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EPA Call for Information on glyphosate, September 2021

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Summary of our submission

A GLYPHOSATE RISK ASSESSMENT IS NEEDED URGENTLY

We welcome the opportunity to respond to this Call for Information on glyphosate.

We submit that Aotearoa New Zealand urgently needs a genuine risk assessment of glyphosate and glyphosate-based herbicides (commercial products containing glyphosate and other chemicals) that are being sold and used in this country.

New Zealand has never conducted a risk assessment of glyphosate-based herbicides (GBHs). This Call for Information effectively delays the long overdue risk assessment of GBHs

This delay pushes back appropriate regulatory measures that might be enacted as a response to risk assessment to protect health.

SURVEY OF COUNCIL USE OF GLYPHOSATE

Our submission includes survey information collected from territorial and regional authorities around the country about their current use of GBHs.

This survey demonstrates both the widespread use of GBHs and the increasing community pressure to eliminate GBHs

THERE ARE KNOWN HEALTH RISKS FROM GLYPHOSATE

There are known health risks of GBHs to humans, domesticated animals, and to aquatic and terrestrial wildlife.

We provide evidence of these risks our submission document.

Given its widespread use, producers and consumers cannot be confident they’re avoiding GBH health risks under the current regulations.

We urge the government to take a strict precautionary approach.

GLYPHOSATE USE LEADS TO INCREASING HERBICIDE RESISTANCE

Herbicide resistance – including resistance to GBHs – is a growing problem globally and here in New Zealand.

Herbicide resistance is leading to the use of several different herbicides together or in rotation.

Farmers and growers (conventional as well as organic) are increasingly seeking safe non-chemical weed management options.

Organic producers are able to successfully employ a range of non-toxic methods of weed management, reducing herbicide resistance pressure

ECONOMIC RISKS OF GLYPHOSATE-BASED HERBICIDES

International demand for safe, healthy food is strong and growing. Our international markets are extremely sensitive to pesticide residues.

For example Japan has rejected New Zealand honey imports this year due to glyphosate residues.

SOIL & HEALTH’S GLYPHOSATE PETITION

We need our Government to hear our concerns, and to that end have established a petition. For further information, and to sign the petition, please see here.

Supporters of our petition are calling on the government to:

  1. Ban the use of glyphosate in public places and around waterways;
  2. Ban foliar sprays (pre-harvest) of glyphosate formulations on human and animal feed crops; and
  3. Conduct a first-ever risk assessment of the active ingredient glyphosate, and the retail formulation sold in shops, using independent published and openly available scientific data.

OUR FULL SUBMISSION

Included in our submission are

Pesticides

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Conventional agriculture relies on pesticides to protect crops from pests and diseases – including synthetic herbicides to control weeds and synthetic

fertilisers to promote crop growth. Over time this heavy use of synthetic chemicals reduces the soil biota and the productive capacity of the soil, and creates increased resistance by pests to the chemicals used, as well as the resurgence of secondary pests.

There are various long-term effects associated with particular pesticides that are found in our food, including endocrine or hormonal disruption, cancer, immune system effects, nervous system damage, genetic damage, infertility and birth defects.  These chemicals are also dispersed in the environment, polluting waterways and damaging ecosystems.

Numerous studies on the adverse impacts of pesticides and chemical fertilisers have raised awareness about the use of synthetic chemicals in agriculture, including how effective they actually are in treating pests and diseases, and the impact they are having on human health as well as the wider environment. People are turning to more natural forms of pest and disease control that are more effective, sustainable and healthier in the long term.

Organic agriculture has a holistic approach to pest and disease management that avoids the need for pesticides by instead focusing on building healthy fertile soil with abundant microbial life, fostering natural predators and using natural remedies. Truly well-nourished plants do not attract pests or provide a suitable situation for pests and diseases to develop. Farmers and producers try to create healthy soil so that plants and animals can be healthy, and build up good natural defences against pests and diseases. The long-term health of the soil is taken into consideration, rather than trying to deal with the immediate problem with synthetic sprays. Biological controls may be used.

The Soil & Health Association is opposed to the use of harmful pesticides in Aotearoa New Zealand. We advocate for farmers and producers to adopt natural, non-harmful methods of pest and disease management.

We believe that:

The most toxic harmful pesticides such as glyphosate should be phased out immediately.

Use of glyphosate in public places, home gardens and for pre-harvest desiccation should cease immediately as these are the routes that expose most people to glyphosate. Other uses should be restricted and phased out as soon as possible. Researchers and farmers should be encouraged to develop and implement nonchemical alternatives to glyphosate that foster soil microbial life instead of destroying it.

Pesticide spray drift across a landowner’s boundaries without the neighbours’ consent should be made illegal.

There is a need for stricter enforcement with higher penalties for any harm from pesticides caused to human or animal health and/or pollution of waterways, groundwater, air and soil.

When pesticides are used the ‘polluter pays’ principle should apply, so that pesticide users should be held financially liable for any adverse effects that might occur from spray drift or chemical trespass.

More resources are needed for the monitoring of farm spraying activities and their effects on the health of the environment and people.

Aerial spraying of pesticides should be a prohibited activity.

 

                                            Photo credit: Nick Holmes

 

Submission on application for the reassessment of chlorothalonil formulations

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16 December 2016

 

Hazardous Substances

Environmental Protection Authority

Private Bag 63002

Wellington 6140

 

Submission on application for the reassessment of chlorothalonil formulations

 

Introduction

  1. The Soil & Health Association of New Zealand Inc. (‘Soil & Health’) was incorporated under the Incorporated Societies Act 1908 on 4 December 1942. Soil & Health’s objectives broadly include soil health and the promotion of organic gardening and farming. It has approximately 3000 members, chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Its age and membership make it the oldest and largest representative organic organisation in New Zealand.

 

  1. Soil & Health is opposed to the use of harmful pesticides in Aotearoa New Zealand. As an organisation we advocate for farmers and growers to adopt natural, organic, non-harmful methods of pest and disease management. We believe that researchers, farmers and growers should be encouraged to develop and implement nonchemical alternatives to pesticides that foster soil microbial life instead of destroying it.

 

  1. Soil & Health is opposed to the use of fungicides containing chlorothalonil in New Zealand. A number of independent scientific studies have raised serious concerns about the effects that chlorothalonil has on human health and the environment.

 

  1. Soil & Health therefore strongly supports the EPA’s recommendation to revoke the approval of four (HSR000480, HSR000147, HSR000586, HSR100872) non-professional use chlorothalonil formulations and to dispose of the existing stocks of these formulations within the next 6 months. However Soil & Health considers that the fifth outstanding (HSR00618) non-professional use chlorothalonil formulation considered in the application should also have its approval revoked.

Detailed submissions

Adverse effects on humans

  1. We strongly agree with and support the EPA’s statement that “the high toxicity of chlorothalonil means that serious human health effects can develop from even small exposures to chlorothalonil.” Chlorothalonil is listed on the Pesticide Action Network International list of Highly Hazardous Pesticides for global phase out.[1] Chlorothalonil is a known carcinogen, mutagen and an environmental toxin and it is thought responsible for aggravating the health effects of other pesticides. The application itself points out that the hazard classification of the substances are all classified as suspected carcinogens while several are classified as acutely toxic by inhalation, corohesive to the eye and/or as suspected mutagens. The carcinogenic classification in the application is based on findings of kidney tumours in male rats and mice and in female rats following administration in long-term toxicity studies. In a study released by the US government health staff it was found that exposure to certain pesticides, chlorothalonil increased the risks 5.6 fold and 2.4 fold respectfully, of a blood disorder that can lead to multiple myeloma.[2]

 

 

Adverse effects on the environment

  1. According to the Environmental Health Criteria 183 of the International Programme on Chemical Safety chlorothalonil is considered by the World Health Organisation and to be highly toxic to fish and aquatic invertebrates.

 

  1. In a study by the University of Florida it was found that chlorothalonil killed nearly every amphibian at the approximate expected environmental concen­trations to which humans are commonly exposed. The study concluded that future studies should be carried out that directly quantify the effects that chlorothalonil has on amphibian populations and human health.[3]

 

  1. In an article published in the peer-reviewed scientific journal ‘Archives of Environmental Contamination and Toxicology’, it was stated that despite the low water solubility of chlorothalonil it has been detected in Australian waterways, and while chlorothalonil can be readily removed from the water column by binding to sediment or suspended solids in the water, the ecotoxicological data from the literature show that it is acutely toxic to nontarget organisms at concentrations much lower than reported environmental concentrations.[4]

 

  1. Research as shown that children are the most vulnerable, up to 108 times, to fatal aerosol effects of chlorothalonil. The home use of the product increases the risk of exposure to children and adolescents.

Adverse effects of Black Spot and Fungus Spray and Watkins Fungus and Mildew Spray (HSR00618)

  1. We consider that due to the harmful effects of McGregor’s Black Spot and Fungus Spray and Watkins Fungus and Mildew Spray, the approval for these substances should also be revoked. The hazard classifications that these products fall into are fatal, suspected human mutagen, toxic to human organs, skin sensitiser, and corrosive to the eye. They are also very toxic to the aquatic environment, persistent and harmful to soil and terrestrial vertebrates (6.1B, 6.3B, 6.5B, 6.6B, 6.9A, 8.3A, 9.1A, 9.2C, 9.3C).

Failure to meet requirements under HSNO Act

  1. Due to the adverse effects of chlorothalonil listed above, we consider that if the decision-making committee decides to reject the EPA’s recommendations and continues to allow the non-professional use of chlorothalonil formulations in New Zealand it would be failing to recognise and provide for the life-supporting capacity of air, water, soil and ecosystems, as required to do under section 5(a) of the HSNO Act.

 

  1. Section 28 (2)(a) of the HSNO Act requires each application for approval to include the unequivocal on all the possible adverse effects on of the substance and its properties. We consider that this has not been met due to the EPA failing to identify the adjuvant properties of the McGregors and Watkins formulations, which increase the toxicity of pesticides.

 

  1. Section 28 (2) (b) requires that each application for approval include information on all the possible adverse effects of each substance. We consider that the EPA has also failed to meet this requirement as the EPA has not assessed the cumulative and synergistic effects of the two chemicals contained in the McGregor Watkins products, and whether they increase the hazardous rating, making this compound even more eco toxic than if applied singly.

Alternatives to chlorothalonil formulations and other toxic pesticides

  1. Conventional agriculture relies on pesticides to protect crops from pests and diseases, including synthetic herbicides to control weeds, and synthetic fertilisers to promote crop growth. Over time this heavy use of synthetic chemicals reduces the soil biota and the productive capacity of the soil, and creates increased resistance by pests to the chemicals used, as well as the resurgence of secondary pests. These chemicals are also dispersed in the environment, polluting waterways and damaging ecosystems.

 

  1. Numerous studies on the adverse impacts of pesticides and chemical fertilisers have raised awareness about the use of synthetic chemicals in agriculture, how effective they actually are in treating pests and diseases, and the impact they are having on human health as well as the wider environment. People are turning to more natural forms of pest and disease control that are more effective, sustainable and healthier in the long term.

 

  1. Organic agriculture has a holistic approach to pest and disease management that avoids the need for pesticides by instead focusing on building healthy fertile soil with abundant microbial life, fostering natural predators and using natural remedies. Truly well-nourished plants do not attract pests or provide a suitable conditions for pests and diseases to develop. Farmers and producers try to create healthy soil so that plants and animals can be healthy, and build up good natural defenses against pests and diseases. The long-term health of the soil is taken into consideration, rather than trying to deal with the immediate problem with synthetic sprays.

 

  1. The application itself points out that there are several alternatives for use in a home-setting available on the market in New Zealand. The application states that several fungicides with lower hazards are available, including horticultural oils, sulfur, and the biological fungicide (Bacillus Subtilis).

 

  1. We consider that even those fungicides currently available can easily be replaced by non-chemical biological controls that do not have an adverse effect on the environment. We therefore consider that chlorothalonil formulations do not provide any extra advantage.

Conclusion

  1. Due to the many adverse effects associated with the use of chlorothalonil formulations as well as the lack of convincing evidence of both its need and safety the Soil & Health Association consider that the decision-making committee should accept the recommendations of the EPA to take a precautionary approach as required under section 7 of the HSNO Act, and revoke the approval of four non-professional use chlorothalonil formulations (HSR000480, HSR000147, HSR000586, HSR100872) and to dispose of the existing stocks of these formulations within the next 6 months.

 

  1. We further request that the fifth (HSR00618) chlorothalonil formulation also have their approval withdrawn for any importation, storage, sale, copating, or dispersal, until international scientific evidence exonerates this fungicide from any linkage with human health impacts.

 

  1. Soil & Health wish to be in heard in support of our submission.

 

Yours sincerely

 

Name: Mischa Davis

Position: Policy Advisor

 

The Soil & Health Association

PO Box 340002

Birkenhead

Auckland 0746

Phone: 06 8775534

Mobile: 0212667754

Email: advocacy@organicnz.org.nz

Website: www.organicnz.org.nz

 

[1] PAN International List of Highly Hazardous Pesticides, Pesticides Action Network International 2011, p 15.

[2] American Society of Hematology Journal, June 2009 (2,3).

[3] The Fungicide Chlorothalonil Is Nonlinearly Associated with Corticosterone Levels, Immunity, and Mortality in Amphibians, Environmental Health Perspectives, vol 119, number 8, August 2011, p 1098.

[4] Assessing the Chronic Toxicity of Atrazine, Permethrin, and Chlorothalonil to the Cladoceran Ceriodaphnia cf. dubia in Laboratory and Natural River Water, Archives of Environmental Contamination and Toxicology (2013) 64 p 420.