29 August 2019
Environmental Protection Authority
Private Bag 63002
Wellington 6140
New Zealand
Submission on application APP203660
To reassess methyl bromide
Introduction
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organisation supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership comprises home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
2. Soil & Health makes this submission on the application by Stakeholders in Methyl Bromide Reduction Inc (STIMBR) to reassess methyl bromide a fumigant that is among other things is used on export timber and logs.
3. Soil & Health accepts the need for fumigation to meet the phytosanitary needs of New Zealand and other countries, should safer methods of pest control not be effective, and if communities and the broader environment are protected from any adverse effects from the fumigant.
4. The EPA in 2018 allowed the possibility of a reassessment application;
‘Grounds to reassess were granted based on data that evidenced New Zealand’s use of the fumigant has increased from over 400 tonnes a year in 2010, to more than 600 tonnes in 2016. One of the criteria required to meet grounds for reassessment under the Hazardous Substances and New Organisms Act, is a significant change in the quantity of a substance imported into or manufactured in New Zealand.’
5. Soil & Health believes that the reassessment criteria were used inappropriately, as that increased use was predicted at the last reassessment with conditions of use and the recapture deadline made in that knowledge. It is misleading to use increased use to allow another reassessment to effectively excuse the log export industry out of their environmental and public health responsibilities when those responsibilities were clearly defined in 2010.
6. Soil & Health submitted to the Environmental Risk Management Authority (ERMA) for the reassessment of methyl bromide in 2010 and has campaigned since to have that fumigant better contained and recaptured or stopped.
7. Those campaigns along with other community, union, and environmental groups have meant that methyl bromide fumigation without recapture is no longer used at log exporting facilities in several ports, notably Nelson, Picton and Wellington. However the problems of worker exposure and release of the atmospheric ozone depleting gas have mostly just shifted north to the ports of Napier, Tauranga, and Marsden Point-Whangarei.
8. This submission writer, later in another role as a Section 274 Party, won an Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12. That case, contested for the applicant Envirofume by legal counsel Helen Atkins (Chairperson of the 2010 ERMA methyl bromide re-assessment), exposed further the significant risks of methyl bromide fumigation for the health and safety of workers and nearby communities.
9. The log exporter industry through STIMBR have variously used public funding as in the Primary Growth Partnership (PGP) funding to look mostly at predictably unlikely alternatives to recapturing residual methyl bromide, while obfuscating attempts at log stack trials of existing recapture technology using carbon filters as available from Nordiko.
10. STIMBR supported Draslovka who applied for an alternative fumigant ethanedinitrile (EDN) which the Ministry for Primary Industries (MPI) appear to be taking seriously in negotiations with log importing countries as an alternative to methyl bromide, on the premise that recapture will not be necessary should EDN be approved, as it is not subject to the Montreal Protocol.
11. Soil & Health submitted in opposition to EDN due to the known risks, and the lack of environmental and safety data, and that the applicant and STIMBR’s approach that recapture would not be required, although in Australia, EDN can ONLY be used with scrubbing (a recapture) technology as part of its label use after being assessed by the national regulatory body there, the Australian Pesticides and Veterinary Medicines Authority (APVMA).
12. Soil & Health is concerned that government agencies such as MPI might be looking at the EPA as a rubber-stamping agency for compounds such as EDN with such confidence that they are putting EDN as an option for fumigation to countries including India and China. Soil & Health is concerned that industry’s economic benefits appear to become paramount over the need of worker, community and environmental health in the decision making around fumigants approval and their use.
13. However, the EPA has decided to process this application by STIMBR as a modified reassessment rather than forcing the previous reassessment’s requirement of recapture onto the users of methyl bromide fumigation.
The Tauranga example
14. While economic considerations are included in the benefits analysis by the EPA, the ability to pay for appropriate safeguards must be included in any analysis, not just the significant earnings the industry generates. All stakeholders including port companies should be part of ensuring the ultimate safety of workers, community and environment.
15. In the Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12, it was noted that Port of Tauranga Limited (POTL) did not attend those proceedings although it was the owner and operator of the port where the log fumigation activity under scrutiny was taking place.
16. The community and Soil & Health have long called for dedicated fumigation facilities incorporating recapture technology to be constructed and used, yet POTL continue to discount any such possibility there.
17. Soil & Health points out that POTL has just announced its largest profit ever (end of year June 2019). Increasing 6.7% on last year’s profit of $94.3 million to reach $100.6 million, with log export volumes increasing during that time 12.5% to 7.1 million tonnes. http://www.port-tauranga.co.nz/growth-in-cargo-volumes-contributes-to-increased-profit-for-port-of-tauranga-limited/
While that growth is expected to ease in the short term, POTL is still the country’s largest export log exporter, close to twice its nearest rival Whangarei.
18. Log exports through POTL for the year ending December 2017 were valued at $968,919,331, almost a staggering billion dollars towards a third of New Zealand’s log export value that year of $3,058,737,889 and yet the port company and log exporting interests continue to deny workers, the community and environment the benefits of recapture.
19. Safeguards to protect people and the environment are becoming more important and need greater attention as increasing development and presence of toxins including fumigants in the environment become more common.
20. Soil & Health submits that the money is there for fast correction of the shortcomings in facilities and responsible management of log and timber fumigation in New Zealand.
Monitoring and modelling
20. Methyl bromide is a risk well beyond fumigation areas due to drift, inversion layers, and the inability by those responsible to adequately monitor its whereabouts. Boundary monitoring is pointless if at head height, when a fumigant plume passes above it and then descends or drifts into other areas.
22. Air modelling techniques cannot fully give assurances about where and at what concentrations methyl bromide will be once released from containers, log stacks or ships holds. Modelling can at best be a best estimate, but the topography of the fumigation surrounds is continually changing with log or container stacks, ships size and presence, and weather variables, including humidity, temperature of air, objects and ground all obfuscating the best air modelling estimates.
23. There is no sure air monitoring possibility, or method for the safe release of methyl bromide in the port and coastal marine area. A previous Environment Court in Nelson noted the possibility for “monitoring devices to miss the most concentrated area of the plume, or even the plume in its entirety, and in fact on four out of seven attempts to sample air quality in Port Nelson during 2003-2004 this had occurred in varying degrees” (Env Court Interim Decision para 50).
24. Soil & Health notes STIMBR’s intent that recapture of fumigant from ships holds be delayed significantly, another 10 years, yet ships’ holds are where the most significant volumes of methyl bromide are used. The communities near the ports of Napier, Tauranga and Mt Maunganui, and Marsden Point (Whangarei port), and potentially elsewhere in New Zealand will be further exposed to the toxicity of methyl bromide, and the damage to the ozone layer will continue.
25. Other port workers, not involved in fumigation but working nearby, may also be exposed to the methyl bromide, particularly when the methyl bromide is released into the atmosphere following fumigation, but also during accidental and spontaneous release, as happens with methyl bromide most years, at most log stack fumigating ports. Log stack fumigations under tarpaulins are subject to strong wind events and accidental tarpaulin puncturing. Both Genera and Envirofume fumigation operators have had log stack tarpaulins rent with spontaneous release of methyl bromide. Dedicated permanent fumigation structures would eliminate the risk of tarpaulin failure.
Worker and community safety
- In the Environment Court decision Envirofume Limited vs Bay of Plenty Regional Council, [2017] NZEnv 12, the court observed the large range of port users that may be exposed inadvertently to the methyl bromide fumigant. [1]
- That Court found significant shortcomings in the current methyl bromide fumigation. EPA and Work Safe requirements are either impractical or are frequently breached.
- Whatever toxic fumigant is used for log, timber and other fumigation, it must be in a dedicated facility with recapture of remnant fumigant, such as is used at Port Nelson. Methyl bromide was linked at that port with the deaths of six men from motor neurone disease. Alternative fumigants such as EDN have their own array of serious health risks. Recapture technology exists but industry individually and collectively has mostly avoided its use for economic reasons.
Ozone depletion
- Continued methyl bromide release means further atmospheric ozone depletion, and New Zealand’s intentional breach of responsibility to its Montreal Protocol obligations, where although phytosanitary requirements allow some continued use of methyl bromide, there is an obligation to be reducing its use. ERMA allowed a continuance of damaging release into the atmosphere in 2010 with the knowledge that there would be a significant increase in methyl bromide use.
- Dr Olaf Morgenstern – Programme leader (Climate Variability and Change) NIWA for the writer at the Environment Court outlined the significance of that release in world terms, with New Zealand being the highest user per capita. That should not continue if we are concerned about climate effects and the health of people and environment, or economically if our international, including trading, clean green branding reputation is to be valued.
Health effects.
- Most people acknowledge the very real danger of methyl bromide from both acute and chronic exposures, and both acute and chronic effects. A recent although limited US study recently published in the Journal of Asthma reported a positive association between methyl-bromide concentrations and asthma-related emergency department (ED) visits among youths between the ages of 6 and 18 years in California.
- After adjusting for the presence of other pollutants, humidity, and meteorological conditions, each 0.01-ppb increase in methyl-bromide concentration was associated with a 7.1% (95% CI, 2.9%-10.8%) greater likelihood of an asthma-related ED visit.
- That science will need more work but further shows the need for recapture if real precaution is to be used.
The solution – dedicated containment and recapture.
- Responsibility for dedicated containment and recapture facilities was considered by the Environment Court to require an integrated approach:
[130] Overall, our view is that this matter requires an integrated approach from the Port of Tauranga, the marshalling/stevedoring companies, the forestry industry and the fumigators to adopt an approach for the safe application of methyl bromide and the recapture of all reasonable emissions. This would probably require a dedicated area for fumigation, and may involve a building or other system that seeks to encapsulate and recapture gas. We are not satisfied that the introduction of another company into the Tauranga market is going to bring about those changes. In our view, the advance towards reduction of emissions has seen little progress since the 1990s, and the Court is surprised to see that there is approximately ten times as much methyl bromide being applied in Tauranga as there was in the 1990s.
- Regardless of the possibility of an alternative fumigant, industry including port companies and possibly government need to bite the bullet and install dedicated facilities for fumigation and recapture.
- The ERMA 2010 methyl bromide re-assessment inappropriately and possibly illegally set a very late 2020 date for recapture of that fumigant to meet Montreal Protocol requirements of phasing out methyl bromide emissions. The EPA must now insist on dedicated fumigation facilities and recapture always, if the EPA is to meet its statutory requirements.
- Soil & Health supports the substantive submission of the Combined Trade Unions, and is in general agreement of the fumigation context and need for stronger and certain safety conditions as supplied by the Bay of Plenty Regional Council.
- Soil & Health submits that the evidence as attached and provided by expert witnesses for the writer for the Envirofume Environment Court case be considered by the EPA. That included evidence by an epidemiologist Dr Dave McLean from the Centre for Public Health Research, Dr Olaf Morgenstern – Programme leader (Climate Variability and Change) NIWA, and Jayne Metcalfe an air scientist.
Conclusion.
39. Soil & Health seek that the current application be declined.
40. Should the application be granted, dedicated fumigation facilities and recapture must be required.
41. Soil & Health wish to be heard in support of our submission and welcome any questions of the writer for clarification or further information.
Yours sincerely
Steffan Browning
021 804 223
greeny25@xtra.co.nz
Position: National Councillor
The Soil & Health Association
PO Box 9693,
Marion Square,
Wellington, 6141
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
[1] https://www.environmentcourt.govt.nz/assets/Documents/Decisions/2017-NZEnvC-012-Envirofume-v-Bay-of-Plenty-Regional-Council.pdf
Event grants for Soil & Health members
/in Association Meetings and EventsThe Soil & Health Association will provide a grant of up to $100 for the running of any public event led and organised by an association member.
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Note: the total amount of grant funding available is limited to a total of $1200 over one financial year, the Association will take this limit into account when considering applications.
Whenua Warrior
/in Education and Knowledge, Health and FoodMoko Morris talks with Kelly Francis, a Kai Oranga graduate and the catalyst for over 250 food gardens that have been planted since last spring.
Motivated by attending a Kai Oranga course at Papatuānuku Marae, Kelly Francis (Ngāti Wharara, Ngāti Korokoro and Ngāpuhi) created a charitable trust and social enterprise movement called Whenua Warrior. Her vision is to have a harvestable garden available to every person in the country and her mission is to feed, teach and empower communities through māra kai (food gardens).
Providing solutions and connection
The idea came to Kelly from understanding communities that she had been in, the challenges they face and the solutions she had learnt to share. It solves multiple issues including knowledge- and time- poor whānau, provides financial stability through not having to purchase vegetables, and offers a connection to Papatuānuku (Mother Earth) and what she provides us with.
“The most important thing I learnt on the Kai Oranga course was Hua Parakore – the six principles of the Hua Parakore verification system,” says Kelly.
“It also came from knowing the mana you can get from providing kai to your whānau, the need to understand the whakapapa of your kai and the advantages of connecting your wairua with mahi māra kai. I wanted to find a way to help our communities with these indigenous techniques and tried to imagine the entire country understanding their food in this depth… and then find a way to give that koha to them.”
So Whenua Warrior was born.
How it works
Involving others comes naturally for Kelly; they usually find her. It’s the story, passion or mahi behind each project that attracts people to her kaupapa. Finding people is very important to her – but whoever is there on the day are the people that were meant to be. Her approach to gardening projects is to ensure that community and their needs are met first and foremost. What Whenua Warrior build and who they build it with needs to be sustainable and beneficial for years to come. Anyone can put a box of dirt in your backyard, but not everyone can teach how to get that box of dirt to benefit you, your family, hapū and iwi.
Once a māra kai is established, there must be buy – in from families so that there is a foundation of people that work together to ensure the benefits are felt wide and far.
‘Build day’ is about the community and its people, not the garden. Post – build is about supporting the people to support the garden.
There are two different arms to the Whenua Warrior approach:
1. 100% community-based, with no money involved. The community identifies what they need and Whenua Warrior supports them to source seedlings, soil and materials, then helps to facilitate the build and works out ways it can be managed.
2. 100% community – based, backed by funding. A call-out is made to the community as above, then funding is accessed if required.
This approach has been successful and over 250 māra kai have been built so far, in South Auckland, Mount Wellington and Whangarei. Whenua Warrior is now in its eleventh month, and has started on more of the larger-sized gardens rather than focus on the number. In September this year, 50 gardens will be built in the back of 50 homes in Kawakawa. The process from initial contact to actual build varies from place to place but is usually done in under six weeks.
Hua Parakore principles
Kelly explains the principles of Hua Parakore (clean, pure, kai atua) in the following way:
“When contemplating a project, I look at the dates of the maramataka (moon planting calendar) that I can plan on to benefit the build day, hui days, decision days. It is an important aspect in all parts of the project for the wellness of people and for the timeline structure for the project.
“I consider te ao tūroa [the natural world] when we are on the whenua and trying to discover what Papatuānuku already has and what can be built to benefit the tangata whenua. Knowing your surroundings and your options for build is something our tohunga would be responsible for before the land was confirmed to build māra on.
“At this stage whakapapa is considered as well. What happened here? How was this whenua used? What is the whakapapa of the area, people, whenua? Kōrero on the land will potentially allow us to discover the best possible places to plant A versus B.
“We then have the holistic connections that are in our principles: wairua, or spirit. I ask to make sure that I am allowed on the land to do the mahi – ask tangata whenua directly but also karakia to ask our tupuna to ensure our holistic safety. We connect everything physical to spiritual and must acknowledge everyone at every time.”
Wairua can also be a verb – ‘acting with wairua, doing with wairua’, says Kelly. “All actions taken in the build day must have everyone’s wairua in mind. I think that the wrong wairua can mean an empty plate. Everyone must be in tune with each other… and share the mauri.
Mauri is what you are passing on from you to kai, and from kai back to you. This is most important when planting – and the atmosphere for planting needs to be completely serene and positive. What you plant is what you eat, and I consider it a hugely important part of build day to get the community mauri at its highest to allow the passing from them to their kai, and eventually from the kai to them.
Mana – this is felt mainly when all of the above has been completed. The principle that can only be reported to yourself. Mana is not something you earn – it is something within you. Only you can choose how much mana you apply to each decision you make. It is your spiritual pat on the back – and I normally feel this when I am back home and contemplating the completion of each project.
Whānau and kai more important than money.
Kelly says the most fun part is meeting the communities and teaching and learning at the same time together. She shares the matauranga (knowledge) in a way that benefits Papatuānuku, focusing on knowing that people are better off and proving her strong view that money shouldn’t be the main focus of life: family and kai is.
“I built this idea out of hope, because I truly care about what your kids will be able to access when they are responsible to provide food for their tables. We should be thinking of what we can do NOW to benefit them then,” says Kelly.
“I strongly encourage all families in New Zealand to plant fruit trees and vegetables in every household. There are no negatives to growing your own food.”
Moko Morris is a Soil & Health National Councillor who lives in Ōtaki. She is also the national coordinator of Te Waka Kai Ora, the NZ Māori Organics Authority.
This artical was originally created in 2018.
Where’s our food from? Better labelling a step forward
/in Campaigns, Food, Health and Food, Media ReleasesThe blindfold will finally be lifted when it comes to buying food, but the Soil & Health Association says consumers need even greater transparency.
Soil & Health welcomes the passing into law of the Consumers’ Right to Know (Country of Origin of Food) Bill. The Bill, which requires food to carry country of origin labelling, passed with near unanimous support last night in Parliament. While footwear and clothing must be identified where they’re from, until now country of origin of food labelling has only been voluntary in New Zealand.
The Bill was a first introduced in 2016 by former MP, and now Soil & Health National Council member, Steffan Browning, as a Green Party Member’s bill.
“Transparent food labelling is fundamental in allowing people to make informed choices. Mandatory country of origin labelling is a step towards allowing consumers to do this,” says Steffan Browning.
The Bill however only applies to single ingredient foods such as fresh fruit, meat, fish and vegetables and Soil & Health says foods of multiple origins should be labelled too. This requirement could be brought in later through the setting of Fair Trading Act regulations.
“The Bill is a building block to more comprehensive food labelling requirements,” says Browning.
Soil & Health is also concerned that several single origin foods have been excluded from the Bill, including flour, oils, nuts and seeds.
“We particularly want flours and grains included, as most of the soy and maize products from the US are genetically modified. It’s absolutely necessary we have GE food labelling, but in that absence of enforcement we should at the very least be able to choose what country maize and soy products are from,” says Browning.
There has been widespread support for country of origin labelling. A survey conducted last year by Consumer NZ and Horticulture NZ found that 71% of Kiwis want mandatory country of origin labelling and 65% said they looked for country of origin labelling when they were shopping.
“There are many reasons why consumers want to know which country their food comes from. Some want to avoid GE food, food with pesticide residues, or food coming from countries with poor labour conditions or environmental and animal welfare standards,” says Browning.
Soil & Health has been campaigning for mandatory country of origin labelling for over a decade, since the government opted out of joining Australia in mandating country of origin labelling under the Food Standards Code on the grounds it would be an impediment to trade.
This media release was originally created in 2018.
Worried about ‘free-range’ chickens? Choose organic!
/in Organic Community, Organics“The only way to ensure that the chickens you are eating are genuinely free range is to choose organic,” says Marion Wood, co-chair of the Soil & Health Association.
She points out that there is no enforceable industry standard for free-range farming. Farms are regularly audited by the Ministry of Primary Industries for food safety standards, but these standards do not relate to auditing free-range farming practices.
“What this means is that the scope of a ‘free-range’ label on your chickens is actually very wide. People think of happy chickens wandering in a field, but the reality is that the label ‘free range’ can be used by farms that confine their hens to small spaces or subject them to overcrowding. In 2014, it came to light that a farmer had been selling cage eggs as ‘free range’ for over two years – something that slipped under the radar because there was no authority checking such claims.”
But if you choose certified organic chickens, says Soil & Health, you know that the hens are looked after and their quality of life guaranteed because the farms are audited every year.
To get BioGro certification, farms must not have more than 10 hens per square metre in fixed housing or 16 per square metre in mobile sheds. Hens must have unrestricted access to outside runs and access to fresh grass or a forage crop containing a diversity of species. Other organic standards are similar.
Marion Wood suggests everyone makes the change:
“Organic food is grown naturally without the routine use of synthetic pesticides or fertilisers. Certified organic chickens are healthy chickens with a good quality of life – something that the label ‘free-range’ alone doesn’t guarantee.”
Note: This content was created in 2019.
Organics: the time is now!
/in Organic Community, OrganicsWe need to lead the way
By Noel Josephson, CEO of Ceres Organics
The growth of the organic market is significant such that within a relatively few years every major food retailer has felt compelled to have an organic offering even though organics is still a very small percentage of the total food market.
Organics is a consumer-driven market, which caught many major food companies off guard, in that it didn’t fit their model and vision of the market as driven primarily by price. Consumers were more future facing towards their health and the environment, and organics rightly captures that through farming that works with nature rather than conventional farming that tries to control nature.
What’s more the organic movement embodies principles of fairness and trust, and holds some of the answers to climate change, working with social issues, economic development and community development. All of this resonates with the shift of conscious towards realising that capitalism, technology and science are not perfect and don’t have many of the answers we need to reverse the damage we are doing to the earth and humankind.
For these reasons the swing of awareness towards organics has passed the threshold where it has now become of interest to the government and the push to legislate for a national standard is overdue. But if we in the organic sector sit back we risk letting this opportunity slip away at the very time when we should be doubling our efforts.
Speaking with one voice
This is precisely the time to encourage good leadership in our sector organisations to unite the movement to speak with one voice to government, and create a comprehensive plan for organics that the sector fully supports.
Any division in the movement opens the door to others taking the lead and government downplaying our voice. We need to speak with one voice representing the domestic market, the export market, growers, processors, certifiers and consumers. We need one voice representing the larger commercial interests in organics and the innovators and leaders of the organic movement who carry its ideals and values. We need one voice to ensure the standards that sit behind the legislation are primarily held within the organic movement and reflect the common interests of those directly involved in organics.
What is our vision of organics and how can we inform government of what is required? We should be approaching multiple government departments talking about the benefits of organics and what is needed.
Funding organics for success
We should orchestrate multiple channels of funding towards sectors of organics that need support, such as financial support and encouragement of farmers to transition to organics, education and advisory services to farmers, research to establish best practice and quantify data to underpin those practices, consumer awareness of organics and its benefits. These all need funding if organics is to succeed.
We can’t just think when legislation passes it will all happen – that is too late. Do we know what will come our way in terms of financial support? Is this something we have contributed to or are we just accepting what’s given to us by a government that’s just starting to understand organics, let alone know what it needs? A whole plan, together with the funding channels, needs to be on the table now.
The many solutions organics offers
Organics Aotearoa New Zealand (OANZ) as the peak body of the organic sector is in the best position to canvass the organic sector, build a comprehensive picture of what is required, and place this before government.
It is in the interests of the government to listen to ways of reducing greenhouse gas emissions, getting a greater return from agriculture as one of the major pillars of the economy without further intensification of agriculture from existing land.
It is in their interest to understand how we can move towards less polluted land and more productive soils, cleaner waterways and air quality, greater biodiversity as well as how to spend some of their $3 billion on regional development for a good return.
Some of the most pressing problems the government is looking for answers to are exactly the ones organics can bring substance to, and this places us in a strong position to engage and bargain with the government.
We cannot leave the door ajar
We should be keenly aware of the experience of organic movements in other countries at the stage we are at, where they didn’t ask up front for their needs and it goes on to the back burner as an issue to be dealt with in the future. Meanwhile the organic movement struggles and never fully develops its potential.
We should also think of the agendas of those interests that will lose out from a strong organic movement and in any vacuum we create, they will quickly fill it with their vision of how to proceed.
The pressure created by consumer demand for organics growing far faster than farmers and land are converting to organics already creates a tension that could undermine the organic movement. Demand will push commercial interests to meet it, and if the supply is not there the temptation to lower the standards to up supply will work its way into the organic movement. Therefore a strong push from the outset with government support to convert more farmers to organics will help keep the standards strong.
Our public image will make or break us
In the minds of many we are still fringe. The more we enter public consciousness the more we need to be leading the story.
Legislation will up our visibility and unless we are telling the story of the benefits of organics, interests that lose out (and who are more financial than us) will tell their story about Luddites and how we block ‘science’. You need only to see the bias in the Listener editorial at the end of April (on the purported benefits of GE ryegrass in decreasing methane emissions to alleviate climate change, and how science needed to trump the ideology of people who were opposed), to understand it doesn’t take much to paint us into a corner of being backward and blocking so-called progress. Once a public perception gains traction it takes a lot to change it.
This is the time we need leadership from our peak sector body, OANZ, to bring a renewed energy into our movement, together with a vision that encompasses the movement and stretches us to reach forward knowing that we are a strong partner for the government to work with.
The AGM for OANZ is yet to be announced but it is normally held in August. Through your membership organisation of OANZ encourage them to speak at the AGM with the purpose of activating organics in New Zealand.
OANZ
Organics Aotearoa New Zealand (OANZ) is the national voice of the New Zealand organic sector. Its member organisations include organic producers, processors, consumers, exporters and domestic traders. Soil & Health, the publisher of Organic NZ, is a member of OANZ.
info@oanz.org.nz
www.oanz.org
Photo: iStock/chameleonseye
The thorny problem of gorse control
/in Farming, Farming and HorticultureBy Jeanette Fitzsimons
Most of New Zealand’s pastoral hill country is badly infested with gorse. Brought by early settlers from the British Isles to make living fences for stock, in our climate it quickly spread everywhere. A small plant left alone can be a large bush in a year and a few of them can cover a paddock in five years.
It’s not a problem in a market garden or home garden or a cultivated field, where it is simply removed like any other weed. It is manageable in an orchard where the shading helps limit its growth. But in a field of grass it goes rampant.
In an area you are wanting to regenerate with native forest it is positively helpful, adding nitrogen to the soil, shelter and mulch for emerging seedlings, and eventually being shaded out by the growing trees. That’s what we are doing on the 80% of our land that is too steep to farm sustainably. But having given up production on 80%, we want to grow some food on the rest.
Experts differ on whether the seed lasts in the ground for 50 years or 200 but I do know that we won’t be rid of it in my lifetime or my children’s. And fire causes it to germinate vigorously.
I have been given lots of advice over the years on what to do about gorse, most of it totally useless. The only useful suggestion was “if you want to be organic, don’t buy land with gorse on it”. Which does rather call into question our goal of New Zealand being totally organic by 2020!
Some methods we have used include:
1. Chainsaw and fire
Chainsawing down old man gorse gives wonderful firewood and the rest can be stacked and burned – preferably when there is no seed on it. The stumps will regrow – but if you need firewood it is quite a good way to initially clear the land (and maybe follow up with Interceptor, a herbicide based on pine oil).
2. Big machinery
A digger or bulldozer costs, but can rip bushes out by the roots and pile them for burning. It leaves a bit of a moonscape but doesn’t leave roots to grow back so you only have to deal with seedlings.
3. Chemicals
We had tried every non-toxic chemical on stumps before we came to Pakaraka Farm – salt, diesel, caustic soda – nothing worked. And you don’t want them in your soil anyway.
Recently we have tried Interceptor – it’s restricted if your farm is certified organic but permission can be given – to spray on regrowing stumps. Saturate the green shoots when they are about 100–150 mm long and the shoots die. (It kills everything so be careful.) If you can remember to revisit the stumps at the right time, put another application on young shoots each time they reappear and after 3–4 applications the root gives up.
On new land with bad gorse I would recommend cut-and-burn if it is big, then spot-spray a commercial herbicide once on sprouting roots and seedlings to get a really good kill. We agonised over which chemical and opted for metsulphuron which isn’t on any of the lists of things to ban, and doesn’t have a withholding period, but of course still doesn’t comply with organic standards. We took the animals out for about three weeks. This will delay your certification process by a year but give you an easier starting point and you can try to control the seedlings that emerge with grubbing.
4. Animals and other living predators
Yes, goats will eat gorse – when they have eaten everything else in sight (especially all your young trees) and are half starved. Sheep will also nibble the shoots but don’t do much damage. I’ve seen quite effective gorse control on an organic farm in South Otago by electric fencing goats intensively when snow is on the ground. You have to be prepared to sacrifice about 10% of them, and not use does in kid. You will still get seedlings germinating.
There are various weevils, mites and other insects being tried by regional councils. They do weaken the gorse but don’t kill it, and sometimes they actually encourage seed spread.
5. Peasant technology – the grubber
Most of our gorse control has been done by old-fashioned hard work – grubbing. You need to get the thick part at the top of the root out, but the thin long tail won’t regrow. Keep an eye on your wwoofers, as chopping the plants off at ground level makes them twice as vigorous next year. If you do this every year without fail to all the seedlings you will make real progress. When the plants are small and the ground wet it is possible to pull them up by the whole root, which is immensely satisfying.
6. Advanced peasant technology – the Extractigator
Where this article has been heading is to introduce a new tool which makes grubbing much easier. It’s Canadian, made in strong steel and comes in two sizes which are identical except for the length of the handle, and therefore the weight you have to carry around. We have bought two so two people can work together, the stronger person taking the heavier one and tackling the larger bushes.
With the jaws, grasp the gorse stem just where it comes out of the ground. Then you lever against a plate on the ground and with luck the whole plant pops out. We find you need wet ground – no point in tackling it in a drought. (Other soils may be different.)
Provided the plant has a single stem that allows you to grip it before it branches, you can lever out quite large bushes. The jaws will grab a stem up to 50 mm through, though it isn’t guaranteed to come out without breaking. Sprawling bushes with several stems that run horizontally along the ground are much harder and you need to take a grubber with you and grub around them to get purchase with the jaws.
After a while you get the feel of whether it is going to pull or break. Give it time to let go. It takes a bit of practice and I still need more of that. But I think it is a worthwhile improvement on standard peasant technology.
It also works well to remove other weeds such as woolly nightshade, barberry, privet and broom.
You can see it in use and New Zealand prices at www.extractigator.co.nz.
As well as being a farmer, Jeanette Fitzsimons was the co-leader of the Green Party and patron of Soil & Health. Sadly, she passed away in March 2020.
Submission on application APP203660 – To reassess methyl bromide
/in Submissions29 August 2019
Environmental Protection Authority
Private Bag 63002
Wellington 6140
New Zealand
Submission on application APP203660
To reassess methyl bromide
Introduction
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organisation supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership comprises home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
2. Soil & Health makes this submission on the application by Stakeholders in Methyl Bromide Reduction Inc (STIMBR) to reassess methyl bromide a fumigant that is among other things is used on export timber and logs.
3. Soil & Health accepts the need for fumigation to meet the phytosanitary needs of New Zealand and other countries, should safer methods of pest control not be effective, and if communities and the broader environment are protected from any adverse effects from the fumigant.
4. The EPA in 2018 allowed the possibility of a reassessment application;
‘Grounds to reassess were granted based on data that evidenced New Zealand’s use of the fumigant has increased from over 400 tonnes a year in 2010, to more than 600 tonnes in 2016. One of the criteria required to meet grounds for reassessment under the Hazardous Substances and New Organisms Act, is a significant change in the quantity of a substance imported into or manufactured in New Zealand.’
5. Soil & Health believes that the reassessment criteria were used inappropriately, as that increased use was predicted at the last reassessment with conditions of use and the recapture deadline made in that knowledge. It is misleading to use increased use to allow another reassessment to effectively excuse the log export industry out of their environmental and public health responsibilities when those responsibilities were clearly defined in 2010.
6. Soil & Health submitted to the Environmental Risk Management Authority (ERMA) for the reassessment of methyl bromide in 2010 and has campaigned since to have that fumigant better contained and recaptured or stopped.
7. Those campaigns along with other community, union, and environmental groups have meant that methyl bromide fumigation without recapture is no longer used at log exporting facilities in several ports, notably Nelson, Picton and Wellington. However the problems of worker exposure and release of the atmospheric ozone depleting gas have mostly just shifted north to the ports of Napier, Tauranga, and Marsden Point-Whangarei.
8. This submission writer, later in another role as a Section 274 Party, won an Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12. That case, contested for the applicant Envirofume by legal counsel Helen Atkins (Chairperson of the 2010 ERMA methyl bromide re-assessment), exposed further the significant risks of methyl bromide fumigation for the health and safety of workers and nearby communities.
9. The log exporter industry through STIMBR have variously used public funding as in the Primary Growth Partnership (PGP) funding to look mostly at predictably unlikely alternatives to recapturing residual methyl bromide, while obfuscating attempts at log stack trials of existing recapture technology using carbon filters as available from Nordiko.
10. STIMBR supported Draslovka who applied for an alternative fumigant ethanedinitrile (EDN) which the Ministry for Primary Industries (MPI) appear to be taking seriously in negotiations with log importing countries as an alternative to methyl bromide, on the premise that recapture will not be necessary should EDN be approved, as it is not subject to the Montreal Protocol.
11. Soil & Health submitted in opposition to EDN due to the known risks, and the lack of environmental and safety data, and that the applicant and STIMBR’s approach that recapture would not be required, although in Australia, EDN can ONLY be used with scrubbing (a recapture) technology as part of its label use after being assessed by the national regulatory body there, the Australian Pesticides and Veterinary Medicines Authority (APVMA).
12. Soil & Health is concerned that government agencies such as MPI might be looking at the EPA as a rubber-stamping agency for compounds such as EDN with such confidence that they are putting EDN as an option for fumigation to countries including India and China. Soil & Health is concerned that industry’s economic benefits appear to become paramount over the need of worker, community and environmental health in the decision making around fumigants approval and their use.
13. However, the EPA has decided to process this application by STIMBR as a modified reassessment rather than forcing the previous reassessment’s requirement of recapture onto the users of methyl bromide fumigation.
The Tauranga example
14. While economic considerations are included in the benefits analysis by the EPA, the ability to pay for appropriate safeguards must be included in any analysis, not just the significant earnings the industry generates. All stakeholders including port companies should be part of ensuring the ultimate safety of workers, community and environment.
15. In the Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12, it was noted that Port of Tauranga Limited (POTL) did not attend those proceedings although it was the owner and operator of the port where the log fumigation activity under scrutiny was taking place.
16. The community and Soil & Health have long called for dedicated fumigation facilities incorporating recapture technology to be constructed and used, yet POTL continue to discount any such possibility there.
17. Soil & Health points out that POTL has just announced its largest profit ever (end of year June 2019). Increasing 6.7% on last year’s profit of $94.3 million to reach $100.6 million, with log export volumes increasing during that time 12.5% to 7.1 million tonnes. http://www.port-tauranga.co.nz/growth-in-cargo-volumes-contributes-to-increased-profit-for-port-of-tauranga-limited/
While that growth is expected to ease in the short term, POTL is still the country’s largest export log exporter, close to twice its nearest rival Whangarei.
18. Log exports through POTL for the year ending December 2017 were valued at $968,919,331, almost a staggering billion dollars towards a third of New Zealand’s log export value that year of $3,058,737,889 and yet the port company and log exporting interests continue to deny workers, the community and environment the benefits of recapture.
19. Safeguards to protect people and the environment are becoming more important and need greater attention as increasing development and presence of toxins including fumigants in the environment become more common.
20. Soil & Health submits that the money is there for fast correction of the shortcomings in facilities and responsible management of log and timber fumigation in New Zealand.
Monitoring and modelling
20. Methyl bromide is a risk well beyond fumigation areas due to drift, inversion layers, and the inability by those responsible to adequately monitor its whereabouts. Boundary monitoring is pointless if at head height, when a fumigant plume passes above it and then descends or drifts into other areas.
22. Air modelling techniques cannot fully give assurances about where and at what concentrations methyl bromide will be once released from containers, log stacks or ships holds. Modelling can at best be a best estimate, but the topography of the fumigation surrounds is continually changing with log or container stacks, ships size and presence, and weather variables, including humidity, temperature of air, objects and ground all obfuscating the best air modelling estimates.
23. There is no sure air monitoring possibility, or method for the safe release of methyl bromide in the port and coastal marine area. A previous Environment Court in Nelson noted the possibility for “monitoring devices to miss the most concentrated area of the plume, or even the plume in its entirety, and in fact on four out of seven attempts to sample air quality in Port Nelson during 2003-2004 this had occurred in varying degrees” (Env Court Interim Decision para 50).
24. Soil & Health notes STIMBR’s intent that recapture of fumigant from ships holds be delayed significantly, another 10 years, yet ships’ holds are where the most significant volumes of methyl bromide are used. The communities near the ports of Napier, Tauranga and Mt Maunganui, and Marsden Point (Whangarei port), and potentially elsewhere in New Zealand will be further exposed to the toxicity of methyl bromide, and the damage to the ozone layer will continue.
25. Other port workers, not involved in fumigation but working nearby, may also be exposed to the methyl bromide, particularly when the methyl bromide is released into the atmosphere following fumigation, but also during accidental and spontaneous release, as happens with methyl bromide most years, at most log stack fumigating ports. Log stack fumigations under tarpaulins are subject to strong wind events and accidental tarpaulin puncturing. Both Genera and Envirofume fumigation operators have had log stack tarpaulins rent with spontaneous release of methyl bromide. Dedicated permanent fumigation structures would eliminate the risk of tarpaulin failure.
Worker and community safety
Ozone depletion
Health effects.
The solution – dedicated containment and recapture.
[130] Overall, our view is that this matter requires an integrated approach from the Port of Tauranga, the marshalling/stevedoring companies, the forestry industry and the fumigators to adopt an approach for the safe application of methyl bromide and the recapture of all reasonable emissions. This would probably require a dedicated area for fumigation, and may involve a building or other system that seeks to encapsulate and recapture gas. We are not satisfied that the introduction of another company into the Tauranga market is going to bring about those changes. In our view, the advance towards reduction of emissions has seen little progress since the 1990s, and the Court is surprised to see that there is approximately ten times as much methyl bromide being applied in Tauranga as there was in the 1990s.
Conclusion.
39. Soil & Health seek that the current application be declined.
40. Should the application be granted, dedicated fumigation facilities and recapture must be required.
41. Soil & Health wish to be heard in support of our submission and welcome any questions of the writer for clarification or further information.
Yours sincerely
Steffan Browning
021 804 223
greeny25@xtra.co.nz
Position: National Councillor
The Soil & Health Association
PO Box 9693,
Marion Square,
Wellington, 6141
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
[1] https://www.environmentcourt.govt.nz/assets/Documents/Decisions/2017-NZEnvC-012-Envirofume-v-Bay-of-Plenty-Regional-Council.pdf
Gene Bill would let the genie out of the bottle
/in GE, GM, Media Releases, NewsMEDIA RELEASE
17 December 2024
Aotearoa New Zealand – Genetically engineered organisms of all kinds must be prevented from being let loose in the environment with no controls, monitoring or public knowledge, says the Soil & Health Association of New Zealand.
The Gene Technology Bill, which is scheduled to have its first reading in Parliament today, would rule a lot of genetic engineering techniques out of scope of regulation. This would mean many GE plants, seeds, microorganisms and animals could be released without any oversight.
“Changing the legal definition of GE doesn’t make these techniques any safer,” said Charles Hyland, chair of the Soil & Health Association. “Gene editing, rather than being precise, has been shown to result in numerous unexpected changes to DNA.”
“Therefore we need a precautionary approach to gene technologies in the outdoor environment, in our food, and for those technologies that involve heritable traits in any species.”
The Bill could mean that GE ryegrass or clover seed, for example, could be sold and sown without the knowledge of farmers, gardeners and their neighbours. It would be almost impossible to prevent the spread of GE plants, which can be spread via wind, insects and other vectors.
“We don’t need GE in food or farming – we already have nature-based solutions to our problems,” said Philippa Jamieson, Organic NZ editor.
“Organic regenerative farming and growing practices result in lower greenhouse gas emissions, cleaner waterways, reduced soil erosion, increased biodiversity and more resilient ecosystems – there’s no need to risk using GE,” she said.
“Our genetic engineering regulations are robust, protective, and must not be loosened.”
ENDS
Contact:
Charles Hyland, Chair, Soil & Health Association of New Zealand, 027 707 0747
Philippa Jamieson, Organic NZ editor, Soil & Health Association of New Zealand, 027 547 3929
Email: editor@organicnz.org.nz
Website: www.soilandhealth.org.nz
UPDATE: The Health Select Committee is receiving submissions on this Bill. They are due by 17 FEBRUARY 2025.
2025 Calendars for sale!
/in Books, Campaigns, Organic CommunityChanging the definition of GE in food would leave consumers in the dark
/in Media Releases, NewsSoil & Health Association stands firm against redefinition of gene technology in food standards
MEDIA RELEASE
For immediate release 6 September 2024
Aotearoa New Zealand – The Soil & Health Association of New Zealand has officially submitted its comprehensive response to Food Standards Australia New Zealand (FSANZ), rejecting Proposal P1055, which seeks to change the definition of genetic engineering technologies used in food production. The association also urges FSANZ to extend the consultation period by at least a month to allow for sufficient time to make submissions.
Charles Hyland, soil scientist and co-chair of the Soil & Health Association, says: “Redefining gene technology to exclude new breeding techniques (like gene editing) without proper labels and safety checks threatens our ability to choose what we eat. We stand for transparency and informed choices in food consumption, not ambiguity.”
Echoing this sentiment, Jenny Lux, organic producer and co-chair of Soil & Health, highlighted the potential impacts on the organic sector. “Introducing gene-edited products into our food system without clear labels could inadvertently lead organic foods to contain genetically engineered ingredients. This is unacceptable and undermines the trust consumers place in organic labels.”
“People are concerned not just about what’s in their food, but also about how it’s been produced. The global market for non-GMO foods is growing.”
Philippa Jamieson, Soil & Health spokesperson on GE issues, emphasised the need for rigorous safety assessments. “Gene editing and NBTs bring significant risks and uncertainties. Any food product derived from these technologies must undergo stringent safety evaluations and be clearly labelled to ensure public health is not compromised.”
The Association also acknowledges the deep cultural, ethical, intellectual property and spiritual concerns associated with gene technology expressed by Te Ao Māori. Soil & Health aligns with the perspectives of our Treaty partner organisation, Te Waka Kai Ora, that the proposal does not support their cultural expressions and rights as guaranteed under Te Tiriti o Waitangi.
The public is urged to participate actively in the consultation process by making individual submissions to FSANZ. The deadline for these submissions is the 10th of September 2024, at 8 PM New Zealand time. Submissions can be made via email or through the FSANZ consultation hub. The association encourages individuals to also communicate their concerns directly to MPs and through media channels to amplify their voice.
For further guidance on making submissions, or to read the full Soil & Health Association submission, please visit the Soil & Health Association website.
Contact:
Rebecka Keeling, Communications Specialist, Soil & Health Association of New Zealand
Email: editor@organicnz.org.nz
Phone: 021 202 7664
Website: www.soilandhealth.org.nz
S&H Submission on P1055: Definitions for gene technology and new breeding techniques
/in GE, SubmissionsThe Soil & Health Association has submitted on the proposal to revise and update the definitions in the Australia New Zealand Food Standards Code for ‘food produced using gene technology’ and ‘gene technology’. This is our second submission on P1055, having first submitted in 2021.
Read our full submission here.
We strongly encourage our members and supporters to make their own submission. The deadline for submissions is Tuesday 10th September, at 8pm New Zealand time.
The following guidelines are provided to assist you to make a submission. Please contact us if you have any questions or require further assistance at editor@organicnz.org.nz.
SUMBISSION TEMPLATE AND GUIDELINES
The proposal
Second call for submissions: Proposal P1055 ‘Definitions for gene technology and new breeding techniques’ – Food Standards Australia New Zealand (FSANZ).
Submission closing deadline
10 September 2024, 8pm New Zealand time.
How to submit
Make your submission EITHER:
Background documents
Ideas for points to make in your submission
IMPORTANT: Please use your own words.
If you simply copy and paste text from below or from Soil & Health’s submission, your submission may not be counted as an individual submission.
Write about how this proposal will affect you, your family, business and community.