Pesticide Action Network Aotearoa NZ

Submission to: ERMA New Zealand

Subject: Application HRC08004 – Reassessment of Dichlorvos

By: Pesticide Action Network Aotearoa New Zealand

Contact: Dr Meriel Watts

Date: 17^th February, 2011

I wish to be heard at a public meeting

Decision sought:

1. Immediate revocation of all domestic use, use in hospitals, schools or other residential or public buildings

2. Immediate revocation of all outdoor uses including glasshouses, mushrooms houses, commercial and industry premises

3. Phase out within 1 year all indoor uses

4. Retain use in impregnated strips for Biosecurity traps until less harmful alternative is found - review this use within 5 years

5. Disallow manufacture in New Zealand

Pesticide Action Network Aotearoa New Zealand (PAN ANZ) agrees with ERMA that all outdoor uses should cease.

However PAN ANZ is of the view that the use of dichlorvos indoors should also cease because of risks to human health, and especially to children through domestic and public use. ERMA’s assessment shows that it poses very high risk to children from exposure to treated surfaces so it is unacceptable to allow any further use in areas in which children may be exposed.

Reasons for seeking this decision:

1. High acute and chronic toxicity

Dichlorvos is highly acutely toxic, and mutagenic and carcinogenic in animals, with reasonable certainty that it is also mutagenic and carcinogenic in humans.

ERMA’s assessment did not take into account epidemiological studies that have indicated increased risk of leukaemia,
non-Hodgkin’s lymphoma, multiple myeloma and childhood brain cancer from exposure to dichlorvos.
A number of laboratory studies have shown elevated rates of mammary tumours in rodents (Gandhi & Snedeker 1999).
These findings have not been taken into account in determining carcinogenic risk to humans.

P222 of the assessment reports ATSDR (1997) as saying dichlorvos has not been found in breast milk. However Gandhi & Snedeker (1999) report that it has been found in breast milk in Taiwan.

ERMA has not assessed the risk of diabetes and obesity. Organophosphate exposure has been shown repeatedly to be associated with hyperglycemia in animal models (Montgomery et al 2008; Rezg et al 2010). Dichlorvos specifically has been shown to disrupt glucose homeostasis in male Wistar rats. Applicators exposed to dichlorvos had increased odds of diabetes and the odds increased with increasing cumulative days of use (Montgomery et al 2008). Organophosphates have also been shown, both in laboratory studies and epidemiological studies to increase the risk of obesity (Rezg et al 2010)

2. High ecotoxicity

Dichlorvos is highly toxic to honeybees, and given the threat to the environment and humanity posed by the rapid decline in honeybees populations round the world, this is also sufficient reason to ban all uses of dichlorvos. ERMA failed to assess the risk to honeybees entering glasshouses.

Dichlorvos is also highly toxic to aquatic organisms and birds.

PAN ANZ agrees with ERMA that all outdoor use should cease, but this should happen immediately. Indoor use involves deliberate release to the environment in order to avoid poisoning people. ERMA failed to account for this release:

“No quantitative modelling of environmental exposure arising from indoor use of dichlorvos has been performed. Nevertheless, washing of treated areas, or drainage from greenhouse watering could lead to contamination of the environment.” P 78, section 6.1.7.1

Venting and run-off from indoor use is unacceptable given the high risk to the environment and so all indoor use must also cease.

3. Alternatives

Although ERMA evaluated alternative plant protection products, pesticides, it failed to evaluate alternative plant protection methods. All of the crops for which ERMA is proposing continued use of dichlorvos are grown without the use of this pesticide under organic management systems – but ERMA has not evaluated these systems and their practices.

There are a multitude of methods for management of insects indoors without using dichlorvos, including yellow sticky paper strips, sticky board cockroach traps and many other environmental management techniques none of which have been evaluated by ERMA, but which are found effective by those who use them.

Concluding remarks:

The assessment acknowledged that ERMA is obliged by its own published Methodology to take into account the need for caution in managing the adverse effects of the substance, where there is scientific and technical uncertainty. There is sufficient certainty that dichlorvos is highly toxic to humans and the environment particularly children and critical elements of the environment such as honey bees, and aquatic organisms. The only uncertainty evident here is whether or not there are sufficient alternatives currently available, and this uncertainty exists partly because ERMA failed to assess alternative non-chemical methods of management. Thus the apparent paucity of chemical alternatives for some uses is not sufficient reason to allow continued use of this highly dangerous pesticide and no further use can be countenanced.

References:

Gandhi R, Snedeker SM. 1999. Critical Evaluation of Dichlorvos’ Breast Cancer Risk. Critical Evaluation # 7. Program on Breast Cancer and Environmental Risk Factors in New York State (BCERF), Cornell University. http://envirocancer.cornell.edu/criticaleval/criticaleval.cfm.

Montgomery MP, Kamel F, Saldana TM, Alavanja MCR, Sandler DP. 2008. Incident diabetes and pesticide exposure among licensed pesticide applicators: Agricultural Health Study, 1993–2003. Am J Epidemiol 167(10):1235-46.

Rezg R, Mornagui B, El-Fazaa S, Gharbi N. 2010.Organophosphorus pesticides as food chain contaminants and type 2 diabetes: a review. Trends Food Sci Technol 21(7):345-7.

© PANANZ 2010