Methyl Bromide Draft Code of Practice for Port Marlborough

Proposed by The Guardians of the Sounds

Site Specific Code of Practice for Use of Methyl Bromide in Shakespeare Bay

1. That no release of fumigant gas shall be released to atmosphere when there is evidence of a cold inversion layer present in the form of cloud cover over Port Shakespeare and Picton that would allow for toxic gas to rise, reach the ceiling and be swept by any North west winds over the Picton community.
2. That wind socks and electronic wind monitors to tell of wind strength and direction, to be erected around the log yard that needs to be checked before fumigations are commenced. And during fumigations if wind direction should change.
3. Fumigant gas not to be released in very still conditions to protect health and safety of fumigators, port workers and employees of businesses adjacent to port boundary. In still conditions the gasses may linger or go to ground.
4. Fumigation not to occur if there are North West Winds that could blow a plume of gas over town.
5. Temperature needs to factor in conditions of release also, not to be released under a set temperature. Should it be allowed to be released on a rainy day that is cool with no sun to help flash it off with still conditions ?
6. No fumigation when there are ferries or cruise ships are berthing or tied at a berth
7. That all fumigation workers must wear protective clothing gas masks and gloves approved for use for handling or exposure to toxic fumigants. Gas masks/ filters to be used only once.
8. All port workers to vacate port yard while fumigations are being undertaken and not to return until monitoring assures the supervisor that there is zero risk of exposure to said fumigant.
9. Fumigations to be monitored by a company that is totally independent of Genera or Port Marlb. NMHD to be notified of any release of fumigant to atmosphere.
   The decision made on whether climatic conditions and wind and weather is suitable needs to be expert in this field, but independent !
10. Not sure what your monitoring regime is, obviously you monitor around the yard and around boundary, but what about the lookout above the port, (outside boundary ) because there is an obvious risk that as the gas rises the wind could blow a plume onto hills above port and threaten public !
    What about monitoring down on the big wharf, terminal, fore shore, Nelson Square.
    It needs to be more than just the yard boundary fence.
11. Owners of houses in residential areas in Port shakespear and on hills in vicinity of port to be notified, along with boat owners on vessels in shakespear bay. To be notified of fumigations
12. Query !!!!! concerned about risk to workers in businesses along West Shore, would it be better to fumigate outside of work hrs ?
13. I suspect that the heat of the sun helps flash the gas off to atmosphere ideal time frame would probably be in early evening after 6.00 pm.
14. Would it be possible for Port Marlb to notify Picton Community of fumigations through Radio Marlborough and Marlb Radio VHF & Port company operators on Ch19.
15. That vehicle access should be denied to public around the west shore while fumigations are being carried out.
16. No Fumigants should be allowed to be stored on Port Marlborough premises unless it is in a specially designed building that complies with HSNO regulations that Port Marlb have a resource consent for.
17. Water quality. Methyl Bromide is eco toxic, so when wharves/ships holds are washed down the discharge must be filtered to prevent toxins entering marine environment. Fresh water streams in shakespear bay must be monitored after fumigations so to shell fish beds.
18. Policy 1.1 of the Marlborough Sounds resource management plan 17.2.3 need to be adhered to.
19. Port supervisors to work with MDC staff to set up an up to date Hazardous screening programme. Keeping good data/records of fumigations eg amount of fumigant used per tonnage, when, where, how often.