Environment Bay of Plenty Proposed Regional Policy Statement

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Submission to: Environment Bay of Plenty
Submission Author: Steffan Browning, Soil & Health Association
Tuesday, February 8, 2011

The Soil & Health Association of New Zealand Inc (Soil & Health) is 70 years old, and is the largest membership organisation supporting organic food and farming in New Zealand, and as such advocates for healthy and safe food and environmental sustainability.

Soil & Health has a membership of about 3000 members and a readership of its retail magazine publication Organic NZ of many thousands.

The Soil & Health Association has many members in EBOP’s rohe which share concern over poor environmental outcomes of many land and water use activities. Genetic engineering (GE) within the region has no real controls besides those of the Environmental Risk Management Authority, and that agency has glossed over the risks.  An holistic approach to land and water use is required if land is to retain its productive capacity, and fresh water and marine habitats are to be restored. Air quality objectives must take special account of methyl bromide use and other pesticide use in the region.

Soil & Health in its submission will refer to a few points but wishes to speak at the EBOP-PRPS hearings.

 

Part One 1.5.1 NPS and NES must always be seen as the lowest common denominator and EBOP must be bold and not allow the national statements and standards to be seen at an aspirational level. They should be the base or beginning of direction. Eg the NES-Plantation Forestry under development is an enabling document designed to smooth the way for forestry development, but would it stop the high sedimentation levels created by existing forestry practices in the region. NO!

This NES is looking to be a rather enabling approach to future plantation forestry especially in light of the ETS, but the environment and forestry needs to be looked at beyond issues of carbon and forestry interests. There a many alternatives to the current pine/conifer/eucalypt plantation models that are far more sustainable, and even in the current dominant plantation models, much more care could be taken through the NES to ensure significant improvements on current practice. There are very serious issues of sedimentation from current forestry roading and  harvesting practices, and a number of marine and fresh water effects are covered in the Ministry of Fisheries report in the link here;     http://fs.fish.govt.nz/Page.aspx?pk=113&dk=22003

EBOP should look to the National documents not as a form of consistency, but as the starting point for objectives that will lift the regions practices into world leader class.

 

1.7 Precautionary Approach

Soil & Health (S&H) commends EBOP for its precautionary approach statement, especially its extension into issues surrounding genetic engineering (GE). S&H has monitored over the last few years most of NZ’s GE field trials and discovered and reported on significant compliance breaches. EBOP has at least two sites of active GE work. Scion’s Rotorua facility and ArborGen’s site near Whakatane. All GE sites need to be logged as contaminated sites, as touted research, eg  on horizontal gene transfer and invertebrates at the field trial sites, has been woefully inadequate and has yet to be published credibly.

Experimenters and regulators have been duplicitous in their portrayal of safety of GE projects, and Scion’s most recent GE approval for thousands of GE pines has large scope for human error that will mean leakage of GE pollen. Developing a Plan that has strong precaution around GE, nanotechnology and other yet to be actualised technologies, or activities is critical. How little was known about GE at the last RPS formation and still is, except for the contamination events worldwide, loss of biodiversity, the stock poisonings, and now in animal feeding studies, the effects on endocrine – reproductive functions. Nanotechnology has also been developed significantly since the last RPS & Plan formation, and emerging information shows some real and possible hazards, such as some nano-materials(nanotechnology) having the same effects as asbestos. The RPS must anticipate emerging technologies such as bioengineering that require the most extreme precaution.

Liability and compensation is poorly provided for by government and until meaningful liability provisions are in place, no GE trials, plantings or animals should be permitted. Co-existence between GE primary production and non-GE production is somehow anticipated by pro-GE groups, however internationally that has proved impossible unless some degree of contamination is accepted by the non-GE producers. This is not acceptable and NZ has a zero tolerance on unintended contamination currently and organic certification systems and many export markets share that position, especially at a consumer level. EBOP must allow for the clean green 100% Pure New Zealand branding to remain as an achievable vision, with GE contamination unacceptable on non-GE producers and the environment.

Nanotechnology needs to be considered in a whole of life way to anticipate some risks, and again liability or the lack of systems to properly assess or apportion liability must be considered.

S&H would like to present its experience and knowledge to appropriate EBOP councillors and staff on the GE activity in the BOP region and the associated risks.

 

1.8 Integrating management of natural and physical resources

Soil & Health supports the whole of catchment approach. However, this needs stronger direction deeper in the RPS to ensure the approach is always used, from how soil is managed at the finest levels of biological activity possible, through to land disturbance and waterways management and extraction, and the human overlay. Soils need development, protection, and restoration to optimum biological states to provide the climate resilience and life supporting capacity that also reduces the need for toxic interventions. Best practice soil management provides significant buffers against flooding damage and conversely the effects of drought.

2.10.2 Soil health and productivity, goes someway to understanding some of what is involved but avoids discussion of the increased use of synthetic fertilizers and herbicides that degrade biological activity. Active promotion of Organic, Biodynamic and Biological farming systems that have been shown to have more climate resilience and incur significantly less externalities needs to be repeated through the RPS’s structure.

A search found the word organic just once and that was “municipal organic waste.” The PRPS appears to be working in another past era in this respect. Organic production methods are recognised by FAO and other key international organisations to be the most resilient for the environment and food supply, even in key areas of concern such as Africa. That recognition need to be part of the RPS as climate change and peak oil threaten negative effects within the life of the RPS and subsequent plans.

Policy WL 9B: Managing rural development and protecting versatile land

This policy appears to totally fail recognition of the difference between different farming management systems, and in respect of Rotorua Lakes and nutrient inputs, suggests that Rural Subdivision may be preferable to pastoral farming. Soil & Health recognises that some small block development can in fact be preferable productively, both economically and environmentally, to larger pastoral units, however some organic and biological farming units have nutrient discharge levels that will be well within EBOP’s targets. A case of maybe not throwing the baby out with the bath water.

EBOP could look at some of the outcomes from the ARGOS project where comparatives of energy use, economics, nutrient discharge and social outcomes between ‘conventional’ and organic and biodynamic primary production are explored.

An example of how the RPS requires more strength is in

3.2.1 Directive methods

“Method 27: Provide information about sustainable land management practices

Prepare and disseminate information about sustainable land management practices, including:…”

The educative approach is not strong or urgent enough. Wording should follow that LTA’s will ensure the outcomes recognised by EBOP as desirable.

Soil & Health supports Method 35: “Take a whole of catchment approach to the management of natural and physical resources within the coastal environment, Adopt a holistic catchment-based approach that recognises the inter-relationships among all elements of the environment …”

As part of a whole of catchment approach EBOP should include pesticide reduction as a desirable outcome, with objectives, policies and directions that ensure recognition of the human and environmental health externalities and the need for either a polluter pays approach where possible or development of a meaningful strategy to reduce pesticide use. ERMA does not, and the new EPA is unlikely to, set adequate controls for human and environmental safety but is strongly affected by the balancing it does with political direction and the market economy.

Not only toxins, as in pesticides including herbicides used directly in primary production, but release to air of fumigants such as methyl bromide, as is used extensively in the BOP must be actively and quickly reduced or recaptured. ERMA has set a decade before recapture of methyl bromide is mandatory, however very clearly allowed for stricter controls to be set by LTAs. The EBOP-PRPS must actively recognise that and set the parameters for definitive action for reduction, reuse and recovery of toxins, especially reduction.

In regards methyl bromide;

New Zealand has an obligation under the Montreal Protocol to: refrain from use of methyl bromide and to use non-ozone-depleting technologies wherever possible. Where methyl bromide is used, Parties are urged to minimise emissions and use of methyl bromide through containment and recovery and recycling methodologies to the extent possible;

And from the ERMA decision following reassessment of methyl bromide

The Committee (ERMA) notes the concerns of Nelson City Council which suggested that the minimum buffer zones proposed in the reassessment application may conflict with local requirements under the RMA. It is very important to emphasise that these minimum buffer zones do not preclude regional councils, unitary authorities or port authorities from setting more stringent controls (e.g. larger buffer zones) if they deem them necessary because of local conditions. The Committee notes that section 142(3) of the Act specifically envisages situations where a local authority may choose to impose more stringent requirements on the use of a hazardous substance than that required under the Act.

Port Tauranga and the related LTAs should be installing recapture of methyl bromide immediately due to worker and community exposure health risks and the effects on the global community. The PRPS should set the scene for this and reduction of other pesticides.

Soil & Health appreciates the opportunity to submit to the development of the Regional Policy Statement and wishes to be heard to present further.

Section 274 interested party in support of Bay of Plenty Regional Council along with GE Free Northland, Zelka Grammar and Anna Murphy, GE Free NZ, Claire Bleakley, John Sanderson, Karen Summerhays

NZ Forest Research Institute Limited (Scion) v Bay of Plenty Regional Council

Appeals against decisions on the Bay of Plenty Regional Policy Statement  (excluding Coastal Environments & Water Quality & Land-use sections)

 

Relief sought by NZ Forest Research Institute Limited (Scion) via Appeal

Deletion of the following statement from section 1.7 of the proposed Regional Policy statement

a) The existence of genetically modified organisms in the environment has generated community concern.  Of particular concern is the placement and location of trial and containment facilities.  The Bay of Plenty Council promotes a precautionary approach to the release, control and use of genetically modified organisms within the region.  The precautionary approach is a necessary response to unresolved issues of potential liability, environmental risks, economic costs and cultural and social effects.  The Hazardous Substances and New Organisms act 1996 contains specific legislation for managing genetically modified organisms.  These legislative functions are carried out by the Environmental Protection Authority. Current legislation may be inadequate to manage potential adverse effects from the use of genetically modified organisms in the region.

 

b) Such further orders, relief, consequential amendments or other amendments as are considered appropriate and necessary to address the concerns set out above and;

c) Costs of and incidental to this appeal.

Soil & Health stands by it’s original submission 146-2, accepted by BOP Regional Council, requiring a precautionary approach with regards to genetic engineering.

Submissions Against GE Brassicas

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Submission to: Environmental Risk Management Authority
Friday, December 8, 2006

Dec 8, 2006

Dear Members

Re: GE Brassica Field Trial

Crop & Food Research has applied to ERMA (Environmental Risk Management Authority) to spend taxpayers’ money on a 10-year field trial of genetically engineered brassicas: specifically cabbage, broccoli, cauliflower and forage kale. Plants would have genes spliced from bacteria and viruses, including ‘Bt’ (Bacillus thuringiensis), in order to kill cabbage white butterfly and diamond backed moth.

Soil and Health is supporting Organic Aotearoa New Zealand’s substantive submission opposing the trial, and putting in our own submission. We encourage members to write submissions to ERMA opposing the field trial.

SUBMISSIONS ARE DUE BY TUES 12 DECEMBER 2006

You should quote Crop and Food Research’s application GMF06001. Submit in writing to ERMA NZ, PO Box 131, Wellington, 6140, by fax to ERMA NZ, 04 914 0433, or online at www.ermanz.govt.nz. Include name, contact details, signature, the date, reasons for your submission, and the decision you seek.

As follows are some points you may wish to use, and websites for further information.
www.gefree.org.nz
www.giantexperiment.co.nz
www.GEinfo.org.nz
www.i-sis.org.uk
www.gmwatch.org

Thanks for considering this! We hope our submissions will lead to a rejection of the trial and protection of organic and GE-free crops and food. Let’s work together towards an Organic 2020.

Mike Palmers, Co-Chair

 

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I/We strongly urge ERMA to decline this application for the following reasons:

Environmental Risks and Lack of Long-term Sustainability

* There is no point approving this field trial for genetically engineered brassicas unless they are to eventually be grown commercially. However, if grown commercially, these GE brassicas will cause GE contamination of other brassica crops and honey, and destroy New Zealand’s clean, green image.
* Target insect pests will become resistant to crops genetically engineered with Bacillus thuringiensis (Bt), as has happened overseas.
* Insect resistance could result in more use of toxic sprays to control pests.
* Brassica pollen is readilty spread by insects, and GE brassicas would cross easily with dozens of wild and cultivated cousins.
* Any short-lived benefits before white cabbage butterfly and diamond backed moth are resistant comes at the cost of irreversible GE contamination.

Removal of Farmer Choice

* Insect resistance to Bt-engineered plants will result in the loss of a safe and important tool (natural Bt) for organic and conventional farmers.
* Contamination will remove farmer choice to grow GE-free food.
* If commercially grown, GE brassicas will contaminate GE-free crops, potentially making farmers liable for having illegal GE plants.

Removal of Consumer Choice

* Contamination will remove people’s right to buy and grow GE-free food. New Zealanders have stated clearly and often that they want to protect the availability of safe, natural and organic food.

Loss of Markets

* GE contamination – even trace levels – threatens our economy because of loss of exports to overseas markets, which have rejected GE foods.
* This field trial would tarnish New Zealand’s clean green image and reputation for producing safe and natural foods.

Liability

* Current liability laws are not strict enough to hold GE experimenters financially accountable for unintended or unforseen adverse impacts on farmers, consumers or the environment.
* Communities face paying (through rates, taxes or indirectly) the costs of clean-up, compensation and dealing with insect pests that have become resistant.

Use of Public Money

* Public money should not be spent on GE products, which the majority of New Zealanders (67% in recent surveys) do not want.
* GE-free methods of pest control in brassicas are already being practiced in organic systems. Public funds should be used for further research into sustainable, organic spest reduction methods.

Potential Negative Health Impacts

* Evidence of health impacts from Bt crops on people and animals must be fully investigated before the application is even considered.
* GE plants containing antibiotic-resistant marker genes can add to existing problems in controlling disease.
* Some forms of Bt toxins have been identified as potential allergens in humans.

Lack of Information from Applicant

* ERMA should not approve this field trial because the precise combination of plant, bacteria, virus and other genes is not known.
* Blanket approval cannot be justified, as different re-combinations may present different risks and therefore should be considered on a case-by-case basis.
* Independent scientists cannot provide expert advice on proper risk-management without knowing the gene-profile of the GE plants created.

Decision Sought
The risks of this field trial far outweigh any potential benefits. For all the above reasons, this field trial application must be rejected.

Mandatory fortification of iodine in bread

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Submission to: Food Standards Authority New Zealand
Submission Author: Steffan Browning, Soil & Health Association
Tuesday, September 19, 2006

Below is the Soil & Health NZ submission to FSANZ’ Proposal for Mandatory Fortification of Iodine in bread.

Bar influence by Food Safety Minister Annette King at the October 25 Ministerial Council meeting, folic acid which has already been recommended by FSANZ, will be likely joined by iodine to be included in NZ bread including organic bread.

Annette King can either press her Australian equivalents, state and federal, to call for a review of the FSANZ decision to allow, for example, an exemption for organics from any mandatory fortification, or the Minister can take New Zealand down a different path than the Australians as happened with Country of Origin Labelling. The Minister has the power. Or of course Australian ministers can call for an organic exemption.

Mandatory fortification of any NZ foods has not occured before. All fortification has been voluntary, including the high uptake of iodised salt in the past. This is a serious intrusion into free choice of all consumers and the integrity of NZ organics.

We have been given support by MPs from two parties so far and given opportunity it would be useful to put our concerns to any MPs that you come in contact with, particularly those close to the Labour Government. This is not new legislation it is over to the Minister.

Remember FREE CHOICE and an ORGANIC EXEMPTION.

Thanks
Steffan
Spokes
person

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Submission to Food Standards Australia New Zealand

Re: PROPOSAL FOR MANDATORY FORTIFICATION WITH IODINE (Proposal P230)

The Soil & Health Association of New Zealand Inc is 65 years old, and is the largest membership organisation supporting organic food and farming in New Zealand, and as such advocates for a healthy natural diet derived from food produced organically and free from additives.

In the event of mandatory fortification of either or both, iodine and folic acid, Soil & Health recommends an exemption for organic foods.

Soil & Health is conscious of the need for good nutritional education and supports strategies that explain the necessity and sources of iodine in diet, and those factors which suppress adequate iodine uptake.

Soil & Health is concerned that other components such as some soy products and fluoride in the contemporary diet may be factors in the rise in iodine deficiency. Organic consumers prefer a solution to the cause, rather than focus on treatment of symptoms.

In the event of need for supplementation, natural products as ingredients are preferred.

Seaweeds are used by some organic consumers with an awareness of the added need for minerals such as iodine, and certified organic kelp – seaweed products exist with that market in mind.

Acknowledging the high level of nutritional and health awareness of organic consumers, in the event of an exemption for organic foods from fortification, monitoring will show any need for increased education or recommendations to that consumer sector.

Fortification with any synthetic additive is contrary to the ideals of the consumer base of Soil & Health’s membership, and mandatory fortification will reduce choice for those wanting to avoid additives.

That said, many pregnant and breastfeeding women in Australia and New Zealand, in the absence of adequate iodine intake or subject to goitrogenic factors, may require daily iodine supplements.

FSANZ states in the draft assessment report that fortification will not be enough to address iodine status shortfalls.

Soil & Health agrees that an education program through the health system, including information on iodine sources and inhibitors is required, with optional supplementation a possibility.

This does not necessitate mass medication and in that event, broader consumer choice than unleavened bread and a few cereals is appropriate. Considering typical diets, the unfortified choices suggested in the Proposal assessment report are not really choice at all.

Soil & Health is aware of small domestic market focused bakeries that would have difficulty complying with the proposed standard for mandatory fortification with iodine. Those bakeries, and also access to markets requiring no added iodine, need to be allowed for in the interests of fair trade. Regulation as recommended so far disadvantages small commercial operations. An exemption for organic foods would reduce the level of commercial disadvantage.

Organic production and processing is based on minimum alteration or addition to food composition. Organic processing standards restrict additives in bread. BioGro for example would have to change its standard to something less than consumer expectations if mandatory fortification was introduced.

The current voluntary fortification regime allows consumer choice and fair trade as long as clear labelling is present.

FSANZ’ Proposal states, ‘Food labeling or promotional claims must be factually correct and not misleading or deceptive under the fair trading legislation of Australia and New Zealand. FSANZ intends to discuss the use of descriptors such as ‘natural food’, and ‘organic foods’ with the

Australian Competition and Consumer Commission and the New Zealand Commerce Commission, to clarify the status of foods using iodised salt with regards to fair trading”

An appropriate descriptor or definition of ‘organic’ produce or goods is likely and appropriately that which has been produced according to either a ‘National’ organic standard, or is organically certified. The 12 month transition period for implementation allows more than sufficient time for that mechanism to be established.

At least three organic certification organisations in New Zealand:
1. Organic Farm NZ Incorporated
2. BioGro Producers and Consumers Council owners of BioGro NZ Certification and BioGro Domestic Organic Certification
3. The Biodynamic Farming and Gardening Association, Demeter certifier in New Zealand, do not agree with mandatory fortification of organic food and in principle agree with an exemption for organic food.

The Soil & Health motto is Healthy Soil , Healthy Food , Healthy People.

Below a paragraph that expresses the principle as presented by one of our prolific members.

“Under genuine organic management the inherent expectation and principle is that the produce grown takes up and produces enough iodine and folic acid to satisfy a person’s need when consuming a balanced organic diet.

While this is not yet necessarily always the case it is the aim of the organic production system to produce ‘whole foods’ in the true sense of the word. We are better off exploring what is required to get acceptable levels in our food crops again and pay the true and fair price for producing quality food.

Giving in to external pressure to fortify foods takes away the only natural option to explore what is required to grow ‘quality’ food and gives producers and wholesalers a cheap and easy way out. It encourages a commodity/quantitative approach (factory farming vs organic farming) and prevents a focus on quality food production. A regulation that encourages fortification encourages poor food production systems!

An exemption would allow the organic producers to continue exploring genetic material and growing methods that deliver ‘genuine’ organic whole foods and will also give consumers a choice”.

Summary

* The Soil and Health Association of New Zealand does not support Mandatory Iodine Fortification.
* Soil & Health supports public education of the need for iodine, sources of iodine and factors that inhibit the uptake of iodine.
* Soil & Health supports informed and fair consumer choice.
* In the event of FSANZ choosing to pursue a Mandatory Fortification regime, Soil & Health requests that an exemption be made for Certified Organic producers and processors.
* Soil & Health and other organic organisations in New Zealand and Australia wish to explore with FSANZ, options for an organic foods exemption from mandatory fortification.

Folic Acid

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Submission to: Food Standards Authority New Zealand
Monday, July 31, 2006

The Soil & Health Association of New Zealand Inc is 65 years old, and is the largest membership organisation supporting organic food and farming in New Zealand, and as such advocates for a healthy natural diet derived from food produced organically and free from additives.

This submission will look at the issue of fortification in terms of the Policy Guideline and the original discussion options.

Policy Guideline, Fortification of Food, Vitamins & Minerals.
The FSANZ Act 1991 (the Act) Section 10 contains ‘High Order’ Principles

Objectives
1. (a) – the protection of public health and safety
(b) – provision of adequate information relating to food to enable consumers to make informed choices.
2. (a) – the need for standards to be based on risk analysis using the best available scientific evidence
(c) – the desirability of an efficient internationally competitive food industry.
(d) – the promotion of fair-trading in food.

Options Considering Fortification with Folic Acid as in the Initial Assessment Report 2004
1. Maintenance of the Status quo
2. Extension of Permissions For Voluntary Folate Fortification
3. Mandatory Folate Fortification
4. Increased Health Promotion and Education strategies to increase folate intakes.

The Soil & Health Association supports the education of consumers on healthy diet and nutritional needs. Soil & Health believes that a healthy diet negates the need for fortification and in the absence of quality national education campaigns promoting healthy diet (option 4), The Act Section 10 Objective 1 (a) is not met.

Objective 1 (a) is also not met considering the risks associated with mandatory fortification as outlined in the submission of the ADHD Association and GE Free NZ in food and environment.

Soil & Health shares the concerns outlined in these submissions. Adequate science has not been researched by FSANZ and NZFSA, and interpretation of the science researched does not appear to be impartial or precautionary. Our members do not share the approach of the authorities.

Soil & Health is conscious of the links between environmental toxins and Neural Tube Defect, for example with dioxin, as in the submission of ADHD Association and others, and Objective 2 (a) should ensure that other causal effects on NTD occurrence are taken into account when or before considering a dietary solution.

FSANZ’s Publication; “Mandatory Folic Acid Fortification – A short guide to the development of a food standard for Australia and New Zealand” includes as a question-answer the following;

Are there any potential adverse effects from taking folic acid?

High doses of folic acid are not known to have any adverse effects on healthy individuals. The US and Canada have had mandatory fortification of flour with folic acid since 1998 and have found this to be a successful and effective means of reducing the rate of NTDs.

This answer does not seriously answer the question and shows a bias towards a mandatory fortification outcome. It is known that high doses of folic acid can have adverse effects, and certainly unhealthy individuals appear not to have been considered. The second part of the answer is not an answer to the question. This type of question-answer PR spin does not meet Objective 1 (a) or (b).

The reduction of options to 1) Status quo & 3) Mandatory Fortification also does not meet Objectives 1 (a) (b), & 2 (a).

There has been no comprehensive promotion and education strategies to increase folate intakes (option 4) in New Zealand, and consequently an appropriate NZ study base on which to use or discount that option, the one preferred by several original submitters and Soil & Health.

Soil & Health is conscious of the need for good nutritional education and supports strategies that explain the necessity and sources of folate in diet. (Option 4)

Fortification with any synthetic additive is contrary to the ideals of the consumer base of Soil & Health’s membership, and mandatory fortification will reduce choice for those wanting to avoid additives.

The Act Section 10 Objective 1 (b) will not be met if any particular food or sub group has mandatory fortification.

For example if white bread or whole grain bread or trim milk were used as a vehicle for fortification, then that food group is no longer a choice for those wanting to avoid fortification.

Informed choice may allow a decision away from that food group, but real informed choice would allow a consumer to have fortified white bread or non-fortified white bread for example. This would favour options 1 or 2 and 4. Certainly not 3. However if option 3 was pursued, an exemption for organic foods would allow consumer choice.

The growth in farm based flourmills and Farmers Markets has not been taken into account in the recommendation to use bread flour as a vehicle for folic acid fortification. Small mills will have difficulty in equipping for fortification and this would be a barrier to fair trade as promoted in Objective 2 (d).

With environmental pressure by primary production intensification, being in part driven by downward pricing mechanisms as identified by The Parliamentary Commissioner for the Environment, in the Growing for Good Report, smaller value added, more direct sales based production is to be encouraged. Objective 2 (d) would encourage such.

These mills invariably are involved with whole grains which have not had the natural folate removed as in the more refined flours, meeting Objectives 1 (a), 2 (d), and fit well into Option 4.

Organic processing standards restrict additives in bread and do not permit the addition of synthetic vitamins. BioGro for example would have to change its standard to something less than consumer expectations if mandatory fortification was introduced.

The current voluntary fortification regime (Option 1) allows consumer choice and fair trade, which could largely remain with Option 2 as long as clear labelling was present.

Organic production and processing is based on minimum alteration or addition to food composition. Pre-mixes for bread have been suggested as an alternative vehicle for fortification, by which some organic bread may be excluded, increasing choice, depending on the bread type/s chosen. However this still is contrary to the expectation of organic consumers, as represented by Soil & Health, that organic food does not have synthetic additives.

With significant growth in organic trade internationally and the New Zealand Organic sectors aim at $1 billion value by 2013, it can be expected that growth in exports of organic flour and baked products from ‘Clean Green NZ’ will increase. There are international variations to acceptance of additives such as folate in organic products, generally based on the domestic market in the importing country, and of course as a trade barrier.

An exemption for organic products from any mandatory folic acid fortification will give New Zealand and Australia’s value added growth industry greater options for trade. The point of difference marketing benefit meets Objective 2 (c & d).

Summary

* The Soil and Health Association of New Zealand does not support Mandatory Folic Acid Fortification.
* Soil & Health supports an Option 4 educative approach to health and nutrition.
* Soil & Health shares the concerns expressed in the submissions of ADHD Association, and GE Free NZ in food and environment.
* Soil & Health supports the submission of Organics Aotearoa New Zealand to which it is a party.
* In the event of FSANZ choosing to pursue a Mandatory Fortification regime, Soil & Health requests that an exemption be made for Certified Organic producers and processors.

GE lucerne / alfalfa

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Submission to: Biosecurity New Zealand
Submission Author: Steffan Browning, Soil & Health Association
Sunday, July 30, 2006

The Soil & Health Association of New Zealand Inc is 65 years old, and is the largest membership organisation supporting organic food and farming in New Zealand, and as such advocates for a GE Free environment and diet.

Soil & Health is concerned at the risks of GE contamination to organic production from seed imported into New Zealand and requests that Biosecurity NZ maintains a strong stance to negate that risk. Soil & Health supports the setting up of an effective protocol that will ensure New Zealand gardeners and primary producers do not have to deal with issues of GE contamination.

Organic producers operate with a consumer expectation of 0% GE contamination in their products, and so Soil & Health is in full support of the submission by GE Free in Food and Environment. Organic producers and consumers share many of the issues their conventional counterparts do concerning possible GE contamination, eg market access, liability in the event of contamination, ability to save seed, new weeds, possible health effects, loss of choice.

While supporting GE Free NZ’s position, the Soil & Health Association of NZ also wishes to speak to its position and of the issues significant to organic producers.

 

Sent to:
Arun Siva
Plant Imports
Biosecurity New Zealand
PO Box 2526
Wellington