Seed saving

/in

Much of the agricultural diversity that has taken 10,000 years to create is under threat due to industrialised agriculture. As late as 1900 there were over 1500 different food crops, each further represented by thousands of different cultivated varieties. Today however over 90% of the world’s food is made up of only 30 different food crops, and of these only four (wheat, rice, corn and soybeans) provide 75% of the calories consumed by humans.

Industrialised agriculture has forced reliance on a small number of crops with narrow genetic diversity. These highly specialised crop cultivars require stable climates and specific growing conditions, making them highly vulnerable to any disturbances. As a result we are seeing a loss of long-term and local crop diversity and resilience, which in turn favours large agribusiness companies by allowing them to have a monopoly on seed supply. This is all at the expense of farming livelihoods and food security with an increased risk of large-scale crop failures, pest and disease outbreaks and pandemics. In addition, industrialised agriculture has led to a reduction in the nutritive value of food.

The Soil & Health Association:

Believes that everyone should have the right to save their own seed and the right to grow, consume and distribute locally adapted varieties of seed.

Supports any government initiative that improves the situation for locally saved seeds and propagation material useful for organic cultivation.

Encourages people to use their own local, traditional and heritage seed varieties and to plant a diversity of cultivars, both for personal and commercial production.

Supports local seed banks, seed libraries and the conservation of locally selected seed varieties.

Advocates for the mandatory labelling of all ingredients used in any seed treatment.

                                            Photo credit: Nick Holmes

GE/GM

/in ,

Genetic engineering (GE), also known as genetic modification (GM), is one of the most controversial technologies of recent times. Soil & Health has found no economic, health or environmental benefits from GE. There is great uncertainty around the adverse effects of GMOs (genetically modified organisms) on natural resources, ecosystems and also on human health. The risks are large and consequences could be irreversible. If GMOs were to be released into the environment, they can be very difficult, if not impossible, to eradicate. The GE-free food producer status of an individual, district or region would likely be permanently lost, along with any marketing advantages that status provides.

Current laws are inadequate to hold GMO users liable for any adverse consequences, intended or even if unintended. Therefore the public is likely to have to pay for anything that might go wrong.

The Soil & Health Association is opposed to the use of GE ingredients and GMOs in human and animal food, and is opposed to the outdoor use of any GE crops, animals and other organisms in Aotearoa New Zealand. We believe that we would do better for our farmers, environment and human health by retaining our market advantage of being GE free.

We support:

  • New Zealand remaining a GE-free country.
  • The establishment of GE-free regions, in the event of there being no Aotearoa New Zealand wide GE-free strategy.
  • Mandatory and comprehensive labelling for any products containing GE ingredients (including products from animals fed GE feed).
  • The precautionary principle and the imposition of strict conditions and severe penalties must be placed on any research and trialling of GE.
  • A ban on field-testing and production of GE crops, animals, trees and other organisms in New Zealand.
  • A ban of all GE food and animal feed imports into Aotearoa New Zealand.
  • Strong precautionary approach to new/novel technologies.

                                            Photo credit: Nick Holmes

Food Sovereignty policy

Food Sovereignty, resilience & security

/in

Everyone should be able to access affordable, safe and nutritious food that is produced in a way that enhances the environment.

The Soil & Health Association is committed to strengthening food sovereignty in Aotearoa New Zealand by:

  • Supporting the right to food as recognised by the Universal Declaration on Human Rights.
  •  Acknowledging Te Tiriti o Waitangi / The Treaty of Waitangi
  • Opposing local food supply being largely subject to international market forces.
  • Opposing multinational corporations’ control over seed and fertiliser patents.
  • Advocating for government support of local food production and processing, for example through food procurement policies.
  • Advocating for increased resilience and self-sufficiency of food production.-
  • Supporting local food economies and initiatives such as community-supported agriculture, community gardens and food forests, public orchards, seed banks and farmers markets.
  • Encouraging the development of food gardens and gardening education in public institutions such as early childhood centres, schools, marae, prisons, hospitals and retirement homes.

We believe in the right of people to:

Be able to access safe and nutritious food, grow diverse and nutritious food, and equip themselves with the resources and knowledge needed to sustain themselves and their communities.

We believe that:

Control of food should be placed in local communities and in a way that is socially, economically and culturally appropriate to their bioregion.

Organic, agroecological and regenerative farming can meet Aotearoa New Zealand’s nutritional needs, our climate change obligations, and improve the prosperity of our economy.

Climate change

/in

Agriculture, poorly executed, is one of the largest contributors to climate change. In Aotearoa New Zealand nearly 50% of greenhouse gas emissions are caused by agriculture. Agriculture can contribute to climate change through the use of synthetic fertilisers, which tend to burn up carbon in the soil, destabilize soil microbe populations and release nitrous oxide. This adds to nutrient deficient, unhealthy, pesticide dependent plants and animals, greater fossil fuel use in transportation, and the release of CO2 into the atmosphere from soil degradation and erosion. Organic agriculture however can work to mitigate climate change through:

Reducing greenhouse gases, especially the release of CO2 from the soil, by avoiding high synthetic soluble nitrogen fertilisers and minimising nutrient losses.

Sequestering carbon in soil and plant biomass by building organic matter in soil, encouraging a greater use of trees and perennial plants, and protecting and enhancing indigenous ecosystems.

Minimising energy consumption by eliminating the energy required in manufacturing synthetic fertilisers, and by reducing reliance on external inputs, by using internal farm inputs as much as possible, thus reducing fuel used for manufacture and transport.

Minerals such as lime, magnesium and trace elements that provide the mineral balance and amounts needed for microbial, root and humus growth, which is fundamental for building healthy soils and sequestering carbon.

Reducing methane emissions from ruminant animals by having lower stock density and by planting high-tannin species such as birdsfoot trefoil, and deep-rooted herbs that recycle minerals with natural efficiency, which in turn reduce methane emissions from stock that eat them.

Using agro-ecological systems that implement crop and stock rotation systems, with Holistic Management which build healthy soils, healthy plants and healthy livestock.

The Soil & Health Association believes it is possible to rapidly and profitably transform Aotearoa New Zealand agriculture from a net emitter of greenhouse gases to net sequesterer. Soil & Health commits to providing education and information to farmers on approaches to grazing and cultivation and agroforestry/farm forestry that will quickly turn NZ agriculture into a net sequesterer of atmospheric carbon in the form of long-term humus in productive, profitable soils and sustainable woodlots.

We are committed to:

Supporting organic farming and land-use practices that reduce greenhouse gas emissions and work to mitigate climate change.

Encouraging appropriate organic agriculture practices that sequester carbon in soil and plant biomass such as taller grass grazing, agro-forestry, cover cropping, mixed cropping, food forests and urban gardens.

Supporting small-scale and local food production and consumption to reduce emissions released through transportation.

 We believe that organic agriculture:

Is part of the solution to climate change.

Can and should form the basis of national governmental policies and common farming practices to reverse climate change.

                                            Photo credit: Nick Holmes

Organics

/in

Agriculture is one of humankind’s most basic activities because all people need to nourish themselves daily.

It is therefore also the biggest way we as humans affect the world around us. Agriculture however, poorly executed, is one of the largest contributors to climate change and is the greatest immediate threat to species and ecosystems around the world. Agriculture can also involve the unethical mistreatment and exploitation of both people and animals.

The Principles of Organic Agriculture, established by the International Federation of Organic Agriculture Movements (IFOAM), serve to inspire the organic movement in its full diversity, presented with a vision of their world-wide adoption.

The Soil & Health Association supports IFOAM’s four principles of organic agriculture which are:

  • Health – organic agriculture should sustain and enhance the health of soil, plant, animal, human and planet as one and indivisible
  • Ecology – organic agriculture should be based on living ecological systems and cycles, work with them, emulate them and help sustain them
  • Fairness – organic agriculture should build on relationships that ensure fairness with regard to the common environment and life opportunities
  • Care – organic agriculture should be managed in a precautionary and responsible manner to protect the health and well-being of current and future generations and the environment.

Read our recent discussion of organics – Safe Food & Healthy Families

                                            Photo credit: Nick Holmes

Submission on the Health (Fluoridation of Drinking Water) Amendment Bill

/in

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. Its membership is 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.
  2. Soil & Health is aware that currently in New Zealand around 60% of public water supplies have fluoride added as a treatment for dental decay. We are also aware that there is conflicting evidence on the benefits of water fluoridation to dental health and that there is growing medical concern about the cumulative negative wider health impacts of ingestion of fluoride and its adverse effects on the environment. The main chemicals used to fluoridate drinking water are known as silicofluorides. These fluorides are not pharmaceutical-grade fluoride products but unprocessed toxic industrial chemical by-products of the phosphate fertiliser industry.
  1. As an organisation that advocates for organics we are opposed to the use of toxic chemicals in New Zealand. We are therefore opposed to the artificial fluoridation of public water supplies. We believe that adding fluoride to local body water supplies is a form of forced medication and therefore is a breach of section 10 of the Bill of Rights Act 1990. We strongly believe that individuals should have a right to choose whether they want to ingest fluoride or not. We believe that dental health is best achieved through a healthy diet and eating fresh, wholesome organic foods.

Detailed submissions

The role of the DHBs and local democracy

  1. The Health (Fluoridation of Drinking Water) Amendment Bill (“the Bill”) was introduced to Parliament in order to enable District Health Boards (“DHBs”) rather than local councils to decide whether community water supplies are fluoridated “with the intention that the change would benefit over 1.4 million New Zealanders who live in areas where networked community water supplies are not currently fluoridated.”[1] This Bill therefore is fundamentally about facilitating the roll out of fluoridation of community water supplies across New Zealand. The Bill itself states in its Explanatory Note that: “Transferring decision-making to DHBs is expected to enable extended fluoridation coverage”.[2]
  2. The Regulatory Impact Statement says: “The Ministry of Health has considered a range of options for managing fluoridation and increasing the proportion of the population having access to fluoridated water supplies.”[3] We argue that “having access” implies having a choice. Under the Bill however there will not be a choice and in fact the Bill is about removing the ability for local communities to have a say on fluoridation. The Bill is therefore dishonest.
  3. It has been argued in the first reading of the Bill that democracy is upheld because the DHB’s have locally elected representatives, and are better placed to make decisions about the health benefits and risks of fluoridation. Part 1 Clause 8(2) of the Bill however sets out only two things the DHBs must consider when making a decision on, which are:

(a) the scientific evidence on the effectiveness on dental health; and

(b) whether the benefits outweigh the costs.

There is no provision for the DHBs to take on board community views, nor to assess health risks or environmental effects. Nor can the DHBs go against Ministry of Health objectives.

  1. The process as it currently exists for considering fluoridation enables local decision making amongst the communities affected. All residents of local councils who want to participate in the process can voice their opinion and a council decision can be appealed in court – as has recently happened in the case of Health New Zealand Inc v South Taranaki District Council.[4] Transferring the decision making from councils to DHBs will effectively remove the ability of communities to be fully involved in the investigation and reporting of any health, community or ecological impacts.
  1. We consider that the DHBs are also less representative of communities than councils because they are not independent. Under the New Zealand Health and Disability Act 2000 DHB’s “must pursue its objectives in accordance with any plan prepared under section 38, its statement of intent, and any directions or requirements given to it by the Minister”[5] and “The Minister may give a direction to all DHBs to comply with stated requirements for the purpose of supporting government policy on improving the effectiveness and efficiency of the public health and disability sector.”[6]

The toxicity of fluoride

  1. The type of fluoride that is added to drinking water is not naturally occurring calcium fluoride, or even pharmaceutical grade sodium fluoride.[7] It is a contaminated chemical by-product of the phosphate fertilizer manufacturing process, known as hydrofluorosilicic acid (“HFA”).[8] It is concentrated, highly toxic and contains hazardous impurities. Due to it’s toxicity by law it cannot be dumped onto the land, into rivers or the sea and cannot be discharged to air. Uranium and radium are found in HFA, both of which are known carcinogens. Two decay products of uranium are even more carcinogenic: radon-222 and polonium-210. Polonium decays into stable lead 206, raising significant health risks, especially for children. Research has shown that drinking fluoridated water increases lead absorption.[9]
  1. New Zealanders are already ingesting elevated levels of fluoride from plants and animals raised on land treated with phosphate which contains naturally occurring fluorides and many people already manifest dental symptoms of fluorosis – fluoride overdose. Further there is no antidote for fluoride toxicity and fluoride does not absorb to activated charcoal in filters.[10]
  1. A further concern is that the Bill’s is sole focus is on dental health with no requirement for the DHBs to assess risk to other parts of the body such as kidneys, liver, brain and thyroid.

Fluoride in the environment

  1. Fluoride ions are directly toxic to aquatic life, and accumulate in the tissues, at concentrations where absorption rates exceed excretion rates.[11] In a scientific journal article titled ‘Fluoride toxicity to aquatic animals’ Julio A. Camargo states how even at concentrations as low as 0.5 mg F−/l fluoride in soft water can adversely affect invertebrates and fishes. Camargo further states that “safe levels below this fluoride concentration are recommended in order to protect freshwater animals from fluoride pollution.”[12] There are other studies that indicate levels below water fluoridation level, 1.5ppm, have lethal and other adverse effects on fish. Delayed hatching of rainbow trout has occurred at 1.5ppm6, brown mussels have died at 1.4ppm7; an alga (Porphyria tenera) was killed by a four-hour fumigation with fluoride with a critical concentration of 0.9ppm 8, and levels below 0.1ppm were shown to be lethal to the water flea, Daphnia magna.[13]
  1. Only 1% of water from community water supplies is ingested by humans, the remaining 99% is discharged into the environment via the wastewater systems. Fluoride is not filtered out by wastewater plants. In 2015 an investigation found that approximately half a tonne of HFA is discharged every year into Lake Taupo via the Hangarito stream from the township of Turangi alone.[14] The safety datasheet for HFA by Orica states it is an exotoxin and to avoid discharge to waterways. New Zealand waterways are already in a dire state with a staggering 62% of monitored waterways being unsafe for swimming. Increasing the amount of fluoridation in local body water supplies will only make this worse.
  1. Of concern for the Bill is that transferring the decision making to the DHBs will mean that environmental effects of fluoride will no longer be taken into account. The DHBs role is to deliver public health services, not to take into account environmental effects. Whereas councils can assess environmental effects when considering fluoridation, DHBs cannot, because their statutory role is restricted to the delivery of health services.

The need for a precautionary approach

  1. Principle 15 of the Rio Declaration mentions the precautionary approach as follows:

“In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation”

  1. The precautionary approach has been considered a milestone in its ability to reduce environmental risk as it involves an anticipatory preventative action in response to uncertainty. In its use public authorities are not only required to anticipate possible adverse effects that could arise from activities but also to act to control the risks even when it is still uncertain whether adverse effects will occur.
  1. A report compiled in 2013 for the Government of Ireland, the European Commission and the World Health Organisation titled ‘Public Health Investigation of Epidemiological Data on Disease and Mortality in Ireland related to Water Fluoridation and Fluoride Exposure’ found that public health authorities have pursued a policy of medicating the population with fluoridation chemicals for half a century without undertaking any clinical trials, medical, toxicological, scientific or epidemiological studies to examine how exposure to such chemicals may be impacting on the general health of the population. The report concludes that in the absence of any scientific data proponents of water fluoridation continue to believe that the policy is both safe and effective for all sectors of society regardless of the age, nutritional requirements, medical status or total dietary intake of fluoride of individuals.[15]
  1. While studies have shown that a lifetime exposure to fluoride can lead to health risks, especially to those with challenged immune systems and the young and the elderly, [16] it is still unknown at what point HFA causes harm. Our health authorities in New Zealand have not yet found the real safe level to protect sensitive groups, particularly people with kidney disease, diabetes and bottle-fed babies. No safety studies have ever been conducted anywhere in the world.
  1. Soil & Health strongly endorses a precautionary approach to fluoridation of local body water supplies at all levels of government and regulation. Due to the uncertainties of the safety of water fluoridation we consider that applying the precautionary approach should involve a moratorium on the fluoridation of local body water supplies until further research is undertaken.

Conclusion

  1. As set out above Soil & Health opposes the introduction of the Bill. Under the Bill local decision making will be removed, making fluoridation of local body water supplies easier to implement. A number of independent scientific studies have raised serious concerns about the adverse effects that HFA has on human health and the environment.
  1. We consider that to transfer decision making to the DHB’s the government is showing disregard for appropriate decision making, especially when any risk for those affected is not required to be assessed, nor can the DHBs assess environmental effects or go against Ministry of Health objectives.
  1. We urge the select committee to apply the precautionary approach and implement a moratorium on the fluoridation of local body water supplies until an ‘independent’ review of its effects on human health and the environment is undertaken.

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: 0212667754

Email: advocacy@organicnz.org.nz

Website: www.organicnz.org.nz

[1] Background to Bill https://www.parliament.nz/en/pb/bills-and-laws/bills-digests/document/51PLLaw24221/health-fluoridation-of-drinking-water-amendment-bill

[2] Page 1 the Bill.

[3] Page 1 Regulatory Impact Statement.

[4] New Health New Zealand Inc v South Taranaki District Council – [2014] NZHC 395

[5] Section 22 (2).

[6] Section 33B (1).

[7] https://www.cdc.gov/niosh/ipcsneng/neng1233.html

[8]http://www.waternz.org.nz/Folder?Action=View%20File&Folder_id=315&File=140604_nzwwa_f_gpg_revision_final.pdf

[9] http://cof-cof.ca/wp-content/uploads/2012/08/Masters-Coplan-Water-Treatment-With-Silicofluorides-And-Lead-Toxicity-International-Journal-Of-Environmental-Studies-1999.pdf and https://www.ncbi.nlm.nih.gov/pubmed/17420053

[10] http://emedicine.medscape.com/article/814774-overview

[11] http://www.env.gov.bc.ca/wat/wq/BCguidelines/fluoride/fluoridetoo-04.html

[12] http://www.sciencedirect.com/science/article/pii/S0045653502004988

[13] Dave G. Effects of fluoride on growth reproduction and survival in Daphnia magna, Comparative Biochemistry and Physiology, 78c (2)

[14] http://fluoridefree.org.nz/campaigns/taupo-turangi/

[15] http://www.enviro.ie/feb2013.pdf

[16] http://www.sciencedirect.com/science/article/pii/S0892036214001809 and https://www.atsdr.cdc.gov/ToxProfiles/tp11-c2.pdf

You can address your submission to:

Committee Secretariat

Health

Parliament Buildings

Wellington

Natural Health & Supplementary Products Bill – Ministry of Health’s consultation paper ‘The Regulation of Natural Health Products’

/in
Submission to: Ministry of Health
Submission Author: Philippa Jamieson and Marion Thomson
Friday, March 4, 2016

Submission on the Natural Health & Supplementary Products Bill
Ministry of Health’s consultation paper ‘The Regulation of Natural Health Products’

TO:
Natural Health Products
Ministry of Health
PO Box 5013
Wellington 6145
naturalhealthproducts@moh.govt.nz

FROM: Soil & Health Association of New Zealand
PO Box 340002
Birkenhead 0746
Auckland

4 March 2016

 

Re: the Ministry of Health’s consultation paper ‘The Regulation of Natural Health Products’

The Soil & Health Association of New Zealand Incorporated (‘Soil & Health’) is the largest membership organisation supporting organic food and farming in New Zealand, and is one of the oldest organic organisations in the world, formed in 1941. We are committed to advocating our maxim ‘Oranga nuku – Oranga kai – Oranga tangata’ meaning ‘Healthy soil – Healthy food – Healthy people’ and to creating an organic New Zealand.

 

The Soil & Health Association of NZ opposes the Natural Health Products Bill and requests that it be removed from the Order Paper.
Our opposition to this Bill includes the following reasons:

 

1.     The Bill would drastically reduce access to, and options for, safe and effective healthcare for New Zealanders.

 

a)     Natural medicines have been used safely and effectively for thousands of years. The Bill would, however, ban numerous natural health product ingredients without just cause. Some of these ingredients could in fact be everyday foods with a long history of safety.

b)    The proposed regulations would severely limit health options for consumers by allowing only a very limited number of permitted ingredients on a ‘white list’.

c)     The limited ‘white list’ approach would mean that many safe and effective natural health ingredients would become illegal.

d)    Many of the ‘white list’ ingredients have severe dosage and application restrictions placed on them. There is no scientific or medical justification for this, and no history of risk to human health.

e)     Soil & Health asks that the current, sensible ‘black list’ approach is retained, so that natural health products are ‘innocent until proven guilty’. If they are shown to cause harm, they are banned and added to the black list.

 

2.     The Bill would severely affect natural health practitioners, who would be robbed of numerous safe and effective health products to recommend to their patients. This would limit or destroy their businesses, as well as impacting on their ethical duty of providing the best care for their patients.

 

3.     The Bill would severely affect New Zealand natural health producers and suppliers, driving many small-to-medium enterprises out of the market.

 

a)     The Bill introduces significant new compliance costs on New Zealand businesses to prove that a natural health ingredient to be safe so it can be added to the proposed ‘white list’.

b)    The compliance costs for businesses go well beyond proving that an ingredient is safe. Costs include notifying the regulator about each ingredient, paying annual fees, providing information about health benefit claims, obtaining a licence to manufacture the product, and complying with the Code of Manufacture Practice. The sum total of compliance costs will be out of reach of many businesses as it could reach into the tens of thousands of dollars or even more.

c)     Businesses will not be able to provide as great a range of natural health products, for sale in New Zealand, or for export.

d)    The only manufacturers likely to be able to survive will be the larger ones.

e)     If consumers are unable to find the products they want in New Zealand they will buy online and import them, therefore bypassing our local industry.

 

This is a Bill whose only benefits are for large and/or multinational companies who can afford to stay in business under this regime, and for the pharmaceutical industry. The primary goal of health legislation or regulation must be the health of New Zealanders. However this Bill does nothing to improve people’s health – in fact it will worsen the health of New Zealanders, as we would lose numerous safe and effective healthcare options.

 

REQUEST

Soil & Health asks that the Bill and associated proposed regulations be abandoned.

GE Free Field NZ

Maori Party says no way to Nick Smith’s power grab

/in , ,

The Soil & Health Association congratulates the Maori Party for standing up for New Zealanders who want to live in a GE-Free community and saying no to Nick Smith’s attempt to ride roughshod over local democracy.
“Maori Party co-leader Marama Fox has told the Environment Minister they will not support his attempts to regulate genetically modified crops nationally through the Environmental Protection Agency (EPA),” says Soil & Health Association spokesperson Karen Summerhays.
“This spells the end for Nick Smith’s attempts to control what is grown in New Zealander’s neighbourhoods and available at their local markets.
“Local Authorities won the right to regulate the planting of genetically modified crops in their territories after years of legal battles over whether they could introduce GMO-Free zones through district plan rules.
“By standing up to Nick Smith, the Maori Party has protected this hard-fought democratic right. The Government doesn’t have the numbers to make this change without their support.
“The Environment Minister insists that genetic modification should be regulated on a national level by the EPA under the Hazardous Substances and New Organisms Act, not under the Resource Management Act. Nick Smith’s view has now been found wrong by both the Environment Court and the High Court.
“Clause 360D of the Resource Legislation Amendment Bill – also known as the ‘dictator clause’ – would have allowed the Government to step in if it deemed council plans duplicated central Government laws.
“Soil & Health would like a sub clause introduced to the Bill prohibiting this power being used in relation to council plans which contain a GMO-free zone.
“Otherwise local food producers – and economies – face being hit in the pocket when they lose the lucrative advantage of being able to market their products “GE-Free” alongside those from the world’s premier GE-Free territories; Tuscany, Provence and Burgundy.
“It’s time for Nick Smith to concede defeat and acknowledge that communities should continue to decide whether GMO crops are grown in their districts,” Karen Summerhays says.

Contact – Soil & Health spokesperson Karen Summerhays on 021 043 7858
GE Free Field NZ

Submission on application for the reassessment of chlorothalonil formulations

/in

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.

Court ruling highlights the dangers of RMA reforms

/in , , , ,

A new court ruling highlights how the Government’s RMA reforms will ride roughshod over public participation in resource management and the power of councils to regulate the use of genetically modified organisms (GMOs) within their territories, says Soil & Health Association chair Marion Thomson.
On Friday the High Court rejected Federated Farmers’ bid to oppose court costs for its failed challenge to members of the public and councils that seek to manage the outdoor use of GMOs under RMA plans. Costs have now been awarded against Federated Farmers for a second time.
“Not only has Federated Farmers now been ordered to pay court costs of more than $10,000 to the Whangarei District Council and the Soil & Health Association, but the High Court found it was not acting in the public interest.
“In fact Justice Peters noted Federated Farmers ‘brought these proceedings because it was in its members’ interest to do so’.
“The National-led Government’s Resource Legislation Amendment Bill will jeopardise local authorities’ ability to manage GMO land use by giving the Environment Minister new powers to override council planning rules.
“These reforms threaten the economic sustainability of a wide range of agricultural export activities reliant on GMO-free status, and would override the ability of councils to respond to community concerns about the planting of GMO crops in their area.
“Friday’s ruling further entrenches the legal rights of councils and communities.
“Environment Minister Nick Smith believes genetic modification should be regulated on a national level by the Environmental Protection Authority under the Hazardous Substances and New Organisms Act (HSNO), not under the Resource Management Act.
“He is no doubt under pressure from Federated Farmers who choose to ignore the fact that while HSNO controls the introduction of new organisms (including GMOs), it is the RMA which oversees the environment new organisms are introduced into.
“Nick Smith is being mischievous in suggesting the management of genetically modified organisms under the RMA will stop access to the development of GMO medicines. He conveniently overlooks the fact that GMO veterinary vaccines are already permitted under the Auckland Unitary Plan.
“The Minister’s claims that GMOs were only ever intended to be regulated under HSNO have now been found to be wrong by both the Environment Court and High Court.
“Nick Smith must protect the ability of councils to act in the best interests of their ratepayers and local producers by amending his Bill to explicitly exclude using these new powers to regulate the release of GMOs.
“There are huge uncertainties around the adverse effects of GMOs on natural resources and ecosystems. The risks are large and consequences irreversible.
“If GMOs were to be released into the environment, they would be very difficult, if not impossible, to eradicate. There is also potential for serious economic loss to regions marketing their products and tourism under New Zealand’s ‘clean green’ brand,” Marion Thomson says.