SUBMISSION TO: Environmental Protection Authority (EPA) FROM: Apiculture New Zealand Science and Research Focus Group SUBMISSION ON:

Transcription

1 SUBMISSION TO: FROM: SUBMISSION ON: Environmental Protection Authority (EPA) Apiculture New Zealand Science and Research Focus Group A new fungicide to protect cereal crops (APP203604) DATE: 17 October 2018 CONTACT DETAILS: Apiculture New Zealand PO Box Wellington ceo@apinz.org.nz

2 1. INTRODUCTION 1.1 This submission has been prepared by the Apiculture New Zealand Science and Research Focus Group. Apiculture New Zealand is the peak industry body representing the interests of beekeepers and honey bees in New Zealand. 1.2 The apiculture industry is now one of New Zealand s fastest growing export enterprises and presently supplying the world with very high value honey products. It is therefore very important that New Zealand protects this resource by ensuring the safety and health of the honey bee. 2. FUNGICIDES ARE A SIGNIFICANT ENVIRONMENTAL POLLUTANT 2.1 The Apiculture NZ Science and Research Focus Group thanks the EPA for the opportunity to make a submission on this application, as we do not get many fungicide applications that are open to public submission. Overseas research has identified that bees do gather fungicides and bring these chemicals back to the hive. As recently as 2016, Fisher II et al identified the effects of fungicides on honey bee health have been so far understudied In a US and Canadian study (Mullins et al) of 887 wax, pollen, bee and associated hive samples, 121 different pesticides and their metabolites were identified 2. Cornell University has quoted the above data observing that the most common pesticides in beehives are acaricides placed in the hive by beekeepers to control Varroa then followed by fungicides A major concern is that we measure environmental effects on honey bees with respect to their mortality to controlled exposures of the active ingredient, which is not what happens in the environment when a fungicide product is sprayed. 2.4 At the moment no one is measuring how much fungicide is applied to crops in New Zealand each year, there is no monitoring by the EPA or anyone else of the amount of fungicide active ingredient and excipients in our ecosystems. 2.5 None of the above papers mention the active ingredient of VIMOY IBLON isoflucypram as it was not in field use at the time of their studies. The Apiculture NZ Science and Research Focus Group is concerned that Bayer has submitted to the EPA 200 studies and documents about this fungicide but not one of them is publicly available for review or discussion in this submission TOXICITY TO BEES 3.1 The Hazard Classification 9.4C (Ecotoxic to terrestrial invertebrates) and the oral and dermal toxicity endpoints (summarised on page 23 of the application) identify that this substance is Adrian Fisher II, Chet Coleman, Clint Hoffmann, Brad Fritz,and Juliana Rangel (2016). The Synergistic Effects of Almond Protection Fungicides on Honey Bee (Hymenoptera: Apidae) Forager Survival. Journal of Economic Entomology, 2017, 1 7 doi: /jee/tox031 2 : Mullin CA, Frazier M, Frazier JL, Ashcraft S, Simonds R, et al. (2010) High Levels of Miticides and doi: /journal.pone Cornell College of Agricultural and Life Sciences. 4 Section 4. Application Summary and Submission guidance Vimoy Iblon (APP

3 ecotoxic to honey bees. It is noted that the summary does not identify the tests conducted but we assume they are OECD 213, 214 and a modified OECD 237 (22 day assessment). An explanation of the tests conducted should have been supplied with the application. 3.2 The Apiculture NZ Science and Research Focus Group is not concerned with application of VIMOY IBLON on cereal crops as it is unlikely that bees will be foraging these crops. 3.3 We have three concerns that we feel is not addressed in the application; 1) Aerial application of VIMOY IBLON which is applied at double the rate to ground spraying reference Table 5.1, Page 16 of the application. The draft label (application Appendix C) has no mention of buffer zones and downwind spray buffer zones, to prevent spray drift on to other crops that maybe flowering, flowering weeds in crop verge areas, and if any specific spray adjuvants recommended for aerial spraying. The draft label should have shown this information. 2) There is no mention of the use if required of spray tank adjuvants to be tank mixed with VIMOY IBLON, in the application or on the draft label. Some spray tank adjuvants can be very toxic to honey bees when applied by spraying. Are they required or not? What products are recommended by Bayer? 3) The use of VIMOY IBLON on ryegrass needs some clear operator instructions. Ryegrass is often grown with clover and hat is an attractive flower for honey bees to gather nectar and pollen. There is no warning to not spray if clover and other pasture weeds are in flower. We strongly recommend a no spray label warning if flowering plants are present in a ryegrass crop or surrounding a crop. 4. RISKS, COSTS AND BENEFITS 4.1 The Apiculture NZ Science and Research Focus Group agrees with the two identified risks to honey bees; 7.1.3C iii) Spray drift Spray drift could occur resulting in off-target effects and bystander exposure C iv) Exposure of beneficial insects Beneficial insects such as bees, predatory mites and parasitic wasps could be exposed to the product during and after application. 4.2 It is our expectation that spray drift will be significantly more important risk when VIMOY IBLON is applied by aerial application, especially on crop verge areas and due to wind dispersion. As VIMOY IBLON is applied at double the ground spraying rate the concentration of spray is a lot higher than ground spraying, which increases the risks to beneficial insects such as bees. Spray buffer zones around the crop would help mitigate these risks to foraging bees. Bayer have we believe understated these two risks. 4.3 Table 7.2A Benefits makes some assumptions that should be questioned. Is it a benefit that a farmer has the freedom of choice of various fungicides? It should be noted by the EPA that Bayer already offers four fungicide products which control similar fungal diseases as to VIMOY IBLON see table below for wheat alone. VIMOY IBLON is a single active ingredient offering the same benefits of KESTREL which is a two active ingredient product. Note co-formulations will be better for managing pesticide fungi resistance compared with single active ingredient products. We would question if this really provides a tangible benefit for the farmer if they choose VIMOY 3

4 Wheat IBLON? Table data is sourced from Speckled Stripe Rust Rust Powdery Mildew Tan Spot Ear Disease Complex Glume Septoria KESTREL DELARO PROLINE PROSARO VIMOY IBLON Is there a true benefit in spraying ryegrass for the control of stem rust (Puccinia graminis). Ryegrass stem rust is widespread throughout NZ and seed company Barenbrug on the Agriseeds website states that using fungicides for control is uneconomic. 5 This is the only evaluation we can obtain concerning the use of fungicides in ryegrass crops to control stem rust. As result the claim of benefits for the farmer must be questioned. It should be noted that Bayer will have four fungicide products claiming control of stem rust when VIMOY IBLON is approved. Bayer claims a low residue benefit for farmers and exporters. Level of residues in treated crops and animal commodities is expected to be below limit of quantification (LoQ). The label clearly states that the withholding periods are substantial for this product. Cereal grains have a 56 day withholding period and ryegrass 14 days. This suggests that the residues are significant and may present a lingering hazard for bees if they come into contact with plants sprayed with VIMOY IBLON example clover plants over sprayed prior to flowering. Have any plant residue effect studies been conducted on terrestrial invertebrates? 5. SUMMARY 5.1 The fungicide VIMPOY IBLON is ecotoxic to bees and will put them at risk if they are over sprayed. 5.2 The Apiculture NZ Science and Research Focus Group supports the adoption of suitable controls to prevent risks to foraging bees. We believe that aerial spraying is possible so long as suitable controls are in place to prevent risks to honey bees. These should include the following; 1) Do not spray or overspray flowering weeds in the crop or in surrounding areas and crops. 2) Aerial spraying which is conducted at double the rate should have suitable buffer zones and downwind protections established to prevent spray drift exposure to bees in surrounding crops. 3) Clear directions should be given on the label about the use of spray tank adjuvants and the possible adverse effects on honey bees. 4) Warning statement on label advising this fungicide is toxic to bees

5 5.3 The Apiculture NZ Science and Research Focus Group would like to reserve the right to be heard at a Public Hearing for the consideration of this substance as described in APP Thank you for considering our submission. Yours faithfully Apiculture New Zealand Science and Research Focus Group Barry Foster (Chair) Dr Oksana Borowik Dr Mark Goodwin Don MacLeod John McKay Dr John McLean 5