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Appendix supplied to complement Draslovka’s application to the New Zealand EPA to import and use EDN


Academic year: 2022

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Appendix supplied to complement Draslovka’s application to the New Zealand EPA to import and use EDN


Appendix Sections

Appendix 1 Applicant details 1.1. Applicant pg 4

1.2 Draslovka background pg 4 1.3 The history of EDN pg 11 1.4 Background on STIMBR pg 12

1.5. Research undertaken by STIMBR to identify alternatives, tools and technologies to manage methyl bromide emissions pg 16

Appendix 4 Life cycle of EDN 4.1 Manufacturing and Importation pg 24 4.2 Packaging pg 25

4.3 Storage pg 28 4.4 Disposal pg 37

4.5 Safety data sheets pg 38

Appendix 5 Use 5.1 Phytosanitary treatments for export logs pg 47 5.2 Where EDN is applied pg 47

5.3 Details on the use of EDN pg 48

5.4 NZ ports and their suitability for fumigation activities pg 50

5.5 Fumigation with EDN pg 60

Sub appendix 5.1 Phytosanitary Treatments for logs exported from New Zealand pg 71

5.1.1 The need for Phytosanitary Treatments pg 71 5.1.2 The Phytosanitary Tool Box pg 72

5.1.3 Market Access Negotiations pg 76

Sub appendix 5.2 Draeger cyanogen circular letter pg 78


Appendix 6 Toxicology and HSNO hazard classifications of the formulated substance

6.1 Classification pg 79

6.2 Toxicology pg 87

6.2.1 Mode of action and toxic kinetic pg 87 6.2.2 Acute toxicity pg 88

 Acute inhalation

 Oral toxicity

 Dermal toxicity

 Eye irritancy

6.2.3 Systemic toxicity pg 90

6.2.4 Reproductive and developmental toxicity pg 90 6.2.5 Neurotoxicity pg 91

6.2.6 Chronic toxicity pg 92 6.2.7 Genotoxicity pg 93 6.2.8 Carcinogenicity pg 95 6.2.9 WES and TEL values pg 96

6.3 Eco-toxicology

6.3.1 Fate in the environment pg 111

6.3.2 Ecotoxicological Classifications pg 113

Appendix 7 7.2 Risks costs and benefits analysis of 7.2.1 Risks pg 114

 Introduction

 Proposed use

 Product description: and approach to risk analysis

 Physical characteristic assessment

 Human toxicological assessment

 Ecotoxicology risk assessment 7.2.2 Costs pg 137

 Associated with a new chemical.

 When compared with methyl bromide

 When compared with methyl bromide

 Of cleaning up an accident.

7.2.3 Benefits pg 140

 Introduction

 Value of forestry

 Benefits of EDN

 Assessing potential scenarios Sub appendix 7.2.2 pg 164

 Exposure EDN fumigation trials

 Modelling of workplace exposure


7.3 Risks, costs and benefits which arise from the kaitiaki relationship of Māori and their culture to the environment

7.3.1 Introduction pg 181

7.3.2 Consultation process pg 181

7.2.3 EDN’s potential effect on the role of Māori as kaitiaki pg 183

7.2.4. MRG meeting and report pg 185 Sub appendix 7.3.1 MRG Report pg 190

Sub appendix 7.3.2 Record of meeting with Iwi pg 198

Sub appendix 7.3.3 Exert from HRC08002 pg 203 Sub appendix 7.3.4 Communication sheet pg 209

Appendix 7.6 Comparison of EDN with methyl bromide and phosphine pg 212

Glossary Page 217


Appendix 1 Details about the applicant and the reason for the application

1.1. Applicant

Company Name: Draslovka a.s. formerly Lucebni zavody Draslovka a.s.

Company Address


Web site www.draslovka.cz/

Contact Name: c/o Helen Gear, Physical Address:

Phone 0064 4 23 999 45 or 0064 (0) 274 868 131 Email: [email protected]

1.2. Draslovka - background

1.2.1. Draslovka overview

Draslovka is a family owned business in the Czech Republic that prides itself on its high environmental standards in all of its businesses. It has identified EDN as a fumigant that has significantly less impact on the environment and human health than methyl bromide.

Draslovka considers that replacing methyl bromide with EDN cannot only prevent damage to the ozone but will also facilitate environmentally sustainable food production and trade in through its use as a soil fumigant and for the control of quarantine insects on logs and wood products.


1.2.2. Draslovka’s vision

Draslovka recognises that it does not operate in seclusion, but, as a manufacturer of products that directly influence produce and raw materials, acknowledges a responsibility to the customer and end user, to the environment itself, and to the global community. Driven by this sense of responsibility, the Board of Directors are actively seeking to meet, through the company’s suite of products, certain global challenges that may lie ahead.

With the world population projected to expand by at least 2.3 billion by 2050, a resultant demand for food and other products is expected to place an unprecedented strain upon the earth’s resources. Not only would this negatively impact the environment, but the socio-economic balance as well. A

fundamental change to the way resources are managed is therefore needed if these disruptions are to be avoided.

Draslovka has a clear picture of how this might be accomplished: namely, by increasing average yield per hectare, bolstering sustainable crop protection, and improving soil conservation. The company believes its line of fumigants, biocides, and services can significantly contribute towards achieving these ends and, through such means, Draslovka intends to make a significant, positive, and lasting global impact.

1.2.3. Company Introduction and History

Draslovka1 Holding B.V. is a company dealing in the development, production, and distribution of cyanide (CN) based industrial chemicals for broad-spectrum applications. The company’s key business unit and production facility, Lučební závody Draslovka a.s. Kolín, is located in Kolín, Czech Republic.

Since the company’s inception, operations have centred on the production of potassium cyanide, sodium cyanide, liquid hydrogen cyanide, ferrocyanides, and ammonium sulfate. Over time, a distinct range of products and services has emerged, with an eye to efficacy and environmental stewardship.

This current range comprises not only bulk chemicals, but also speciality chemicals, for applications in agriculture; nutraceuticals; electronics; polymers; energy storage; and the flavour and food,

cosmetics, and automotive industries.



Founded in 1906 by Deutsch Gold und Silberscheideanstalt, under the commercial name of Akciová společnost pro zpracování draselných louhu v Kolíně, the company was later nationalised under the name Lučební závody, during communist rule.

It was once again brought under private ownership in 1992, under the name of Lučební závody Draslovka (LZD) a.s. Kolín, and, in 1996, the majority of LZD a.s. Kolín was acquired by ITCE s.r.o (now expanded under the name B3 Holding).

As the first step in extending Draslovka’s activities outside of the Czech Republic, in 2012, a joint venture was established between B3 Holding and bpd partners investment group to form Draslovka Holding B.V.—a Dutch based holding company owning both LZD a.s. Kolín and Draslovka Services Pty. Ltd.

1.2.4. Draslovka Today

Under the guidance of the company’s four co-owning families, Draslovka has established itself as an ethical and reliable supplier of effective yet environmentally friendly chemicals. The company is continually diversifying and streamlining its operations, organically and through mergers with like- minded companies.

LZD a.s. Kolín acts as hub of operations for Draslovka Holding B.V. Its activities include developing and optimising production, sales and marketing, and research and development (R&D). The Kolín business unit is complemented by the Melbourne, Australia based Draslovka Services Pty. Ltd.- a quarantine and crop protection consultancy, working closely with the company’s distributors, suppliers, and customers.

The 162,000 m2 production facility in Kolín—which has operated almost continuously since 1906 - features connections to a main railway and highway, a natural water source from the Elbe River for cooling purposes, three 22kV power cables, and a supply of natural gas. Employing the Andrussow process2, the plant produces a continuous flow of both pure liquid hydrogen cyanide (HCN) and cyanogen chloride (CICN) - the two principal compound bases Draslovka uses to synthesise its products.

2 The Andrussow process is an industrial process for the production of hydrogen cyanide from methane and ammonia, in the presence of oxygen and a platinum catalyst. The process is based on a reaction that was discovered by Leonid Andrussow in 1927. It is one of two commercial methods used to produce cyanide. Details of the process were described by Pirie in 1958.


Draslovka is currently planning additional production facilities around the globe that will be located closer to key market areas. These new units will be constructed and operated according to the same standards as those of the Kolín plant.

1.2.5. Additional Activities

In addition to its investments in Draslovka Holding B.V. and in accordance with its own self-imposed environmental mandate, bpd partners invest in environmentally sustainable buildings, through its Prague-based specialist real estate company - bpd Development (bpd).

Through its investments in the alternative energy projects of REN Power Investment B.V., bpd seeks to counteract CO2 emissions and provide sustainable alternatives to non-renewable and nuclear energy sources. Currently, REN Power has solar and wind operated power plants in the Czech Republic, Poland, the United Kingdom, and Italy.

Bpd partners also have a philanthropic arm that supports activities in civil society, education, and the arts. The company makes financial contributions to the work of two non-profit groups: Post Bellum, an organisation devoted to documenting, through eye-witness accounts, pivotal events of the 20th century in danger of being forgotten; and the Pudil Family Foundation, which seeks to promote appreciation of modern and contemporary art - both Czech and international - through exhibitions, research, and educational offerings.

Under the Draslovka Holding B.V. banner, both B3 Holding and bpd partners have helped finance exhibitions - in the Czech Republic and New Zealand - of the works of Gottfried Lindauer, a Bohemian born artist who spent most of his adult life in New Zealand.

1.2.6. Waste Management

Draslovka strives to reduce overall waste through efficient production methods and state-of-the art facilities, and every effort is made to handle what waste there is, in-house. Great care is taken to contain contaminants and recycle these when possible.

All waste gases produced at Kolín are burned, on site, to produce heat for both the factory and the city. Any remaining gases are neutralised by chemisorption.

Draslovka’s standards in wastewater treatment not only meet but exceed those of the International Safety Management Code. All wastewater is handled in-house, so that any water released from the production facilities into the environment is free of contaminants.


Wastewater is treated at three primary plants - one for handling wastewater produced by employees, another for the removal of cyanide ions, and a third, specialised chemical-biological plant.

This last makes use of a special two-stage technology wherein wastewater is chemically brought to the correct pH level for the biological remediation that follows. In this latter stage, genetically-modified bacteria consume cyanide ions and organic waste products to produce ammonia-based nitrogen and other naturally occurring compounds.

In addition to these treatment facilities, there is a fourth - a standby multipurpose plant, equipped with retention tanks, where a range of treatments, including coagulation and press filtration, can be performed as needed.

When it was discovered that the soil beneath the factory site was contaminated, due to damage sustained from an air raid during the Second World War and to environmentally unfriendly practices under communist control, the new ownership installed the so-called “Milan Wall” to remove the contamination and prevent it recurring.

The “Milan Wall” is a subterranean aquatic retention system, in which a deep underground dam causes large quantities of groundwater to collect beneath the site. This water absorbs contaminants from the soil, after which it is pumped out of the earth, taking the contaminants with it. The water is then treated on-site to remove those contaminants before being discharged.

The underground dam serves a secondary but important role as a containment buffer, protecting local natural water sources, in the event of any spills at the production and treatment facilities. This

safeguard is complemented by an Emergency Shut Down (ESD) valve, which can immediately halt the release of treated waters from the plant to the river, should the need arise.

1.2.7. Health and Safety, Transparency

Draslovka endeavours to continually raise its standards of health and safety. To ensure the welfare of its employees and the people of Kolín, the company has implemented up-to-date safety measures at the plant, in line with the most stringent international standards. These measures are applied throughout all facilities and cover the handling of raw materials, production, product storage, and transportation.


Draslovka adheres to a policy of complete transparency, regarding every aspect of its operations, and welcomes inspections of its production facilities by outside environmental agencies, both state and private. Should the citizens of Kolín wish to know more about practices at the plant, they too may obtain such information by appeal to the city council.

The Kolín facility’s integrated monitoring and safety system consists of more than 350 detection points and over 50 closed circuit cameras. This system is accessible to the city council whose direct

connection with police and fire departments as well as hospital allows for a quicker response time in the event of an emergency - should Draslovka’s own in-house fire and safety department (staffed by 21 full-time employees) require assistance.

The company is a member of or qualified in the following:

ISO 9001and ISO 14001 quality and environmental management systems

 Hard Analysis and Critical Control Points (HACCP) safety management system

 Occupational Health and Safety Advisory Services (OHSAS)

 Responsible Care Management System

 International Cyanide Management Code (ICMC)

 Member of the European Chemical Council (Cefic), with Draslovka’s own Board chairman holding the position of vice-chairman in the Cefic Cyanides Sector Group

 Member of MAS and TRINS (Integrated Safety Systems).

1.2.8. Quality Control

Draslovka has put in place exacting standards of quality control. The company oversees the development of each product, from the laboratory to industrial production, and is able to ensure standards are consistently met by carefully monitoring every step in that process.

Draslovka’s quality control laboratory was refurbished and modernised in 2014, and the company is fully-equipped to handle the in-house chemical analysis required to monitor the quality of its products.

Quality control functions are active year-round, with regular checks on starting materials,

manufacturing processes, and final products. Every product leaving the production facility is tested and inspected to ensure it has reached the applicable standard.


1.2.9. Research and Development with Innovation

Draslovka strives for continual improvement and innovation of all its products and services. With a team of more than 22 chemical scientists and over 200 years of collective experience, the company can carry out R&D and move any cyanide-based molecule from concept to laboratory and, from there, to production on an industrial scale.

Draslovka also interfaces with universities and independent laboratories in the Czech Republic, United Kingdom, United States, Australia, and New Zealand, each being selected for its world-class science. It is in these labs that third party testing is conducted to aid in product registration around the world. In all cases the testing is carried out to the highest standards, including those of The

Organisation for Economic Co-operation and Development (OECD).

At present, Draslovka and STIMBR3 are jointly funding an approximately $2 million NZD study on the efficacy of EDN, conducted at the facilities of Plant & Food Research. When completed, the results from this work will enable the New Zealand Government to better negotiate the use of EDN as a fumigant in the treatment of logs destined for some of the country’s key markets.

R&D at Draslovka, both internal and external, is conducted with the field application of its products clearly in mind. To this end, the company has a team of engineers dedicated to developing methods and technologies for the safe, efficient, and effective use of its fumigants, biocides, and


As a prime example, considerable effort is currently being put into developing both stationary and portable detectors/monitors to safeguard users against unacceptable levels of any of the company’s products and raw materials.

1.2.10. Registration and Regulatory Affairs

Draslovka has its own product registration teams, consisting of toxicologists, agronomists,

entomologists, and regulatory experts, with teams located in both the Czech Republic and Australia.

The company also understands that registration and regulatory requirements can vary a good deal from country to country and, as such, selects local, experienced consultants to oversee these matters in their respective countries.

3 Stakeholders in Methyl Bromide Reduction Inc. (STIMBR) is a research funder supported by voluntary levies on two fumigants (methyl bromide and phosphine) used as phytosanitary treatments in New Zealand.


1.3. The history of EDN

1.3.1. EDN overview

EDN is a cyanide based chemical that occurs naturally and had previously been used in the production of nitrate fertilisers. It was identified as a possible fumigant in 1996 and was purchased by Draslovka in 2014. Since that time Draslovka has invested in a significant amount of research to allow it to be assessed for registration as a possible fumigant.

Gay-Lussac first prepared EDN in 1815 but was not manufactured on a large scale until the late nineteenth century because its preparation was relatively expensive. Large-scale preparation of EDN began about mid-1916 when it was used in the production of nitrocellulose, a combustible explosive component in military armaments. In 1960 Fierce and Sandner patented an inexpensive method for preparing EDN, which by then had become useful in the nitrate fertiliser industry.

In 1996, CSIRO patented EDN internationally as “a fumigant… [that] provides a viable alternative to conventional fumigants, such as methyl bromide, phosphine, and carbonyl sulphide.” Although there were a number of preceding patents on EDN uses and production, the CSIRO patent was the first to identify EDN specifically as a fumigant.

CSIRO publicised in 2005 that the EDN patent would be licensed to BOC as an ozone-safe

alternative to methyl bromide and that the intellectual property licensing would enable BOC to obtain registration (i.e. a “label”) for the various uses of EDN as a fumigant. The actual agreement between CSIRO and BOC was signed in September, 2004. In 2006 BOC stated that they were preparing a registration application e for the devitalisation of grains and weed seeds (including sterilisation of seed pathogens), disinfestation of timber and logs for export, and as a soil fumigant for strawberry runners and fruit growing.EDN was successfully registered for use on logs and timber in Australia in 2011.

A previous application to register EDN™ Fumigas was made to the EPA in November 2011 by BOC.

This application was made by the previous owners of EDN and did not contain any of the recent international research to identify how ethanedinitrile affects animals and the environment. Due to this lack of information which prevented EDN from being properly assessed this application was

withdrawn. Draslovka has been involved with EDN for over 10 years. The company purchased the sole rights to the product from Linde Gas in 2014 and has made significant investment to develop not only the chemical manufacturing processes; but, to also undertake extensive research required to support the development of a commercially accepted broad spectrum fumigant.



1.4.1. STIMBR overview

The Stakeholders in Methyl bromide Reduction Inc. (STIMBR) is an industry body of like- minded stakeholders formed to identify alternatives to methyl bromide in New Zealand. Over the last 8 years STIMBR has invested industry funds in a significant research programme to identify possible alternatives. EDN has been identified as the only fumigant that could possibly replace methyl bromide to support log exports. While a possible second fumigant has been identified it is a green-house gas and has limited efficacy. At this stage no other fumigant solution has been identified by STIMBR that could possibly be ready by 2020. Research continues across a range of technologies to manage methyl bromide emissions.

1.4.2. STIMBR History and purpose

STIMBR4 was formed in 2008 by key stakeholders involved in forestry and with interests in the use of methyl bromide.

Members soon recognised that there is no one single solution to methyl bromide that will provide log, lumber, wood product and horticultural product exporters with an alternative phytosanitary treatment.

As a consequence STIMBR initiated a strategic research programme. The research programme aimed to reduce methyl bromide emissions by developing effective alternative treatments or by recapturing or destroying methyl bromide at the end of fumigation.

STIMBR set itself the goal of identifying solutions by the end of 2018. This would allow time prior to the EPA’s 2020 deadline for either the Ministry for Primary Industries (MPI) to negotiate new market access conditions and/or enable industry to install the necessary recapture/destruction technologies that would the use of methyl bromide beyond 2020.



STIMBR’s Vision

STIMBR brings together industry, government and research organisations and individuals with the aim of:

Providing a united voice in support of initiatives aimed at enhancing market access and

biosecurity clearances for goods and products while reducing the release of methyl bromide into the atmosphere and seeking the long term reduction in its use.

STIMBR provides an interface between users of methyl bromide, fumigation service providers, government departments / regulators, researchers seeking alternative treatments and strategies, and other affected parties such as port companies.

STIMBR’s objectives

 To act as a forum for the discussion of stakeholder interests and activities.

 To inform government and the wider public as to the unique needs of New Zealand’s situation with regard to methyl bromide and the need for urgent action in the development of alternatives to methyl bromide, recapture technologies and other matters related to

achievement of the aim of the organisation.

 To seek funding to support its objectives.

 To commission, coordinate, promote and publish research undertaken on alternatives to methyl bromide, recapture technologies and other initiatives to enhance the achievement of

the aim of the organisation.

 To develop and implement agreed outcomes from research activity into commercial activities used by industry.

 To allocate and manage funds from subscriptions, levies and other contributions, to priority areas as agreed at the Annual General Meeting or Special General Meeting.

 To undertake any other activities which from time to time are seen by STIMBR to be in the interests of the organisation and achievement of its aims?

STIMBR’s governance STIMBR is governed by a Board elected annually. The Levy Sub- committee is led by Peter Hill. The Levy Sub-committee is made up of all of the levy payers. This Sub-committee reviews and determines the levy rate annually.

1.4.3. STIMBR’s Board

Don Hammond (Independent Chair) - Don is a New Zealand Institute of Forestry Registered Forestry Consultant with over 35 years forest industry experience in most aspects of natural and commercial forest management. Don holds a number of directorships and is also Chairman of the New Zealand Game Council


 Peter Hill – represents the United Forestry Group and is the Chairman of the STIMBR Levy payers subcommittee. United Forestry Group Ltd (UFG), has been formed in New Zealand to help the owners of some 14,000 small plantation forests, totalling more than half a million hectares, with the challenge of marketing a “wall of wood” coming to maturity over the next two decades.

 Jess Logan - represents TPT Forests Ltd, New Zealand’s largest log exporter. TPT exports into all major softwood log markets across Asia as well as the Middle East and Pacific.

 John Gardner - represents Pacific Forest Products. Pacific forest products trade logs and lumber, and provide marketing and shipping services into the Asia Pacific, Indian and Middle Eastern Markets.

 Cecil Grant – represents Rayonier a significant levy payer. Rayonier is the third largest forestry company in New Zealand with approximately 130,000 hectares of plantations across the country.

 Tim Charleson - represents the Wood Processors and Manufacturers. He is the Environmental & Quality Manager at Red Stag Timber an independent, privately owned timber company, based in Rotorua. Red Stag is currently New Zealand's largest sawmill, focussing on producing high-quality timber products for the residential construction markets in New Zealand, Australia, and the Pacific Island.

 Russell Dale - represents the Forest Owners Association where he manages the organisations extensive research programme.

 Helen Gear - represents the Plant Market Access Council (PMAC) and other users. PMAC provides a forum for the horticultural and seed industries to work with MPI and MFAT to progress market access issues.

1.4.4. STIMBR Management

Ian Gear is the Executive Officer / Research Director for STIMBR. Ian has extensive experience in biosecurity management, science planning, stakeholder engagement and strategy and is director of In Gear Global Ltd.

1.4.5. STIMBR’s funding

STIMBR’s funding is derived primarily through a voluntary levy. STIMBR’s investment is reliant on those using methyl bromide and phosphine as phytosanitary treatments agreeing to pay a voluntary levy on both products. All bar one log exporter pay the levy.


The levy is set annually by a Levy Subcommittee. The levy rates have been struck at: methyl bromide

$1.00 per kg; and, phosphine $0.05 per grain cubic metre equivalent. Suppliers of methyl bromide and phosphine collect the levy at point of sale. Quarterly levy payments are made to STIMBR. The levy income is vulnerable to the demand for logs. As volumes increase so does the levy. Equally if the market contracts the levy take declines. The 2017 levy take is anticipated to be $1.6m.

Leveraging the levy funds – where possible STIMBR leverages the levy funds it has available by seeking co-funding from either government research funds or from industry. In the past 7 years cofounding has been received from:

 The Ministry for Primary Industries - Primary Growth Partnership (PGP) and Operational research fund

 The Ministry for Foreign Affairs and Trade- Trade Access Support Programme

 Ministry for Business and Innovation and Employment - Contestable funding pool

 The Agricultural and Marketing Research and Development Trust (AGMARDT)

 Draslovka

 Plant Biosecurity Co-operative Research Centre

 Crown Research Institute discretionary funding - Plant and Food Research and Scion

 BOC Australia.


1.5. Research undertaken by STIMBR to identify alternatives , tools and technologies to manage methyl bromide emissions

1.5.1. Research overview

STIMBR commenced a comprehensive research programme in January 2011 seeking alternative phytosanitary treatments to methyl bromide. The programme spread its net wide looking at a range of approaches from management of logs in the forest; physical treatments including debarking and the use of electricity to heat logs; chemical treatments and methods of destroying methyl bromide. EDN is the only fumigant treatment that could conceivably be available in time for the 2020 deadline and which could maintain exports at their current levels.

1.5.2. Background

On the release of the EPA reassessment decision in 2010 methyl bromide users predicted that if alternative treatments, tools and technologies to manage emissions were not found, the introduction of the control preventing the discharge of methyl bromide to the atmosphere would potentially have a significant negative effect on New Zealand export earnings. Moreover; the loss of methyl bromide as a phytosanitary treatment, in the absence of suitable alternatives, would increase the biosecurity risks associated with a number of New Zealand’s imports.

At the time the EPA and others (including the Methyl bromide technical options committee, a

committee within the United Nations United Nations Environment Program) were confident that there was a significant range of alternative fumigants or technologies that could potentially replace methyl bromide. The EPA believed that this goal could be achieved within the 10 year stay of execution the decision allowed for the release of methyl bromide to the atmosphere.

Immediately following the release of the decision STIMBR engaged a research director to drive the research in a coordinated and cohesive approach. STIMBR considered the EPA’s reassessment document consequently undertaking a scan in early 2011 of international work that identified that while there were a large number of potential solutions, there were no economically viable solutions that could be guaranteed to safely and reliably replace methyl bromide or prevent its release to the atmosphere. The alternatives/tools that did exist varied widely. STIMBR realised that identifying those which warranted serious development would require significant funding. Funding for such a ‘stone turning’ programme within the tight time frames required, to deliver a solution by 2020 would be a


challenge since industry already had other significant research requirements and established commitments. Methyl bromide in the phytosanitary tool box

STIMBR believes that methyl bromide must be retained as a quarantine and phytosanitary treatment until such time as suitable proven alternatives, systems and technologies are available. To do this STIMBR works closely with the exporting community5, regulators and scientists to identify research needs and to ensure that the research meets the needs of all of the affected parties. Any results must be able to be integrated into the log export supply chain to maximise opportunities and reduce potential negative impacts. STIMBR’s position on methyl bromide

STIMBR is neutral with regard to the use of methyl bromide, and strives to approach its business without bias. Sound science is sought to inform decisions. STIMBR is active in looking for

alternatives, recapture technologies, and understanding where continued use of methyl bromide is legitimate and appropriate. STIMBR transparently pursues pragmatic cost efficient solutions that can be delivered to users in the shortest possible time. It does not persist in developing previously funded activity if a more promising opportunity becomes available. Research

STIMBR made application to MPI in late 2010 and was successful in gaining Primary Growth Partnership (PGP) funding for a programme totalling ca $2.4 million to undertake the initial ‘stone turning’ research. To meet STIMBR’s co-funding obligations the sector increased the voluntary levy on methyl bromide and phosphine by 40%. A consequent application for further research funding from a Ministry of Business Innovation and Employment (MBIE) contestable fund was successful.

The STIMBR-PGP research programme sought to identify tools and techniques which with further development would avert or minimise the potential negative effects the EPA controls might have on trade. The programme was designed to identify cost efficient solutions to:

 Enable the ongoing export of the rapidly increasing log volumes to New Zealand’s main log Markets i.e. China and India (the total log harvest expected is expected to continue to rise to 35 million m3 in 2025).

 Minimise the phytosanitary risks associated with the export of produce.

 Prevent methyl bromide emissions to the atmosphere.

 Provide importers and MPI with tools to protect New Zealand from quarantine pests on imported products.

5 Includes the entire supply chain including growers, exporters and service providers


The research programme was designed to be wide in its initial screening of possible solutions. The programme reviewed potential phytosanitary treatments identified by the EPA (and MBTOC6) and followed lines of enquiry to identify possible research that might provide solutions. In doing so the programme worked across the key areas outlined below.

1.5.3. Assessing ways to reduce methyl bromide emissions

1.5.3.a Methyl bromide treatment rates

Armstrong et al 2011 reviewed methyl bromide treatment rates concluding that; based on an analysis of the Cross (1992) data; and, through direct comparison of the schedules for China, Japan and Korea, they could conservatively recommend that the treatment rates for China could be reduced by 40%. The hypothesis has been proven. Work is currently underway to complete the efficacy data.

Initial conversations to change the treatments schedules for New Zealand logs took place in Beijing with Chinese government officials in May/June 2017.

1.5.3.b Interrupted fumigations

Fumigation schedules specify temperature ranges with increased methyl bromide concentration or fumigation time required for each decreasing temperature range. Where the temperature during fumigation falls below the minimum requirement (10oC), the fumigation is considered by MPI to be interrupted, or a failed fumigation. Research to model the effects of a specified range of degree variance and the durations of temperature variances, from the minimum temperature requirements was required. However; discussion with log exporters identified that this would have limited effect as fumigators managed fumigations to avoid such instances where possible. Consequently following discussion with MPI it was determined that the return on research investment did not warrant progressing.

1.5.3.c Recapture or destruction of methyl bromide

By October 2020 the EPA requires that no methyl bromide is released to the atmosphere. As a consequence STIMBR considers it is imperative that a cost efficient methyl bromide recapture or destruction process is available by that time to allow log exports to continue if alternative treatments are not available to provide pest free logs for export.

Early in its research programme the technology using carbon as a sink to remove methyl bromide from a fumigation space after treatment was explored. However, while methyl bromide capture onto carbon worked well the high volumes of carbon required (four to five times the quantity of methyl

6 Methyl Bromide Technical Options Committee


bromide) would result in disposal issues. The technology was dismissed because landfill operators in New Zealand do not want to deal with the potentially large volumes of methyl bromide saturated carbon. The cost to dispose of the waste in landfill would be high. Moreover; STIMBR was concerned that such disposal was simply burying the issue for later generations to deal with.

Several other technologies identified and explored are listed below:

 Incineration of the methyl bromide was considered.

 Twelve natural and artificial occurring substrates were screened for their scrubbing potential.

Photograph: Filed testing a natural occurring substance for methyl bromide recapture.

 One artificial substrate proved successful but is not economically viable for use with log fumigations.

 A desk top feasibility study has been completed for a technology which may allow the removal and re-pressurization of methyl bromide from the carbon substrate used in to capture methyl bromide.

 Genera is working on the development of a scrubbing system.

 STIMBR provided funding to have promising technologies independently validated by Plant and Food Research (PFR).

1.5.4. Alternative physical treatments

1.5.4.a Joule heating to kill insects in logs.


Joule heating is an innovative approach to the existing methods for the control of beetles and wood boring insects in logs. The concept has been proven and technologies developed by the University of Canterbury. Joule heating uses electricity to individually heat logs to a minimum temperature. The target temperature and duration (56°C for 30 minutes) of this treatment was taken from the

international standard for wood packaging materials (ISPM 15). This concept has been proven in the laboratory and a feasibility study (the first of two) prepared for the construction of a pilot plant which can treat multiple logs.

Note as with fumigation logs must be treated immediately before they are loaded on the ship to prevent re-infestation by insects. This means any plant will need to be able to handle logs quickly and efficiently.

1.5.4.b Debarking

Some consider that debarking (removing bark from logs prior to export) may be used to replace fumigation. Debarking is a risk reduction treatment approved by the Chinese government. A review, commissioned by STIMBR in 2015, indicated that the cost per log will be significantly higher than methyl bromide and phosphine fumigation.

1.5.5. Assessing non-fumigant pathway risk management strategies.

Non-chemical approaches to the control and reduction of insect pests have been investigated to:

 Identify sources and points of risk pressure to inform the development of strategies for managing risks on the supply chain pathway; and,

 Determining pest life cycles and the critical factors influencing these to potentially allow pest free periods to be identified.

Non fumigant pathway risk management strategies explored included:

1.5.5.a Insecticide coated nets

Two types of insecticide coated nets were investigated for protecting sawn timber from re-infestation by Arhopalus. This research was to be used to support discussions with MPI about their inclusion in post treatment protocols for sawn timber to prevent the need for re-fumigation that may result from delayed export. This work was not conclusive.

1.5.5.b A National Quarantine Pest Trapping Network

A trapping network has been established throughout New Zealand. The network was used to monitor forest insect activity at over 100 sites over a three year plus period. The network has provided vital


information about insect activity which has been used to underpin adjustments to the time allowed to loading from when the covers are removed following fumigation. As a result the post fumigation period where timber can loaded has been extended from 36 hours to 21 days during the period when Arhopalus is not flying (approximately April - October).

1.5.5.c Light trapping of insect pests

The use of light traps during the Arhopalus flight season was trialledat wood processing facilities and ports. While the study showed that there is potential to improve trap efficacy, the data did not support the use of the traps to trap Arhopalus ferus.

1.5.5.d Supply chain management

Initial research forest insect populations and their relationship to the environment was undertaken to establish whether it would be possible to apply the international concepts of areas pest freedom and low pest prevalence to allow logs to be exported without fumigation. Results to date indicate that the scope of application of this approach will be limited. Furthermore; a considerable amount of research will be required to provide data before the case can be considered in support of the concept.

1.5.6. Assessing alternative fumigants

1.5.6.a Literature review

The EPA reassessment of methyl bromide noted that a number of other fumigants may be suitable replacements for methyl bromide. Within two years of commencing the research programme it was apparent there is no silver bullet to replace methyl bromide. Methyl bromide is in fact ‘the silver bullet’.

Consequently, STIMBR commissioned a literature review of both potential fumigant and physical phytosanitary treatments in an attempt to identify other possible leads. Armstrong et al 2014

considered over 30 fumigants including 15 major fumigants (methyl bromide and phosphine were not included as they are in use) and 18 minor fumigants and concluding that; “other than ethanedinitrile and sulphuryl fluoride, no other fumigant had any possibility of being considered for further research as a methyl bromide alternative or New Zealand log exports.” Sulphuryl fluoride was considered by Armstrong to be a distant second to EDN as it is a green-house gas and has low efficacy against insect eggs unless the fumigation is prolonged.

1.5.6.b Phosphine

Phosphine a slow acting respiratory fumigant requiring 240h fumigations is currently used to treat logs carried in the hold of ships bound for China. China approved the use of phosphine on an

“experimental basis” in July 2001. Fumigations are required to maintain 200ppm Phosphine over 240


hours. STIMBR is currently undertaking a series of monitoring voyages to audit fumigations. An international search undertaken by PFR identified two suitable monitors for use in transit.

1.5.6.b Ethanedinitrile (EDN)

Based on this advice (Armstrong et al, 2014) STIMBR commissioned initial research on EDN focusing on its possible use as a fumigant for processed timber. A component of this research project which considered the use of EDN on recently harvested logs provided enough confidence for STIMBR to commission a techno-economic assessment of EDN as a potential phytosanitary treatment for Pinus radiata logs.

A techno-economic study confirmed that EDN may be a potential alternative to methyl bromide noting that there are no significant technical issues to prevent STIMBR from pursuing EDN as an alternative export log phytosanitary treatment. The report anticipated that EDN log fumigations are expected to be carried out similarly to current methyl bromide log fumigations.

The study confirmed that:

 investigation undertaken by PFR demonstrated that EDN is likely to be efficacious against New Zealand forest insects.

 research is needed to develop life stage mortality tables for target forest insect species, to provide data for MPI’s market access negotiations and to develop an efficacious fumigation schedule for industry use.

Following the release of an EDN Techno-economic report, Draslovka and STIMBR agreed to co-fund the development of efficacy data.

Confidence that robust data would be able to be produced was raised when scientists from PFR were successful in being able to establish laboratory colonies of burnt pine longhorn beetle, Arhopalus ferus (Mulsant), golden-haired bark beetle, Hylurgus ligniperda (F.) and black pine bark beetle, Hylastes ater (Paykull), for all of which efficacy is required. The ability to manage laboratory colonies of these species are regarded as world firsts.

Some 120,000 individuals of insect species are needed to conduct replicated tests to obtain the data necessary to identify relative tolerances to fumigants, and to develop and confirm effective fumigation schedules. Robust treatment efficacy datasets based on replicated experiments require healthy ‘fit’

insects of each life stage.

Photograph. Log raising insects (Arhopalus) to teat fumigants.


The use of laboratory-reared forest insects in fumigation research eliminates the dependence on the collection of insects by trapping flying adults or extracting other life stages from logs as these methods produce individuals of unknown age and health that are possibly injured during the extraction process resulting in highly variable test results with unacceptable mortalities in the treatment controls. Additionally the availability of laboratory reared insects overcomes the challenge of having the numbers needed for testing. Laboratory-reared insects provide test results with

statistically-viable control mortalities and reduced variability in treatment response. Control mortalities which previously ranged as high as 50% have been reduced to about 10%.


Appendix 4 Life cycle of EDN

4.1 Manufacturing

EDN will be manufactured overseas and will then be imported as a liquefied gas under pressure into New Zealand as sea freight only. Currently the only source of EDN is Lučební Závody Draslovka (LZD) in Czech Republic.

4.1.1 Importation

The exportation of EDN from Czech Republic will be strictly controlled by LZD and all importing distributors will undergo a Product Stewardship Training Program to ensure compliance and understanding of the chemical.

EDN will be manufactured in Czech Republic and then imported into New Zealand through sea freight. EDN will be imported in the form of a liquefied gas under pressure (vapour pressure 5.16 bar at 21.10C) in cylinders constructed of Chromium Molybdenum Steel 34CrMo4 and fitted with a tied diaphragm stainless steel valve compliant with AS 2473. The cylinder’s product capacity is 50 kg. The AS 2473 compliant valves are high integrity (tied diaphragm), guarded, and the outlets fitted with a gas tight seal, capped and fitted with a stainless steel chain. The product will not be repacked into other cylinders once in New Zealand. The product will be dispensed from the original containers through specialised fumigation application equipment when it is used.

4.1.2 Transport Shipping:

The International Shipping Code for EDN is UN No 1026 CYANOGEN, Class 2.3, Subsidiary Risk 2.1, HAZCHEM 2PE. The imported shipments would be transported from the port by road to a secure storage area. Cylinders will be transported using a fixed cage/pallet to securely hold the cylinders.


Transport from the port to the storage facility and then to customers within NZ would be undertaken by road transport operators approved to handle products classified as hazardous (flammable toxic gases).

Cylinders would not be transported inside a passenger compartment in a vehicle.

Although it is unlikely packaging would rupture or leak there is potential risk of damage to the cylinder in the event of a traffic accident. Drivers would carry protective equipment (respiratory protective equipment) and the required product documentation. Under such circumstances site management would be assisted by the emergency services (Police, Fire) to contain the leak and oversee the recovery and clean up.

While the majority of domestic transport will occur using road transport it is possible that rail or sea transport will be used in the future. In this situation such transport will use suitably qualified operators and comply with the transport regulations for UN1026.

4.2 Packaging

Pack sizes: EDN is filled into specially designed 73 litre high pressure gas cylinders for the highest level of safety. The specification of the cylinders is as per the details below and are compliant with ISO9809-1. The cylinders are filled with liquefied gas based on the fill ratio of the product as determined by the IMDG and DOT / ADR regulations:

 design pressure 73 bar

 test pressure 110 bar

 range of working temperatures t = -28 to 100 °C

 experimentally determined pressure in case of damage / rupture of the cylinder: 176 bar

 minimum thickness of the shell wall: 3.7 mm

 minimum thickness of the bottom wall: 7.4 mm

 manufactured from plate

 cylinder material: Chromium Molybdenum Steel 34CrMo4

 approved according to TPED 2010/35/EU

 produced according to ISO 9809-1 standards

 dual port valve Rotarex D195 (DIN 477 Nr 1-5, DIN 477 Nr 1-10), stainless steel AISI 316L (1.4435).


This packaging is compatible with the Plant Protection Product. These cylinders comply with all international regulations for the transport and storage of EDN (UN1026) and in most cases exceed them. The pressure cylinder has been custom designed for EDN whereby it is shorter and wider giving greater stability in the field, and greater protection for the cylinder valve. EDN will not be repacked into other receptacles once in New Zealand. The gas will be dispensed from the original containers into the treatment structure.

UN-DOT/ TPED compliant Cylinder Manufacturer Faber Industries SpA Design Std ISO9809-1

Man. Cylinder Dwg COMM 1S01-352-110-607 PTP-119Rev.1

Description Seamless cylinder

Material 34CrMo4

Inlet thread 25E

Neck ring W80

Volume 73 litre

Max capacity 50 kg Test pressure 110 bar


Cylinders are fitted with a valve compliant with AS 2473. The valves are a high integrity (tied diaphragm), guarded, and the outlets fitted with a gas tight seal, capped and fitted with a stainless steel chain.

UN-DOT/ TPED Cylinder valves

Supplier Rotarex

Part Number: D19510032

Description High pressure 316 Stainless Steel dual port

packed cylinder valve with PCTFE seat

Inlet thread 25E

Outlet size (liquid) CGA660 or DIN no. 5

Outlet size (vapour) CGA580 or DIN no.10

Orifice size 6.0 mm

Material 316 l stainless steel

The gas-tightness of the packaging will be tested using an EDN specific detector (MSA ULTIMA XA Portable gas detector or similar) at set tollgates in the lifecycle. The gas detection procedure is conducted:

(1) after filling of the pressure receptacle (by overseas manufacturer), (2) before loading onto transport (by overseas supplier),

(3) at the time the shipping container is opened in New Zealand; and (4) if there is any suspicion that a leak has occurred.

Note as described in section 7 EDN causes lacrimation in mammals (irritation of the eyes resulting in tears) at levels greater than 16ppm. This physical characteristic will ensure that levels of EDN do not accumulate unnoticed to levels that would be toxic to humans.

4.2.1 Identification

Each package will carry a product label identifying the substance, active ingredient, priority identifiers (hazard classifications), warning and first aid information, manufacturer and contact details.


In addition a Safety Data Sheet will be made available to users. The Safety Data Sheets for both EDN (the product) and Ethanedinitrile (the active ingredient) are presented at the end of this appendix

4.3 Storage

Storage of any substance or compound is governed by local regulations according to the UN code, and the classification of the substance including subsidiary risks. As EDN is UN1026 and classified as Category 2.3 subsidiary risk 2.1, all storage will be according to the New Zealand regulatory


The EDN will be stored at a single distribution point, prior to dispatch elsewhere in New Zealand when required for use as a fumigant. The storage of significant quantities of gas cylinders will comply with AS 4332 and will not be stored near sources of ignition, oxygen and fluorine, water or steam, and acid or acid fumes.

Cylinders will be stored upright with measures in place to prevent falling, at a temperature less than 50° Celsius, in a dry and well-ventilated area constructed of non-combustible material with a firm level floor, and away from areas of heavy traffic.

The following storage conditions will be provided as guidance to the distributor:

Store cylinder vertically and secure them 1. Cylinders must be stored vertically

2. Vertically stored cylinders must always be secured or under your direct control. When standing or rotating and walking cylinders about their vertical axis, be aware of the hazards of uneven, slopping, slippery and unstable surfaces as well as loose surfaces. Secure cylinders to prevent falling as unsecured cylinders are a potential hazard to users and passers –by should they inadvertently bump them.

3. Cylinders must never be stacked horizontally in storage or in use.

4. Whenever possible use a cylinder trolley for transporting cylinders.

5. Stored at a temperature at less than 45 deg. C, in a dry and well-ventilated area constructed of non- combustible material with a firm level floor, away from areas of heavy traffic


Plan for emergencies

A. Ensure free and clear access to cylinder storage areas

All persons with a responsibility for storage or use of gas cylinders must be familiar with the

emergency procedures. Store layouts and emergency procedures need to be structured accordingly and to cater for such possible incidents.

B. Cylinders will be stored in dedicated cylinder-only areas

The distributor will not store any other products in a cylinder store, particularly oil, paint or corrosive liquids. The following advice will be provided to the distributor regarding storage and handling.

Rotate your stock

The distributor’s storage arrangements will ensure adequate turnaround of stock. Do not store empty cylinders longer than necessary; return them to the supplier as soon as possible. This applies particularly to cylinders which normally contain flammable or toxic gases.

Wear the correct Personal Protective equipment (PPE)

All persons handling gas cylinders must wear the correct PPE. The correct grade of gloves (where appropriate) may also be required. In many places, safety signs will designate where and what PPE is to be worn. Loose clothing and hair is an entanglement hazard, and steps must be taken to avoid this.

Storage and segregation of cylinders

Within the storage area, oxidising gases such as oxygen must be stored at least 3 metres away from fuel gas cylinders. The use of an appropriately fire rated wall may provide the required separation.

Full cylinders must be stored separately from the empty cylinders, and cylinders of different gases whether full or empty must be segregated from each other.

Storage of toxic gases

Toxic gases must be stored separately from all other gases and the detailed instructions on the individual Material Safety Data Sheets (MSDS) must be followed. It is essential that when handling or storing cylinders containing toxic gases that the cylinder valve outlet threaded plug or cap is always replaced in the valve outlet when the cylinder is not in use. The cylinder valve outlet threaded plug or cap acts as a secondary valve to the valve itself and provides increased safety against leakage. For full details of local storage requirements consult the State Dangerous Goods regulations, and AS 4332( As per Australian regulations an equivalent New Zealand regulation will be applied once


registered in New Zealand) . In the case of an emergency, the local emergency services should be contacted

Storing your EDN cylinders safely

 Stores must clearly show signage in accordance with the Hazardous Substances regulations.

This includes Class Diamonds; HAZCHEM; no smoking and naked flame warning signs.

 All cylinders will be considered and treated as full, regardless of their content. This means:

 Keep cylinders away from artificial heat sources (e.g. flames or heaters).

 Do not store cylinders near combustible materials or flammable liquids.

 Keep flammable gases away from sources of ignition.

 Keep cylinders in well drained areas, out of water pools or ponds.

 The storage area will be kept well ventilated and clean at all times.

 Do not store in confined spaces.

 Avoid below-ground storage where possible. Where impractical, consider enclosed space risks.

 There will be good access to the storage area for delivery vehicles. The ground surface will be reasonably level and firm (preferably concrete).

 The storage area will be designed to prevent unauthorised entry, to protect untrained people from hazards and to guard cylinders from theft.

 Different types of gases must be stored separately, in accordance with Hazardous Substances Legislation. Also refer to AS 4332 (The Storage and Handling of Gases in Cylinders).

 Liquefied flammable cylinders must be stored upright, to keep the safety devices in the vapour phase, on a firm, level floor (ideally concrete). This is also preferable for most other gas cylinders.

 Store cylinders away from heavy traffic and emergency exits.

 Rotate stock of full cylinders, and use cylinders on a ‘first in, first out’ basis.

 Never repaint or obscure a cylinder label, even if the cylinder is rusty, dirty or damaged. This can result in unsafe situations.

 Never apply any unauthorised labels or markings to cylinders, unless advised by Draslovka to identify faulty cylinders.

 Regularly check for leaks and faults, only with approved leak detection fluid.

 Keep ammonia-based leak detection solutions, oil and grease away from cylinders and valves.

 Never use force when opening or closing valves.

4.3.1 Monitor


An EDN specific monitoring device (MSA Ultima XA Portable gas monitor) will be used to monitor the concentration of EDN during storage (as stated in section 4.1.3). Draslovka uses these same monitors in their factory in the Czech Republic and around the factory fence to continuously monitor for toxic substances around their factory. The monitors are part of an integrated online system which Draslovka has made visible to the City Council and its departments.

The MSA Ultima XA Portable Gas Monitor is an electrochemical gas detector calibrated for EDN by one of the largest global manufacturers of gas detection equipment. The Ultima® X Series Gas Monitors Instruction Manual and data sheet have been provided with the application. The units are widely used in the Czech Republic at the manufacturing facility. Draslovka worked with MSA to develop this unit. The price will be approximately $3000 per unit.

Element Detail

Gas types Combustibles , Oxygen, Toxics Measuring principles Electrochemical

Temperature range -40 to m+60 deg Celsius

Drift <5% per annum

Response time <12 secs (typically 6 secs)

Humidity 15-95 %

Sensor life 2 years

Physical parameters Polycarbonate .68kg 103 x 76 x239 mm

Approval rating CE low voltage/ EMC/ ATEX, EN 60079-1 112G Ex d 11C T4 1P 66

The MSA Ultima XA gas detector is a handheld portable gas detection unit capable of detecting Ethanedinitrile between 1ppm and 50ppm concentration.

The detection limit of the MSA Ultima XA for Ethanedinitrile is 1 – 50ppm. The lowest detection limit is 1ppm and the gradation of readings is 1ppm (i.e. 1ppm, 2ppm, 3ppm…, and 50ppm).


The audible and visual alarm (flashing light) will activate at 5ppm concentration – this will continue until the concentration has dropped below 5ppm.

The response time for the MSA Ultima XA, like any electrochemical sensor, is approximately 6 seconds. Faster response times decrease accuracy of the system.

The MSA Ultima XA incorporates an electrochemical sensor with a large surface area, allowing for increased accuracy at low concentrations. The electrochemical sensor used in the unit is a Hydrogen Cyanide sensor which has been calibrated and cross-sensitised to Ethanedinitrile. Standard handheld units typically used for other gases generally do not have a large enough surface area of the sensor to specifically detect ethanedinitrile and hence there will create “noise” or unwarranted readings on the unit. The MSA Ultima XA (although slightly bigger than a standard handheld unit ) uses the same size sensor as that found in static detection and monitoring systems, which means that it can eliminate this noise and give higher accuracy.

As the system is cross-sensitive with hydrogen cyanide it can also have some interference with hydrogen cyanide concentration – however the levels will be extrapolated by the system and

‘magnified’ therefore the detector is showing an indicative range of both substances.

If the electrochemical sensor gets saturated, the system will remain in the alarm state – even if turned off and turned back on again. In this situation the only option is to exchange the unit for another one.

The MSA Ultima XA weighs less than 1 kilogram and can be carried easily, or worn over the shoulder with a strap. It can also be placed on the ground or allocated locations as a static detector.

It is IP67 rated meaning it can be used outdoors in dust and wet conditions.

The MSA Ultima XA is an easy unit to use as there is only an ON/OFF switch – like any gas detector it should only be turned on when in a fresh air environment. The unit has a 30 second warm-up time, after which it is ready to use. Calibration will be checked six monthly in either Australia or New Zealand through MSA, or through Draslovka Services as an appointed and approved agent.

Draslovka recommend charging the battery of the unit at least once every 48 hours depending on usage, and it can be charged in-situ during operation. Charging the unit will take approximately 2 hours to charge 80%.

Training will be provided by Draslovka asthe Product Stewardship Program they will provide to those involved in applying EDN as a fumigator.MSA can also provide certified training for gas detection systems on request. The unit is also explained (as a part of a family of detectors) in the following YouTube clip: https://www.youtube.com/watch?v=NOdvZ1ou_78


Additional MSA EDN Detector Background Information to inform the following EPA queries:

Established in 1914, MSA Safety Incorporated, USA is the global leader in the development,

manufacture and supply of safety products that protect people and facility infrastructures. Many MSA products integrate a combination of electronics, mechanical systems and advanced materials to protect users against hazardous or life threatening situations. The company's comprehensive product line is used by workers around the world in a broad range of markets, including the oil, gas and petrochemical industry, the fire service, the construction industry, mining and the military. MSA’s core products include self-contained breathing apparatus, fixed gas and flame detection systems, portable gas detection instruments, industrial head protection products, fire and rescue helmets, and fall protection devices. With 2016 revenues of $1.15 billion, MSA employs approximately 4,300 people worldwide. The company is headquartered north of Pittsburgh in Cranberry Township, Pa., and has manufacturing operations in the United States, Europe, Asia and Latin America.

As the key supplier of safety equipment to Draslovka, MSA has developed the EDN safety detector in collaboration with the Draslovka R&D team. Having extensive experience in the development of HCN detection systems, MSA have developed the EDN detector based on a slightly modified MSA HCN sensor‐ the producer of this sensor is MSA (US) directly.

The general principle of operation is that of any Electro Chemical Detector whereby an

electrochemical reaction to generate a current proportional to the gas concentration is realised. When the positive ions flow to the cathode and the negative ions flow to the anode, a current proportional to the gas concentration is generated. In all Electro Chemical Detection, the sensor chamber contains a gel or electrolyte and two active electrodes – the measuring (sensing / working) electrode (anode) and the counter electrode (cathode). A third electrode (reference) is used to build up a constant voltage between the anode and the cathode. The gas sample enters the casing through a non‐reactive membrane; oxidation occurs at the anode and reduction takes place at the cathode.

Response to EPA queries

Why is leak detection based on a threshold of 50ppm? Why 50ppm and not another value?

The MSA Ultima XA gas detector is designed as a safety detector for personnel. Therefore the unit has been calibrated at the low end of EDN concentrations, i.e. 1 to 50ppm. It is impossible to have a detector which can measure a full range of concentrations from low range to high range without compromising the accuracy of the system, and without damaging the sensor. When the detector detects a concentration outside of its range it will read ‘ERROR’ with both an audible and visual alarm. Therefore, this detector should be used to determine the source of a leak, not the extent of a leak i.e. it will be possible to know that a leak is occurring and that rectification should take place, but


it will not give you a quantitative measurement of the leak.

However, this is why a fumigation zone is established around a log stack or fumigated volume. It is always expected that leaks can occur during both application and treatment that is commercial reality.

These leaks are typically short lived events which can be rectified quickly. Once the detector is in

‘ERROR’ the unit should be moved away upwind from the suspected leak area, and the suspected leak should be rectified. If the unit remains in ‘ERROR’ even after removing to fresh air, the unit should be changed over as the sensor may be damaged and will need recalibration.

Are there interferences for the EDN sensor that users must be aware of?

One of the chief limitations of electrochemical sensors is the effect of interfering gases (the ones that you are not trying to measure with the sensor) on the sensor readings. Substance specific sensors are ideally supposed to respond only to the gases they are supposed to measure. The higher the specificity of the sensor, the less likely the sensor will be affected by other gases. The composition of the electrodes and type of electrolyte, as well as the use of selective filters for the removal of

interfering gases are all ways to increase the specificity of the sensor. As the detection of HCN is very specific in terms of EC sensor technology – and is very sensitive to small changes in concentration ‐ the major cross‐interference to EDN detection is HCN itself. However; this

proportional change is negligible as HCN is not produced as a result of EDN fumigation and hence is only reliant on the concentration of HCN as an impurity with the EDN concentration. In saying that, this is actually seen as a positive outcome for the EDN detection as an increase in HCN concentration will yield an increased EDN reading. This is in contrary to some other gas specific EC detectors whereby other substances can “mask” the target gas reading and hence create an unsafe environment by giving false positives – in the case of EDN detection, an increase in HCN concentration will yield an increase in EDN readout and hence the user can react accordingly. In saying that, it is impossible that EDN can exist without a HCN component being present, and the calibration of the detector has been based on the minimum impurity of HCN in EDN to give the highest sensitivity in changing conditions.

What is the error for the EDN sensor?

The EDN sensor has been tested by MSA and has shown the following repeatability error ranges: ±4

% Full Scale or 2 ppm. The monitor rounds up to the higher number.

The gas meter instruction manual indicates direct sunlight can cause problems for the sensor


– how would this issue be managed?

Electrochemical sensors are quite sensitive to temperature and, therefore, the sensors are typically internal temperature compensated. However, it is better to keep the sample temperature as stable as possible. In general, when the temperature is above 25°C, the sensor will potentially read higher;

when it is below 25°C, it will potentially read lower. The temperature effect is typically 0.5% to 1.0%

per degree centigrade. For example, a reading of 10ppm at 25°C would be equivalent to 10.5ppm at 30°C, or 9.5ppm at 20°C – again, internal components of the unit assist with this temperature equalisation to minimise the impact of temperature fluctuation.

On the MSA EDN detector, the unit will temperature compensate at lower temperatures in order to maintain a stable internal temperature by keeping the sensor at a constant temperature, hence at lower temperatures there are no issues with concentration variation – at higher temperatures, potentially caused by direct exposure to sunlight, the sensor could climb above 25°C however as these detectors are designed for outdoor use, the sensor is insulated and hence impact to readings by increasing (and decreasing) temperature are limited.

Will there be issues with the substances that can cause loss of sensitivity of the gas meter e.g.

silicones? Will the tarp or repairs to the tarps be source of any substances that can affect the sensor?

Silicone interference can cause loss of sensitivity on any detector, the build‐up of silicones on the electrodes on sensing mechanisms are such that it can degrade the linearity of the sensor and provide false positives – it is recommended that sensors are calibrated often, and bump tested often – in order to ensure they are in good working order. The levels of silicones in the immediate

environment due to the tarp or tarp repairs is an unquantified value, which is completely variable, based the extent of the issue. However, given that tarps must be in good condition before being used, any minor tarp repairs are relatively small in proportion to the size of the overall tarp, and hence the impact of silicone exposure is insignificant.

The sensor requires 1 hour settling in the conditions to be used in before calibration can occur – is this period going to be allowed for?

Every detector, regardless of type of detection method or type of gas being detected, requires an equalisation period in which the electronics and the system is allowed to warm up in order to give accurate detection. This is very important, especially in colder conditions, where a temperature fluctuation can cause false positive read outs. Therefore, it is important that the stabilisation of the sensor is allowed to occur before exposing the sensor to the potentially contaminated environment.


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5.15 At the time of Mr C’s requests for access to the NDIS, the NDIA did not have any policy or guideline dealing specifically with incarcerated individuals and access to the NDIS.

• An analysis of the broader context of the Business Plan identifies that it was anticipated to progress with the construction of the Public Works not only to put in place

 Mastitis, though more of a challenge on the organic farm, is manageable and has remained below tolerance levels; other animal health issues have not been a problem under organic