. Robinson and J. Hendrichs (eds.). Area-wide control of insect pests: from research to field implementation. Springer SBM, Dordrecht, Netherlands.
SUCKLING DM, WILLIAMS DG, WOODS B, BAKER G, CRISP P, STEPHENS AEA, EL-SAYED AM AND STRINGER LD 2009 Integrated pest eradication for perennial horticulture: A review of current technologies. Report CRC Plant Biosecurity/B3 joint output-report available on request.
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Application for containment approval for new organisms
14. Signature of applicant or person authorised to sign on behalf of applicant
I request the Authority to waive any legislative information requirements (i.e. concerning the information that shall be supplied in my application) that my application does not meet (tick if applicable).
I have completed this application to the best of my ability and, as far as I am aware, the information I have provided in this application form is correct.
Signature Date
September 2011 EPA0061