Hydrogen cyanamide reassessment
We are reassessing the use of hydrogen cyanamide, a restricted spray ingredient used in commercial orchards. This reassessment is open for public submission.
Application formally received
Submissions close on Monday 20 December 2021 at 5.00 pm.
Hydrogen cyanamide has been used in Aotearoa New Zealand since 1988. It is used mainly in kiwifruit orchards to promote bud growth. It is also used in some apple, cherry, apricot, and kiwiberry crops, but to a lesser extent.
There are six hydrogen cyanamide products approved for use. They are restricted to commercial use, and can only be used by trained professionals.
Why we are reassessing hydrogen cyanamide
We have assessed the risks to people and the environment, and economic benefits of hydrogen cyanamide use in New Zealand. Our assessment was based on risk analyses, economic assessments, information on alternative bud-break agents, and general comments we received from industry groups, iwi, and individuals.
Other significant information included a European Food Safety Authority review, and assessments published by regulators in the United States and Europe.
Human health risks
Hydrogen cyanamide is toxic to the reproductive system and thyroid if people are exposed to it over time. It is a suspected carcinogen, and is corrosive to skin and eyes. The risks to operators are of concern.
Environmental health risks
There are risks to the aquatic environment, non-target plants, pollinators, non-target arthropods, and birds. Risks can be mitigated by using buffer zones, restrictions on application rate and timing, and prohibiting use when bees are present.
Impact on Māori culture and social wellbeing
The continued use of hydrogen cyanamide is likely to enhance Māori economic and social development in terms of prosperity, livelihoods, and lifestyles. But it is likely to adversely affect the relationship of Māori and their culture and traditions with their environment and taonga, including culturally significant species, resources, and places, and the customary values, practices and uses associated with these taonga.
In mid-2021 we held hui in kiwifruit-growing regions to gather information for our Māori impact assessment report. In advance of the hui, we provided two documents summarising the key issues identified in our risks and benefits assessments.
We recommend that current approvals for hydrogen cyanamide be declined, and the substance banned.
We propose it is phased out over five years, with tighter controls taking immediate effect after the final decision. A gradual phase out would allow existing stock to be used up, for growers to get familiar with alternatives, and to introduce additional alternatives to New Zealand.
We propose implementing the following controls, taking immediate effect, subject to a short transitional period to update labelling and packaging.
- Update hazard classifications to:
- classify the soluble concentrate as skin and eye corrosive, rather than an irritant
- include a carcinogenicity classification
- change the specific target organ toxicity classification (from Category 1 to 2)
- classify as hazardous to soil organisms.
- Lowest possible application rates, keeping the benefits of hydrogen cyanamide, while minimising risk.
- Buffer zones of up to 50 metres to protect bystanders, aquatic habitats and plants.
- Maximum wind speed of between 3 km/h and 20 km/h.
- Update labelling and packaging requirements.
- Users should be appropriately trained and qualified to handle hydrogen cyanamide substances and manage the environmental risks.
The application documents include a standard application form, an application report, and separate reports that review both the positive and adverse effects of hydrogen cyanamide.
The application report includes preliminary proposals for hydrogen cyanamide, based on the results of the risk and benefit assessments, and the information currently available.
Zespri International, the kiwifruit industry body, has asked us for definitions of some technical terms, and to clarify parts of the reassessment application and risk assessment reports. We have published our response to Zespri to ensure all submitters have the same level of information, and access to it.
Make a submission
Anyone can make a submission. Before you begin, please read the application summary submission guide.
Carefully read the privacy information and notes on completing the form. You can answer some of or all the questions.
Submissions close on Monday 20 December 2021 at 5.00 pm.
We encourage you to use the secure online submission form. When you submit the form you will be emailed a copy of your response and a reference number.
Alternatively, download the Word form, and email or post your response to us.
Or post: Reassessments
Environmental Protection Authority
Private Bag 63002
Information we are looking for
We want to hear from industry, importers, manufacturers, growers, iwi and the public.
We are interested in receiving feedback on our draft proposal, and data to inform the Decision-making Committee when it is considering its final decision.
- Feedback on the input values we used for the risk assessment on human health.
- Feedback on the proposed maximum application rate restrictions, and information on the effectiveness of lower application rates.
- Information on advances in closed cab application, closed systems for mixing and loading, and other technological developments
- occupational exposure monitoring data
- crop-specific spray drift curve information with full supporting data, or refined risk assessments
- information on birds, for example, foraging habits and behaviour in New Zealand orchards
- information on alternatives to hydrogen cyanamide, their relative cost and effectiveness, and any recent developments.
Background to the reassessment
Hydrogen cyanamide was last reassessed in 2006. It was decided that risks would be managed by an industry-led approach to ensure safe use of hydrogen cyanamide substances.
Grounds for reassessment
Grounds for reassessment were established in September 2019 based on new information on the effects of hydrogen cyanamide.
The new information included the European Food Safety Authority review and associated human health and environmental risk assessments, and the subsequent European Union decision implementing the authority's recommendations.
Call for information
We opened a public call for information about hydrogen cyanamide at the start of 2020. It closed on 29 May 2020, and we received 12 responses. The information provided has been used to inform this reassessment application.
Read the application documents for the grounds to reassess hydrogen cyanamide in 2019, documents from the previous reassessment undertaken in 2006, and our 2012 HSNO Monitoring Report.