12 February 2025
The Soil & Health Association of New Zealand, representing a diverse community of organic producers, consumers, and advocates, submits this response to the proposed reassessment of chlorpyrifos under the current Evironmental Protection Authority review.
Our association is committed to advocating for the production and consumption of organic food under the motto ‘Healthy soil – healthy food – healthy people: Oranga nuku – oranga kai – oranga tāngata.’ It is from this foundation that we express our concerns regarding the continued use of chlorpyrifos in agricultural practices in New Zealand.
Recommendation
Soil & Health fully supports the EPA’s proposal to ban the use of chlorpyrifos by revoking its approvals.
Reasons
1. Environmental and Health Risks
Chlorpyrifos is widely documented as a persistent environmental pollutant with significant detrimental effects on wildlife and human health. Its persistence in ecosystems and its ability to degrade slowly in environmental conditions pose a long-term risk to ecological health and biodiversity.
Notably, chlorpyrifos has been linked to developmental delays and other health risks in humans, which is particularly concerning for communities in agricultural areas and for consumers globally. Babies in the womb and young children are at greater risk of neurological damage and developmental disorders, even when exposed to very low levels of chlorpyrifos.
2. Global Regulatory Actions
We note that several international jurisdictions, including the European Union and Canada, have moved towards severe restrictions or outright bans of chlorpyrifos, reflecting growing scientific consensus and public health policy shifts towards more sustainable and safe agricultural practices. This global trend underscores the need for New Zealand to consider similar actions to align with international health and safety standards.
3. Incompatibility with Organic Standards
Chlorpyrifos use is incompatible with organic farming principles, which focus on maintaining ecological balance and avoiding synthetic toxins in agriculture. Continuing its use undermines the integrity of New Zealand’s organic sector and the trust of domestic and international consumers in New Zealand’s organic produce.
4. Advocacy for an Outright Ban
Given the substantial evidence of chlorpyrifos’ adverse impacts, and in support of a precautionary approach to pesticide regulation, Soil & Health advocates for an outright ban on the use of chlorpyrifos in New Zealand. We recommend that the EPA facilitate a transition to safer, sustainable, and equally effective alternatives that are available and increasingly being adopted worldwide.
5. Support for Affected Farmers
We propose that the EPA and relevant agricultural bodies work together to support farmers who may be affected by such a ban, including providing access to training in alternative pest control methods and financial support and/or peer support network facilitation during the transition period.
In conclusion
Soil & Health wishes to reiterate the importance of a proactive regulatory approach that prioritizes public and environmental health. We believe that banning chlorpyrifos will represent a significant step forward in protecting our environment, health, and the integrity of our agricultural sector.
We appreciate the opportunity to submit on this critical issue and are available for further discussion or to provide additional information as needed.
Warm regards,
Charles Hyland
Chair, Soil & Health Association of New Zealand
References
Re-evaluation Note REV2021-04, Cancellation of remaining chlorpyrifos registrations under paragraph 20(1)(a) of the Pest Control Products Act. Health Canada. (2021). Retrieved from Health Canada website: https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/decisions-updates/reevaluation-note/2021/cancellation-remaining-chlorpyrifos-registrations.html
U.S. Environmental Protection Agency (EPA). (2020). Revised human health risk assessment on chlorpyrifos. Retrieved from EPA website: https://www.epa.gov/ingredients-used-pesticide-products/chlorpyrifos
White, Alison (2024). Neurotoxic Pesticide in our Food. Retrieved from Organic NZ magazine: https://organicnz.org.nz/magazine-articles/neurotoxic-pesticide-in-our-food/
European Food Safety Authority (EFSA). (2019). Statement on the available outcomes of the human health assessment in the context of the pesticides peer review of the active substance chlorpyrifos. Retrieved from EFSA website: https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2019.5809
Pesticide Action Network Asia and the Pacific. (2022). Children at risk from toxic pesticide: New Zealand should urgently reassess chlorpyrifos. Retrieved from https://panap.net/2022/06/children-at-risk-from-toxic-pesticide-new-zealand-should-urgently-reassess-chlorpyrifos/
